NUREG-1900, Vol. 2

Safety Evaluation Report

Related to the License Renewal of

Nine Mile Point Nuclear Station,

Units 1 and 2

Docket Nos. 50-220 and 50-4 10

Constellation Energy Group, LLC

U.S. Nuclear Regulatory Commission

Office of Nuclear Reactor Regulation

Washington,' DC 20555-0001
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NUREG-1900, Vol. 2

Safety Evaluation Report

Related to the License Renewal of

Nine Mile Point Nuclear Station,

Units 1 and 2

Docket Nos. 50-220 and 50-4 10

Constellation Energy Group, LLC

Manuscript Completed: June 2006

Date Published: September 2006

Prepared by

T. Le

Division of License Renewal

Office of Nuclear Reactor Regulation

U.S. Nuclear Regulatory Commission

Washington, DC 20555-0001

ABSTRACT

This safety evaluation report (SER) documents the technical review of the Nine Mile Point

Nuclear Station Units 1 and 2 (NMPNS), license renewal application (LRA) by the staff of the

U.S. Nuclear Regulatory Commission (NRC) (the staff). By letter dated May 26, 2004,

Constellation Energy Group, LLC submitted the LRA for NMPNS in accordance with Title 10,

Part 54, of the Code of Federal Regulations (10 CFR Part 54). Due to concerns with the

adequacy of support for and documentation of the license renewal activities in the initial

submission, the applicant submitted an amended LRA (ALRA) on July 14, 2005. Constellation

Energy Group, LLC is requesting renewal of the operating licenses for NMPNS (Facility

Operating License Numbers DPR-63 and NPF-69, respectively), for a period of 20 years

beyond the current expiration dates of midnight August 22, 2009, for Unit 1 (NMP1) and

midnight October 31, 2026, for Unit 2 (NMP2).

NMPNS is located approximately six miles northeast of Oswego, NY. The NRC issued the

construction permits for NMP1 on April 12, 1965, and for NMP2 on June 24, 1974. The NRC

issued the operating licenses for NMP1 on December 26, 1974 and for NMP2 on July 2, 1987.

NMP1 is a boiling water reactor design with a Mark I containment. The nuclear steam supply

system was supplied by General Electric and the balance of the plant was originally designed

and constructed by Stone and Webster with the assistance of its agent, Niagra Mohawk Power

Corporation. NMP1 's licensed power output is 1850 megawatt thermal, with a gross electrical

output of approximately 615 megawatt electric. NMP2 is a boiling water reactor design with a

Mark 2 containment. The nuclear steam supply system was supplied by General Electric and

the balance of the plant was originally designed and constructed by Stone and Webster.

NMP2's licensed power output is 3467 megawatt thermal, with a gross electrical output of

approximately 1144 megawatt electric.

This SER presents the status of the staff's review of information submitted to the staff through

April 21, 2006, the cutoff date for consideration in this SER. On March 3, 2006, the staff issued

a draft SER which identified two open items that had to be resolved before the staff makes a

final determination on the application. The two open items have now been resolved and SER

Section 1.5 summarizes these items and their resolutions. SER Section 6 provides the staff's

final conclusion on the review of the NMPNS License Renewal Application dated May 26, 2004,

as amended July 14, 2005, and all its subsequent supplemental letters as listed in SER

Appendix B.

iii

TABLE OF CONTENTS

A bstract .................................................................. iii

Table of Contents ........................................................... v

Abbreviations ............................................................ xviii

1 Introduction and General Discussion ......................................... 1-1

1.1 Introduction ..................................................... 1-1

1.2 License Renewal Background ...................................... 1-3

1.2.1 Safety Review ........................................... 1-4

1.2.2 Environmental Review ....................... ............. 1-5

1.3 Principal Review Matters .......................................... 1-6

1.4 Interim Staff Guidance ............................................ 1-7

1.5 Summary of Open Items ........................................... 1-9

1.6 Summary of Confirmatory Items .................................... 1-10

1.7 Summary of Proposed License Conditions ............................ 1-10

2 Structures and Components Subject to Aging Management Review ................. 2-1

2.1 Scoping and Screening Methodology ................................. 2-1

2.1.1 Introduction ............................................. 2-1

2.1.2 Summary of Technical Information in the Amended Application ...... 2-1

2.1.2.1 Scoping Methodology .............................. 2-2

2.1.2.2 Screening Methodology ............................. 2-6

2.1.3 Staff Evaluation ........................................ 2-7

2.1.3.1 Scoping Methodology .............................. 2-8

2.1.3.2 Screening Methodology ............................ 2-27

2.1.4 Evaluation Findings ...................................... 2-31

2.2 Plant-Level Scoping Results ....................................... 2-32

2.2.1 Introduction ............................................ 2-32

2.2.2 Summary of Technical Information in the Amended Application ..... 2-32

2.2.3 Staff Evaluation ......................................... 2-33

2.2.4 Conclusion ............................................. 2-36

2.3 Scoping and Screening Results: Mechanical Systems ................... 2-36

2.3A NMP1 Scoping and Screening Results: Mechanical Systems ............ 2-37

2.3A.1 Reactor Vessel, Internals, and Reactor Coolant Systems ........ 2-37

2.3A.1.1 NMP1 Reactor Pressure Vessel .................... 2-37

2.3A.1.2 NMP1 Reactor Pressure Vessel Internals ............. 2-39

2.3A.1.3 NMP1 Reactor Pressure Vessel Instrumentation System . 2-42

2.3A.1.4 NMP1 Reactor Recirculation System ................ 2-43

2.3A.1.5 NMP1 Control Rod Drive System ................... 2-45

2.3A.1.6 NMP1 Reactor Coolant Pressure Boundary Components in

Other Systems ................................... 2-47

2.3A.2 Engineered Safety Features Systems ....................... 2-48

2.3A.2.1 NMP1 Automatic Depressurization System ............ 2-49

2.3A.2.2 NMP1 Containment Spray System .................. 2-50

2.3A.2.3 NMP1 Core Spray System ........................ 2-51

v
2.3A.2.4 NMP1 Emergency Cooling System .................. 2-53

2.3A.3 Auxiliary Systems ...................................... 2-54

2.3A.3.1 NMP1 Administration Building Heating, Ventilation, and Air

Conditioning (HVAC) System ........................ 2-55

2.3A.3.2 NMP1 Circulating Water System .................... 2-56

2.3A.3.3 NMP1 City Water System ......................... 2-58

2.3A.3.4 NMP1 Compressed Air Systems .................... 2-60

2.3A.3.5 NMP1 Containment Systems ...................... 2-63

2.3A.3.6 NMP1 Control Room HVAC System ................. 2-65

2.3A.3.7 NMP1 Diesel Generator Building Ventilation System .... 2-67

2.3A.3.8 NMP1 Emergency Diesel Generator System ........... 2-68

2.3A.3.9 NMP1 Fire Detection and Protection System .......... 2-71

2.3A.3.1 0 NMP1 Hydrogen Water Chemistry System ........... 2-76

2.3A.3.11 NMP1 Liquid Poison System ...................... 2-77

2.3A.3.12 NMP1 Miscellaneous Non-Contaminated Vents and

Drains System ................................... 2-79

2.3A.3.13 NMP1 Neutron Monitoring System ................. 2-80

2.3A.3.14 NMP1 Process Radiation Monitoring System ......... 2-82

2.3A.3.15 NMP1 Radioactive Waste Disposal Building HVAC

System ......................................... 2-83

2.3A.3.16 NMP1 Radioactive Waste System .................. 2-84

2.3A.3.17 NMP1 Reactor Building Closed Loop Cooling Water

System ......................................... 2-88

2.3A.3.18 NMP1 Reactor Building HVAC System .............. 2-90

2.3A.3.19 NMP1 Reactor Water Cleanup System .............. 2-92

2.3A.3.20 NMP1 Sampling System ......................... 2-96

2.3A.3.21 NMP1 Service Water System ..................... 2-99

2.3A.3.22 NMP1 Shutdown Cooling System ................. 2-101

2.3A.3.23 NMP1 Spent Fuel Pool Filtering and Cooling System .. 2-104

2.3A.3.24 NMP1 Technical Support Center HVAC System ...... 2-106

2.3A.3.25 NMP1 Turbine Building Closed Loop Cooling Water

System ........................................ 2-107

2.3A.3.26 NMP1 Turbine Building HVAC System ............. 2-108

2.3A.3.27 NMP1 Electric Steam Boiler System ............... 2-109

2.3A.3.28 NMP1 Makeup Demineralizer System .............. 2-110

2.3A.4 Steam and Power Conversion Systems ..................... 2-112

2.3A.4.1 NMP1 Condensate and Condensate Transfer System .. 2-112

2.3A.4.2 NMP1 Condenser Air Removal and Off-Gas System ... 2-117

2.3A.4.3 NMP1 Feedwater/High Pressure Coolant Injection

System ........................................ 2-119

2.3A.4.4 NMP1 Main Generator and Auxiliary System .......... 2-124

2.3A.4.5 NMP1 Main Steam System ....................... 2-125

2.3A.4.6 NMP1 Main Turbine and Auxiliary Systems ........... 2-129

2.3A.4.7 NMP1 Moisture Separator Reheater Steam System .... 2-130

2.3B NMP2 Scoping and Screening Results: Mechanical Systems ........... 2-132

2.3B.1 Reactor Vessel, Internals, and Reactor Coolant Systems ....... 2-132

2.3B.1.1 NMP2 Reactor Pressure Vessel ................... 2-132

2.3B.1.2 NMP2 Reactor Pressure Vessel Internals ............ 2-134

2.3B.1.3 NMP2 Reactor Pressure Vessel Instrumentation

vi
System ................... .*.. ................... 2-136

2.3B.1.4 NMP2 Reactor Recirculation System ............... 2-138

2.31.1.5 NMP2 Control Rod Drive System .................. 2-139

2.31.1.6 NMP2 Reactor Coolant Pressure Boundary Components

in Other Systems ................................ 2-141

2.3B.2 Engineered Safety Features Systems ...................... 2-142

2.3B.2.1 NMP2 Automatic Depressurization System ........... 2-142

2.3B.2.2 NMP2 Hydrogen Recombiner System ............... 2-143

2.3B.2.3 NMP2 High Pressure Core Spray System ............ 2-144

2.3B.2.4 NMP2 Low Pressure Core Spray System ............ 2-145

2.3B.2.5 NMP2 Primary Containment Isolation System ......... 2-147

2.3B.2.6 NMP2 Reactor Core Isolation Cooling System ........ 2-148

2.3B.2.7 NMP2 Residual Heat Removal System .............. 2-149

2.3B.2.8 NMP2 Standby Gas Treatment System .............. 2-151

2.3B.3 Auxiliary Systems ..................................... 2-152

2.3B.3.1 NMP2 Air Startup-Standby Diesel Generator System ... 2-153

2.3B.3.2 NMP2 Alternate Decay Heat Removal System ........ 2-156

2.3B.3.3 NMP2 Auxiliary Service Building HVAC System ....... 2-158

2.3B.3.4 NMP2 Chilled Water Ventilation System (Removed) .... 2-159

2.3B.3.5 NMP2 Compressed Air Systems ................... 2-159

2.3B.3.6 NMP2 Containment Atmosphere Monitoring System .... 2-162

2.3B.3.7 NMP2 Containment Leakage Monitoring System ...... 2-164

2.3B.3.8 NMP2 Control Building Chilled Water System ......... 2-165

2.3B.3.9 NMP2 Control Building HVAC System ............... 2-166

2.3B.3.10 NMP2 Diesel Generator Building Ventilation System ... 2-168

2.3B.3.11 NMP2 Domestic Water System ............... 2-169

2.3B.3.12 NMP2 Engine-Driven Fire Pump Fuel Oil System ...... 2-170

2.3B.3.13 NMP2 Fire Detection and Protection System ........ 2-171

2.3B.3.14 NMP2 Floor and Equipment Drains System ......... 2-187

2.3B.3.15 NMP2 Generator Standby Lube Oil System ......... 2-191

2.3B.3.16 NMP2 Glycol Heating System (Removed) ........... 2-194

2.3B.3.17 NMP2 Hot Water Heating System ................. 2-194

2.3B.3.18 NMP2 Makeup Water System .................... 2-197

2.3B.3.19 NMP2 Neutron Monitoring System ................ 2-198

2.38.3.20 NMP2 Primary Containment Purge System .......... 2-199

2.3B.3.21 NMP2 Process Sampling System ................. 2-201

2.3B.3.22 NMP2 Radiation Monitoring System ................ 2-203

2.3B.3.23 NMP2 Reactor Building Closed Loop Cooling Water

System ................................. ..... 2-205

2.38.3.24 NMP2 Reactor Building HVAC System ............. 2-206

2.3B.3.25 NMP2 Reactor Water Cleanup System ............. 2-207

2.3B.3.26 NMP2 Seal Water System (Removed) ............. 2-211

2.3B.3.27 NMP2 Service Water System .................... 2-211

2.3B.3.28 NMP2 Spent Fuel Pool Cooling and Cleanup System .. 2-213

2.3B.3.29 NMP2 Standby Diesel Generator Fuel Oil System .... 2-216

2.3B.3.30 NMP2 Standby Diesel Generator Protection (Generator)

System ........................................ 2-220

2.3B.3.31 NMP2 Standby Liquid Control System .............. 2-224

2.38.3.32 NMP2 Yard Structures Ventilation System .......... 2-228

vii
2.3B.3.33 NMP2 Auxiliary Boiler System .................... 2-229

2.3B.3.34 NMP2 Circulating Water System .................. 2-230

2.3B.3.35 NMP2 Makeup Water Treatment System ........... 2-232

2.3B.3.36 NMP2 Radioactive Liquid Waste Management

System ........................................ 2-233

2.3B.3.37 NMP2 Roof Drainage System .................... 2-234

2.3B.3.38 NMP2 Sanitary Drains and Disposal System......... 2-235

2.3B.3.39 NMP2 Service Water Chemical Treatment System .... 2-236

2.3B.3.40 NMP2 Turbine Building Closed Loop Cooling Water

System ........................................ 2-237

2.3B.4 Steam and Power Conversion Systems ..................... 2-238

2.3B.4.1 NMP2 Main Condenser Air Removal System ......... 2-239

2.3B.4.2 NMP2 Condensate System ....................... 2-240

2.3B.4.3 NMP2 Feedwater System ........................ 2-244

2.31.4.4 NMP2 Main Steam System ....................... 2-247

2.3B.4.5 NMP2 Moisture Separator and Reheater System ...... 2-250

2.3B.4.6 NMP2 Extraction Steam and Feedwater Heater Drain

System ........................................ 2-251

2.3B.4.7 NMP2 Turbine Main System ...................... 2-252

2.4 Scoping and Screening Results: Structures and Component Supports ..... 2-254

2.4A NMP1 Structures ........................................... 2-255

2.4A.1 NMP1 Primary Containment Structure ...................... 2-255

2.4A.1.1 Summary of Technical Information in the Amended

Application ..................................... 2-255

2.4A.1.2 NMP1 Reactor Building .......................... 2-260

2.4A.1.3 NMP1 Essential Yard Structures ................... 2-263

2.4A.1.4 NMP1 Fuel Handling System ..................... 2-264

2.4A.1.5 NMP1 Material Handling System ................... 2-266

2.4A.1.6 NMP1 Offgas Building ........................... 2-268

2.4A.1.7 NMP1 Personnel/Equipment Access System ......... 2-269

2.4A.1.8 NMP1 Radwaste Solidification and Storage Building .... 2-270

2.4A.1.9 NMP1 Screen and Pump House Building ............ 2-272

2.4A.1.10 NMP1 Turbine Building ......................... 2-274

2.4A.1.11 NMP1 Vent Stack ............................. 2-277

2.4A.1.12 NMP1 Waste Disposal Building ................... 2-278

2.4B NMP2 Structures ........................................... 2-280

2.48.1 NMP2 Primary Containment Structure ...................... 2-281

2.4B.1.1 Summary of Technical Information in the Amended

Application ..................................... 2-281

2.4B.1.2 Staff Evaluation ................................ 2-283

2.4B.1.3 Conclusion ................................... 2-284

2.4B.2 NMP2 Reactor Building ................................. 2-284

2.4B.2.1 Summary of Technical Information in the Amended

Application ..................................... 2-284

2.41.2.2 Staff Evaluation ................................ 2-286

2.48.2.3 Conclusion ................................... 2-288

2.4B.3 NMP2 Auxiliary Service Building .......................... 2-288

2.48.3.1 Summary of Technical Information in the Amended

Application ..................................... 2-288

viii
2.4B.3.2 Staff Evaluation ................................ 2-289

2.4B.3.3 Conclusion ............. .... .................. 2-290

2.4B.4 NMP2 Control Room Building ............................ 2-290

2.4B.4.1 Summary of Technical Information in the Amended

Application ..................................... 2-290

2.48.4.2 Staff Evaluation ................................ 2-291

2.4B.4.3 Conclusion ................................... 2-291

2.4B.5 NMP2 Diesel Generator Building .......................... 2-292

2.4B.5.1 Summary of Technical Information in the Amended

Application ..................................... 2-292

2.4B.5.2 Staff Evaluation .............................. 2-293

2.4B.5.3 Conclusion ................................... 2-293

2.4B.6 NMP2 Essential Yard Structures .......................... 2-293

2.4B.6.1 Summary of Technical Information in the Amended

Application ..................................... 2-293

2.41.6.2 Staff Evaluation ................................ 2-295

2.48.6.3 Conclusion ................................... 2-296

2.48.7 NMP2 Fuel Handling System ............................. 2-296

2.48.7.1 Summary of Technical Information in the Amended

Application ..................................... 2-296

2.41.7.2 Staff Evaluation ................................ 2-297

2.48.7.3 Conclusion ................................... 2-297

2.4B.8 NMP2 Main Stack .................................. .. 2-298

2.48.8.1 Summary of Technical Information in the Amended

Application ..................................... 2-298

2.4B.8.2 Staff Evaluation ................................ 2-299

2.4B.8.3 Conclusion ................................... 2-299

2.4B.9 NMP2 Material Handling System .......................... 2-299

2.48.9.1 Summary of Technical Information in the Amended

Application ..................................... 2-299

2.4B.9.2 Staff Evaluation ................................ 2-300

2.4B.9.3 Conclusion ................................... 2-300

2.48.10 NMP2 Motor Operated Doors System ..................... 2-300

2.4B.10.1 Summary of Technical Information in the Amended

Application ..................................... 2-300

2.48.10.2 Staff Evaluation ............................... 2-301

2.4B.10.3 Conclusion .................................. 2-301

2.48.11 NMP2 Radwaste Building .............................. 2-301

2.4B.11.1 Summary of Technical Information in the Amended

Application ..................................... 2-301

2.48.11.2 Staff Evaluation ............................... 2-303

2.4B.11.3 Conclusion .................................. 2-303

2.48.12 NMP2 Screenwell Building .............................. 2-303

2.4B.12.1 Summary of Technical Information in the Amended

Application ..................................... 2-303

2.48.12.2 Staff Evaluation ............................... 2-305

2.48.12.3 Conclusion .................................. 2-306

2.48.13 NMP2 Standby Gas Treatment Building ................... 2-307

2.48.13.1 Summary of Technical Information in the Amended

ix
Application ..................................... 2-307

2.4B.13.2 Staff Evaluation ............................... 2-308

2.4B.13.3 Conclusion .................................. 2-308

2.4B.14 NMP2 Turbine Building ................................. 2-308

2.4B.14.1 Summary of Technical Information in the Amended

Application ..................................... 2-308

2.4B.14.2 Staff Evaluation ............................... 2-310

2.4B.14.3 Conclusion .................................. 2-310

2.4C NMPNS Structural Commodities ................................. 2-311

2.4C.1 Component Supports ................................. 2-311

2.4C.1.1 Summary of Technical Information in the Amended

Application ..................................... 2-311

2.4C.1.2 Staff Evaluation ................................ 2-312

2.4C.1.3 Conclusion ................................... 2-313

2.4C.2 Fire Stops and Seals ................................... 2-313

2.4C.2.1 Summary of Technical Information in the Amended

Application ..................................... 2-313

2.4C.2.2 Staff Evaluation ................................ 2-314

2.4C.2.3 Conclusion .................................. 2-314

2.5 Scoping and Screening Results: Electrical and Instrumentation and Controls

System s ................................................... 2-314

2.5.1 NMPNS Electrical Commodities ............................ 2-316

2.5.1.1 Cables and Connectors ........................... 2-317

2.5.1.2 Non-Segregated/Switchyard Bus .................... 2-318

2.5.1.3 Containment Electrical Penetrations ................. 2-320

2.5.1.4 Switchyard Components .......................... 2-321

2.6 Conclusion for Scoping and Screening .............................. 2-322

3 Aging Management Review Results ......................................... 3-1

3.0 Applicant's Use of the Generic Aging Lessons Learned Report ............. 3-1

3.0.1 Format of the License Renewal Application ..................... 3-2

3.0.1.1 Overview of Table 1 ................................ 3-3

3.0.1.2 Overview of Table 2 ................................ 3-3

3.0.2 Staff's Review Process .................................... 3-4

3.0.2.1 Review of AMPs ................................. 3-5

3.0.2.2 Review of AMR Results ............................. 3-6

3.0.2.3 UFSAR and USAR Supplements ...................... 3-6

3.0.2.4 Documentation and Documents Reviewed .............. 3-6

3.0.3 Aging Management Programs ............................... 3-6

3.0.3.1 AMPs That Are Consistent with the GALL Report ........ 3-12

3.0.3.2 AMPs That Are Consistent with the GALL Report with

Exceptions or Enhancements ........................ 3-26

3.0.3.3 AMPs That Are Not Consistent with or Not Addressed in the

GALL Report .................................... 3-122

3.0.4 Quality Assurance Program Attributes Integral to Aging Management

Program s ............................................ 3-160

3.0.4.1 Summary of Technical Information in the Amended

Application ..................................... 3-160

3.0.4.2 Staff Evaluation ................................ 3-161

x
3.0.4.3 Conclusion ..................................... 3-162

3.1 Aging Management of Reactor Vessel, Internals, and Reactor Coolant

Systems ................................................ 3-162

3.1A NMP1 Aging Management of Reactor Vessel, Internals, and Reactor Coolant

System s ................................................... 3-162

3.1A.1 Summary of Technical Information in the Amended Application .. 3-163

3.1A.2 Staff Evaluation ....................................... 3-163

3.1A.2.1 AMR Results That Are Consistent with the GALL Report 3-171

3.1A.2.2 AMR Results That are Consistent with the GALL Report, for

Which Further Evaluation is Recommended ............ 3-180

3.1A.2.3 AMR Results That Are Not Consistent with or Not

Addressed in the GALL Report ...................... 3-192

3.1A.3 Conclusion ...................... ................... 3-202

3.1 B NMP2 Aging Management of Reactor Vessel, Internals, and Reactor Coolant

System s ................................................... 3-203

3.16.1 Summary of Technical Information in the Amended Application .. 3-203

3.1B.2 Staff Evaluation ..................................... 3-203

3.16.2.1 AMR Results That Are Consistent with the GALL Report 3-211

3.1 B.2.2 AMR Results That are Consistent with the GALL Report,

for Which Further Evaluation is Recommended ......... 3-215

3.1B.2.3 AMR Results That Are Not Consistent with or Not

Addressed in the GALL Report ...................... 3-224

3.1 B.3 Conclusion ........................................... 3-238

3.2 Aging Management of Engineered Safety Features .................... 3-238

3.2A NMP1 Aging Management of Engineered Safety Features ............. 3-238

3.2A.1 Summary of Technical Information in the Amended Application .. 3-238

3.2A.2 Staff Evaluation ..................................... 3-238

3.2A.2.1 AMR Results That Are Consistent with the GALL Report 3-242

3.2A.2.2 AMR Results That Are Consistent with the GALL Report,

for Which Further Evaluation is Recommended ......... 3-245

3.2A.2.3 AMR Results That Are Not Consistent with or Not

Addressed in the GALL Report ...................... 3-250

3.2A.3 Conclusion ............................... .......... 3-262

3.2B NMP2 Aging Management of Engineered Safety Features ............. 3-262

3.28.1 Summary of Technical Information in the Amended Application .. 3-262

3.26.2 Staff Evaluation ....................................... 3-263

3.26.2.1 AMR Results That Are Consistent with the GALL Report 3-266

3.26.2.2 AMR Results That Are Consistent with the GALL Report,

for Which Further Evaluation is Recommended ......... 3-268

3.26.2.3 AMR Results That Are Not Consistent with or Not

Addressed in the GALL Report ...................... 3-273

3.26.3 Conclusion ............................................ 3-285

3.3 Aging Management of Auxiliary Systems ............................. 3-285

3.3A NMP1 Aging Management of Auxiliary Systems ...................... 3-285

3.3A.1 Summary of Technical Information in the Amended Application .. 3-286

3.3A.2 Staff Evaluation ....................................... 3-286

3.3A.2.1 AMR Results That Are Consistent with the GALL Report 3-292

3.3A.2.2 AMR Results That are Consistent with the GALL Report, for

Which Further Evaluation is Recommended ............ 3-297

xA
3.3A.2.3 AMR Results That Are Not Consistent with or Not Addressed in

the GALL Report ................................. 3-305

3.3A.3 Conclusion .......................................... 3-346

3.3B NMP2 Aging Management of Auxiliary Systems...................... 3-346

3.36.1 Summary of Technical Information in the Amended Application .. 3-347

3.3B.2 Staff Evaluation ........................................ 3-347

3.36.2.1 AMR Results That Are Consistent with the GALL Report 3-353

3.3B.2.2 AMR Results That are Consistent with the GALL Report,

for Which Further Evaluation is Recommended ......... 3-359

3.3B.2.3 AMR Results That Are Not Consistent with or Not

Addressed in the GALL Report ...................... 3-366

3.3B.3 Conclusion ........................................... 3-400

3.4 Aging Management of Steam and Power Conversion Systems ........... 3-401

3.4A NMP1 Aging Management of Steam and Power Conversion Systems ..... 3-401

3.4A.1 Summary of Technical Information in the Amended Application .. 3-401

3.4A.2 Staff Evaluation ....................................... 3-401

3.4A.2.1 AMR Results That Are Consistent with the GALL Report 3-404

3.4A.2.2 AMR Results That Are Consistent with the GALL Report,

for Which Further Evaluation is Recommended ......... 3-408

3.4A.2.3 AMR Results That Are Not Consistent with or Not

Addressed in the GALL Report ...................... 3-411

3.4A.3 Conclusion ........................................... 3-420

3.4B NMP2 Aging Management of Steam and Power Conversion Systems ..... 3-420

3.4B.1 Summary of Technical Information in the Amended Application .. 3-421

3.4B.2 Staff Evaluation ....................................... 3-421

3.4B.2.1 AMR Results That Are Consistent with the GALL Report 3-424

3.4B.2.2 AMR Results That are Consistent with the GALL Report,

for Which Further Evaluation is Recommended ......... 3-426

3.4B.2.3 AMR Results That Are Not Consistent with or Not

Addressed in the GALL Report ...................... 3-429

3.4B.3 Conclusion ........................................... 3-435

3.5 Aging Management of Structures and Component Supports ............. 3-435

3.5A NMP1 Aging Managementof Structures and Component Supports ....... 3-435

3.5A.1 Summary of Technical Information in the Amended Application .. 3-435

3.5A.2 Staff Evaluation ....................................... 3-436

3.5A.2.1 AMR Results That Are Consistent with the GALL Report 3-442

3.5A.2.2 AMR Results That Are Consistent with the GALL Report,

for Which Further Evaluation is Recommended ......... 3-446

3.5A.2.3 AMR Results That Are Not Consistent with or Not

Addressed in the GALL Report ...................... 3-455

3.5A.3 Conclusion ........................................... 3-471

3.5B NMP2 Aging Management of Structures and Component Supports ....... 3-471

3.5B.1 Summary of Technical Information in the Amended Application .. 3-471

3.5B.2 Staff Evaluation ....................................... 3-472

3.5B.2.1 AMR Results That Are Consistent with the GALL Report 3-478

3.58.2.2 AMR Results That are Consistent with the GALL Report,

for Which Further Evaluation is Recommended ......... 3-482

3.5B.2.3 AMR Results That Are Not Consistent with or Not

Addressed in the GALL Report ...................... 3-494

xii
3.5B.3 Conclusion ........................................... 3-511

3.6 Aging Management of Electrical and Instrumentation and Controls ........ 3-511

3.6.1 Summary of Technical Information in the Application ............ 3-511

3.6.2 Staff Evaluation ........................................ 3-511

3.6.2.1 AMR Results That Are Consistent with the GALL Report 3-514

3.6.2.2 AMR Results That Are Consistent with the GALL Report,

for Which Further Evaluation is Recommended ......... 3-515

3.6.2.3 AMR Results That Are Not Consistent With or Not

Addressed in the GALL Report ...................... 3-516

3.6.3 Conclusion ............................................ 3-525

3.7 Conclusion for Aging Management Review Results .................... 3-526

4 Time-limited Aging Analyses ............................................... 4-1

4.1 Identification of Time-Limited Aging Analyses .......................... 4-1

4.1.1 Summary of Technical Information in the Amended Application ...... 4-1

4.1.2 Staff Evaluation .................................... 4-2

4.1.3 Conclusion ............................................ 4-2

4.2 Reactor Vessel Neutron Embrittlement Analysis ......................... 4-2

4.2.1 Upper-Shelf Energy ....................................... 4-4

4.2.1.1 Summary of Technical Information in the Amended

Application ....................................... 4-4

4.2.1.2 Staff Evaluation ................................... 4-4

4.2.1.3 UFSAR and USAR Supplements ...................... 4-9

4.2.1.4 Conclusion ..................................... 4-9

4.2.2 Pressure-Temperature (P-T) Limits ........................... 4-9

4.2.2.1 Summary of Technical Information in the Amended

Application ....................................... 4-9

4.2.2.2 Staff Evaluation ................................ 4-10

4.2.2.3 UFSAR and USAR Supplements ..................... 4-10

4.2.2.4 Conclusion ...................................... 4-11

4.2.3 Elimination of Circumferential Weld Inspection (NMP1 Only) ....... 4-11

4.2.3.1 Summary of Technical Information in the Amended

Application ...................................... 4-11

4.2.3.2 Staff Evaluation ................................... 4-12

4.2.3.3 UFSAR Supplement .............................. 4-14

4.2.3.4 Conclusion ...................................... 4-14

4.2.4 Axial W eld Failure Probability ............................... 4-14

4.2.4.1 Summary of Technical Information in the Amended

Application ...................................... 4-14

4.2.4.2 Staff Evaluation .................................. 4-14

4.2.4.3 UFSAR and USAR Supplements ............. 4-15

4.2.4.4 Conclusion ...................................... 4-15

4.3 Metal Fatigue Analysis ........................................... 4-15

4.3.1 Reactor Vessel Fatigue Analysis ............................ 4-16

4.3.1.1 Summary of Technical Information in the Amended

Application ..................................... 4-16

4.3.1.2 Staff Evaluation .................................. 4-16

4.3.1.3 UFSAR and USAR Supplements ..................... 4-18

xiii
4.3.1.4 Conclusion .................................... 4-19

4.3.2 ASME Section III Class 1 Piping and Components Fatigue Analysis

(NMP2 Only) ......................................... 4-19

4.3.2.1 Summary of Technical Information in the Amended

Application ..................................... 4-19

4.3.2.2 Staff Evaluation ................................. 4-19

4.3.2.3 USAR Supplement ............................... 4-19

4.3.2.4 Conclusion ...................................... 4-19

4.3.3 Feedwater Nozzle and Control Rod Drive Return Line (CRDRL) Nozzle

Fatigue and Cracking Analyses ............................ 4-20

4.3.3.1 Summary of Technical Information in the Amended

Application ...................................... 4-20

4.3.3.2 Staff Evaluation .................................. 4-20

4.3.3.3 UFSAR and USAR Supplements ..................... 4-22

4.3.3.4 Conclusion ................................... 4-22

4.3.4 Non-ASME Section III Class 1 Piping and Components Fatigue

Analysis .............................................. 4-23

4.3.4.1 Summary of Technical Information in the Amended

Application ...................................... 4-23

4.3.4.2 Staff Evaluation .................................. 4-23

4.3.4.3 UFSAR and USAR Supplements ..................... 4-24

4.3.4.4 Conclusion .................................... 4-24

4.3.5 Reactor Vessel Internals Fatigue Analysis ..................... 4-24

4.3.5.1 Summary of Technical Information in the Amended

Application ...................................... 4-24

4.3.5.2 Staff Evaluation ................................ 4-24

4.3.5.3 UFSAR and USAR Supplements ..................... 4-25

4.3.5.4 Conclusion ...................................... 4-25

4.3.6 Environmentally Assisted Fatigue ........................... 4-26

4.3.6.1 Summary of Technical Information in the Amended

Application ...................................... 4-26

4.3.6.2 Staff Evaluation ................................ 4-26

4.3.6.3 UFSAR and USAR Supplements .................... 4-27

4.3.6.4 Conclusion ...................................... 4-27

4.3.7 Fatigue of the Emergency Condenser (NMP1 Only) ............. 4-27

4.3.7.1 Summary of Technical Information in the Amended

Application ...................................... 4-27

4.3.7.2 Staff Evaluation .................................. 4-27

4.3.7.3 UFSAR Supplement .............................. 4-28

4.3.7.4 Conclusion ...................................... 4-28

4.4 Environmental Qualification ....................................... 4-28

4.4.1 Electrical Equipment EQ .................................. 4-28

4.4.1.1 Summary of Technical Information in the Amended

Application ...................................... 4-28

4.4.1.2 Staff Evaluation .................................. 4-29

4.4.1.3 UFSAR and USAR Supplements ..................... 4-29

4.4.1.4 Conclusion ...................................... 4-29

4.4.2 Mechanical Equipment EQ (NMP2 Only) ...................... 4-29

4.4.2.1 Summary of Technical Information in the Application ..... 4-30

xiv
4.4.2.2 Staff Evaluation .................................. 4-30

4.4.2.3 USAR Supplement ............................... 4-31

4.4.2.4 Conclusion ...................................... 4-31

4.5 Concrete Containment Tendon Prestress Analysis ...................... 4-31

4.6 Containment Liner Plate, Metal Containments, and Penetrations Fatigue

Analysis .................................................... 4-31

4.6.1 Torus Shell and Vent System Fatigue Analysis (NMP1 Only) ....... 4-31

4.6.1.1 Summary of Technical Information in the Amended

Application ...................................... 4-32

4.6.1.2 Staff Evaluation .................................. 4-32

4.6.1.3 UFSAR Supplement .............................. 4-33

4.6.1.4 Conclusion .................................... 4-33

4.6.2 Torus Attached Piping Analysis (NMP1 Only) .................. 4-33

4.6.2.1 Summary of Technical Information in the Amended

Application ...................................... 4-33

4.6.2.2 Staff Evaluation .................................. 4-33

4.6.2.3 UFSAR Supplement ............................. 4-34

4.6.2.4 Conclusion ...................................... 4-34

4.6.3 Torus Wall Thickness (NMP1 Only) .......................... 4-35

4.6.3.1 Summary of Technical Information in the Amended

Application ...................................... 4-35

4.6.3.2 Staff Evaluation .................................. 4-35

4.6.3.3 UFSAR Supplement .............................. 4-35

4.6.3.4 Conclusion ...................................... 4-35

4.6.4 Containment Liner Analysis (NMP2 Only) ..................... 4-36

4.6.4.1 Summary of Technical Information in the Amended

Application ...................................... 4-36

4.6.4.2 Staff Evaluation .................................. 4-36

4.6.4.3 USAR Supplement ............................... 4-36

.4.6.4.4 Conclusion .................................... 4-36

4.6.5 Fatigue of Primary Containment Penetrations .................. 4-37

4.6.5.1 Summary of Technical Information in the Amended

Application ...................................... 4-37

4.6.5.2 Staff Evaluation .................. ............... 4-37

4.6.5.3 UFSAR and USAR Supplements ..................... 4-38

4.6.5.4 Conclusion ...................................... 4-38

4.6.6 Downcomer and Safety/relief Valve Discharge Line Fatigue Evaluation

(NMP2 Only) ........................................... 4-38

4.6.6.1 Summary of Technical Information in the Amended

Application ...................................... 4-38

4.6.6.2 Staff Evaluation .................................. 4-39

4.6.6.3 USAR Supplement ............................... 4-39

4.6.6.4 Conclusion ...................................... 4-39

4.7 Other Plant-Specific TLAAs ................................. ...... 4-40

4.7.1 RPV Biological Shield (NMP2 Only) .......................... 4-40

4.7.1.1 Summary of Technical Information in the Application ..... 4-40

4.7.1.2 Staff Evaluation .................................. 4-41

4.7.1.3 USAR Supplement ............................... 4-44

4.7.1.4 Conclusion ...................................... 4-44

xv
4.7.2 Main Steam Isolation Valve Corrosion Allowance (NMP2 Only) . .... 4-44

4.7.2.1 Summary of Technical Information in the Amended

Application ...................................... 4-44

4.7.2.2 Staff Evaluation .................................. 4-45

4.7.2.3 USAR Supplement ............................... 4-45

4.7.2.4 Conclusion .................................... 4-46

4.7.3 Stress Relaxation of Core Plate Hold-Down Bolts (NMP2 Only) ..... 4-46

4.7.3.1 Summary of Technical Information in the Amended

Application ...................................... 4-46

4.7.3.2 Staff Evaluation .................................. 4-47

4.7.3.3 USAR Supplement ............................... 4-48

4.7.3.4 Conclusion ...................................... 4-48

4.7.4 Reactor Vessel and Reactor Vessel Closure Head Weld Flaw

Evaluations (NMP1 Only) ................................. 4-49

4.7.4.1 Summary of Technical Information in the Amended

Application ...................................... 4-49

4.7.4.2 Staff Evaluation .................................. 4-50

4.7.4.3 UFSAR Supplement .............................. 4-51

4.7.4.4 Conclusion ...................................... 4-51

4.7.5 Reactor Water Cleanup System Weld Overlay Fatigue Flaw Growth

Evaluations (NMP1 Only) ................................ 4-52

4.7.5.1 Summary of Technical Information in the Amended

Application ...................................... 4-52

4.7.5.2 Staff Evaluation .................................. 4-52

4.7.5.3 USAR Supplement ............................... 4-55

4.7.5.4 Conclusion ...................................... 4-56

4.8 Conclusion for Time-Limited Aging Analyses .......................... 4-56

5. Review by the Advisory Committee on Reactor Safeguards ...................... 5-1

6. Conclusion ............................................................ 6-1

Appendices

Appendix A: Commitments for License Renewal ................................. A-1

Appendix B: Chronology ................................................... B-1

Appendix C: Principal Contributors ............................................ C-1

Appendix D: References ................................................... D-1

Tables

Table 3.0.3-1 NMPNS's Aging Management Programs ............................ 3-7

Table 3.1A-1 Staff Evaluation for NMP1 Reactor Vessel, Internals, and Reactor Coolant

Systems.Components in the GALL Report .............................. 3-164

xvi
Table 3.1 B-1 Staff Evaluation for NMP2 Reactor Vessel, Internals, and Reactor Coolant

Systems Components in the GALL Report .............................. 3-204

Table 3.2A-1 Staff Evaluation for NMP1 Engineered Safety Features Systems

Components in the GALL Report ...................................... 3-239

Table 3.2B-1 Staff Evaluation for NMP2 Engineered Safety Features Systems

Components in the GALL Report ...................................... 3-263

Table 3.3A-1 Staff Evaluation for NMP1 Auxiliary Systems Components in the

GALL Report ..................................................... 3-287

Table 3.3B-1 Staff Evaluation for NMP2 Auxiliary Systems Components in the

GALL Report ..................................................... 3-348

Table 3.4A-1 Staff Evaluation for NMP1 Steam and Power Conversion Systems

Components in the GALL Report ...................................... 3-402

Table 3.4B-1 Staff Evaluation for NMP2 Steam and Power Conversion Systems

Components in the GALL Report ...................................... 3-422

Table 3.5A-1 Staff Evaluation for NMP1 Structures and Component Supports in the

GALL Report ..................................................... 3-437

Table 3.5B-1 Staff Evaluation for NMP2 Structures and Component Supports in the

GALL Report ..................................................... 3-473

Table 3.6-1 Staff Evaluation for Electrical and Instrumentation and Controls Systems

Components in the GALL Report ....................................... 3-512

Table 4.2-1 Reactor Vessel USE Analysis Summary for NMP1 and NMP2 ............. 4-8

Table 4.2-2 RV Circumferential Weld Inspection Relief Analysis .................... 4-13

Table 4.2-3 RV Axial Weld Probability of Failure Analysis ......................... 4-15

xvii
ABBREVIATIONS

115KVAC 115KV AC electrical distribution

120VAC 120V AC electrical distribution

125VDC 125V DC electrical distribution

13.8KVAC, 13.8KV AC electrical distribution

24VDC 24V DC electrical distribution

4.16KVAC 4.16KV AC electrical distribution

600VAC 600V AC electrical distribution

AC alternating current

ACI American Concrete Institute

ACRS Advisory Committee on Reactor Safeguards

ADAMS Agency Document Access Management System

AERM aging effects requiring management

AFW auxiliary feedwater

AISC American Institute of Steel Construction

ALARA as low as reasonably achievable

ALRA amended license renewal application

AMP aging management program

AMR aging management review

ANSI American National Standards Institute

ARI alternate rod insertion

ART adjusted reference temperature

ASB auxiliary service building

ASME American Society of Mechanical Engineers

ASTM American Society for Testing and Materials

ATWS anticipated transient without scram

B24V battery-24V-station

BSW biological shield wall

BTP branch technical position

BWR boiling water reactor

BWROG Boiling Water Reactor Owners Group

BWRVIP boiling water reactor vessel internals project

CAP corrective action program

CAS compressed air system

CASS cast austentitic stainless steel

CBF cycle-based fatigue .

CCCWS closed-cycle cooling water system

CEG Constellation Energy Group

CF chemistry factor

CFR Code of Federal Regulations

CGG Constellation Generation Group

CI confirmatory item

CLB current licensing basis

CMEB Chemical and Mechanical Engineering Branch

xviii
CNS Constellation Nuclear Services

CR condition report

CRB control room building

CRD control rod drive

CRDRL control rod drive return line

CSH high pressure core spray

CST condensate storage tank

CUF cumulative usage factor

DBA design basis accident

DBD design basis document

DBE design basis event

DBTT ductile-to-brittle transition temperature

DC direct current

DER deviation event report

DG diesel generator

DGB diesel generator building

EC emergency condenser

ECCS emergency core cooling systems

ECP electrochemical cooling system

ECS emergency cooling system

ECT eddy current testing

EDG emergency diesel generator

EFPY effective full power years

EMA equivalent margin analysis

EOL end of life

EPRI Electric Power Research Institute

EQ environmental qualification

ERV electromatic relief valve

ESF engineered safety feature

EVT-1 enhanced VT-1 visual inspection

EYS essential yard structures

FAC flow-accelerated corrosion

F.. environmental fatigue life correction factor

FMP fatigue monitoring program

FP fire protection

FPEE fire protection engineering evaluation

FSAR final safety analysis report

FW feedwater

FW/HPCI feedwater/ high pressure coolant injection

FWS feedwater system

GALL Generic Aging Lessons Learned Report

GDC general design criteria or general design criterion

GE general electric

GElS Generic Environmental Impact Statement

GL generic letter

xix
GSI generic safety issue

GWT ground water table

HCU hydraulic control unit

HELB high-energy line break

HEPA high efficiency particulate air

HFIR 'high flux isotope reactor

HPCI high pressure coolant injection

HPCS high pressure core spray

HVAC heating, ventilation, and air conditioning

HWC hydrogen water chemistry

HX heat exchanger

I&C instrumentation and controls

IASCC irradiation assisted stress corrosion cracking

IBA intermediate-break accident

IEEE Institute of Electrical and Electronics Engineers

IGA intergranular attack

IGSCC intergranular stress corrosion cracking

IN information notice

INPO Institute of Nuclear Power Operations

IPA integrated plant assessment

ISG interim staff guidance

ISl inservice inspection

ISP integrated surveillance program

J joule

J-R joule-resistent

KV kilovolt

KVA kilovolt Amperes

LBS leakage boundary (spatial)

LOCA loss of coolant accident

LOOP loss of offsite power

LPCI low pressure coolant injection

LPCS low pressure core spray

LR license renewal

LRA license renewal application

LRT leak rate test

MCC motor control center

MEL master equipment list

MIC mircrobiologically induced corrosion

MG motor generator

MS main steam

MSIV main steam isolation valve

MWe megawatt electric

MWt megawatt thermal

xx
NDE non-destructive examinations

NEI Nuclear Energy Institute

NEIL Nuclear Electric Insurance Limited

NEPA National Environmental Policy Act of 1969

NER Nuclear Engineering Report

NFPA National Fire Protection Association

NMP1 Nine Mile Point Unit 1

NMP2 Nine Mile Point Unit 2

NMPC Niagra Mohawk Power Corporation

NMPNS Nine Mile Point Nuclear Station

NRC U.S. Nuclear Regulatory Commission

NSR nonsafety-related

NSSS nuclear steam supply system

NUMARC Nuclear Management and Resources Council (now NEI)

NUREG U.S. Nuclear Regulatory Commission Regulatory Guide

OCCW open-cycle cooling water

ODSCC outside-diameter stress-corrosion cracking

OGB offgas building

01 open item

ORNL Oak Ridge National Laboratory

P&ID piping and instrumentation diagram

PAA program attribute assessment

PCS primary containment structure

PEO period of extended operation

PM preventive maintenance

PMT post-maintenance test

P-T pressure-temperature

PTS pressurized thermal shock

PUAR plant-unique analysis report

PWR pressurized water reactor

PWSCC primary water stress-corrosion cracking

RAI request for additional information

RB reactor building

RBCLC reactor building closed look cooling

RBEDT reactor building equipment drain tank

RCIC reactor core isolation cooling

RCPB reactor coolant pressure boundary

RCS reactor coolant system

RG regulatory guide

RHR residual heat removal

RI-ISI risk-informed inservice inspection

RPS reactor protection system

RPT reactor recirculation pump trip

RPV reactor pressure vessel

RSSB radwaste solidification and storage building

RTNDT reference temperature nil ductility transition

xxi
RVID reactor vessel integrity database

RVSP Reactor Vessel Surveillance Program

RWB radwaste building

RWCU reactor water cleanup

S&W Stone and Webster

SBA small-break accident

SBF stress based fatigue

SBO station blackout

SC structure and component

SCC stress-corrosion cracking

SDC shutdown cooling

SE safety evaluation

SER safety evaluation report

SGTB standby gas treatment building

SGTS standby gas treatment system

SHE standard hydorgen reference electrode

SIA structural integrity attached

SIL service information letters

SOC statements of consideration

SPH screen and pumphouse

SR safety-related

SRP Standard Review Plan

SRP-LR Standard Review Plan for Review of License Renewal Applications for Nuclear

Power Plants

SSC system, structure, and component

SSE safe-shutdown earthquake

SWB screenwell building

t thickness

TAP torus attached piping

TB turbine building

TBCLC turbine building closed loop cooling

TER technical evaluation report

TLAA time-limited aging analysis

TS technical specification

UFSAR updated final safety analysis report (for Nine Mile Point Unit 1)

UPS uninterruptible power supplies

USAR updated safety analysis report (for Nine Mile Point Unit 2)

USAS United States of America Standards

USE upper-shelf energy

UT ultrasonic testing

UV ultra violet

V Volt

WDB waste disposal building

WO work order

xxii
SECTION 3

AGING MANAGEMENT REVIEW RESULTS

This section of the safety evaluation report (SER) contains the staff's evaluation of the

applicant's aging management programs (AMPs) and aging management reviews (AMRs). In

amended license renewal application (ALRA) Appendix B, the applicant described the 43 AMPs

that it relies on to manage or monitor the aging of long-lived, passive components and

structures.

In ALRA Section 3, the applicant provided the results of the AMRs for those structures and

components that were identified in ALRA Section 2 as being within the scope of license renewal

and subject to an AMR.

3.0 Applicant's Use of the Generic Aging Lessons Learned Report

In preparing its ALRA, Constellation Energy Group, LLC (CEG or the applicant) credited

NUREG-1801, Revision 0, "Generic Aging Lessons Learned (GALL) Report," The GALL Report

contains the staffs generic evaluation of the existing plant programs, and it documents the

technical basis for determining when existing programs are adequate without modification, and

when existing programs should be augmented for the extended period of operation. The

evaluation results documented in the GALL Report indicate that many of the existing programs

are adequate to manage the aging effects for particular structures or components for license

renewal without change. The GALL Report also contains recommendations on specific areas

for which existing programs should be augmented for license renewal. An applicant may

reference the GALL Report in its LRA to demonstrate that the programs at its facility

correspond to those reviewed and approved in the report.

The purpose of the GALL Report is to provide the staff with a summary of staff-approved AMPs

to manage or monitor the aging of structures and components that are subject to an AMR. If an

applicant commits to implementing these staff-approved AMPs, the time, effort, and resources

used to review an applicant's LRA will likely be reduced, thereby improving the efficiency and

effectiveness of the license renewal review process. The GALL Report also serves as a

reference for applicants and staff reviewers to quickly identify those AMPs and activities that the

staff has determined will adequately manage or monitor aging during the period of extended

operation.

The GALL Report identifies: (1) systems, structures, and components (SSCs); (2) structure and

component (SC) materials; (3) the environments to which the SCs are exposed; (4) the aging

effects associated with the materials and environments; (5) the AMPs that are credited with

managing or monitoring the aging effects; and (6) recommendations for further applicant

evaluations of aging management for certain component types.

To determine whether using the GALL Report would improve the efficiency of the license

renewal review, the staff conducted a demonstration project to exercise the GALL process and

to determine the format and content of a safety evaluation based on this process. The results of

the demonstration project confirmed that the GALL process will improve the efficiency and

3-1
effectiveness of the LRA review, while maintaining the staffs focus on public health and safety.

NUREG-1800, Revision 0, "Standard Review Plan for the Review of License Renewal

Applications" (SRP-LR) was prepared based on both the GALL Report model and lessons

learned from the demonstration project.

The staff performed its review in accordance with the requirements of Title 10, Part 54, of the

Code of Federal Regulations (10 CFR Part 54), "Requirements for Renewal of Operating

Licenses for Nuclear Power Plants," the guidance provided in the SRP-LR, and the guidance

provided in the GALL Report.

In addition to its review of the ALRA, the staff conducted an onsite audit of selected AMRs and

associated AMPs, as described in the "Audit and Review Plan for Plant Aging Management

Reviews and Programs, Nine Mile Point Nuclear Power Station, Units 1 and 2," (Audit and

Review Report) dated January 18, 2006. The onsite audits and reviews are designed to

maximize the efficiency of the staffs review of the LRA. The need for formal correspondence

between the staff and the applicant is reduced, thereby resulting in an improvement in the

review's efficiency. Also, the applicant could respond to questions and the staff could readily

evaluate the applicant's responses.

3.0.1 Format of the License Renewal Application

The applicant submitted an application that followed the standard LRA format, which was

agreed to by the Nuclear Regulatory Commission (NRC or the staff) and the Nuclear Energy

Institute (NEI) (see letter dated April 7, 2003, ML030990052). This revised LRA format

incorporates lessons learned from the staffs reviews of the previous five LRAs. These previous

applications used a format developed from information gained dufing an NRC staff and NEI

demonstration project that was conducted to evaluate the use of the GALL Report in the staff's

review process.

The organization of the amended LRA (ALRA) Section 3 parallels SRP-LR Chapter 3. The AMR

results information in ALRA Section 3 is presented in the following two table types:

" Table 1: Table 3.x.1 .A or 3.x.l.B - where "3" indicates the ALRA section number, "x"

indicates the subsection number from the GALL Report, "1" indicates that this is the first

table type in ALRA Section 3; "A" and "B" indicate that the table applies to Nine Mile Point

Unit 1 (NMP1) or Nine Mile Point Unit 2 (NMP2), respectively.

" Table 2: Table 3.x.2.A-y or 3.x.2.B-y - where "3" indicates the ALRA section number; "x"

indicates the subsection number from the GALL Report; "2" indicates that this is the

second table type in ALRA Section 3; "A" and "B" indicate that the table applies to NMP1

or NMP2, respectively, and "y" indicates the system table number.

The content of the original LRA and the Nine Mile Point Nuclear Station (NMPNS) ALRA is

essentially the same. The intent of the ALRA revised format was to modify the tables in LRA

Section 3 to provide additional information that would assist the staff in its review. Table 1 of

ALRA Section 3, summarizes portions of the application that it is considered to be consistent

with the GALL Report. In Table 2 of ALRA Section 3, the applicant identified the linkage

between the scoping and screening results in ALRA Section 2 and the AMRs in ALRA

Section 3.

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3.0.1.1 Overview of Table I

Table 3.x.l.A or 3.x.1.B (Table 1) provides a summary comparison of how the facility aligns with

the corresponding tables of the GALL Report, Volume 1. The table is essentially the same as

Tables 1 through 6 provided in the GALL Report, Volume 1, except that the "Type" column has

been replaced by an "Item Number" column and the "Item Number in GALL" column has been

replaced by a "Discussion" column. The "Item Number" column provides the reviewer with a

means to cross-reference from Table 2 to Table 1. The "Discussion" column is used by the

applicant to provide clarifying and amplifying information. The following are examples of

information that might be contained within this column:

" further evaluation recommended - information or reference to where that information is

located

* the name of a plant-specific program being used

* exceptions to the GALL Report assumptions

* a discussion of how the line is consistent with the corresponding line item in the GALL

Report when this may not be intuitively obvious

* a discussion of how the item is different from the corresponding line item in the GALL

Report (e.g., when there is exception taken to a GALL AMP)

The format of Table 1 allows the staff to align a specific Table 1 row with the corresponding

GALL Report, Volume 1, table row so that the consistency can be verified.

3.0.1.2 Overview of Table 2

Table 3.x.2.A-y or 3.x.2.B-y (Table 2) provides the detailed results of the AMRs for those

components identified in ALRA Section 2 as being subject to an AMR. The ALRA contains a

Table 2 for each of the systems or components within a system grouping (e.g., reactor coolant

systems, engineered safety features, auxiliary systems, etc.). For example, the engineered

safety features group contains tables specific to the core spray system, high pressure coolant

injection system, and residual heat removal system. Table 2 consists of the following nine

columns:

(1) Component Type - The first column identifies the component types from ALRA

Section 2 that are subject to aging management review. The component types are listed

in alphabetical order.

(2) Intended Function - The second column contains the license renewal intended functions

(including abbreviations, where applicable) for the listed component types. Definitions

and abbreviations of intended functions are contained within ALRA Table 2.0-1.

(3) Material - The third column lists the particular materials of construction for the

component type.

(4) Environment - The fourth column lists the environment to which the component types

are exposed. Internal and external service environments are indicated and a list of these

environments is provided in ALRA Table 3.0-1.

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(5) Aging Effect Requiring Management - The fifth column lists aging effects requiring

management (AERMs). As part of the aging management review process, the applicant

determined any AERMs for each combination of material and environment.

(6) Aging Management Programs - The sixth column lists the AMPs that the applicant used

to manage the identified aging effects.

(7) NUREG-1801 Volume 2 Item - The seventh column lists the GALL Report item(s) that

the applicant identified as being similar to the AMR results in the ALRA. The applicant

compared each combination of component type, material, environment, AERM, and

AMP in Table 2 of the ALRA to the items in the GALL Report. If there were no

corresponding items in the GALL Report, the applicant left the column blank. In this way,

the applicant identified the AMR results in the ALRA tables that corresponded to the

items in the GALL Report tables.

(8) Table 1 Item - The eighth column lists the corresponding summary item number from

Table 1. If the applicant identifies AMR results in Table 2 that are consistent with the

GALL Report, then the associated Table 1 line summary item number should be listed in

Table 2. If there is no corresponding item in the GALL Report, then column eight is left

blank. That way, the information from the two tables can be correlated.

(9) Notes - The ninth column lists the corresponding notes that the applicant used to

identify how the information in Table 2 aligns with the information in the GALL Report.

The notes, identified by letters, were developed by an NEI working group and will be

used in future license renewal applications. Any plant-specific notes are identified by a

number and provide additional information concerning the consistency of the line item

with the GALL Report.

3.0.2 Staff's Review Process

The staff conducted the following three types of evaluations of the AMRs and associated AMPs:

(1) For items that the applicant stated were consistent with the GALL Report, the staff

conducted either an audit or a technical review to determine consistency with the GALL

Report.

(2) For items that the applicant stated were consistent with the GALL Report with

exceptions and/or enhancements, the staff conducted either an audit or a technical

review of the item to determine consistency with the GALL Report. In addition, the staff

conducted either an audit or a technical review of the applicant's technical justification

for the exceptions and the adequacy of the enhancements.

(3) For other items, the staff conducted a technical review.

The staff performed audits and technical reviews of the license renewal applicant's AMPs and

AMRs. These audit and technical reviews are to determine whether the effects of aging on

structures and components can be adequately managed so that their intended functions can be

maintained consistently with the plant's current licensing basis (CLB) for the period of extended

operation, as required by 10 CFR Part 54, "Requirements for Renewal of Operating Licenses

for Nuclear Power Plants."

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3.0.2.1 Review of AMPs

For those AMPs for which the applicant claimed consistency with the GALL AMPs, the staff

conducted either an audit or a technical review to verify that the applicant's AMPs were*

consistent with the AMPs in the GALL Report. For each AMP that had one or more deviations,

the staff evaluated each deviation to determine: (1) whether the deviation was acceptable; and

(2) whether the AMP, as modified, would adequately manage the aging effect(s) for which it

was credited. For AMPs that were not evaluated in the GALL Report, the staff performed a full

review to determine the adequacy of the AMPs. The staff evaluated the AMPs against the

following 10 program elements defined in SRP-LR Appendix A.

(1) Scope of Program - Scope of the program should include the specific structures and

components subject to an AMR for license renewal.

(2) Preventive Actions - Preventive actions should prevent or mitigate aging degradation.

(3) Parameters Monitored or Inspected - Parameters monitored or inspected should be

linked to the degradation of the particular structure or component intended function(s).

(4) Detection of Aging Effects - Detection of aging effects should occur before there is a

loss of structure or component intended function(s). This includes aspects such as

method or technique (i.e., visual, volumetric, surface inspection), frequency, sample

size, data collection, and timing of new/one-time inspections to ensure a timely detection

of aging effects.

(5) Monitoring and Trending - Monitoring and trending should provide predictability of the

extent of degradation, as well as timely corrective or mitigative actions.

(6) Acceptance Criteria - Acceptance criteria, against which the need for corrective action

will be evaluated, should ensure that the structure or component intended function(s)

are maintained under all CLB design conditions during the period of extended operation.

(7) Corrective Actions - Corrective actions, including root cause determination and

prevention of recurrence, should be timely.

(8) Confirmation Process - Confirmation process should ensure that preventive actions are

adequate and that appropriate corrective actions have been completed and are

effective.

(9) Administrative Controls -Administrative controls should provide a formal review and

approval process.

(10) Operating Experience - Operating experience of the AMP, including past corrective

actions resulting in program enhancements or additional programs, should provide

objective evidence to support the conclusion that the effects of aging will be adequately

managed so that the SC intended function(s) will be maintained during the period of

extended operation.

Details of the staff's audit evaluation of program elements (1) through (6) are documented in

the Audit and Review Report dated January 18, 2006, and are summarized in SER

Section 3.0.3.

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The staff reviewed the applicant's corrective action program (CAP) and documented its

evaluations in SER Section 3.0.4. The staffs evaluation of the CAP included assessment of the

following program elements: (7) corrective actions, (8) confirmation process, and (9)

administrative controls.

The staff reviewed the information concerning the (10) operating experience program element

and documented its evaluation in the Audit and Review Report. The staff also included a

summary of the program in SER Section 3.0.3.

The staff reviewed the respective NMP1 updated final safety analysis report (UFSAR) and

NMP2 updated safety analysis report (USAR) supplements for each AMP to determine if it

provided an adequate description of the program or activity, as required by 10 CFR 54.21(d).

3.0.2.2 Review of AMR Results

ALRA Table 2 contains information concerning whether or not the AMRs align with the AMRs

identified in the GALL Report. For a given AMR in Table 2, the staff reviewed the intended

function, material, environment, AERM, and AMP combination for a particular component type

within a system. The AMRs that correlate between a combination in Table 2 and a combination

in the GALL Report were identified by a referenced item number in column seven,

"NUREG-1801 Volume 2 Item." The staff also conducted onsite audits to verify the correlation.

A blank column seven indicates that the applicant was unable to locate an appropriate

corresponding combination in the GALL Report. The staff conducted a technical review of these

combinations that were not consistent with the GALL Report. The next column, uTable 1 Item,"

provided a reference number that indicated the corresponding row in Table 1.

3.0.2.3 UFSAR and USAR Supplements

Consistent with the SRP-LR, for the AMRs and associated AMPs that it reviewed, the staff also

reviewed the UFSAR and USAR supplements that summarize the applicant's programs and

activities for managing the effects of aging for the period of extended operation, as required by

10 CFR 54.21(d).

3.0.2.4 Documentation and Documents Reviewed

In performing its review, the staff used the ALRA, ALRA supplements, SRP-LR, and the GALL

Report

Also, during the onsite audit, the staff examined the applicant's justification, as documented in

the staff's Audit and Review Report, to verify that the applicant's activities and programs will

adequately manage the effects of aging on SCs. The staff also conducted detailed discussions

and interviews with the applicant's license renewal project personnel and others with technical

expertise relevant to aging management.

3.0.3 Aging Management Programs

SER Table 3.0.3-1 presents the AMPs credited by the applicant and described in ALRA

Appendix B. The table also indicates the GALL AMP that the applicant claimed its AMP was

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consistent with (if applicable) and the SSCs it monitors and manages. The section of the SER,

in which the staff's evaluation of the program is documented, is also provided.

Table 3.0.3-1 NMPNS's Aging Management Programs

.'NMPNS's AMP } GALL } GALL i ALRASystems orI-, Staff's

(ALRA Section) Comparison AMP(s) Structures, SER Section _ _ _. _j. - j : j That Credit the AMP

Existing AMPs

ASME Section XI Consistent with XI.M1 NMPI: 3.0.3.2.1

Inservice Inspection exception reactor vessel, internals, and

(Subsections IWB, IWC, reactor coolant systems;

IWD) Program engineered safety features;

(B2.1.1) auxiliary systems; steam and

power conversion systems

NMP2:

reactor vessel, internals, and

reactor coolant systems;

engineered safety features;

auxiliary systems

Water Chemistry Consistent with XI.M2 reactor vessel, internals, and 3.0.3.2.2

Control Program exception reactor coolant systems;

(B2.1.2) engineered safety features;

auxiliary systems; steam and

power conversion systems;

structures and component

supports

Reactor Head Closure Consistent with XI.M3 reactor vessel, internals, and 3.0.3.2.3

Studs Program exception reactor coolant systems (B2.1.3)

BWR Vessel ID Consistent XI.M4 reactor vessel, internals, and 3.0.3.1.1

Attachment Welds reactor coolant systems

Program

(B2.1.4).

BWR Feedwater Nozzle Consistent with XI.M5 reactor vessel, internals, and 3.0.3.2.4

Program exception reactor coolant systems

(B2.1.5) _

BWR Stress Corrosion Consistent with XI.M7 NMPI: 3.0.3.2.5

Cracking Program exception reactor vessel, internals, and

(B2.1.6) reactor coolant systems; engineered safety features; auxiliary systems

NMP2:

reactor vessel, internals, and

reactor coolant systems;

engineered safety features

BWR Penetrations Consistent XI.M8 reactor vessel, internals, and 3.0.3.1.2

Program reactor coolant systems

(B2.1.7) I I I

3-7
NMPNS's AMP GALL -• GALL ALRA Systems or staff's

•.(ALRASection) comparison AMP(s) .Structues SER Section

That Credit the AMP';

BWR Vessel Internals Consistent with XI.M9 reactor vessel, internals, and 3.0.3.2.6

Program enhancements reactor coolant systems

(B2.1.8)

Flow-Accelerated Consistent XI.M17 reactor vessel, internals, and 3.0.3.1.3

Corrosion Program reactor coolant systems;

(B2.1.9) engineered safety features;

auxiliary systems; steam and

power conversion systems

Open-Cycle Cooling Consistent with XI.M20 engineered safety features; 3.0.3.2.7

Water System Program enhancements auxiliary systems

(12.1.10)

Closed-Cycle Cooling Consistent with XI.M21 NMPI: 3.0.3.2.8

Water System Program enhancements auxiliary systems; steam and

(B2.1.11) power conversion systems

NMP2:

auxiliary systems

Boraflex Monitoring Consistent with XI.M22 structures and component 3.0.3.2.9

Program, NMP1 Only enhancements supports

(B2.1.12)

Inspection of Overhead Consistent with XI.M23 structures and component 3.0.3.2.10

Heavy Load and Light enhancements supports

Load Handling Systems

Program

(B2.1.13)

Compressed Air Consistent with XI.M24 auxiliary systems 3.0.3.2.11

Monitoring Program, exceptions and

NMP1 Only enhancements

(B2.1.14)

BWR Reactor Water Consistent with XI.M25 NMP1 3.0.3.2.12

Cleanup System exception auxiliary systems

Program

(B2.1.15)

Fire Protection Program Consistent with XI.M26 auxiliary systems; structures 3.0.3.2.13

(B2.1.16) exceptions and and component supports

enhancements

Fire Water System Consistent with XI.M27 auxiliary systems 3.0.3.2.14

Program enhancements

(12.1.17)

Fuel Oil Chemistry Consistent with XI.M30 auxiliary systems 3.0.3.2.15

Program exceptions and

(B2.1.18) enhancements

Reactor Vessel Consistent with XI.M31 reactor vessel, internals, and 3.0.3.2.16

Surveillance Program enhancements reactor coolant systems

(B2.1.19) _1 1

3-8
-.NMPNS's'AMP GALL GALL' : ALRA Systems or Staff's

'(ALRASection) Comparison .AMP(s) 'Structures ' SER'Section

'That Credit the AMP. ______

ASME Section XI Consistent with XI.S1 structures and component 3.0.3.2.17

Inservice Inspection exception supports; electrical and

(Subsection IWE) instrumentation and controls

Program ' systems

(B2.1.23)

ASME Section XI Consistent with XI.S2 structures and component 3.0.3.2.18

Inservice Inspection exception supports

(Subsection IWL)

Program, NMP2 Only (B2.1.24)

ASME Section XI Consistent with XI.S3 structures and component 3.0.3.2.19

Inservice Inspection exception supports

(Subsection IWF)

Program

(B2.1.25)

10 CFR 50 Appendix J Consistent XI.S4 auxiliary systems; structures 3.0.3.1.7

Program and component supports;

(B2.1.26) electrical and instrumentation

and controls systems

Masonry Wall Program Consistent with XI.S5 structures and component 3.0.3.2.20

(82.1.27) enhancements supports

Structures Monitoring Consistent with XI.S6 structures and component 3.0.3.2.21

Program enhancements supports

(82.1.28)

Non-EQ Electrical Consistent with XI.E2 electrical and instrumentation 3.0.3.2.22

Cables and Connections enhancements and controls systems

Used in Instrumentation

Circuits Program (B2.1.30)

Non-EQ Inaccessible Consistent with XI.E3 electrical and instrumentation 3.0.3.2.27

Medium-Voltage Cables enhancements and controls systems

Program, NMP2 Only (82.1.31)

Preventive Maintenance Plant-specific engineered safety features; 3.0.3.3.1

Program auxiliary systems; steam and

(B2.1.32) power conversion systems; electrical and instrumentation

and controls systems

Systems Walkdown Plant-specific reactor vessel, internals, and 3.0.3.3.2

Program reactor coolant systems;

(82.1.33) engineered safety features;

auxiliary systems; steam and

power conversion systems

Non-Segregated Bus Plant-specific electrical and instrumentation 3.0.3.3.3

Inspection Program and controls systems (82.1.34) 1

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NMPNS' AMP '.'GALL':''-. GALL ALRASystems or Staff's

i.(ALRA Section)'"'.', Comparison' AMP(s) -:Structures,-- SER Section

-______ ______ •,That Credltthe AMP ______-_-_

Bolting Integrity Consistent with XI.M18 NMP1: 3.0.3.2.23

Program exception and reactor vessel, internals, and

(B2.1.36) enhancements reactor coolant systems; engineered safety features;

auxiliary systems; steam and

power conversion systems

NMP2:

reactor vessel, internals, and

reactor coolant systems;

engineered safety features;

auxiliary systems; steam and

power conversion systems;

structures and component

supports

BWR Control Rod Drive Consistent with XI.M6 reactor vessel, internals, and 3.0.3.2.24

Return Une (CRDRL) exceptions reactor coolant systems

Nozzle Program

(B2.1.37)

Protective Coating Consistent with XI.S8 structures and component 3.0.3.2.25

Monitoring and exceptions and supports

Maintenance Program enhancements

(B2.1.38)

Environmental Consistent X.E1 reactor vessel, internals, and 3.0.3.1.9

Qualification Program reactor coolant systems;

(B3.1) engineered safety features;

auxiliary systems; steam and

power conversion systems;

structures and component

supports

Fatigue Monitoring Consistent with X.M1 reactor vessel, internals, and 3.0.3.2.26

Program enhancements reactor coolant systems;

(B3.2) engineered safety features;

auxiliary systems; steam and

power conversion systems;

structures and component

supports

Torus Corrosion Plant-specific structures and component 3.0.3.3.7

Monitoring Program, supports

NMPI Only

(B3.3)

New AMPs

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NMPNS's AMP... . .. GALL ^.;GALL ALRASystems or.i .- ,Staffs

(ALRA Section) Comparison> AMP(s)' Structures LSER Section

. .I ' + .. .. - ... . / : ." . : : - .... .-. " .... That Credit the AM P .' ' ' , - .:

One-Time Inspection Consistent XI.M32 NMP1: 3.0.3.1.4

Program reactor vessel, internals, and

(B2.1.20) reactor coolant systems;

engineered safety features;

auxiliary systems; steam and

power conversion systems;

structures and component

supports

NMP2:

reactor vessel, internals, and

reactor coolant systems;

engineered safety features;

auxiliary systems; steam and

power conversion systems

Selective Leaching of Consistent XI.M33 NMPI: 3.0.3.1.5

Materials Program reactor vessel, internals, and

(B2.1.21) reactor coolant systems;

engineered safety features;

auxiliary systems; steam and

power conversion systems

NMP2:

auxiliary systems

Buried Piping and Tanks Consistent XI.M34 auxiliary systems 3.0.3.1.6

Inspection Program

(B2.1.22)

Non-EQ Electrical Consistent XI.E1 electrical and instrumentation 3.0.3.1.8

Cables and Connections and controls systems

Program

(92.1.29)

Fuse Holder Inspection Plant-specific electrical and instrumentation 3.0.3.3.4

Program and controls systems (B2.1.35)

Non-EQ Electrical Cable Plant-specific electrical and instrumentation 3.0.3.3.5

Metallic Connections and controls systems

Inspection Program

(82.1.39)

Wooden Power Pole Plant-specific structures and component 3.0.3.3.6

Inspection Program, supports

NMP2 Only

(B2.1.40)

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3.0.3.1 AMPs That Are Consistent with the GALL Report

In ALRA Appendix B, the applicant identified that the following AMPs were consistent with the

GALL Report:

* BWR Vessel ID Attachment Welds Program

* BWR Penetrations Program

* Flow-Accelerated Corrosion Program

* One-Time Inspection Program

* Selective Leaching of Materials Program

* Buried Piping and Tanks Inspection Program

* 10 CFR 50 Appendix J Program

* Non-EQ Electrical Cables and Connections Program

* Environmental Qualification Program

3.0.3.1.1 BWR Vessel ID Attachment Welds Program

Summary of Technical Information in the Amended Application. In ALRA Section B2.1.4, the

applicant described the BWR Vessel ID Attachment Welds Program, stating that this is an

existing program that is consistent with GALL AMP XI.M4, "BWR Vessel ID Attachment Welds."

The BWR Vessel ID Attachment Welds Program manages the effects of cracking in reactor

pressure vessel inside diameter attachment welds. The BWR Vessel ID Attachment Welds

Program is based on industry guidelines issued by the Boiling Water Reactor Vessel Internals

Project (BWRVIP) and approved by the staff. Implementation of the BWR Vessel ID

Attachment Welds Program is discussed in the program description for the BWR Vessel

Internals Program (ALRA Section B2.1.8). The attributes of the BWR Vessel ID Attachment

Welds Program related to maintaining reactor coolant water chemistry are discussed in the

program description for the Water Chemistry Control Program (ALRA Section B2.1.2).

Staff Evaluation. During its audit and review, the staff confirmed the applicant's claim of

consistency with the GALL Report. Details of the staffs evaluation of this AMP are documented

in the Audit and Review Report. The staff determined that this AMP is consistent with the AMP

described in the GALL Report, including the associated operating experience attribute.

As documented in the Audit and Review Report, the staff noted that NMP credited Revisions 1

and 2 of the Electric Power Research Institute (EPRI) TR-103515 guidelines for its reactor

coolant water chemistry instead of the GALL Report recommended guidelines in BWRVIP-29.

The applicant stated that the "preventive actions" program element is addressed in its Water

Chemistry Control Program. The staffs review and evaluation of the applicant's Water

Chemistry Control Program are in SER Section 3.0.3.2.2. The staff found this method

acceptable.

The staff reviewed those portions of the BWR Vessel ID Attachment Welds Program for which

the applicant claimed consistency with GALL AMP XI.M4 and found them consistent.

Operating Experience. As documented in the Audit and Review Report, the applicant explained

that no industry operating experience with vessel ID attachment weld flaws has emerged since

the release of BWRVIP-48; therefore, there is no recent applicable operating experience. The

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applicant also stated that program changes and updates have resulted from the ongoing review

of regulatory notices for applicability to the reactor vessel internals. NMP closely monitors the

activity of the BWR Vessel Internals Program and ASME Section XI Code Committees. In these

ways, the applicant addresses vessel internal degradation noted at other BWRs systematically

and revises BWR Vessel Internals Program inspections accordingly. Operating experience

issues affecting NMP1 include core shroud cracking, shroud support weld cracking, control rod

drive (CRD) stub tube intergranular stress corrosion cracking (IGSCC) and leakage and top

guide cracking. Operating experience issues identified at NMP2 include core shroud cracking

and jet pump wedge wear. No other cracking has been identified for vessel internals at either

unit.

The staff reviewed the operating experience stated in the ALRA and interviewed the applicant's

technical staff to confirm that plant-specific operating experience revealed no degradation not

bounded by industry experience.

After review of industry and plant-specific experience and discussions with the applicant's

technical staff, the staff concludes that there is reasonable assurance that the applicant's BWR

Vessel ID Attachment Welds Program will adequately manage the aging effects and aging

effects mechanisms identified in the ALRA for which this AMP is credited.

UFSAR and USAR Supplements. In ALRA Sections A1.1.1 I and A2.1.12, the applicant

provided the respective UFSAR and USAR supplements for the BWR Vessel ID Attachment

Welds Program. The staff reviewed these sections and determined that the information in the

supplements provides adequate summary descriptions of the program, as required by

10 CFR 54.21(d).

Conclusion. On the basis of its review and audit of the applicant's BWR Vessel ID Attachment

Welds Program, the staff determined that those program elements for which the applicant

claimed consistency with the GALL Report are consistent with the GALL Report.The staff

concludes that there is reasonable assurance that the applicant demonstrated that the effects

of aging will be adequately managed so that the intended functions will be maintained

consistent with the CLB for the period of extended operation, as required by

10 CFR 54.21 (a)(3). The staff also reviewed the UFSAR supplement for this AMP and

concludes that it provides an adequate summary description of the program, as required by

10 CFR 54.21(d).

3.0.3.1.2 BWR Penetrations Program

Summary of Technical Information in the Amended Application. In ALRA Section B2.1.7, the

applicant described the BWR Penetrations Program, stating that this is an existing program that

is consistent with GALL AMP XI.M8, "BWR Penetrations." The BWR Penetrations Program

manages the effects of cracking in the various penetrations of the reactor pressure vessels.

The BWR Penetrations Program is based on guidelines issued by the BWRVIP and approved

by the NRC. Implementation of the BWR Penetrations Program is discussed in the program

description for the BWR Vessel Internals Program (ALRA Section B2.1.8). The attributes of the

BWR Penetrations Program related to maintaining reactor coolant water chemistry are included

in the Water Chemistry Control Program (ALRA Section B2.1.2).

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Staff Evaluation. During its audit and review, the staff confirmed the applicant's claim of

consistency with the GALL Report. Details of the staffs evaluation of this AMP are documented

in the Audit and Review Report. The staff determined that this AMP is consistent with the AMP

described in the GALL Report, including the associated operating experience attribute.

As documented in the Audit and Review Report, the staff noted that NMP credited Revision 1

and Revision 2 of the EPRI TR-103515 guidelines for its reactor coolant water chemistry

instead of the GALL Report recommended guidelines in BWRVIP-29. The applicant stated that

the "preventive actions" program element is addressed in its Water Chemistry Control Program.

The staff's review and evaluation reviewed the applicant's Water Chemistry Control Program

are documented in SER Section 3.0.3.2.2. The staff found this method acceptable.

The staff reviewed those portions of the BWR Penetrations Program for which the applicant

claimed consistency with GALL AMP XI.M8 and found them consistent. The staff found the

applicant's BWR Penetrations Program acceptable because it conforms to the recommended

GALL AMP XI.M8.

Operating Experience. As documented in the Audit and Review Report, the applicant explained

that operating experience issues affecting NMP1 include core shroud cracking, shroud support

weld cracking, CRD stub tube penetration IGSCC and leakage, and top guide cracking.

Operating experience issues identified at NMP2 include core shroud cracking and jet pump

wedge wear. No other cracking has been identified for vessel internals at either unit. The

applicant also stated that program changes and updates have resulted from the ongoing review

of industry operating experience and regulatory notices for applicability to the reactor vessel

internals. NMP closely monitors the activity in the BWRVIP and ASME Section Xl Code

Committees. In these ways the applicant addressed vessel internal degradation noted at other

BWRs in a systematic manner and revised the BWRVIP inspections accordingly.

The staff reviewed the operating experience referenced in the ALRA and interviewed the

applicant's technical staff to confirm that (1) the plant-specific operating experience did not

reveal any degradation not bounded by industry experience and (2) no industry operating

experience with penetration and nozzle cracking has emerged since the release of BWRVIP-49

and BWRVIP-27.

The staff recognized that the CAP, which captures internal and external plant operating

experience issues, ensures operating experience review and incorporation of objective

evidence to support the conclusion that the effects of aging will be adequately managed.

UFSAR and USAR Supplements. In ALRA Sections A1.1.8 and A2.1.9, the applicant provided

the respective UFSAR and USAR supplements for the BWR Penetrations Program. The staff

reviewed these sections and determined that the information in the supplements provides

adequate summary descriptions of the program, as required by 10 CFR 54.21(d).

Conclusion. On the basis of its review and audit of the applicant's BWR Penetrations Program,

the staff determined that those program elements for which the applicant claimed consistency

with the GALL Report are consistent with the GALL Report. The staff concludes that there is

reasonable assurance that the applicant has demonstrated that the effects of aging will be

adequately managed so that the intended functions will be maintained consistent with the CLB

for the period of extended operation, as required by 10 CFR 54.21(a)(3). The staff also

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reviewed the UFSAR supplement for this AMP and concludes that it provides an adequate

summary description of the program, as required by 10 CFR 54.21(d).

3.0.3.1.3 Flow-Accelerated Corrosion Program

Summary of Technical Information in the Amended Application. In ALRA Section B2.1.9, the

applicant described the Flow-Accelerated Corrosion (FAC) Program, stating that this is an

existing program that is consistent with GALL AMP XI.M 17, "Flow-Accelerated Corrosion." The

FAC Program, also referred to as the Erosion/Corrosion Program, manages aging effects due

to flow-accelerated corrosion in carbon steel and low alloy steel piping containing single-phase

and two-phase high-energy fluids. Program activities include: (1) analysis using a predictive

code (CHECWORKS) to determine critical locations, (2) baseline inspections to determine the

extent of thinning at the selected locations, (3) follow-up inspections to confirm the predictions,

and (4) repair or replacement of components, as necessary. The inspection results provide

input to the predictive computer code to calculate the number of refueling or operating cycles

remaining before the component reaches the minimum allowable wall thickness. If the

component trend indicates that an area will reach the minimum allowed thickness before the

next scheduled outage, the component is repaired, replaced, or re-evaluated. The program

considers the recommended actions in NRC Bulletin 87-01 and Information Notice (IN) 91-18,

and implements the guidelines for an effective FAC program presented in EPRI Report

NSAC-202L-R2. The program also implements the recommendations provided in NRC generic

letter (GL) 89-08, "Erosion/Corrosion Induced Pipe Wall Thinning."

Staff Evaluation. During its audit and review, the staff confirmed the applicant's claim of

consistency with the GALL Report. Details of the staff's evaluation of this AMP are documented

in the Audit and Review Report. The staff determined that this AMP is consistent with the AMP

described in the GALL Report, including the associated operating experience attribute.

As documented in the Audit and Review Report, the staff requested that the applicant clarify the

minimum acceptable wall thickness defined in its FAC Program. The applicant stated that its

FAC Program minimum acceptable wall thickness is the thickness required by the design code

to withstand design loads. The applicant's FAC Program uses 87.5 percent of the nominal wall

thickness as the first threshold for minimum wall thickness because newly purchased pipe to a

nominal design specification could have actual wall thickness as low as 87.5 percent of the

nominal wall thickness. The applicant also explained that if degradation is detected such that

the measured wall thickness is less than the minimum predicted thickness it will take additional

examinations in adjacent areas and at similar locations in sister trains/parallel lines to bound the

thinning and ensure that the actual minimum wall is measured. Because the applicant is using

an industry-accepted 87.5 percent of the nominal pipe wall thickness based on the piping

manufacturer's design tolerance for the minimum acceptable wall thickness determination and

because the applicant is following the EPRI Report NSAC-202L-R2, 'Recommendations for an

Effective Flow Accelerated Corrosion Program," for selection of the sampling size the staff

found this explanation satisfactory.

The staff found the applicant's FAC Program acceptable because it conforms to the

recommended GALL XI.M17 as claimed by the applicant in the ALRA.

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Operating Experience. In ALRA Section B2.1.9, the applicant explained that wall thinning

problems in single- and two-phase systems have occurred throughout the industry, as

documented in various NRC Bulletins and INs. NMPNS reviewed both industry and

plant-specific operating experience in establishing the basis for the FAC Program, which is

continually adjusted to account for further industry experience and research.

The staff reviewed the operating experience stated in the ALRA and interviewed the applicant's

technical staff to confirm that the plant-specific operating experience did not reveal any

degradation not bounded by industry experience.

As documented in the Audit and Review Report, the staff asked the applicant how well the

CHECWORKS model predictions compared with the actual field measurements. The applicant

informed the staff that the specific software inputs pertaining to the NMP application have been

verified properly and tested satisfactorily. Although minor changes in wall thickness were

detected the measurements confirmed that overall the CHECWORKS model was conservative.

The applicant also stated that the model will be updated periodically, refined, and calibrated

based on the comparison of inspection data with predicted wear rates.

As documented in the Audit and Review Report, the staff reviewed the applicant's carbon steel

piping erosion/corrosion program review plan for high energy systems. This procedure lists all

NMPI SSCs inspected in the applicant's FAC Program. The staff noted that plant-specific

operating experience has been incorporated into this procedure. The staff also sampled several

condition reports (CRs) that resulted from flow-accelerated corrosion inspections. The staff

noted that these inspection results were evaluated and documented properly. The staff also

noted that the applicant's FAC Program resulted in the identification and replacement of

susceptible piping sections with materials more resistant to FAC. For example, in 1997, at NMP,

the reheater drain line inlet nozzles to the fifth point feedwater heat exchangers were found to

be degrading due to FAC. As a corrective measure FAC-resistent materials were used to

replace these piping components and in 2002 at NMP2 a second point feedwater heat

exchanger low pressure drain line leaked before its scheduled FAC inspection. The degraded

low pressure heater drain lines were replaced with FAC-resistent chrome-moly piping material.

Based on this review, the staff concludes that continued review of operating experience will

ensure that FAC aging effects will be adequately managed.

After review of industry and plant-specific operating experience and discussions with the

applicant's technical staff the staff concludes that there is reasonable assurance that the

applicant's FAC Program will adequately manage the aging effects and aging effects

mechanisms identified in the ALRA for which this AMP is credited.

UFSAR and USAR Supplements. In ALRA Sections Al.1.19 and A2.1.19, the applicant

provided the respective UFSAR and USAR supplements for the FAC Program. The staff

reviewed these sections and determined that the information in the supplements provides

adequate summary descriptions of the program, as required by 10 CFR 54.21(d).

Conclusion. On the basis of its review and audit of the applicant's FAC Program, the staff

determined that those program elements for which the applicant claimed consistency with the

GALL Report are consistent with the GALL Report.The staff concludes that there is reasonable

assurance that the applicant demonstrated that the effects of aging will be adequately managed

so that the intended functions will be maintained consistent with the CLB for the period of

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extended operation, as required by 10 CFR 54.21 (a)(3). The staff also reviewed the UFSAR

supplement for this AMP and concludes that it provides an adequate summary description of

the program, as required by 10 CFR 54.21(d).

3.0.3.1.4 One-Time Inspection Program

Summary of Technical Information in the Amended Application. In ALRA Section B2.1.20, the

applicant described the One-Time Inspection Program, stating that this is a new program that is

consistent with GALL AMP XI.M32, "One-Time Inspection." The One-Time Inspection Program

manages aging effects with potentially long incubation periods for susceptible components

within the scope of license renewal. Program activities include visual, volumetric, and other

established inspection techniques consistent with industry practice to provide a means of

verifying that an aging effect is either not occurring or progressing so slowly that it has a

negligible effect on the intended function of the structure or component. The program also

provides measures for verifying the effectiveness of existing AMPs. If a one-time inspection

reveals an AERM, an evaluation is required to determine the ability of the affected component

to perform its intended function(s) during the period of extended operation and any appropriate

corrective action. For stagnant or low flow areas in treated-water systems, the One-Time

Inspection Program will determine the effectiveness of the Water Chemistry Control Program in

managing the effects of aging. For Class I piping less than four inches in diameter (nominal

pipe size) that is directly connected to the reactor coolant pressure boundary, the One-Time

Inspection Program will determine if cracking is occurring. If a flaw is detected, appropriate

additional examinations will be performed using methods currently employed for similar

components within the scope of the ASME Section Xl Inservice Inspection (Subsections IWB,

IWC, IWD) Program. Selective leaching is also part of the One-Time Inspection Program. It is

an aging effect that occurs very slowly, and NMPNS has identified potentially susceptible

components in various systems.

Staff Evaluation. During its audit and review, the staff confirmed the applicant's claim of

consistency with the GALL Report. Details of the staff s evaluation of this AMP are documented

in the Audit and Review Report. The staff determined that this AMP is consistent with the AMP

described in the GALL Report, including the associated operating experience attribute.

The staff reviewed those portions of the One-Time Inspection Program for which the applicant

claimed consistency with GALL AMP XI.M32 and found them consistent. The staff found the

applicant's One-Time Inspection Program acceptable because it conforms to the recommended

GALL AMP XI.M32.

Operating Experience. In ALRA Section B2.1.20, the applicant explained that the One-Time

Inspection Program is a new program at NMPNS; therefore, no programmatic operating

experience is available.

The staff recognized that the CAP captures internal and external plant operating experience

issues and ensures review and incorporation of operating experience for objective evidence to

support the conclusion that the effects of aging are adequately managed.

UFSAR and USAR Supplements. In ALRA Sections A1.1.28 and A2.1.28, the applicant

provided the respective UFSAR and USAR supplements for the One-Time Inspection Program.

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The staff reviewed these sections and determined that the information in the supplements

provides adequate summary descriptions of the program, as required by 10 CFR 54.21(d).

Conclusion. On the basis of its review and audit of the applicant's One-Time Inspection

Program, the staff determined that those program elements for which the applicant claimed

consistency with the GALL Report are consistent with the GALL Report.The staff concludes that

there is reasonable assurance that the applicant demonstrated that the effects of aging will be

adequately managed so that the intended functions will be maintained consistent with the CLB

for the period of extended operation, as required by 10 CFR 54.21(a)(3). The staff also

reviewed the UFSAR supplement for this AMP and concludes that it provides an adequate

summary description of the program, as required by 10 CFR 54.21(d).

3.0.3.1.5 Selective Leaching of Materials Program

Summary of Technical Information in the Amended Application. In ALRA Section B2.1.21, the

applicant described the Selective Leaching of Materials Program, stating that this is a new

program that is consistent with GALL AMP XI.M33, "Selective Leaching of Materials." The

Selective Leaching of Materials Program manages aging of components susceptible to

selective leaching. The potentially susceptible components include valve bodies, valve bonnets,

pump casings, and heat exchanger components in various systems. Implementation of the

Selective Leaching of Materials Program is discussed in the program description for the

One-Time Inspection Program.

Staff Evaluation. During its audit and review, the staff confirmed the applicant's claim of

consistency with the GALL Report. Details of the staffs evaluation of this AMP are documented

in the Audit and Review Report. The staff determined that this AMP is consistent with the AMP

described in the GALL Report, including the associated operating experience attribute. The

staff found the applicant's Selective Leaching of Materials Program acceptable because it

conforms to the recommended GALL AMP XI.M33.

Operating Experience. In ALRA Section B2.1.21, the applicant explained that the Selective

Leaching of Materials Program is implemented through its One-Time Inspection Program.

However, the applicant has had plant-specific operating experience with selective leaching.

As documented in the Audit and Review Report, the staff reviewed the operating experience in

the ALRA for the applicant's Selective Leaching of Materials Program and interviewed the

applicant's technical staff. The staff determined that the plant-specific operating experience

revealed no degradation not bounded by industry experience.

UFSAR and USAR Supplements. In ALRA Sections A1.1.33 and A2.1.33, the applicant

provided the respective UFSAR and USAR supplements for the Selective Leaching of Materials

Program. The staff reviewed these sections and determined that the information in the

supplements provides adequate summary descriptions of the program, as required by

10 CFR 54.21(d).

Conclusion. On the basis of its review and audit of the applicant's Selective Leaching of

Materials Program, the staff determined that those program elements for which the applicant

claimed consistency with the GALL Report are consistent with the GALL Report.The staff

concludes that there is reasonable assurance that the applicant demonstrated that the effects

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of aging will be adequately managed so that the intended functions will be maintained

consistent with the CLB for the period of extended operation, as required by

10 CFR 54.21 (a)(3). The staff also reviewed the UFSAR supplement for this AMP and

concludes that it provides an adequate summary description of the program, as required by

10 CFR 54.21(d).

3.0.3.1.6 Buried Piping and Tanks Inspection Program

Summary of Technical Information in the Amended Application. In ALRA Section B2.1.22, the

applicant described the Buried Piping and Tanks Inspection Program, stating that this is a new

program that is consistent with GALL AMP XI.M34, "Buried Piping and Tanks Inspection." The

Buried Piping and Tanks Inspection Program will manage the aging effects on the extemal

surfaces of carbon steel, low-alloy steel, and cast iron components (e.g., tanks, piping) that are

buried in soil. Program activities will include visual inspections of external coatings and

wrappings to detect damage and degradation. Periodicity of inspections will be based on plant

operating experience and opportunities for inspection due to maintenance. If an opportunistic

inspection does not occur within the first ten years of extended operation, NMPNS will excavate

a representative sample for the purpose of inspection.

Staff Evaluation. During its audit and review, the staff confirmed the applicant's claim of

consistency with the GALL Report. Details of the staff's evaluation of this AMP are documented

in the Audit and Review Report. The staff determined that this AMP is consistent with the AMP

described in the GALL Report, including the associated operating experience attribute.

In ALRA Section B2.1.22 the applicant stated that its new Buried Piping and Tanks Inspection

Program will manage the aging effects and aging effects mechanisms on the external surfaces

of carbon steel, low-alloy steel, and cast iron components buried in soil. However, GALL

AMP XI.M.34 states that the program manages the effects of corrosion on the

pressure-retaining capacity of buried carbon steel piping and tanks. During the staff audit and

review of the original LRA documented in the March 3, 2005, initial Audit and Review Report

(ML050660380) the staff asked the applicant to explain how aging effects and aging effects

mechanisms of cast iron and low-alloy components will be managed, e.g., how selective

leaching for cast iron will be detected and managed. The applicant responded that low alloy

steel and malleable cast iron are in the same material group as carbon steel with similar AERM.

Selective leaching is a gray cast iron AERM that will be diagnosed by visual inspection and

hardness measurement of selected samples. These hardness measurements will be

administered under the Selective Leaching of Materials Program.

The staff found the applicant's response acceptable. Low alloy steel and malleable cast iron

have similar aging effects and aging effects mechanisms as carbon steel and selective leaching

for cast iron components will be discovered by hardness testing. These hardness

measurements will be administered under the Selective Leaching of Materials Program.

The following sentence has been added to ALRA Section B2.1.22, Buried Piping and Tanks

Inspection Program, under the program description (Page B2-51): "If an opportunistic

inspection does not occur within the first ten years of extended operation, NMPNS will excavate

a representative sample for the purpose of inspection." The staff asked the applicant to explain

why the program description in the ALRA for its Buried Piping and Tanks Inspection Program

was revised to address the possible need for focused inspections for only the first 10-year

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period of extended operation and not also for the 10-year period prior to extended operation.

The applicant responded that its Buried Piping and Tanks Inspection Program was incomplete

and that the ALRA will be amended to address the need for possible focused inspections during

the 10-year period prior to extended operation.

In its letter dated December 1, 2005, the applicant stated that Sections A1.1.6, A2.1.7, and

B2.1.22 under the program description of the ALRA will be revised to read as follows:

The Buried Piping and Tanks Inspection Program is a new program that will

manage the aging effects/mechanisms on the external surfaces of carbon steel,

low-alloy steel, and cast iron components (e.g. tanks, piping) that are buried in

soil. Program activities will include visual inspections of external coatings and

wrappings to detect damage and degradation. Prior to entering the period of

extended operation, NMP will verify that there has been at least one

opportunistic or focused inspection within the past ten years. Upon entering the

period of extended operation, NMP will perform a focused inspection within ten

years, unless an opportunistic inspection occurred within this ten year period. All

credited inspections will be performed in areas with the highest likelihood of

corrosion problems, and in areas with a history of corrosion problems.

Sections A1.1.6 and A2.1.7 include the following additional last sentence:

This program will be implemented prior to the period of extended operation.

The staff found the applicant's response acceptable. With the clarification statements added by

the applicant to the ALRA to perform focused inspections as needed 10 years prior and within

the first 10 years of license extension, the applicant's Buried Piping and Tank Inspection

Program is now consistent with Element 4 of GALL AMP XI.M34.

The staff reviewed those portions of the Buried Piping and Tanks Inspection Program for which

the applicant claimed consistency with GALL AMP XI.M34 and found them consistent. The staff

found the applicant's Buried Piping and Tanks Inspection Program acceptable because it

conformed to the recommended GALL AMP XI.M34.

Operating Experience. In ALRA Section B2.1.22, the applicant explained that the Buried Piping

and Tanks Inspection Program is a new program at NMPNS; therefore, no programmatic

operating experience is available.

The staff reviewed the operating experience provided in the ALRA (however, only information

about related plant-specific and industry experience was available) and interviewed the

applicant's technical staff to confirm that the plant-specific operating experience revealed no

degradation not bounded by industry experience.

The staff recognized that the CAP, which captures internal and external plant operating

experience issues, ensures operating experience review and incorporation for objective

evidence to support the conclusion that the effects of aging are adequately managed.

UFSAR and USAR Supplements. In ALRA Sections A1.1.6 and A2.1.7, the applicant provided

the respective UFSAR and USAR supplements for the Buried Piping and Tanks Inspection

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- Program. The staff reviewed these sections and determined that the information in the

supplements provides adequate summary descriptions of the program, as required by

10 CFR 54.21(d).

Conclusion. On the basis of its review and audit of the applicant's Buried Piping and Tanks

Inspection Program, the staff determined that those program elements for which the applicant

claimed consistency with the GALL Report are consistent with the GALL Report.The staff

concludes that there is reasonable assurance that the applicant demonstrated that the effects

of aging will be adequately managed so that the intended functions will be maintained

consistent with the CLB for the period of extended operation, as required by

10 CFR 54.21 (a)(3). The staff also reviewed the UFSAR supplement for this AMP and

concludes that it provides an adequate summary description of the program, as required by

10 CFR 54.21(d).

3.0.3.1.7 10 CFR Part 50, Appendix J Program

Summary of Technical Information in the Amended Application. In ALRA Section B2.1.26, the

applicant described the 10 CFR Part 50, Appendix J Program, stating that this is an existing

program that is consistent with GALL AMP XI.S4, "10 CFR Part 50, Appendix J." The

10 CFR Part 50, Appendix J Program [or Containment Leak Rate Test (LRT) Program] detects

degradation of the containment structure and components that comprise the containment

pressure boundary, including seals and gaskets. The program is not relied on to detect the

onset or progression of degradation prior to it resulting in leakage. Containment leak rate tests

are performed to assure that leakage through the primary containment and systems and

components penetrating primary containment does not exceed allowable leakage limits

specified in the technical specifications (TSs). Type A tests measure the primary reactor

containment overall integrated leakage rate, and include visual examination of the interior and

exterior surfaces of the containment for evidence of structural deterioration. Type B tests

measure leakage across each pressure-containing or leakage-limiting boundary, including: (1)

containment penetrations whose design incorporates resilient seals, gaskets, or sealant

compounds; (2) piping penetrations fitted with expansion bellows; (3) electrical penetrations

fitted with flexible metal seal assemblies; (4) air lock door seals; and (5) doors with resilient

seals or gaskets. Type C tests measure the leakage rates for containment isolation valves.

Staff Evaluation. During its audit and review, the staff reviewed those portions of the 10 CFR

Part 50, Appendix J, Program for which the applicant claimed consistency with GALL :!

AMP XI.S4 to confirm the applicant's claim of consistency with the GALL Report. Details of the

staff's evaluation of this AMP are documented in the Audit and Review Report dated January 18

2006. The staff determined that this AMP is consistent with the AMP described in the GALL

Report, including the associated operating experience attribute.

Operatinq Experience. In ALRA Section B2.1.26, the applicant explained that it has reviewed

both industry and plant-specific operating experience relating to the Containment LRT Program.

Neither NMP1 nor NMP2 has experienced in the past two refueling outages a total leakage rate

above Containment LRT Program acceptance criteria.

As documented in the Audit and Review Report, in response to the staffs inquiry the applicant

stated that during the past two refueling outages the CAP identified no problems affecting its

Appendix J Program. In March-May 2004 the Appendix J Program was appraised to be sound

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by the applicant's self-assessment and by an external independent organization. The staff

noted that the applicant has demonstrated good operating experience in maintaining the

integrity of the primary containment boundaries as shown by the selection of Option B of

10 CFR Part 50, Appendix J leakage testing requirements at established frequencies consistent

with plant experience.

The staff sampled several items on the CR list that were associated with the containment LRT

testing and did not identify any items related to the 10 CFR Part 50, Appendix J Program that

would necessitate a change to NMP AMP B2.1.26.

The staff reviewed the operating experience provided in the ALRA and interviewed the

applicant's technical staff to confirm that the plant-specific operating experience revealed no

degradation not bounded by industry experience.

The staff found that based on the review of operating history, corrective actions, and

self-assessments the applicant's 10 CFR Part 50 Appendix J Program is monitored continually

and enhanced to incorporate the results of operating experience; as such it provides an

effective means of managing aging affecting the structural integrity and leakproof tightness of

the NMP containments.

After review of plant-specific operating experience and discussions with the applicant's

technical staff the staff concludes that there is reasonable assurance that the applicant's

10 CFR 50 Appendix J Program will adequately manage the aging effects and aging effects

mechanisms identified in the ALRA for which this AMP is credited.

UFSAR and USAR Supplements. In ALRA Sections A1.1.1 and A2.1.1, the applicant provided

the respective UFSAR and USAR supplements for the 10 CFR Part 50, Appendix J Program.

The staff reviewed these sections and determined that the information in the supplements

provides adequate summary descriptions of the program, as required by 10 CFR 54.21(d).

Conclusion. On the basis of its review and audit of the applicant's 10 CFR Part 50, Appendix J

Program, the staff determined that those program elements for which the applicant claimed

consistency with the GALL Report are consistent with the GALL Report.The staff concludes that

there is reasonable assurance that the applicant demonstrated that the effects of aging will be

adequately managed so that the intended functions will be maintained consistent with the CLB

for the period of extended operation, as required by 10 CFR 54.21 (a)(3). The staff also

reviewed the UFSAR supplement for this AMP and concludes that it provides an adequate

summary description of the program, as required by 10 CFR 54.21 (d).

3.0.3.1.8 Non-EQ Electrical Cables and Connections Program

Summary of Technical Information in the Amended Application. In ALRA Section B2.1.29, the

applicant described the Non-EQ Electrical Cables and Connections Program, stating that this is

a new program that is consistent with GALL AMP XI.E1, "Electrical Cables and Connections Not

Subject to 10 CFR 50.49 Environmental Qualification Requirements." The Non-EQ Electrical

Cables and Connections Program manages aging of cables and connectors within the scope of

license renewal exposed to adverse localized temperature, moisture, or radiation environments.

Program activities include visual inspection of susceptible cables for evidence of cable and

connection jacket surface anomalies. Inspections are conducted at least once every ten years,

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with the first representative sample of susceptible cables inspected prior to expiration of the

current NMPNS licenses.

Staff Evaluation. During its audit and review, the staff confirmed the applicant's claim of

consistency with the GALL Report. Details of the staff s evaluation of this AMP are documented

in the Audit and Review Report. The staff determined that this AMP is consistent with the AMP

described in the GALL Report, including the associated operating experience attribute.

The staff reviewed those portions of the Non-EQ Electrical Cables and Connections Program

for which the applicant claimed consistency with GALL AMP XI.E1 and found them consistent.

The staff found the applicant's Non-EQ Electrical Cables and Connections Program acceptable

because it conformed to the recommended GALL AMP XI.E1.

Operating Experience. In ALRA Section B2.1.29, the applicant explained that the Non-EQ

Electrical Cables and Connections Program is a new program at NMPNS; therefore, no

programmatic operating experience is available.

The staff reviewed the plant-specific operating experience stated in the ALRA and interviewed

the applicant's technical staff to confirm that the plant-specific operating experience revealed no

degradation not bounded by industry experience.

As stated in the Audit and Review Report, the applicant will thoroughly review accessible

non-EQ cables and connections documents (e.g., bulletins, letters, notices, advisories, et

cetera) for applicability. If these documents are affecting or thought to affect NMP, the applicant

will enter these documents into its CAP for resolution. Other nuclear power plants operating

experience reports are reviewed to assess potential impact to NMP. Operating experience

found to be applicable to NMP is added to its CAP for resolution.

After review of industry and plant-specific operating experience and discussions with the

applicant's technical staff, the staff concludes that there is reasonable assurance that the

applicant's Non-EQ Electrical Cables and Connections Program will adequately manage the

aging effects and aging effects mechanisms identified in the ALRA for which this AMP is

credited.

The staff recognizes that the CAP captures internal and external plant operating experience

issues and ensures operating experience review and incorporation for objective evidence to

support the conclusion that the effects of aging are adequately managed.

UFSAR and USAR Supplements. In ALRA Sections A1.1.24 and A2.1.24, the applicant

provided the respective UFSAR and USAR supplements for the Non-EQ Electrical Cables and

Connections Program. The staff reviewed these sections and determined that the information in

the supplements provides adequate summary descriptions of the program, as required by

10 CFR 54.21(d).

Conclusion. On the basis of its review and audit of the applicant's Non-EQ Electrical Cables and

Connections Program, the staff determined that those program elements for which the applicant

claimed consistency with the GALL Report are consistent with the GALL Report.The staff

concludes that there is reasonable assurance that the applicant demonstrated that the effects

of aging will be adequately managed so that the intended functions will be maintained

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consistent with the CLB for the period of extended operation, as required by

10 CFR 54.21 (a)(3). The staff also reviewed the UFSAR supplement for this AMP and

concludes that it provides an adequate summary description of the program, as required by

10 CFR 54.21(d).

3.0.3.1.9 Environmental Qualification Program

Summary of Technical Information in the Amended Application. In ALRA Section B3. 1, the

applicant described the Environmental Qualification Program, stating that this is an existing

program that is consistent with GALL AMP X.E1, "Environmental Qualification (EQ) of Electric

Components." The Environmental Qualification (EQ) Program manages thermal, radiation, and

cyclical aging for electrical equipment important to safety and located in harsh plant

environments at NMPNS. At NMP2, the EQ Program also manages these effects for active

safety-related mechanical equipment located in harsh plant environments. EQ program

activities (1) identify applicable equipment and environmental requirements; (2) establish,

demonstrate, and document the level of qualification (including configuration, maintenance,

surveillance, and replacement requirements); and (3) maintain (or preserve) qualification. The

EQ Program employs aging evaluations based on 10 CFR 50.49(f) qualification methods.

Components in the EQ Program must be refurbished, replaced, or have their qualification

extended prior to reaching the aging limits established in the evaluation. Aging evaluations for

environmentally qualified components that specify a qualification of at least 40 years are

considered time-limited aging analysis (TLAAs) for license renewal. The EQ Program ensures

that these SSCs are maintained within the bounds of their qualification bases.

Staff Evaluation. During its audit and review, the staff confirmed the applicant's claim of

consistency with the GALL Report. Details of the staff's evaluation of this AMP are documented

in the Audit and Review Report. The staff determined that this AMP is consistent with the AMP

described in the GALL Report, including the associated operating experience attribute.

As documented in the Audit and Review Report, the staff identified one difference between the

GALL AMP and the NMP EQ Program description. EQ of electrical equipment in ALRA

Section 4.4 indicates that the aging effects and aging effects mechanisms of the EQ of

electrical equipment identified in the TLAA will be managed during the extended period of

operation under 10 CFR 54.21(c)(1)(iii). However, as documented in the Audit and Review

Report, no information is provided on reanalysis of an aging evaluation to extend the

qualification life of electrical equipment identified in the TLAA. Important attributes of a

reanalysis are analytical methods, data collection and reduction methods, underlying

assumptions, acceptance criteria, and corrective actions. GALL AMP X.E1 under the EQ

component reanalysis attributes describes each attribute under the program description. The

EQ Program does not include this information.

As documented in the Audit and Review Report, the staff requested that the applicant address

the reanalysis attributes listed in GALL AMP X.EI or justify why this information was not

included. In response to this request, the applicant informed the staff that it agreed to include

the detailed EQ component reanalysis attributes in its NMP AMP. The staff concludes that the

applicant's response is acceptable because the NMP AMP will be consistent with the GALL

Report AMP program description. In its letter dated December 1, 2005, the applicant revised its

ALRArto included a detailed description of reanalysis attributes.

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As documented in the Audit and Review Report, the staff also asked if the applicant has plans

to monitor temperature in order to extend the qualified life of components if the EQ reanalysis

option is chosen. The applicant's response recognized that thermal aging is limiting component

life. It plans to incorporate actual plant temperature monitoring data into the aging evaluation

reanalysis for EQ components with a qualified life greater than 40 years similar to the

temperature monitoring data used to assess equipment qualified life during the current

operation period to represent existing plant thermal conditions accurately.

The staff reviewed those portions of the EQ Program for which the applicant claimed

consistency with GALL AMP X.E1 and found them consistent. The staff found the applicant's

EQ Program acceptable because it conforms to the recommended GALL AMP X.E1.

Operating Experience. In ALRA Section B3.1, the applicant explained that the EQ Program

started in 1980 as a project at NMP1, and was developed as an integral part of construction at

NMP2. Since its inception, consideration of plant and industry operating experience has been

an important element of the EQ Program. Recorded measurements of ambient temperature

have been used to define conditions for some harsh environments, and records of

representative actual temperatures have been used as preliminary data to resolve concerns for

certain terminal blocks installed in the NMP1 drywell. Qualified life evaluations for certain

sealing materials and lamp assemblies were reevaluated to remove excess conservatism and

eliminate unnecessary maintenance activities. The program is evolving as administrative

improvements have been identified to address issues such as communication and

organizational transitions. A major program reconstitution effort began in 2003, in response to

internal assessments, to improve the overall strength of the EQ Program. With additional

operating experience lessons learned will be used to adjust this program as needed. The

applicant's EQ Program has been effective in managing thermal, radiative, and cyclical aging of

components within the scope of 10 CFR 50.49.

The staff reviewed the operating experience stated in the ALRA and interviewed the applicant's

technical staff to confirm that the plant-specific operating experience revealed no degradation

not bounded by industry experience.

After review of industry and plant-specific operating experience and discussions with the

applicant's technical staff the staff concludes that there is reasonable assurance that the

applicant's EQ Program will adequately manage the aging effects and aging effects

mechanisms identified in the ALRA for which this AMP is credited.

UFSAR and USAR Supplements. In ALRA Sections Al.1.15 and A2.1.15, the applicant

provided the respective UFSAR and USAR supplements for the Environmental Qualification

Program. The staff reviewed these sections and determined that the information in the

supplements provides adequate summary descriptions of the program, as required by

10 CFR 54.21(d).

Conclusion. On the basis of its review and audit of the applicant's Environmental Qualification

Program, the staff determined that those program elements for which the applicant claimed

consistency with the GALL Report are consistent with the GALL Report.The staff concludes that

there is reasonable assurance that the applicant demonstrated that the effects of aging will be

adequately managed so that the intended functions will be maintained consistent with the CLB

for the period of extended operation, as required by 10 CFR 54.21(a)(3). The staff also

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reviewed the UFSAR supplement for this AMP and concludes that it provides an adequate

summary description of the program, as required by 10 CFR 54.21(d).

3.0.3.2 AMPs That Are Consistent with the GALL Report with Exceptions or

Enhancements

In ALRA Appendix B, the applicant identified that the following AMPs were, or will be, consistent

with the GALL Report, with exception(s) or enhancement(s):

* ASME Section Xl Inservice Inspection (Subsections IWB, IWC, IWD) Program

* Water Chemistry Control Program

* Reactor Head Closure Studs Program

* BWR Feedwater Nozzle Program

* BWR Stress Corrosion Cracking Program

* BWR Vessel Internals Program

• Open-Cycle Cooling Water System Program

* Closed-Cycle Cooling Water System Program

* Boraflex Monitoring Program (NMP1 Only)

* Inspection of Overhead Heavy Load and Light Load Handling Systems Program

* Compressed Air Monitoring Program (NMP1 Only)

* BWR Reactor Water Cleanup System Program

* Fire Protection Program

* Fire Water System Program

* Fuel Oil Chemistry Program

* Reactor Vessel Surveillance Program

* ASME Section XI Inservice Inspection (Subsection IWE) Program

• ASME Section XI Inservice Inspection (Subsection IWL) Program (NMP2 Only)

* ASME Section Xl Inservice Inspection (Subsection IWF) Program

* Masonry Wall Program

* Structures Monitoring Program

* Non-EQ Electrical Cables and Connections Used in Instrumentation Circuits Program

* Bolting Integrity Program

* BWR Control Rod Drive Return Line (CRDRL) Nozzle Program

* Protective Coating Monitoring and Maintenance Program

* Fatigue Monitoring Program

* Non-EQ Inaccessible Medium Voltage Cables Program (NMP2 Only)

For AMPs that the applicant claimed are consistent with the GALL Report, with exceptions or

enhancements, the staff performed an audit to confirm that those attributes or features of the

program for which the applicant claimed consistency with the GALL Report were indeed

consistent. The staff also reviewed the exceptions and enhancements to the GALL Report to

determine whether they were adequate and acceptable. The results of the staff's audit and

reviews are documented in the following sections.

3.0.3.2.1 ASME Section Xl Inservice Inspection (Subsections IWB, IWC, IWD) Program

Summary of Technical Information in the Amended Application. In ALRA Section B2.1.1, the

applicant described the ASME Section XI Inservice Inspection (Subsections IWB, IWC, IWD)

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Program, stating that this is an existing program that is consistent, with exception, with GALL

AMP XI.M1, "ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD." The

ASME Section XI Inservice Inspection (Subsections IWB, IWC, IWD) Program (referred to

herein as the IWB/C/D ISI Program) manages aging of Class 1, 2, and 3 pressure-retaining

components and their integral attachments. Program activities include periodic visual, surface,

and/or volumetric examination and pressure tests of Class 1, 2, and 3 pressure-retaining

components. The IWB/C/D ISI Program is based on ASME Section XI, 1989 edition, with no

Addenda and ASME Section XI, Appendix VIII, 1995 Edition through 1996 Addenda.

Examination categories B-F, B-J, C-F-I, C-F- 2 and IGSCC Category A are inspected using the

EPRI risk-informed methodology and implemented in accordance with ASME Code Case

N-578-1 as approved by NRC plant-specific Relief Request.

Staff Evaluation. During its audit and review, the staff confirmed the applicant's claim of

consistency with the GALL Report. Details of the staffs audit evaluation of this AMP are

documented in the Audit and Review Report. The staff reviewed the exception and the

associated justifications to determine whether the AMP, with the exception, remains adequate

to manage the aging effects for which it is credited.

The staff reviewed those portions of the IWB/C/D ISI Program for which the applicant claimed

consistency with GALL AMP XI.M1 and found them consistent. The staff found the applicant's

IWB/C/D ISI Program acceptable because it conforms to the recommended GALL AMP XI.M1

with exception.

In the ALRA the applicant stated that its IWB/C/D ISI Program is consistent with the GALL

Report with exception in the "detection of aging effects" and "monitoring and trending" program

elements. The program is based on the 1989 Edition of ASME Section XI with no addenda.

Examination categories B-F, B-J, C-F-I, and C-F-2 and IGSCC Category A are inspected per

the requirements of the EPRI risk-informed methodology and ASME Code Case N-578-1.

In addition in the ALRA the applicant stated that its IWB/C/D ISI Program based on the 1989

Edition with no addenda was found acceptable by the NRC in safety evaluations (SEs) dated

October 5, 2000 and March 3, 2000, and that the IWB/C/D ISI Program for NMP1 and NMP2

implement the EPRI risk-informed methodology and ASME Code Case N-578-1 as approved by

the staff in an NRC plant-specific relief request.

The GALL Report states that the 1989 Code Edition covers all examination categories identified

in the 1995 Edition through the 1996 Addenda and that the 1995 ASME Code Edition eliminates

the hydrostatic test because equivalent results are obtained from the leakage test. The staff

also compared the acceptance criteria differences between the 1989 and 1995 Editions through

the 1996 Addenda of ASME Section X1. The staff found the acceptance criteria of the 1989

Edition more conservative than those of the 1995 Edition through the 1996 Addenda.

Subsection IWB-3640 in the 1989 Edition sets the acceptable flaw depth upper limit as 60

percent of wall thickness whereas Subsection IWB-3640 in the 1995 Edition through the 1996

Addenda sets the acceptable flaw depth upper limit as 75 percent of wall thickness for shielded

metal-arc welds and submerged arc welds. The staff also reviewed the SERs for the NMP ISI

plans based on the ASME Section Xl 1989 Edition. On this basis, the staff finds the code

edition exception acceptable.

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As documented in the Audit and Review Report, the staff noted that the applicant's

risk-informed Inservice inspection (RI-ISI) relief request is valid for a 10-year inspection interval

under the CLB and requested that the applicant provide additional justification for extending this

risk-informed relief request for the period of extended operation. In its letter dated

December 1, 2005, the applicant stated that the program description had been revised by

deleting "using the EPRI risk-informed methodology and implemented in accordance with

ASME Code Case N-578-1 as approved by the NRC plant-specific Relief Request" and

inserting "using NRC approved Risk-Informed Methodology." Prior to the period of extended

operation, the ISI Program will be updated to the latest Edition and Addenda of ASME

Section Xl as mandated by 10 CFR 50.55a and 10 CFR Part 54 requirements." At present, an

RI-ISI program is approved for use on an ASME Code 10-year ISI for specific intervals.

However, the applicant will have to request approval to use the RI-ISI program for specific

intervals 12 months prior to each interval during the period of extended operation under

10 CFR 50.55a. Therefore, the staff determined that the ASME Section Xl code in effect

referenced in 10 CFR 50.55a, for which the applicant will request approval 12 months prior to

each inspection interval, is acceptable for the period of extended operation. The staff concludes

that the applicant's response is acceptable.

The staff determined that although the number of the examinations is reduced, the risk from

implementation of RI-ISI is expected to decrease slightly from that estimated from the current

requirements. The primary reason for the risk reduction is that examinations will be required for

piping segments of safety significance that may not be inspected per the existing ASME

Section Xl Program. In addition the RI-ISI program is on ongoing program that requires update

and expansion based on industry and site-specific inspection findings. On this basis the staff

finds this exception acceptable.

Operating Experience. In ALRA Section B2.1.1, the applicant explained it has reviewed both

industry and plant-specific operating experience relating to the IWB/C/D ISI Program. Review of

plant-specific operating experience revealed CRs documenting indications of flaws in

recirculation components, piping, and various nozzle connection welds. Deficiencies identified

by IWB/C/D ISI Program activities have been repaired, replaced,,or evaluated as acceptable in

accordance with ASME Section XI and station implementing procedures.

The staff reviewed the applicant's supporting documents that evaluate industry experiences as

identified in General Electric (GE) service information letters (SILs) against the applicant's ISI

Program. The staff determined that the applicant continuously evaluates industry operating

experience and adjusts its inspection plans accordingly.

The staff also reviewed the applicant's CAP, which revealed that CRs were initiated when ISI

inspections found stress corrosion cracking (SCC) in the reactor coolant system. The staff

reviewed the applicant's CRs as described in the Audit and Review Report and found that the

applicant's ISl Program is effective in identifying degradation and implementing repairs.

The staff reviewed the operating experience stated in the ALRA and interviewed the applicant's

technical staff to confirm that the plant-specific operating experience revealed no degradation

not bounded by industry experience.

After review of industry and plant-specific operating experience and discussions with the

applicant's technical staff, the staff concludes that there is reasonable assurance that the

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applicant's IWB/C/D ISl Program will adequately manage the aging effects and aging effects

mechanisms identified in the ALRA for which this AMP is credited.

UFSAR and USAR Supplements. The applicant provided its UFSAR and USAR supplements

for the IWB/C/D ISI Program in ALRA Section A1.1.4 for NMP1 and Section A2.1.5 for NMP2

stating that the program manages aging of Class 1, 2, or 3 pressure-retaining components and

their integral attachments. Program activities include periodic visual surface or volumetric

examinations and pressure tests of Class 1, 2, and 3 pressure-retaining components. The

applicant also stated that its IWB/C/D ISI Program is based on the ASME Section XI 1989

Edition with no Addenda and ASME Section XI, Appendix VIII, 1995 Edition through 1996

Addenda. Examination categories B-F, B-J, C-F-i, and C-F-2 and IGSCC Category A are

inspected using EPRI risk-informed methodology and implemented in accordance with ASME

Code Case N-578-1 as approved by an NRC plant-specific relief request. These are program

exceptions described in the GALL Report (which cites ASME Section Xl requirements covered

in the 1995 Edition through the 1996 Addenda).

As documented in the Audit and Review Report, the staff noted that the applicant's RI-ISI relief

request is. valid for a 10-year inspection interval under the CLB and requested that the applicant

provide additional justification for extending this risk-informed relief request for the period of

extended operation. The applicant stated that it would revise Appendix A to remove that relief

request. In its letter dated December 1, 2005, the applicant stated that ALRA Sections A1.1.4

and A2.1.5 have been revised by deleting "using the EPRI risk-informed methodology and

implemented in accordance with ASME Code Case N-578-1 as approved by the NRC

plant-specific Relief Request" and replacing it with "using NRC approved Risk-Informed

Methodology." Prior to the period of extended operation, the ISI Program will be updated to the

latest Edition and Addenda of ASME Sectioh Xl as mandated by 10 CFR 50.55a and

10 CFR 54 requirements." The staff reviewed the applicant's response, found the revised

information to be adequate, and concludes that it is acceptable. The staff reviewed these

sections and determined that the information in the UFSAR and USAR supplements also

provides adequate summary program descriptions required by 10 CFR 54.21(d).

Conclusion. On the basis of its review and audit of the applicant's IWB/C/D ISI Program, the

staff determined that those program elements for which the applicant claimed consistency with

the GALL Report are consistent with the GALL Report. In addition, the staff reviewed the

exception and the associated justifications, and determined that the AMP, with the exception, is

adequate to manage the aging effects for which it is credited.The staff concludes that there is

reasonable assurance that the applicant demonstrated that the effects of aging will be

adequately managed so that the intended functions will be maintained consistent with the CLB

for the period of extended operation, as required by 10 CFR 54.21(a)(3). The staff also

reviewed the UFSAR and USAR supplements for this AMP and concludes that the supplements

provide an adequate summary description of the program, as required by 10 CFR 54.21(d).

3.0.3.2.2 Water Chemistry Control Program

Summary of Technical Information in the Amended Application. In ALRA Section B2.1.2, the

applicant described the Water Chemistry Control Program, stating that this is an existing

program that is consistent, with exceptions, with GALL AMP XI.M2, "Water Chemistry." The

Water Chemistry Control Program manages aging effects by controlling the internal

environment of the reactor water, feedwater, condensate, and control rod drive systems, and

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related auxiliaries (such as the NMP1 torus, NMP2 suppression pool, condensate storage tank,

and spent fuel pool). The aging effects of concern are loss of material and crack initiation and

growth. Program activities include monitoring and controlling concentrations of known

detrimental chemical species below the levels known to cause degradation. The Water

Chemistry Control Program implements the guidelines for BWR water chemistry presented in

Electric Power Research Institute (EPRI) Reports TR-103515-R1 and TR-103515-R2. The

Water Chemistry Control Program credits activities performed under the direction of the ASME

Section XI Inservice Inspection (IWB, IWC, IWD) Program and the One-Time Inspection

Program to verify program effectiveness, including areas of low flow or stagnant water.

Staff Evaluation. During its audit and review, the staff confirmed the applicant's claim of

consistency with the GALL Report. Details of the staff's audit evaluation of this AMP are

documented in the Audit and Review Report. The staff reviewed the exceptions and the

associated justifications to determine whether the AMP, with the exceptions, remains adequate

to manage the aging effects for which it is credited.

The staff reviewed those portions of the Water Chemistry Control Program for which the

applicant claimed consistency with GALL AMP XI.M2 and found them consistent. The staff

found the applicant's Water Chemistry Control Program acceptable because it conforms to the

recommended GALL AMP XI.M2 with exceptions.

In the ALRA the applicant stated that its Water Chemistry Control Program is consistent with

the GALL Report with an exception to the "scope of program" program element. The program

described in GALL AMP XI.M2 identifies the EPRI TR-103515-RO report as the basis for BWR

water chemistry programs. EPRI periodically updates the water chemistry guidelines as new

industry experience becomes available. Revisions I and 2 of the EPRI report incorporate

industry experience and are the basis for the NMP1 Water Chemistry Control Program whereas

NMP2 uses only TR-103515 Revision 2.

The specific impacts of this scope of program exception are addressed with the program

elements affected by the use of later revisions of the EPRI TR-103515 so no evaluation is

provided for the "scope of program" element

The applicant also stated in the ALRA that its Water Chemistry Control Program has an

exception to the "parameters monitored/inspected" program element. The program described in

GALL AMP XI.M2 identifies the EPRI TR-103515-RO report as the basis for BWR water

chemistry programs. EPRI TR-103515-RO recommends that electrochemical potential (ECP) be

monitored during power operations and does not distinguish between normal water chemistry

and hydrogen water chemistry (HWC). The NMP1 program takes an exception in that ECP is

monitored only under HWC operation. The NMP2 program also takes an exception by not

monitoring ECP directly but the molar ratio of hydrogen-to-oxygen as an acceptable alternative.

The GALL Report also recommends that hydrogen peroxide be monitored to manage stress

corrosion cracking and corrosion in BWR plants. Both NMPI and NMP2 programs takes

exceptions to this recommendation because accurate measurement of this chemical is

extremely difficult due to its rapid decomposition in the sample lines. As an alternative

consistent with Revision 2 of the EPRI report NMP1 measures ECP and NMP2 measures the

molar ratio of hydrogen to oxygen.

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With regard to the NMP1 exception of monitoring ECP only when under HWC, EPRI TR-10315

Revision 2 recommends, based on the latest industry experience, that ECP be monitored only if

plants implement HWC or HWC with noble metal chemical addition (NMCA). Based on the

latest industry information the staff found this practice acceptable. In regard to NMP2 the

applicant stated in the ALRA that it does not monitor ECP directly but rather the molar ratio of .

hydrogen to oxygen as an acceptable alternative based on the latest industry guidance of EPRI

TR-1 0315 Revision 2. The staff found acceptable this use of an alternative measurement

providing the same level of effectiveness.

From review of the information provided in the ALRA the staff determined that the applicant

proposed acceptable alternative methods for both NMP1 and NMP2 for measuring the level of

hydrogen peroxide in the coolant. As described in the exception, NMP1 measures

electrochemical potential. The molar ratio of hydrogen to oxygen is used by NMP2 to monitor

the presence of excessive hydrogen peroxide. The staff found these exceptions acceptable.

In addition, in the ALRA the applicant stated that its Water Chemistry Control Program also

takes an exception to the "monitoring and trending" program element. The program described

in GALL AMP XI.M2 identifies the EPRI TR-103515-RO report as the basis for BWR water

chemistry programs. EPRI TR-103515-R0 recommends that chlorides and sulfates in reactor

water be sampled daily. NMP2 takes an exception to this recommendation by sampling for

these chemical species only three times per week. EPRI TR-103515-RO also recommends that

ECP be monitored continuously for reactor water. NMP2 takes an exception to this

recommendation by not monitoring ECP. EPRI TR-103515-RO recommends that the sampling

frequencies and action levels for feedwater iron and copper commence at > 10 percent power.

Both NMP1 and NMP2 takes exceptions to this recommendation by not commencing these

sampling activities until 25 percent power.

With regard to the NMP2 exception to daily monitoring of chlorides and sulfates, the applicant

stated in the ALRA that these species are part of the conductivity measurement monitored

continuously and any increase in conductivity above Action Level 1 requires daily sampling to

determine the concentration of monitored species. The applicant further stated that this

sampling plan is consistent with the guidance of Revisions 0 and 2 of the EPRI report. Because

the program does not reduce the effectiveness of the NMP2 Water Chemistry Control Program,

the staff found this exception acceptable.

With regard to NMP2 not continuously monitoring ECP the applicant stated in the ALRA that the

molar ratio of hydrogen to oxygen is used as an acceptable alternative. Furthermore, the

applicant stated that BWRVIP-62 provides the technical correlation between these two

parameters and establishes an operating goal for the value of hydrogen-to-oxygen molar ratio.

Because the use of the BWRVIP-62 correlation does not reduce the effectiveness of the NMP2

Water Chemistry Control Program, the staff found this exception acceptable.

With regard to initiating sampling frequencies and action levels for feedwater iron and copper at

> 10 percent power, the applicant states, in the ALRA, that, for both NMP1 and NMP2, the

justification for this exception is that the filter samples collected below 25 percent power are not

representative and the operating time between 10 and 25 percent power is short enough to be

considered insignificant. Because of the limited time between 10 and 25 percent power, the

staff concludes that this does not reduce the effectiveness of the applicant's Water Chemistry

Control Program. On this basis, the staff found this acceptable.

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Furthermore, in the ALRA the applicant stated that its Water Chemistry Control Program takes

an exception to the "acceptance criteria" program element. The program described in GALL

AMP XI.M2 identifies the EPRI TR-103515-RO report as the basis for BWR water chemistry

programs. EPRI periodically updates water chemistry guidelines as new industry experience

becomes available. Revisions I and 2 of the EPRI report incorporating industry experience are

the basis for the NMP1 Water Chemistry Control Program whereas NMP2 uses only

TR-1 03515 Revision 2. EPRI TR-103515-RO recommends that an action level be established

for ECP during power operations. NMP1 takes an exception to the establishment of an action

level but establishes an administrative goal of the same value. EPRI TR-103515-RO

recommends specific values for action levels 2 and 3 for reactor water chlorides and sulfates

under HWC/NMCA conditions during power operations. NMP2 takes an exception to these

values by using the corresponding values recommended in Revision 2 of the EPRI report.

With regard to NMP1 establishing an action level for ECP in the ALRA, the applicant stated that

it establishes a plant-specific administrative goal for ECP and the actions required by the NMP

administrative procedure are consistent with the EPRI recommended actions for exceeding the

value. The applicant further stated that there is, therefore, no impact on program effectiveness.

Because NMP1 has established an administrative procedure that does not reduce the

effectiveness of the applicant's Water Chemistry Control Program the staff found this exception

acceptable.

With regard to establishing action levels 2 and 3 for reactor water chlorides and sulfates in the

ALRA, the applicant stated that the latest industry experience indicates that these higher values

do not reduce the effectiveness of the applicant's Water Chemistry Control Program while

operating at power using HWC. For maintaining program effectiveness the staff found this

exception acceptable.

Operating Experience. In ALRA Section B2.1.2, the applicant explained that it has reviewed

both industry and plant-specific operating experience relating to the Water Chemistry Control

Program. As chemistry control guidelines were evolving in the industry, NMP experience with

reactor water system chemistry was similar to that of the industry. Review of plant-specific

* operating experience revealed CRs documenting instances where monitored parameters

exceeded specified action levels or goals. In those instances where a chemistry action level

was exceeded, prompt corrective actions were taken to re-establish proper chemistry.

As documented in the Audit and Review Report dated January 18, 2006, the staff reviewed the

summary of specific operating experience for the applicant's Water Chemistry Control Program.

The staff found a significant number of CRs on water chemistry control limit monitoring,

demonstrating the effectiveness of the program in minimizing propagation of aging effects and

aging effects mechanisms of concern for SSCs for which water chemistry is controlled.

The staff also reviewed the operating experience stated in the ALRA and interviewed the

applicant's technical staff to confirm that the plant-specific operating experience revealed no

degradation not bounded by industry experience.

After review of industry and plant-specific operating experience and discussions with the

applicant's technical staff the staff concludes that there is reasonable assurance that the

applicant's Water Chemistry Control Program adequately manages the aging effects and aging

effects mechanisms identified in the ALRA for which this AMP is credited.

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UFSAR and USAR Supplements. In ALRA Sections A1.1.37 and A2.1.36, the applicant

provided the respective UFSAR and USAR supplements for the Water Chemistry Control

Program. The staff reviewed these sections and determined that the information in the

supplements provides adequate summary descriptions of the program, as required by

10 CFR 54.21(d).

Conclusion. On the basis of its review and audit of the applicant's Water Chemistry Control

Program, the staff determined that those program elements for which the applicant claimed

consistency with the GALL Report are consistent with the GALL Report. In addition, the staff

reviewed the exceptions and the associated justifications, and determined that the AMP, with

the exceptions, is adequate to manage the aging effects for which it is credited.The staff

concludes that there is reasonable assurance that the applicant demonstrated that the effects

of aging will be adequately managed so that the intended functions will be maintained

consistent with the CLB for the period of extended operation, as required by

10 CFR 54.21 (a)(3). The staff also reviewed the UFSAR supplement for this AMP and

concludes that it provides an adequate summary description of the program, as required by

10 CFR 54.21(d).

3.0.3.2.3 Reactor Head Closure Studs Program

Summary of Technical Information in the Amended Application. In ALRA Section B2.1.3, the

applicant described the Reactor Head Closure Studs Program, stating that this is an existing

program that is consistent, with exception, with GALL AMP XI.M3, "Reactor Head Closure

Studs." The Reactor Head Closure Studs Program manages cracking of and loss of material

from the reactor pressure vessel closure studs. The Reactor Head Closure Studs Program

implements the preventive measures of Regulatory Guide 1.65. Inservice examinations are

performed in accordance with the 1989 edition of the ASME Boiler and Pressure Vessel Code

with no Addenda, and ASME Section Xl, Appendix VIII, 'Performance Demonstration for

Ultrasonic Examination Systems," 1995 Edition through 1996 Addenda as approved by the

NRC in plant-specific exemptions.

Staff Evaluation. During its audit and review, the staff confirmed the applicant's claim of

consistency with the GALL Report. Details of the staffs audit evaluation of this AMP are

documented in the Audit and Review Report. The staff reviewed the exception and the

associated justifications to determine whether the AMP, with the exception, remains adequate

to manage the aging effects for which it is credited.

The staff reviewed portions of the Reactor Head Closure Studs Program for which the applicant

claimed consistency with GALL AMP XI.M3 and found them consistent. The staff found the

applicant's Reactor Head Closure Studs Program acceptable because it conforms to the

recommended GALL AMP XI.M3.

In the ALRA, the applicant stated that its Reactor Head Closure Studs Program is consistent

with the GALL Report with an exception to the program description. The program described in

GALL AMP XI.M3 cites ASME Section Xl requirements covered in the 1995 Edition through the

1996 Addenda. The IWB/C/D ISI Programs for NMP1 and NMP2 are based on the 1989 Edition

with no addenda.

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The staff noted that the code of record is updated and approved by the staff for each inspection

interval in accordance with 10 CFR 50.55a and that this regulation mandates the application of

ASME Section XI, Appendix VIII, "Performance Demonstration for Ultrasonic Examination

Systems," (1995 Edition with the 1996 Addenda). On this basis, the staff found this exception

acceptable.

Operating Experience. In ALRA Section B2.1.3, the applicant explained that it has reviewed

both industry and plant-specific operating experience relating to the Reactor Head Closure

Studs Program. NMP reactor vessel studs have experienced very little degradation. A review of

plant-specific operating experience revealed only a few CRs initiated as a result of inspections

of the studs, associated nuts, and washers. The review demonstrated that the CRs were related

to normal maintenance issues and not to age-related defects. There are no existing defects in

the head studs or nuts.

The staff determined that the applicant's inspection program is adequate to detect timely

indications of aging to allow for repair or replacement prior to bolting failure.

The staff reviewed the operating experience stated in the ALRA and interviewed the applicant's

technical staff to confirm that the plant-specific operating experience revealed no degradation

not bounded by industry experience.

After review of industry and plant-specific operating experience and discussions with the

applicant's technical staff the staff concludes that the applicant's Reactor Head Closure Studs

Program will adequately manage the aging effects and aging effects mechanisms identified in

the ALRA for which this AMP is credited.

UFSAR and USAR Supplements. In ALRA Sections A1.1.31 and A2.1.31, the applicant

provided the respective UFSAR and USAR supplements for the Reactor Head Closure Studs

Program. The staff reviewed these sections and determined that the information in the

supplements provides adequate summary descriptions of the program, as required by

10 CFR 54.21(d).

Conclusion. On the basis of its review and audit of the applicant's Reactor Head Closure Studs

Program, the staff determined that those program elements for which the applicant claimed

consistency with the GALL Report are consistent with the GALL Report. In addition, the staff

reviewed the exception and the associated justifications, and determined that the AMP, with the

exception, is adequate to manage the aging effects for which it is credited.The staff concludes

that there is reasonable assurance that the applicant demonstrated that the effects of aging will

be adequately managed so that the intended functions will be maintained consistent with the

CLB for the period of extended operation, as required by 10 CFR 54.21 (a)(3). The staff also

reviewed the UFSAR supplement for this AMP and concludes that it provides an adequate

summary description of the program, as required by 10 CFR 54.21(d).

3.0.3.2.4 BWR Feedwater Nozzle Program

Summary of Technical Information in the Amended Application. In ALRA Section B2.1.5, the

applicant described the BWR Feedwater Nozzle Program, stating that this is an existing

program that is consistent, with exception, with GALL AMP XI.M5, "BWR Feedwater Nozzle."

The NMP1 and NMP2 Feedwater Nozzle Programs are existing programs that require

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ultrasonic testing (UT) inspections of the feedwater nozzles every 10 years to verify the nozzles

are acceptable for continued service. The Feedwater Nozzle Programs are implemented

through the ISI Program which at the time the original LRA Was submitted conformed to the

requirements in ASME Code, Section Xl, Subsection IWB, Table IWB 2500-1 (1989 Edition, no

Addenda), and ASME Section XI, Appendix VIII, 1995 Edition through 1996 Addenda,

"Performance Demonstration for Ultrasonic Examination Systems," to ASME Section Xl,

Division 1. UT and PT inspections discussed in NUREG-0619 have been superseded because

the inspections are now performed in accordance with ASME Section Xl, Appendix VIII.

Staff Evaluation. During its audit and review, the staff confirmed the applicant's claim of

consistency with the GALL Report. Details of the staff's audit evaluation of this AMP are

documented in the Audit and Review Report. The staff reviewed the exception and the

associated justifications to determine whether the AMP, with the exception, remains adequate

to manage the aging effects for which it is credited.

The staff reviewed those portions of the BWR Feedwater Nozzle Program for which the

applicant claimed consistency with GALL AMP XI.M5 and found them consistent. The staff

found the applicant's BWR Feedwater Nozzle Program acceptable because it conforms to the

recommended GALL AMP XI.M5 with an exception.

In the ALRA, the applicant stated that its BWR Feedwater Nozzle Program is consistent with

the GALL Report with an exception to the program description. The NMP Inservice Inspection

Program does not comply with the specific edition and addenda of ASME Section Xl cited in the

GALL Report because prior to the start of each inspection interval, the program is updated to

the latest edition and addenda of ASME Section XI as mandated by 10 CFR 50.55a. This

exception (i.e., updating the ISI Program to the latest edition and addenda of ASME Section Xl

as mandated by 10 CFR 50.55a) is acceptable because the NMP ISI Programs are consistent

with the recommendation of GALL AMP XI.M5 in that the feedwater nozzles are subject to

ASME Section XI requirements.

In the ALRA, the applicant further stated that the program described in GALL AMP XI.M5 cites

ASME Section XI requirements covered in the 1995 Edition through the 1996 Addenda. The

IWBICID ISI Programs for NMP are based on the 1989 Edition with no addenda and ASME

Section XI, Appendix VIII, 1995 Edition through 1996 Addenda. As documented in the Audit and

Review Report, the staff noted that the code of record is updated and approved by the NRC

staff for each inspection interval under 10 CFR 50.55a. On this basis the staff found this

exception acceptable.

Operatina Experience. In ALRA Section B2.1.5, the applicant explained that no industry

experience was identified that indicates that existing programs and practices will not be

effective in the timely identification of feedwater nozzle cracking.

The staff reviewed the operating experience stated in the ALRA and interviewed the applicant's

technical staff to confirm that the plant-specific operating experience revealed no degradation

not bounded by industry experience.

After review of industry and plant-specific operating experience and discussions with the

applicant's technical staff the staff concludes that the applicant's BWR Feedwater Nozzle

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Program will adequately manage the aging effects and aging effects mechanisms identified in

the ALRA for which this AMP is credited.

UFSAR and USAR Supplements. In ALRA Sections A1.1.7 and A2.1.8, the applicant provided

the respective UFSAR and USAR supplements for the BWR Feedwater Nozzle Program. The

staff reviewed these sections and determined that the information in the supplements provides

adequate summary descriptions of the program, as required by 10 CFR 54.21(d).

Conclusion. On the basis of its review and audit of the applicant's BWR Feedwater Nozzle

Program, the staff determined that those program elements for which the applicant claimed

consistency with the GALL Report are consistent with the GALL Report. In addition, the staff

reviewed the exception and the associated justifications, and determined that the AMP, with the

exception, is adequate to manage the aging effects for which it is credited.The staff concludes

that there is reasonable assurance that the applicant demonstrated that the effects of aging will

be adequately managed so that the intended functions will be maintained consistent with the

CLB for the period of extended operation, as required by 10 CFR 54.21 (a)(3). The staff also

reviewed the UFSAR supplement for this AMP and concludes that it provides an adequate

summary description of the program, as required by 10 CFR 54.21(d).

3.0.3.2.5 BWR Stress Corrosion Cracking Program

Summary of Technical Information in the Amended Application. In ALRA Section B2.1.6, the

applicant described the BWR SCC Program, stating that this is an existing program that is

consistent, with exception, with GALL AMP XI.M7, "BWR Stress Corrosion Cracking." The BWR

SCC Program manages intergranular stress corrosion cracking in reactor coolant pressure

boundary piping made of stainless steel as delineated in NUREG-0313, Revision 2, and

Generic Letter 88-01 and its Supplement 1, as modified by BWRVIP-75. Augmented

inspections are performed in accordance with these documents. The attributes of the BWR

SCC Program related to maintaining reactor coolant water chemistry are included in the Water

Chemistry Control Program.

Staff Evaluation. During its audit and review, the staff confirmed the applicant's claim of

consistency with the GALL Report. Details of the staff's audit evaluation of this AMP are

documented in the Audit and Review Report. The staff reviewed the exception and the

associated justifications to determine whether the AMP, with the exception, remains adequate

to manage the aging effects for which it is credited.

As documented in the Audit and Review Report, the staff noted that NMP credited Revision I

and Revision 2 of the EPRI TR-103515 guidelines for its reactor coolant water chemistry

instead of the GALL Report recommended guidelines in BWRVIP-29. The applicant stated that

the "preventive actions" program element is addressed in its Water Chemistry Control Program.

The staff reviewed the applicant's Water Chemistry Control Program and documented its

evaluation in SER Section 3.0.3.2.2. The staff found this exception acceptable.

The staff reviewed those portions of the BWR SCC Program for which the applicant claimed

consistency with GALL AMP XI.M7 and found them consistent. The staff found the applicant's

BWR SCC Program acceptable because it conforms to the recommended GALL AMP XI.M7

with an exception.

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In the ALRA, the applicant stated that its BWR SCC Program is consistent with the GALL

Report with an exception to the "acceptance criteria" program element. The current NMP

licensing is based on the 1989 Edition of ASME Section Xl whereas the GALL Report cites the

1995 Edition with the 1996 Addenda of the ASME Section Xl Code.

The staff compared the 1989 Edition to the 1995 Edition through 1996 Addenda of ASME

Section XI Subsection IWB-3640. The staff found the acceptance criteria in the 1989 Edition

more conservative than those in the 1995 Edition through 1996 Addenda. Subsection IWB-3640

in the 1989 Edition sets the acceptable flaw depth upper limit as 60 percent of the wall

thickness whereas IWB-3640 in the 1995 Edition through 1996 Addenda sets the acceptable

flaw depth upper limit as 75 percent of the wall thickness for the shielded metal-arc welds and

submerged arc welds. On this basis the staff found the exception acceptable.

Operating Experience. In ALRA Section B2.1.6, the applicant explained it has reviewed both

industry and plant-specific operating experience relating to BWR stress corrosion cracking.

Along with other plants in the BWR fleet, NMP1 has found indications of IGSCC in recirculation

system piping and welds that were evaluated and dispositioned in accordance with the

applicable ISI Program plan.

The staff reviewed the applicant's CAP, which shows that CRs were initiated when ISI

inspections found SCC in the reactor coolant system.

The staff reviewed the applicant's CRs as described in the Audit and Review Report and found

that operating experience indicates that the BWR SCC Program at NMP1 has been generally

effective in managing aging effects and aging effects mechanisms in BWR coolant

pressure-retaining boundary piping.

The staff also reviewed the operating experience stated in the ALRA and interviewed the

applicant's technical staff to confirm that plant-specific operating experience revealed no

degradation not bounded by industry experience.

After review of industry and plant-specific operating experience and discussions with the

applicant's technical staff the staff concludes that there is reasonable assurance that the

applicant's BWR SCC Program adequately manages the aging effects and aging effects

mechanisms identified in the ALRA for which this AMP is credited.

UFSAR and USAR Supplements. In ALRA Sections A1.1.10 and A2.1.11, the applicant

provided the respective UFSAR and USAR supplements for the BWR SCC Program. The staff

reviewed these sections and determined that the information in the supplements provides

adequate summary descriptions of the program, as required by 10 CFR 54.21(d).

Conclusion. On the basis of its review and audit of the applicant's BWR SCC Program, the staff

determined that those program elements for which the applicant claimed consistency with the

GALL Report are consistent with the GALL Report. In addition, the staff reviewed the exception

and the associated justifications, and determined that the AMP, with the exception, is adequate

to manage the aging effects for which it is credited.The staff concludes that there is reasonable

assurance that the applicant demonstrated that the effects of aging will be adequately managed

so that the intended functions will be maintained consistent with the CLB for the period of

extended operation, as required by 10 CFR 54.21 (a)(3). The staff also reviewed the UFSAR

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supplement for this AMP and concludes that it provides an adequate summary description of

the program, as required by 10 CFR 54.21(d).

3.0.3.2.6 BWR Vessel Internals Program

Summary of Technical Information in the Amended Application. In ALRA Section B2.1.8, the

applicant described the BWR Vessel Internals Program, stating that this is an existing program

that is consistent, with enhancements, with GALL AMP XI.M9, "BWR Vessel Internals." The

BWR Vessel Internals Program manages aging of materials inside the reactor vessel. Program

activities include: (1) inspections for the presence and effects of cracking and (2) monitoring

and control of water chemistry. This program is based on guidelines issued by the BWRVIP and

approved (or pending approval) by the NRC. The attributes of the BWR Vessel Internals

Program related to maintaining reactor coolant water chemistry are included in the Water

Chemistry Control Program. Inspections and evaluations of reactor vessel internal components

are consistent with the guidelines provided in the following BWRVIP reports:

• BWRVIP-18, BWR Core Spray Internals Inspection and Flaw Evaluation Guidelines

" BWRVIP-25, BWR Core Plate Inspection and Flaw Evaluation Guidelines

" BWRVIP-26, BWR Top Guide Inspection and Flaw Evaluation Guidelines

BWRVIP-27, BWR Standby Liquid Control System/Core Plate AP Inspection and Flaw

Evaluation Guidelines

• BWRVIP-38, BWR Shroud Support Inspection and Flaw Evaluation Guidelines

" BWRVIP-41, BWR Jet Pump Assembly Inspection and Flaw Evaluation Guidelines

(NMP2 only)

* BWRVIP-42, LPCI Coupling Inspection and Flaw Evaluation Guidelines (NMP2 only)

" BWRVIP-47, BWR Lower Plenum Inspection and Flaw Evaluation Guidelines

• BWRVIP-48, Vessel ID Attachment Weld Inspection and Flaw Evaluation Guidelines

• BWRVIP-49, Instrument Penetration Inspection and Flaw Evaluation Guidelines

• BWRVIP-74, BWR Reactor Pressure Vessel Inspection and Flaw Evaluation Guidelines

• BWRVIP-76, BWR Core Shroud Inspection and Flaw Evaluation Guidelines

Staff Evaluation. During its audit and review, the staff confirmed the applicant's claim of

consistency with the GALL Report. Details of the staff's audit evaluation of this AMP are

documented in the Audit and Review Report. The staff reviewed the enhancements and the

associated justifications to determine whether the AMP, with the enhancements, remains

adequate to manage the aging effects for which it is credited.

As documented in the Audit and Review Report, the staff noted that the applicant credited

Revisions I and 2 of EPRI TR-103515, "BWR Water Chemistry Guidelines - 1996," for its

reactor coolant water chemistry instead of the GALL Report recommended guidelines in

BWRVIP-29. The applicant stated that the "preventive actions" program element is addressed

in its Water Chemistry Control Program. The staff reviewed the applicant's Water Chemistry

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Control Program and documented its evaluation in SER Section 3.0.3.2.2. The staff found this

method acceptable.

As documented in the Audit and Review Report, the staff has stated that BWRVIP-62 has not

been approved by the NRC, the staff requested that the applicant provide a program with

respect to BWRVIP-62. The applicant responded that BWRVIP-62 allows inspection relief for

plants using HWC. Furthermore, the applicant responded that NMP2 credited BWRVIP-62 in a

shroud evaluation during 2000-2004 but is not invoking BWRVIP-62 currently and that NMP1

has never taken credit for HWC in shroud reinspection evaluations. In the future the applicant

plans to credit the relief allowed by BWRVIP-62 when the document is approved for license

renewal by the staff. The staff found this response acceptable.

The staff reviewed those portions of the BWR Vessel Internals Program for which the applicant

claimed consistency with GALL AMP XI.M9 and found them consistent. The staff found the

applicant's BWR Vessel Internals Program acceptable because it conforms to the

recommended GALL AMP XI.M9 with enhancements.

In the ALRA, the applicant stated that its BWR Vessel Internals Program is consistent with

GALL AMP XI.M9 with enhancements. As stated in the ALRA, the first enhancement in meeting

the GALL Report for the "detection of aging effects" program element is that NMP will address

open items identified in the staffs SER for the BWRVIP, herein referred as BWRVIP open

items, regarding the inspection of inaccessible welds for core spray, jet pump, and low pressure

coolant injection (LPCI) components (NMP1 and NMP2 Commitment 13).

In the ALRA, the applicant also stated that BWRVIP-18, "BWR Core Spray Internals Inspection

and Flaw Evaluation Guidelines," BWRVIP-41, "BWR Jet Pump Assembly Inspection and Flaw

Evaluation Guidelines (NMP2 Only)," and BWRVIP-42, "LPCI Coupling Inspection and Flaw

Evaluation Guidelines (NMP2 Only)" identify BWRVIP open items regarding the inspection of

inaccessible welds for core spray, jet pump, and LPCI components respectively. The applicant

additionally stated that it will implement the resolution of these BWRVIP open items as

documented in the BWR Vessel Internals Program response to be reviewed and accepted by

the NRC. These three BWRVIP open items are applicable to NMP2. For NMP1 only the open

item for core spray components is applicable due to the design of the plant. The staff found that

this enhancement addresses the renewal application BWRVIP open items. The staff found this

enhancement acceptable. These changes to the applicant's program will provide assurance that

aging effects will be adequately managed.

In the ALRA, the applicant further stated that its BWR Vessel Internals Program is consistent

with the GALL Report with the second enhancement in meeting the "detection of aging effects"

program element by the steam dryers inspection (NMP1 and NMP2 Commitment 13). The

applicant stated that the inspection and evaluation guidelines for steam dryers are currently

under development by the BWR Vessel Internals Program committee. Once these guidelines

are documented, reviewed, and accepted by the NRC staff, actions will be implemented at

NMPI and NMP2 according to the BWR Vessel Internals Program. The staff was aware that

BWRVIP-139, "BWR Vessel and Internals Project, Steam Dryer Inspection and Flaw Evaluation

Guidelines," issued by the BWR Vessel Internals Program is under staff review to address

steam dryer inspection activities. The staff found this enhancement consistent with the GALL

Report and acceptable. These changes to the applicant's program will provide assurance that

aging effects will be adequately managed.

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In addition, in the ALRA, the applicant stated that its BWR Vessel Internals Program is

consistent with the GALL Report with the third enhancement in meeting the "detection of aging

effects" program element, access cover holes inspection.

In the ALRA, the applicant stated that the inspection and evaluation guidelines for access hole

covers are currently under development by the BWR Vessel Internals Program committee.

Once these guidelines are documented, reviewed, and accepted by the NRC, the actions will be

implemented at NMP2 according to the BWR Vessel Internals Program (NMP2

Commitment 13). This issue is not applicable to NMP1 due to the design of the plant. The staff

found that currently, inspection of access cover holes per a GE SIL and the BWR Vessel

Internals Program will develop guidelines for such inspections. Because the applicant's

enhancement is consistent with the GALL Report, the staff found this enhancement acceptable.

These changes to the applicant's program will provide assurance that aging effects will be

adequately managed.

Furthermore, in the ALRA the applicant stated that its BWR Vessel Internals Program is

consistent with the GALL Report with the fourth enhancement in meeting the GALL Report "detection of aging effects" program element. The baseline inspections for the BWR lower

plenum components will be incorporated into the appropriate program and implementation

documents (NMP1 and NMP2 Commitment 13).

In the ALRA, the applicant stated that the baseline inspections recommended in BWRVIP-47

for the BWR lower plenum components will be incorporated into the appropriate program and

implementation documents. The staff found that this enhancement meets the recommendation

of the BWRVIP-47 report. The staff found this enhancement acceptable because these

changes to the applicant's program provide assurance that aging effects will be adequately

managed.

Regarding the fifth enhancement, in the ALRA, the applicant also stated that its BWR Vessel

Internals Program is consistent with the GALL Report in meeting the "detection of aging effects"

program element, top guide inspection regarding BWRVIP-26 (NMP1 and NMP2

Commitment 13).

In the ALRA, the applicant stated that a schedule for additional inspections of the top guide

locations (using enhanced VT-1 visual inspection (EVT-1) or techniques demonstrated to be

appropriate in BWRVIP-03, "BWR Vessel and Internals Project, Reactor Pressure Vessel and

Internals Examination Guidelines") will be incorporated into the appropriate program and

implementation documents. A minimum of 10 percent of the locations will be inspected within

12 years of the beginning of the period of extended operation with at least 5 percent of the

inspections completed within six years. As documented in the Audit and Review Report, the

staff noted that the inspection commitment (NMP2 Commitment 13) is within 12 years of the

beginning of the period of extended operation only. The staff asked the applicant to confirm that

the commitment also addressed subsequent intervals. The staff reviewed the latest NMP1 top

guide inspection findings and requested that the applicant provide additional plant-specific

information regarding the reinspection and scope expansion to additional locations. In its letter

dated December 1, 2005, the applicant provided its plant-specific information regarding the top

guide inspection summarized as follows:

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* Prior to 2003 the NMP1 top guide fluence was estimated, using the latest best estimate

transport techniques, to have exceeded the GALL Report identified 5E20 n/cm 2

threshold for irradiation-assisted stress corrosion cracking (IASCC) concerns.

" Consistent with the GALL Report guidance and a GE SIL recommendation, NMP1

implemented the recommended EVT-1 sample inspection in 2003 (Refueling Outage 17

(RFO17)) and found one crack.

In the subsequent 2005 outage (RFO18), NMP1 expanded the inspection scope to

include all accessible top guide grid beam locations using UT inspection methods. The

scope expansion achieved essentially 95 percent coverage of the grid beam. This scope

expansion and the UT inspection method are fully consistent with the current guidance

in BWRVIP-26, "BWR Vessel and Internals Project, Top Guide Inspection and Flaw

Evaluation Guidelines," and with a GE SIL specifically issued for the top guide grid

beam. This UT inspection verified the presence of the crack identified by the 2003

EVT-1 examination and identified five others.

A CR provides the disposition of the indications identified in the 2005 inspection. The

CR disposition references the NMP1 flaw handbook and justifies at least one operating

cycle prior to the next inspection. The CR corrective actions include a reanalysis of the

as-found condition and the definition of the appropriate inspection scope and frequency.

This plan is consistent with the guidance provided in BWRVIP-26 for top guide grid

beam flaw analysis (i.e., to perform a plant-specific flaw analysis to define the structural

margin and the appropriate inspection interval and scope) to which NMP is committed.

In its letter dated December 1, 2005, the applicant also stated that the top guide grid beam

inspection sample plan addressed in the GALL Report is a sample program. At NMPI the

inspection program included a sample inspection similar to the GALL Report recommendation

and the program has.identified top guide cracking.

BWRVIP-26 does not identify any inspection plan for the top guide. The BWRVIP-47 sample

inspection plan was chosen for the top guide grid beam. NMP1 implemented a scope expansion

inspection of the grid beam during RFO18 (2005) as a result of the inspection results from

RFO17 (2003). This scope expansion was performed using UT inspection methods which

achieved approximately 95 percent coverage of the grid beam. The volumetric coverage was

capable of detecting flaws through the height of both the upper and lower grid beams and at the

intersections. The 2005 UT inspection is the NMP1 top guide grid beam baseline inspection

identified in the BWRVIP-47 guidance. The staff determined that the applicant's sample

inspection plan was acceptable and concludes that the program identified in the ALRA

enhancements needed for its sample inspection plan. As documented in the Audit and Review

Report, the applicant stated that NMP will (1) revise its program basis document to address

inspection locations and re-inspection frequency, (2) revise ALRA Sections Al.1.12, A1.4, and

B2.1.8 to address the top guide inspection enhancement, and (3) revise ALRA

Sections A2.1.13, A2.4, and B2.1.8 to address the top guide inspection enhancement. In its

letter dated December 1, 2005, the applicant provided its ALRA revisions:

In Sections Al.1.12 and A1.4 the existing enhancement and commitment on top

guide inspections for NMP1 will be revised to address re-inspection frequency as

follows:

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The reinspection scope and frequency for the grid beam going forward will be

based on BWRVIP-26 guidance for plant-specific flaw analysis and crack growth

assessment. The maximum reinspection interval for'the grid beam will not

exceed 10 years, consistent with standard BWRVIP guidance for the core

shroud. The reinspection scope will be equivalent to the UT baseline 2005

inspection scope. In addition, the reinspection scope will include an EVT-1

sample inspection of at least two locations with accessible indications within the

initial six years of the 10 year interval. The intent of the EVT-1 is to monitor the

known cracking to confirm flaw analysis crack growth assumptions.

In Sections A2.1.13 and A2.4, the existing enhancement and commitment to

perform the top.guide inspections for NMP2 will be revised as follows:

NMP2 will perform inspections of the guide beams similar (in inspection

methods, scope and frequency of inspection) to the inspections specified in

BWRVIP-47 for the control rod guide tube components. The extent of

examination and its frequency will be based on a ten percent sample of the total

population, which includes all grid beam and beam-to-crevice slots, being

inspected within 12 years of entry into the period of extended operation with five

percent of the population being inspected within the first six years. The sample

locations selected for examination will be in areas that are exposed to the

highest neutron fluence. The top guide grid beam reinspection requirements will

depend on the inspection results; however, at a minimum, the applicant's

BWRVIP will follow the same guidance for the subsequent 12 year interval as

defined for the initial 12 year baseline.

In Section B2.1.8, the existing enhancement to the "detection of aging effects" program

element to perform the top guide inspections will be revised as follows:

The reinspection scope and frequency for the NMP1 grid beam going forward

will be based on BWRVIP-26 guidance for plant-specific flaw analysis and crack

growth assessment. The maximum reinspection interval for the grid beam will not

exceed 10 years, consistent with standard BWRVIP guidance for the core

shroud. The reinspection scope will be equivalent to the UT baseline 2005

inspection scope. In addition, the reinspection scope will include an EVT-1

sample inspection of at least two locations with accessible indications within the

initial six years of the 10 year interval. The intent of the EVT-1 is to monitor the

known cracking to confirm flaw analysis crack growth assumptions.

NMP2 will perform inspections of the guide beams similar (in inspection

methods, scope and frequency of inspection) to the inspections specified in

BWRVIP-47 for the control rod guide tube components. The extent of

examination and its frequency will be based on a ten percent sample of the total

population, which includes all grid beam and beam-to-crevice slots, being

inspected within 12 years of entry into the period of extended operation with five

percent of the population being inspected within the first six years. The sample

locations selected for examination will be in areas that are exposed to the

highest neutron fluence. The top guide grid beam reinspection requirements will

depend on the inspection results; however, at a minimum, the applicant's BWR

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Vessel Internals Program will follow the same guidance for the subsequent 12

year interval as defined for the initial 12 year baseline;

Because the applicant's enhancement is consistent with the GALL Report recommendations,

the staff found the enhancement acceptable. These changes to the applicant's program will

provide assurance that aging effects will be adequately managed.

In the ALRA, the applicant also stated that its BWR Vessel Internals Program is consistent with

the GALL Report with another enhancement in meeting the GALL Report "corrective actions"

program element by performing CRD stub tube repair (NMP1 Commitment 36).

In RAI 3.1.2-1 dated January 13, 2005, the staff requested that the applicant address the

difference between the alternative repair roll/expansion techniques and the accepted ASME

Code weld repair for NMP1 CRD stub tube penetration leakage. In a letter dated February 14,

2005, the applicant responded to RAI 3.1.2-1, stating that, "NMP committed to implement a

strategy whereby during the period of extended operation a leaking CRD stub tube penetration

would be roll repaired. If following the roll repair, this stub tube was to leak within acceptable

limits, then a weld repair would be effected no later than one operating cycle following discovery

of the leakage." In the ALRA, the applicant stated that it will follow the status of the proposed

ASME Code change with respect to allowing roll/expansion techniques for CRD stub tubes and

will implement the final code change or provide an alternative plan for the NMP1 period of

extended operation at least one year prior to the expiration of the current operating license.

As documented in the Audit and Review Report, the staff noted that the wording in ALRA

Table 3.1.1.A and in the applicant's response to RAI 3.1.2-1 imply that NMP1 will operate with

CRD stub tube leakage for one operating cycle (two years). The staff did not consider this

implication acceptable for the period of extended operation. The staffs safety evaluation dated

March 25, 1987, allowing NMP1 to operate with CRD stub tube leakage was acceptable only as

a temporary repair. Specifically, Item (6) of the staffs safety evaluation conclusions stated that,

"The proposed leakage criteria provide sufficient time to complete the final development of the

prototype mechanical seal and associated tooling and to investigate other methods like weld

repair."

In a-RAI 3.1.2-1 dated November 2, 2005, the staff requested that the applicant address CRID

stub tube leaking for an additional operating cycle.

In its response by letter dated November 30, 2005, the applicant revised ALRA Section 2.1.8

Commitment 36 in ALRA Section A1.4 and ALRA Table 3.1.1.A Item 3.1.1.A-30 to clarify its

position related to the use of roll/expansion techniques for the repair of leaking NMP1 CRD stub

tubes as follows:

The 2n, paragraph of ALRA Table 3.1.1.A, LA Item 3.1.1.A-30 (Page 3.1-29),

Commitment 36 of ALRA Section A1.4 (Page A1-42), and the Corrective Action

bullet in ALRA Section B2.1.8 (Page B2-25) is replaced with:

If the 10/19/05 draft of Code Case N-730 is approved by the

ASME, NMP Unit 1 will implement the final code case as

conditioned by the NRC. If the code case is not approved by the

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ASME, NMP1 will seek NRC approval of the 10/19/05 code case

draft on a plant specific basis as conditioned by the NRC.

During the period of extended operation, should a CRD stub tube rolled in

accordance with the provisions of the code case resume leaking, NMP will

implement one of the following zero leakage permanent repair strategies prior to

startup from the outage in which the leakage was detected:

(1) A welded repair consistent with BWRVIP-58-A, "BWRVIP Internal access

Weld Repair" and Code Case N-606-1, as endorsed by the NRC in

Regulatory Guide 1.147.

(2) A variation of the welded repair geometry specified in BWRVIP-58-A

subject to the approval of the NRC using Code Case N-606-1.

(3) A future developed mechanical/welded repair method subject to the

approval of the NRC.

The staff found the applicant's response acceptable because it is consistent with the GALL

Report recommendation. The staff found this enhancement acceptable. These changes to the

applicant's program will provide assurance that aging effects will be adequately managed.

Therefore, the staffs concern described in RAI 3.1.2-1 is resolved.

In its letter dated November 17, 2005, the applicant revised its original enhancement in meeting

the GALL Report for the "detection of aging effects" program element as follows: add

management of fracture toughness of NMP1 and NMP2 Cast Austenitic Stainless Steel (CASS)

components (NMP1 Commitment 37 and NNP2 Commitment 35).

In the ALRA, the applicant stated that maintenance procedures for the inspection of the orificed

fuel support casting will be enhanced to include a sample VT17-i inspection of the casting and an

EVT-1 inspection if any evidence of impact or mishandling is identified. In a letter dated

November 17, 2005, the applicant provided its self-identified changes and its basis for change

to the ALRA for the management of the fracture toughness of NMP1 and NMP2 CASS

components with the BWR Vessel Internals Program as follows:

In Sections A1.1.12, A2.1.13 and B2.1.8, clarify that the program activities include

effects on fracture toughness due to neutron fluence and thermal embrittlement by

1) replacing the last bullet on Page A1-6 of Section A1.1.12; 2) replacing the last bullet

on Page A2.6 of Section A2.1.13; and 3) replacing the text under the "parameters

monitored/inspected" program element in NMP AMP B2.1.8 with the following:

Enhance the program to evaluate component susceptibility to loss

of fracture toughness. Assessments and inspections will be

performed, as necessary to ensure that intended functions are not

impacted by the aging effect.

In Sections A1.4 and A2.4, replace the commitments in Item 37 of Section A1.4 and

Item 35 in Section A2.4 as follows:

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Enhance the program to evaluate component susceptibility to loss

of fracture toughness. Assessments and inspections will be

performed, as necessary to ensure that intended functions are not

impacted by the aging effect.

The staff reviewed the applicant's self-identified ALRA change. The staff found this acceptable

since its change meets the GALL Report's recommendation. On this basis, the staff found this

enhancement acceptable. These changes to the applicant's program will provide assurance that

aging effects will be adequately managed.

In its letter dated December 1, 2005, the applicant provided an additional enhancement to the

GALL Report "detection of aging effects" program element: Inspect additional locations to

address the aging management for reactor vessel feedwater nozzle thermal sleeves (NMP1

Commitment 38 and NMP2 Commitment 37) and control rod drive return line nozzle thermal

sleeves (NMP1 Commitment 40). An EVT-1 examination of the NMP1 and NMP2 feedwater

sparger end bracket welds will be performed. The inspection extent and frequency of the end

bracket weld inspection will be the same as the ASME Section XI inspection of the feedwater

sparger bracket vessel attachment welds. If the final fabrication review of the NMP2 feedwater

thermal sleeves concludes that the hidden welds are not IGSCC susceptible the NMP2

inspections will be discontinued as appropriate (NMP1 Commitment 38 and NMP2 Commitment

37). NMP1 will perform an EVT-1 inspection of the thermal shield to flow shield weld starting

2007 and proceed at a 10 year-frequency thereafter consistent with the ISI inspection interval

(NMP1 Commitment 40).

In a letter dated September 15, 2005, the applicant stated that its BWR Feedwater Nozzle

Program and BWR CRDRL Nozzle Program had been removed as credits for the feedwater

nozzle and CRDRL nozzle thermal sleeves. As documented in the Audit and Review Report,

the staff asked the applicant to address aging management for the thermal sleeves. In a letter

dated December 1, 2005, the applicant stated that it will use inspections performed under its

BWR Vessel Internals Program using surrogate components more readily accessible for

examination. For NMP1 the surrogate components will be the feedwater sparger end bracket

welds. In this letter the applicant also provided its basis for choosing the feedwater sparger end

bracket welds:

The NMP1 feedwater nozzle thermal sleeves are fabricated from nickel-based

Alloy 600 (Inconel 600). A full penetration weld joins the thermal sleeve to the

outboard end of the carbon steel feedwater sparger. This weld was made with

Alloy 82 and Alloy 182 weld fillers. The thermal-sleeve to sparger weld, or the

heat affected zone in the Alloy 600 base material, is considered the most likely

location for IGSCC in the thermal sleeve.

The applicant added that each feedwater sparger is supported by end brackets providing a

spring force that helps hold the thermal sleeve in place. The feedwater sparger end bracket

welds consist of three welds, sparger arm to sparger end plate welds (Weld #1), sparger end

plate to bracket end plate weld (Weld #2), and sparger bracket end plate to end bracket

assembly welds (Weld #3), which are dissimilar metal welds that use Alloy 182 or 82 weld

fillers.

3-45
In addition the applicant stated that SCC of the feedwater thermal sleeves or the associated

welds is possible but considered less likely than for other welds with the same weld filler

associated with the feedwater sparger because the inconel to carbon steel welds are

heat-treated shop welds and are not creviced. Service experience has demonstrated that Alloy

82 is resistant to IGSCC in BWR coolant. Alloy 182 is less resistant to IGSCC than Alloy 82 but

performs acceptably with such aggravating factors as lack of fusion or a creviced condition.

These conditions are more likely in field welds. The Alloy 600-to-carbon steel welds in the

thermal sleeve are full penetration and do not create a creviced condition. Additionally, the

thermal sleeve assembly was heat-treated after welding. The #1 end bracket welds use Alloy

182 filler metal in a mildly creviced condition, making them more susceptible to IGSCC than the

thermal sleeve-to-sparger welds. Additionally, the #1 welds are exposed to reactor coolant

chemistry on the outer diameter, which has a higher ECP, and thus are more likely to cause

IGSCC than feedwater, which has a much lower ECP. Therefore, the applicant stated, if

cracking is not found in the #1 welds inspection of the thermal sleeve-to-sparger welds is not

necessary.

Furthermore, the applicant stated that the most susceptible of the three feedwater sparger end

bracket welds (Weld #2) is subject to EVT-1 under a BWRVIP. If cracking is found in these

welds the other end bracket welds (#1 and #3) will be inspected. If cracking is found in the less

susceptible end bracket welds the necessity to inspect the thermal sleeve-to-sparger welds will

be evaluated. The applicant's BWR Vessel Internals Program will, therefore, be credited with

managing cracking bounded of the thermal sleeve as the susceptibility of the critical thermal

sleeve weld to IGSCC is covered by other welds inspected under the applicant's BWR Vessel

Internals Program. In its letter dated December 1, 2005, the applicant stated that it will revise

the ALRA to add an EVT-1 examination of the NMP1 feedwater sparger brackets as a BWR

Vessel Internals Program enhancement to address this issue. The staff found the applicant's

response acceptable because it demonstrated that inspection of surrogate components

includes the NMP1 feedwater nozzle thermal sleeves.

In its letter dated December 1' 2005, the applicant stated that NMP2 also will use inspections

performed under the BWR Vessel Internals Program using surrogate components that are

more readily accessible for examination. For NMP2 the surrogate components will be the

feedwater sparger end bracket welds. In this letter the applicant also provided its basis for

choosing the feedwater sparger end bracket welds:

...a similar evaluation of the NMP2 feedwater sparger welds and the selection of

surrogate welds that are accessible for inspection would also be acceptable for

NMP2. These accessible welds would be used as a leading indicator for potential

IGSCC cracking of the thermal sleeve. If cracking is found in these welds, a

supplemental evaluation of the thermal sleeve integrity would be required.

The applicant also stated that the review of the NMP2 feedwater thermal sleeve and sparger

had been completed and had confirmed that the thermal sleeve material is 316L with several

hidden stainless steel welds. The incomplete fabrication method review will determine the

welding procedures and whether the welds were stress-relieved. If the hidden welds were

stress-relieved they would not be considered susceptible to IGSCC and the cracking aging

mechanism would not be considered applicable to NMP2.

3-46
In addition the applicant stated that the review of the NMP2 feedwater sparger installation

details found that the field installation applied a 20,000 lbs load creating a 0.125" cold spring to

the sparger. The sparger end brackets were pinned, locking in the cold spring, and then final

field-welded with a fillet weld. The applicant further stated that this installation detail is similar to

that of NMP1. The result of the cold spring is a fit-up net tensile stress superimposed on the

weld residual stress. The combination of the fit-up stress (cold spring) and the residual stress of

the field weld conditions and the fillet weld crevice geometry creates a susceptibility to IGSCC

higher than that of the thermal sleeve welds. The corrosion potential of the reactor water in the

region of the feedwater sparger end bracket welds is equivalentto if not greater than that of the

reactor water in contact with the outside diameter weld of the thermal sleeve. The applicant also

stated that an EVT-1 examination of the NMP1 and NMP2 feedwater sparger end bracket welds

will be added to its BWR Vessel Internals Program as a program enhancement. The inspection

extent and frequency of the end bracket weld inspection will be the same as the ASME

Section Xl inspection of the feedwater sparger bracket vessel attachment welds. If the final

fabrication review of the NMP2 feedwater thermal sleeve finds that the hidden welds are not

IGSCC susceptible the NMP2 inspections will be discontinued.

Furthermore, the applicant stated that examination of the NMP2 feedwater sparger end bracket

welds is a representative inspection of the material condition of the hidden thermal sleeve welds

regarding potential IGSCC cracking. Therefore, consistent with the discussion between the staff

and the applicant documented in the Audit and Review Report, cracking of the NMP2 feedwater

nozzle thermal sleeves will be a matter for the applicant's BWR Feedwater Nozzle Program,

BWR Vessel Internals Program, and Water Chemistry Control Program. In its letter dated

December 1, 2005, the applicant stated that an EVT-1 examination of the NMP1 and NMP2

feedwater sparger end bracket welds will be added to its BWR Vessel Internals Program as a

program enhancement (NMP1 Commitment 38 and NMP2 Commitment 37). The inspection

extent and frequency of the end bracket weld inspection will be the same as for the ASME

Section Xl inspection of the feedwater sparger bracket vessel attachment welds. If the final

fabrication review of the NMP2 feedwater thermal sleeve finds that the hidden welds are not

IGSCC susceptible the NMP2 inspections will be discontinued. The staff reviewed the

applicant's response and found it acceptable since the applicant's surrogate weld inspection

provides adequate aging management for the NMP2 feedwater thermal sleeve. The staff found

that the applicant appropriately addressed the aging effect and aging effect mechanism for

NMP2 feedwater nozzle thermal sleeves.

In its letter dated December 1, 2005, the applicant also narrated operating experience in

addressing the CRDRL nozzle thermal sleeves:

The inspections of the CRDRL nozzle and safe-ends in 1978 identified IGSCC

cracking of the safe-end material, but did not identify fatigue-related cracking.

The CRDRL safe-end and the thermal sleeve were replaced in 1978 with design

changes to improve resistance to both IGSCC and fatigue. The replacement

thermal sleeve material is IGSCC resistant low carbon Type 316L stainless steel

material. The thermal sleeve is welded to the safe-end with low carbon Type

308L weld filler. To reduce the probability of fatigue, the thermal sleeve pipe

protrudes 7 inches out from the flow shield which promotes mixing away from the

vessel wall thus preventing thermal cycling at the vessel wall and at the flow

shield.

3-47
The applicant stated that as a result of industry operating experience from 2002 and 2003, NMP

completed detailed thermal fatigue assessments and expanded inspections of the safe-end, the

thermal sleeve attachment weld to the safe-end, and the thermal sleeve weld to the flow shield.

These inspections were performed in 2004 and 2005. The inspections to date have identified no

IGSCC or thermal fatigue-related cracking. Because the 2003 operating experience identified

cracking of the thermal shield flow baffle additional EVT-ls of the thermal shield to flow shield

weld from the vessel ID are planned for 2007 and at a 10-year frequency thereafter consistent

with the ISI inspection interval. This EVT-1 examination of the CRDRL thermal sleeve flow

shield weld visible from the vessel ID during each ISI interval is consistent with the frequency

that has been adopted for the feedwater nozzle surrogate weld location on the feedwater end

brackets.

In addition the applicant stated that a one-time UT of the CRDRL safe-end base metal in 2004

was performed under the NMP augmented ISI program 26 years of operation after the 1978

replacement (three outages prior to the license renewal term). This inspection identified no

IGSCC or thermal fatigue cracking of the safe-end location. The inspection was a manual

performance demonstration initiative (PDI) qualified inspection and the PDI mockup included

the thermal sleeve attachment weld to the safe-end. The inspection records note the presence

of the thermal sleeve attachment weld. This inspection is considered sufficient to detect

significant circumferential IGSCC cracking of the thermal sleeve at the thermal sleeve

attachment weld; however, consistent with the surrogate weld inspection methodology

employed for the feedwater nozzle thermal sleeve, the EVT-1 inspection of the thermal sleeve

flow shield weld also will be used as a Surrogate weld inspection location for the thermal sleeve

to safe-end attachment weld.

In addition to the inspections the applicant stated that temperature monitoring for thermal

cycling was performed to confirm that the CRD return flow rates were sufficient at NMP1 to

ensure that no unstable thermal cycling caused by hot reactor water return flow occurs. The

testing and analyses have found the minimum CRD return flow required to ensure stable return

line conditions and that no reverse flow.

The applicant's overall assessment is that the safe-end and thermal sleeve replacement with

IGSCC-resistant materials and the one-time UT of the thermal sleeve attachment weld after 26

years establish that the thermal sleeve attachment weld is not a high risk IGSCC location. In

addition the thermal monitoring of this location and the inspection after 26 years of operation

also found no high-cycle thermal fatigue conditions at this location that could create high

thermal cycle fatigue-related cracking.

Furthermore, the applicant continued, the analyses and one-time inspections performed in 2004

to 2005 are adequate to detect potential cracking of the CRDRL nozzle thermal sleeve to

safe-end attachment weld from either IGSCC or fatigue. Even though IGSCC is considered a

low probability for this location for materials of construction the BWR Vessel Internals Program

will include an enhancement starting in 2007. An EVT-1 inspection of the thermal shield to flow

shield weld from the vessel ID will be performed at that time and thereafter at a 10-year

frequency consistent with the ISI inspection interval.

The applicant also stated that in addition to determining the condition of the flow shield weld this

EVT-1 inspection will be used as a surrogate weld inspection location for the thermal sleeve to

3-48
the safe-end attachment weld. In its letter dated December 1, 2005, the applicant provided its

ALRA revisions:

* Revise ALRA Sections A1.1.12, A1.4, and B2.1.8 to incorporate the commitment to

perform the EVT-1 inspection of the thermal shield to flow shield weld starting in 2007

and proceeding at a 10 year frequency consistent with the ISI inspection interval

thereafter.

" Revise ALRA Table 3.1.1.A-1, Item 3.1.1.A-27 and ALRA Table 3.1.2.A-1 to reflect the

changes.

The staff reviewed the applicant's response and found it acceptable because the applicant's

surrogate weld inspection in addition to the results of its one-time inspections 2004 to 2005

provide adequate aging management for the CRDRL thermal sleeve. The staff concludes that

the applicant appropriately addressed the aging effect and aging effect mechanism for NMP1

CRDRL nozzle thermal sleeves.

Operating Experience. In ALRA Section B2.1.8, the applicant explained that it has reviewed

both industry and plant-specific operating experience relating to the BWR Vessel Internals

Program. Review of plant-specific operating experience revealed conditions discovered by

BWRVIP examinations similar to those identified elsewhere in the BWR fleet. In each case,

indications were evaluated and either found acceptable for further service or appropriately

repaired. The BWRVIP is continually adjusted to account for industry experience and research

(including activities of the BWRVIP and ASME Section XI Code Committees). In 2001, the

Institute of Nucear Power Operations (INPO) conducted a review of activities related to BWR

Vessel Internals Program at NMP2. Several strengths were identified, and recommendations for

improvement were addressed by program upgrades at NMP1 and NMP2.

The staff reviewed the operating experience provided in the ALRA and the applicant's operating

issues related to SCC and determined that the current program has proven to be effective in

managing the aging of the vessel internals within the scope of license renewal. The following is

a sample list of NMP1 operating experience issues including core shroud cracking, shroud

support weld cracking, CRD stub tube IGSCC and leakage, and top guide cracking:

NMP1 identified CRD stub tube leakage in 1984. The root cause investigation and

inspection confirmed IGSCC of the furnace-sensitized 304 CRD stub tubes. The

applicant implemented a roll repair of the leakage and a structural evaluation of the

tolerability of the cracking. NMPI is also working through its BWR Vessel Internals

Program to obtain approval of an ASME Section XI code case for the roll repair

technique for this location.

" NMP1 identified core shroud horizontal weld cracking following the BWRVIP-01, "BWR

Vessel and Internals Project, BWR Core Shroud Inspection and Flaw Evaluation

Guideline (Revision 2)," baseline inspection in 1995. The corrective action taken was to

install a pre-emptive core shroud tie-rod repair which followed the BWRVIP-02, "BWR

Vessel and Internals Project, BWR Core Shroud Repair Design Criteria," shroud repair

guidelines. This repair was designed for a 20-year license renewal term.

* NMP1 identified core shroud vertical weld cracking in 1997 following a baseline

inspection required by BWRVIP-02 guidelines. This inspection safeguarded operations

3-49
for at least two years until the next inspection. A pre-emptive repair was installed in 1999

for the core shroud vertical welds. This repair was designed for a 20-year license

renewal term.

NMP1 detected indications in the core shroud support H9 vessel attachment weld during

baseline BWRVIP-38, "BWR Shroud Support Inspection and Flaw Evaluation

Guidelines," inspections in 2001. This attachment weld is an Alloy 182 nickel-based alloy

with operational experience from an overseas BWR of IGSCC. The analysis was

consistent with BWRVIP-38 methods and the detected indications were deemed

acceptable over a 10-year re-inspection frequency. Supplemental sampling inspections

have shown the indications are confined to the weld with no propagation into the vessel

low-alloy steel. The indications were similar to those discussed in a GE SIL. Other core

shroud indications were found in weld H8, weld H3, and weld H6A.

NMP1 completed a sample baseline inspection of the top guide grid beam identified in

BWRVIP-26, "BWR Top Guide Inspection and Flaw Evaluation Guidelines," as having

the potential for IASCC and as such representing a condition that warranted review for

license renewal. The inspection of the top guide based on the recommendations of a GE

SIL detected one indication consistent with grid beam cracking at Oyster Creek. The

indication was evaluated consistently with BWRVIP-26 methods and found to be

tolerable for continued service. Ongoing inspection and monitoring consistent with

BWRVIP-26 requirements are proper long-term based on the current top guide fluence

predictions and extent of cracking.

Operating experience problems that have been identified at NMP2 include core shroud cracking

and jet pump wedge wear. The applicant's BWR Vessel Internals Program has not identified

other cracking of internals covered by its BWR Vessel Internals Program. The BWR Vessel

Internals Program recommended actions to inspect the core shroud and internals welds for

cracks illustrate the effectiveness of the BWR Vessel Internals Program inspections. For

example:

NMP2 detected core shroud horizontal weld cracking during the BWRVIP-01 required

baseline inspection in 1998. The inspection found that the core shroud welds H4, H5,

and H7 had greater than 30 percent cracking warranting plant-specific evaluation. The

condition was evaluated consistently with BWRVIP-01 methods and judged to be fit for

conditioned service without repair. The limiting inspection interval is four years for each

re-inspection. The condition currently is managed through IGSCC mitigation and

re-inspection. Core shroud repair according to BWRVIP-02 is considered a contingency

dependent on observed IGSCC growth.

The BWRVIP-41 required baseline inspections are approximately 75 percent complete

with no cracking detected. The baseline inspections that detected wedge bearing

surface wear contact and set screw gaps were recommended by the BWR Vessel

Internals Program based on industry operating experience. The inspections detected jet

pump wedge wear in the sample population. The required BWRVIP-41 scope expansion

was completed and the results showed the wear isolated to one location. The scope

expansion identified set screw gaps one of which warranted a preemptive auxiliary

wedge installation to eliminate it. The program has identified corrective measures

needed to prevent flow- induced vibration if NMP2 operates above rated core flow.

NMP2 detected several cracks in the steam dryer upper support ring side of drain

channel 1,2, and 3 horizontal 304 stainless steel welds ranging in length from 0.1 to

3-50
0.7 inches during inspections in RFO6. A GE evaluation concludes the indications

observed are typical of IGSCC. Factors contributing to the initiation of IGSCC (weld

residual stresses, weld sensitized 304 stainless steel in the heat affected zone (HAZ),

and surface cold work due to fabrication) are all present in the steam dryer upper

support ring. The cracking discovered at the NMP2 steam dryer upper support ring is

similar to but less severe than that seen on several similar steam dryers at other plants.

The IS[ program plan was revised to re-inspect the locations of the cracks to detect any

significant increase in length or number.

NMP2 detected several cracks on the stiffener to upper guide ring welds at various

locations between the shroud head bolts during inspections performed in 1998. A GE

evaluation concluded that the indications detected are characteristic of IGSCC known to

occur in weld-sensitized type 304 stainless steel. NMP2 determined that no repair was

required during the current outage; however, the ISI program plan was revised to

re-inspect the locations of the indications to detect any significant increase in length or

number.

The staff found that the applicant's BWR Vessel Internals Program recommended actions to

inspect the core shroud and internal welds for cracks indicate the effectiveness of its BWR

Vessel Internals Program inspections. The staff also found that changes and updates to the

applicant's BWR Vessel Internals Program have resulted from the ongoing review of industry

operating experience and regulatory notices as these are reviewed regularly for applicability to

the reactor vessel internals. In these ways the applicant addressed vessel internals degradation

noted at other BWRs systematically and revised its BWR Vessel Internals Program inspections

accordingly.

After review of industry and plant-specific operating experience and discussions with the

applicant's technical staff, the staff concludes that there is reasonable assurance that the

applicant's BWR Vessel Internals Program will adequately manage the aging effects identified

in the ALRA for which this AMP is credited.

UFSAR and USAR Supplements. The applicant provided its UFSAR and USAR supplements

for the BWR Vessel Internals Program in ALRA Section A1.1.12 for NMP1 and Section A2.1.13

for NMP2 stating that its BWR Vessel Internals Program manages aging of materials inside the

reactor vessel. Program activities include (1) inspections for the presence and effects of

cracking and (2) monitoring and control of water chemistry. This program is also used to

manage loss of material for carbon steel vessel instrumentation penetrations for NMP2. This

program is based on guidelines issued by the BWRVIP and approved (or pending approval) by

the staff. Inspections and evaluations of reactor vessel components are consistent with the

guidelines provided in the applicable BWRVIP reports.

The applicant has completed or will complete each of the license renewal BWRVIP action items

described in the staff safety evaluations for these BWRVIP reports. In addition the applicant will

implement the NRC-approved inspection and flaw evaluation guidelines for the steam dryer and

inaccessible core spray components weld at NMP1, and for the steam dryer, access hole cover,

inaccessible core spray, jet pumps, and LPCI components welds at NMP2.

The applicant also provided its UFSAR supplement for NMP1 enhancements to its BWRVIP

including the following revisions to existing activities credited for license renewal.

3-51
The reinspection scope and frequency for the grid beam will be based on BWRVIP-26

guidance for plant-specific flaw analysis and crack growth assessment. The maximum

reinspection interval for the grid beam will not exceed 10 years consistent with standard

BWRVIP guidance for the core shroud. The reinspection scope will be equivalent to the

UT baseline 2005 inspection scope. In addition the reinspection scope will include an

EVT-1 sample inspection of at least two locations with accessible indications within the

initial six years of the 10-year interval. The intent of the EVT-1 is t6 monitor the known

cracking to test flaw analysis crack growth assumptions.

0 As stated in the ALRA, the applicant will implement the resolution of the BWRVIP-18

open items regarding the inspection of inaccessible welds for core spray. It will be

included in its BWRVIP response to be reviewed and accepted by the staff.

0 Once the guidelines for inspection and evaluation for steam dryers currently under

development by the BWRVIP committee are documented, reviewed and accepted by

the staff, the actions will be implemented in accordance with the BWRVIP.

The baseline inspections recommended in BWRVIP-47 for the BWR lower plenum

components will be incorporated into the program.

If the October 19, 2005 draft of Code Case N-730 is approved by the ASME, NMP1 will

implement the final code case as conditioned by the staff. If the code case is not approved by

the ASME, NMP1 will seek staff approval of the 10/19/05 code case draft on a plant specific

basis from the staff.

If during the period of extended operation, a CRD stub tube, rolled in accordance with the

provisions of the code case, resumes leaking, NMP will implement one of the following zero

leakage permanent repair strategies prior to startup from the outage in which the leakage was

detected:

(1) A welded repair consistent with BWRVIP-58-A, "BWRVIP Intemal access Weld Repair"

and Code Case N-606-1, as endorsed by the NRC in Regulatory Guide 1.147.

(2) A variation of the welded repair geometry specified in BWRVIP-58-A subject to the

approval of the NRC using Code Case N-606-1.

(3) A future developed mechanical/welded repair method subject to the approval of the

staff.

Enhance the program to evaluate component susceptibility to loss of fracture

toughness. Assessments and Inspections will be performed, as necessary to

ensure that intended functions are not impacted by the aging effect. (Note: This

enhancement was revised through its letter dated December 1, 2005).

An EVT-1 examination of the NMP1 feedwater sparger end bracket welds will be

performed. The inspection extent and frequency of the end bracket weld

inspection will be the same as the ASME Section Xl inspection of the feedwater

sparger bracket vessel attachment welds. (Note: This enhancement was revised

through its letter dated December 1, 2005).

3-52
NMP1 will perform an EVT-1 inspection of the thermal shield to flow shield weld

starting 2007 and proceeding at a 10 year frequency thereafter consistent with

the ISI inspection interval. (Note: This enhancement was revised through its

letter dated December 1, 2005).

The applicant also provided its USAR supplement for NMP2 enhancements to its BWRVIP

including the following revisions to existing activities credited for license renewal:

NMP2 will perform inspections of the guide beams similar in methods, scope, and

frequency to the inspections specified in BWRVIP-47 for the control rod guide tube

components. The extent of examination and its frequency will be based on inspection of

a 10 percent sample of the total population, which includes all grid beam and

beam-to-crevice slots, within 12 years of entry into the period of extended operation with

5 percent of the population inspected within the first six years. The sample locations

selected for inspection will be in areas exposed to the highest neutron fluence. The top

guide grid beam reinspection requirements will depend on the inspection results;

however, at a minimum the applicant's BWRVIP will follow the same guidance for the

subsequent 12-year interval as defined for the initial 12-year baseline. (Note: This

enhancement was revised through letters dated December 1, 2005, and December 13,

2005).

" The applicant will implement the resolution of the open items documented in

BWRVIP-18, BWRVIP-41, and BWRVIP-42 regarding the inspection of inaccessible

welds for core spray, jet pump, and LPCI components, respectively. It will be included in

its BWRVIP response to be reviewed and accepted by the staff. (Note: This

enhancement was provided in the ALRA).

" Once the guidelines for inspection and evaluation for steam dryers currently under

development by the BWRVIP committee are documented, reviewed, and accepted by

the staff they will be implemented according to the BWRVIP. (Note: This enhancement

was provided in the ALRA).

Once the inspection and evaluation guidelines for access hole covers guidelines are

documented, reviewed, and accepted by the staff they will be implemented according to

the BWRVIP. (Note: This enhancement was provided in the ALRA).

The baseline inspections recommended in BWRVIP-47 for the BWR lower plenum

components will be incorporated into the program. (Note: This enhancement was

provided in the ALRA).

The applicant will enhance the program to evaluate component susceptibility to loss of

fracture toughness. Assessments and inspections will be performed as necessary to

ensure that intended functions are not impacted by the aging effect. (Note: This

enhancement was revised through a letter).

An EVT-1 examination of the NMP2 feedwater sparger end bracket welds will be

performed. The extent and frequency of the end bracket weld inspection will be the

same as the ASME Section XI inspection of the feedwater sparger bracket vessel

attachment welds. If the final fabrication review of the NMP2 feedwater thermal sleeves

finds that the hidden welds are not IGSCC- susceptible NMP2 inspections will be

discontinued. (Note: This enhancement was revised through its letter dated

December 1, 2005).

3-53
The staff reviewed the information in the supplements and found that they provide adequate

summary descriptions of the program required by 10 CFR 54.21(d).

Conclusion. On the basis of its review and audit of the applicant's BWRVIP, the staff

determined that those program elements for which the applicant claimed consistency with the

GALL Report are consistent with the GALL Report. Also, the staff has reviewed the

enhancements and confirmed that the implementation of the enhancements prior to the period

of extended operation would result in the existing AMP being consistent with the GALL Report

AMP to which it was compared.The staff concludes that there is reasonable assurance that the

applicant demonstrated that the effects of aging will be adequately managed so that the

intended functions will be maintained consistent with the CLB for the period of extended

operation, as required by 10 CFR 54.21(a)(3). The staff also reviewed the UFSAR supplement

for this AMP and concludes that it provides an adequate summary description of the program,

as required by 10 CFR 54.21(d).

3.0.3.2.7 Open-Cycle Cooling Water System Program

Summary of Technical Information in the Amended Application. In ALRA Section B2.1.10, the

applicant described the Open-Cycle Cooling Water System (OCCWS) Program, stating that this

is an existing program that is consistent, with enhancements, with GALL AMP XI.M20,

"Open-Cycle Cooling Water System." The OCCWS Program manages aging of components

exposed to raw, untreated (e.g., service) water. For NMP1 this includes portions of the service

water system, the emergency service water system, shell side of the RBCLC heat exchangers,

the EDG cooling water system, containment spray raw water system, and portions of the

circulating water system. Also included are other components WSLR wetted by the service

water system that are credited in the AMR. The NMP2 OCCWS scope includes a portion of the

alternate decay heat system with associated portions of the service water system, the RHR

heat exchangers, diesel generator jacket water coolers, and control room chillers. Also included

are components within the scope of license renewal that are wetted by the service water system

and credited in the AMR. Program activities include: (1) surveillance and control of biofouling

(including biocide injection); (2) verification of heat transfer capabilities for components cooled

by the service water system; (3) inspection and maintenance; (4) walkdown inspections; and (5)

review of maintenance, operating and training practices and procedures. Inspections may

include visual, UT, and ECT methods. The OCCWS Program is based on the recommendations

of GL 89-13.

Staff Evaluation. During its audit and review, the staff confirmed the applicant's claim of

consistency with the GALL Report. Details of the staffs audit evaluation of this AMP are

documented in the Audit and Review Report. The staff reviewed the enhancements and the

associated justifications to determine whether the AMP, with the enhancements, remains

adequate to manage the aging effects for which it is credited.

The staff reviewed those portions of the OCCWS Program for which the applicant claimed

consistency with GALL AMP XI.M20 and found them consistent. The staff found the applicant's

OCCWS Program acceptable because it conforms to the recommended GALL AMP XI.M20

with enhancements.

3-54
In the ALRA, the applicant stated that its OCCWS Program is consistent with GALL

AMP XI.M20 with enhancements and that the enhancements in meeting the GALL Report

program description, "scope of program," "preventive actions," and "monitoring and trending"

program elements revises procedures to address the following:

* Ensure that the applicable NMP1 commitments made for GL 89-13 and the

recommendations in GALL AMP XI.M20 are stated in the NMP1 implementation

documents for GL 89-13. (NMP1Commitment 14).

" Ensure that the applicable NMP2 commitments made for GL 89-13 and the

recommendations in GALL AMP XI.M20 are stated in N2-TDP-REL-0104, "GL 89-13,

Service Water.System Problems Affecting Safety Related Equipment Program Plan,"

(NMP2 Commitment 14).

" Incorporate into the OCCWS Program GALL AMP XI.M20 recommendations when they

are more conservative than the GL 89-13 commitments (NMP1 and NMP2

Commitment 14).

As documented in the audit and review report, the applicant stated that it is developing an

implementing program for both units to integrate the commitments made according to GL 89-13

and the recommendations made in the GALL Report for GALL AMP XI.M20. When the GALL

Report recommendations are more conservative than the GL 89-13 commitments, the GALL

Report recommendations will be integrated. This enhancement will make the applicant's AMP

consistent with the GALL Report and is, therefore, acceptable. These changes to the

applicant's program will provide assurance that aging effects will be adequately managed.

Also in its letter dated November 17, 2005, the applicant revised the ALRA to expand the

discussion of the program to clarify that it includes internal portions of nonsafety-related

segments of the circulating water and service water systems within the scope of license

renewal under 10 CFR 54.4(a)(2) to maintain their pressure integrity. This letter also stated that

this program manages all aging effects for components subject to the recommendations for GL

89-13. The staff found this enhancement acceptable because it clarifies the overall program

scope.

In addition in the ALRA the applicant stated that its OCCWS Program is consistent with the

GALL Report with another enhancement and that the enhancement in meeting the GALL

Report "aceptance criteria" program element revises procedures to address the following:

Revise the NMP1 and NMP2 preventive maintenance and heat transfer performance

test procedures to incorporate specific inspection criteria, corrective actions, and

frequencies. (NMP1 and NMP2 Commitment 14).

As documented in the Audit and Review Report, the applicant stated that the heat exchanger

preventive maintenance procedures will be revised to incorporate inspection criteria to ensure

thorough cleaning of all affected OCCW components and to initiate appropriate corrective

actions prior to the loss of intended function if progressive degradation persists. This

enhancement makes the applicant's AMP consistent with the GALL Report and is, therefore,

acceptable. These changes to the applicant's program will provide assurance that aging effects

will be adequately managed.

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Operating Experience. In ALRA Section B2.1.10, the applicant explained that it has reviewed

both industry and plant-specific operating experience relating to the OCCWS Program.

Inspections implementing the guidance of GL 89-13 have identified deterioration (including pipe

wall thinning, pinhole leakage, and microbiologically influenced corrosion (MIC)) and

degradation (including clogged lines, flow restrictions, and fouling). These deficiencies were

documented in CRs and resulted in cleaning, repair, or replacement of the affected components

prior to loss of system function.

The staff reviewed the operating experience stated in the ALRA and interviewed the applicant's

technical staff to confirm that the plant-specific operating experience revealed no degradation

not bounded by industry experience.

After review of industry and plant-specific operating experience and discussions with the

applicant's technical staff the staff concludes that there is reasonable assurance that the

applicant's OCCWS Program will manage adequately the aging effects and aging effects

mechanisms identified in the ALRA for which this AMP is credited.

UFSAR and USAR Supplements. In ALRA Sections A1.1.29 and A2.1.29, the applicant

provided the respective UFSAR and USAR supplements for the OCCWS Program. The staff

reviewed these sections and determined that the information in the supplements provides

adequate summary descriptions of the program, as required by 10 CFR 54.21(d).

Conclusion. On the basis of its review and audit of the applicant's OCCWS Program, the staff

determined that those program elements for which the applicant claimed consistency with the

GALL Report are consistent with the GALL Report. Also, the staff has reviewed the

enhancements and confirmed that the implementation of the enhancements prior to the period

of extended operation would result in the existing AMP being consistent with the GALL Report

AMP to which it was compared.The staff concludes that there is reasonable assurance that the

applicant demonstrated that the effects of aging will be adequately managed so that the

intended functions will be maintained consistent with the CLB for the period of extended

operation, as required by 10 CFR 54.21(a)(3). The staff also reviewed the UFSAR supplement.

for this AMP and concludes that it provides an adequate summary description of the program,

as required by 10 CFR 54.21(d).

3.0.3.2.8 Closed-Cycle Cooling Water System Program

Summary of Technical Information in the Amended Application. In ALRA Section B2.1.11, the

applicant described the Closed-Cycle Cooling Water System Program (CCCWS), stating that

this is an existing program that is consistent, with enhancements, with GALL AMP XI.M21,

"Closed-Cycle Cooling Water System." The CCCWS Program manages loss of material and

fouling of components exposed to closed-cycle cooling water environments. The applicable

piping systems at NMPNS include the NMP1 and NMP2 reactor building closed loop cooling

systems, NMP1 control room HVAC system, the NMP2 control building ventilation chilled water

system, the heat exchanger jacket water cooling portions of the NMP1 emergency diesel

generator system and the NMP2 standby diesel generator protection (generator) system.

Program activities include chemistry monitoring, surveillance testing, data trending, and

component inspections. The CCCWS Program implements the guidelines for controlling system

performance and aging effects described in EPRI Report TR-107396.

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Staff Evaluation. During its audit and review, the staff confirmed the applicant's claim of

consistency with the GALL Report. Details of the staff's audit evaluation of this AMP are

documented in the Audit and Review Report. The staff reviewed the enhancements and the

associated justifications to determine whether the AMP, with the enhancements, remains

adequate to manage the aging effects for which it is credited.

The staff reviewed those portions of the CCCWS Program for which the applicant claimed

consistency with GALL AMP XI.M21 and found them consistent. The staff found the applicant's

CCCWS Program acceptable because it conforms to the GALL AMP XI.M21 recommendations

with enhancements.

In the ALRA, the applicant stated that its CCCWS Program is consistent with GALL

AMP XI.M21 with enhancements to meet the GALL Report "preventive actions" program

element by revising procedures to address the following:

" Expand periodic chemistry checks of CCCW systems consistent with the guidelines of

EPRI TR-107396 (NMP1 and NMP2 Commitment 15).

" Implement a program to use corrosion inhibitors in the NMP1 and NMP2 reactor building

closed loop cooling systems, NMP1 control room HVAC system, and NMP2 control

building ventilation chilled water system (NMP1 and NMP2 Commitment 15).

In the ALRA, the applicant stated that it is expanding chemistry parameters for the closed-cycle

cooling water systems for consistency with the guidelines of EPRI TR-107396. The staff found

this enhancement acceptable because it will make the applicant's AMP consistent with the

GALL Report. Furthermore, in the ALRA the applicant stated that it will develop an

enhancement to implement the use of corrosion inhibitors in the NMP1 and NMP2 reactor

building closed loop cooling system, NMP1 control room HVAC system, and NMP2 control

building ventilation chilled water system according to the guidelines in EPRI TR-1 07396. The

staff found this enhancement acceptable because it will make the applicant's AMP consistent

with the GALL Report.

As documented in the Audit and Review Report, the staff asked the applicant to clarify whether

the chromate corrosion inhibitor used in the NMP1 diesel generator jacket cooling water is

consistent with the guidelines in EPRI TR-107396. The applicant responded that the chromate

concentrations are outside the range of values provided in that document. The staff asked the

applicant to justify the use of a corrosion inhibitor concentration outside the range of values

recommended in EPRI Report TR-107396.

In a letter dated December 1, 2005, the applicant stated that the chromate concentration is

above the EPRI recommended control limit but consistent with vendor recommendations. In this

letter the applicant further stated that the lower concentration limit in the EPRI report is based

on the potential impact that the more highly concentrated corrosion inhibitor could have on the

life of mechanical seals. The applicant further stated that it had reviewed the maintenance

history of mechanical seals at NMP1 and found no occurrence of catastrophic failure. In order

to manage the impact of the higher concentration of corrosion inhibitor on the mechanical seal

life, the applicant stated that it will establish a required seal replacement frequency of 10 years

maximum in lieu of the recommended replacement frequency of every 12 years. Based on

satisfactory operation with the vendor-recommended chromate corrosion inhibitor concentration

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and the establishment of a program to replace the mechanical seals more frequently than

recommended. In summary, the staff found the enhancement as committed in ALRA

Appendix B2.1.11 acceptable (NMP1 and NMP2 Commitment 15):

For NMP2 the applicant is using a nitrite corrosion inhibitor in the diesel generator jacket

cooling water. As documented in the Audit and Review Report, the staff asked the applicant to

clarify whether the nitrite corrosion inhibitor used in the NMP2 diesel generator jacket cooling

water is consistent with the guidelines in EPRI TR-107396. The applicant stated that the nitrite

concentrations are within the range of values provided in that report. The staff found this use

acceptable because it is consistent with the chemistry basis recommended in the GALL Report.

In the ALRA, the applicant stated that its CCCWS Program is consistent with the GALL Report

with additional enhancements to meet the GALL Report "parameters monitored/inspected" and

"detection of aging effects" program elements by revising procedures to address the following:

" Direct periodic inspections to monitor for loss of material in CCCW systems piping

(NMP1 and NMP2 Commitment 15).

" A corrosion monitoring program for larger bore CCCW piping not subject to inspection

under another NMP1 program (NMP1 Commitment 15).

As documented in the Audit and Review Report, the applicant stated that expanding the existing

corrosion monitoring program for small bore CCCW piping to include larger bore (greater than

3-inch outer diameter) makes its CCCWS Program consistent with the GALL Report. The staff

found this enhancement consistent with the GALL Report and, therefore, acceptable. These

changes to the applicant's program will provide assurance that aging effects will be adequately

managed.

Furthermore, in the ALRA the applicant stated that its CCCWS Program is consistent with the

GALL Report with enhancements to meet the GALL Report 'monitoring and trending" program

element by revising procedures to address the following:

Establish inspection frequencies for degradation of components in CCCW systems,

including heat exchanger tube wall thinning (NMP1 and NMP2 Commitment 15).

Perform a heat removal capability test for the NMP1 control room HVAC system at least

every five years (NMP1 Commitment 15).

Establish periodic monitoring, trending, and evaluation of performance parameters for

the NMP1 and NMP2 reactor building closed loop cooling, NMP1 control room HVAC,

and NMP2 control building ventilation chilled water systems (NMP1 and NMP2

Commitment 15).

Specify chemistry sampling frequency for the NMP2 control building ventilation chilled

water system. (NMP2 Commitment 15).

The staff found these enhancements to be consistent with the GALL Report and therefore

acceptable. These changes to the applicant's program will provide assurance that aging effects

will be adequately managed.

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In the ALRA, the applicant stated that its CCCWS Program is consistent with the GALL Report

with additional enhancements to meet the GALL Report "acceptance criteria" program element

by revising procedures to address the following:

" Provide controls and sampling necessary to maintain water chemistry parameters in

CCCW systems within the guidelines of EPRI Report TR-1 07396. (NMP1 and NMP2

Commitment 15).

" Ensure acceptance criteria are specified in implementing procedures for indications of

degradation (NMP1 and NMP2 Commitment 15).

The staff reviewed these enhancements and found them consistent with the GALL Report and

therefore acceptable. These changes to the applicant's program will provide assurance that

aging effects will be adequately managed.

In the ALRA, the applicant stated that these enhancements are scheduled for completion prior

to the period of extended operation.

Operating Experience. In ALRA Section B2.1.11, the applicant explained that it has reviewed

both industry and plant-specific operating experience relating to the CCCWS Program. Review

of plant-specific operating experience revealed various forms of degradation that were

discovered by CCCWS Program activities at NMP. Corrective actions for observed degradation

included increased monitoring, component repair, or component replacement as deemed

necessary. Periodic monitoring of CCCW systems assures that any worsening trends are

identified and the capabilities of CCCWS components within the scope of license renewal are

maintained.

The staff reviewed the operating experience stated in the ALRA and interviewed the applicant's

technical staff to confirm that the plant-specific operating experience revealed no degradation

not bounded by industry experience.

After review of industry and plant-specific operating experience and discussions with the

applicant's technical staff, the staff concludes that there is reasonable assurance that the

applicant's CCCWS Program will manage adequately the aging effects and aging effects

mechanisms identified in the ALRA for which this AMP is credited.

UFSAR and USAR Supplements. In ALRA Sections A1.1.13 and A2.1.14, the applicant

provided the respective UFSAR and USAR supplements for the CCCWS Program. The staff

reviewed these sections and determined that the information in the supplements provides

adequate summary descriptions of the program, as required by 10 CFR 54.21(d).

Conclusion. On the basis of its review and audit of the applicant's CCCWS Program, the staff

determined that those program elements for which the applicant claimed consistency with the

GALL Report are consistent with the GALL Report. Also, the staff has reviewed the

enhancements and confirmed that the implementation of the enhancements prior to the period

of extended operation would result in the existing AMP being consistent with the GALL Report

AMP to which it was compared.The staff concludes that there is reasonable assurance that the

applicant demonstrated that the effects of aging will be adequately managed so that the

intended functions will be maintained consistent with the CLB for the period of extended

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operation, as required by 10 CFR 54.21(a)(3). The staff also reviewed the UFSAR supplement

for this AMP and concludes that it provides an adequate summary description of the program,

as required by 10 CFR 54.21(d).

3.0.3.2.9 Boraflex Monitoring Program (NMP1 Only)

Summary of Technical Information in the Amended Appl ication. In ALRA Section B2.1.12, the

applicant described the Boraflex Monitoring Program for NMP1, stating that this is an existing

program that is consistent, with enhancements, with GALL AMP XI.M22, "Boraflex Monitoring."

The Boraflex Monitoring Program manages degradation of neutron absorbing material in spent

fuel pool storage racks resulting from radiation exposure and possible water ingress. Program

activities include: (1) inspection of the NMP1 test coupons to detect dimensional changes; (2)

correlation of measured levels of silica in the spent fuel pool with analysis using a predictive

code (e.g., RACKLIFE) to estimate boron loss from Boraflex panels; and (3) neutron

attenuation testing to measure the boron areal density of the short-length test coupons. The

Boraflex Monitoring Program will be enhanced to require periodic in-situ neutron attenuation

testing and measurement of boron areal density to confirm the correlation of the conditions of

test coupons to those of Boraflex racks that remain in use during the period of extended

operation.

Staff Evaluation. During its audit and review, the staff confirmed the applicant's claim of

consistency with the GALL Report. Details of the staff's audit evaluation of this AMP are

documented in the Audit and Review Report. The staff reviewed the enhancements and the

associated justifications to determine whether the AMP, with the enhancements, remains

adequate to manage the aging effects for which it is credited.

The staff reviewed those portions of the Boraflex Monitoring Program for which the applicant

claimed consistency with GALL AMP XI.M22 and found them consistent. The staff found the

applicant's Boraflex Monitoring Program acceptable because it conforms to the recommended

GALL AMP XI.M22, "Boraflex Monitoring Program," with enhancements.

In the ALRA and in its letter dated November 17, 2005, the applicant stated that its Boraflex

Monitoring Program is consistent with GALL AMP XI.M22 with enhancements to meet the GALL

Report "preventive actions," "parameters monitored/inspected,""detection of aging effects," and "monitoring and tranding" program elements. These enhancements include (1) performance of

periodic neutron attenuation testing and measurement of boron areal density to confirm the

correlation of the conditions of the test coupons to those of the Boraflex racks remaining in use

during the period of extended operation and (2) establishing monitoring and trending

instructions for in-situ test results, silica levels, and coupons results. (NMP1 Commitment 16).

In the LRA, the applicant stated that it originally planned to rely mainly on the test coupons,

both short and full-length versions, to monitor the Boraflex panel condition. During the initial

audit and review (August 9-13, 2004), the staff expressed concern that there is no plan to

perform periodic boron areal density testing in the current NMP Boraflex panel conditions. To

address the staff's concern, the applicant revised its plan and stated in the ALRA and in its

letter dated November 17, 2005, that it will provide direction for periodic performance of neutron

attenuation testing and measurement of boron areal density to confirm the correlation of the

conditions of the test coupons to those of the Boraflex racks remaining in use during the period

of extended operation and establishing monitoring the trending instructions for in-situ test

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results, silica levels, and coupons results. The staff found these enhancements acceptable.

These changes to the applicant's program will provide assurance that aging effects will be

adequately managed.

Operating Experience. In ALRA Section B2.1.12, the applicant explained that it has reviewed

both industry and plant-specific operating experience relating to the Boraflex Monitoring

Program. Plant-specific operating experience at NMP is related to testing of surveillance

coupons, whose results indicate expected levels of degradation. Review of plant-specific

operating experience revealed additional conditions that were discovered by Boraflex

Monitoring Program activities in 2002. When the results of chemistry analysis indicated silica

levels in the NMP1 spent fuel pool slightly greater than the established criteria for plant

operation, a CR was initiated. A technical evaluation determined that actual silica levels were

acceptable and the operating range was revised accordingly.

As documented in the Audit and Review Report, the staff noted that the applicant is managing

the current Boraflex rack conditions. For NMP1 the applicant is in the process of replacing six of

the eight Boraflex racks with racks made of Boral. Boraflex racks remaining in the spent fuel

pool will be used only in low flux areas and not in the vicinity of freshly discharged fuel. For

NMP2 the applicant plans to replace all Boraflex panels with Boral panels prior to period of

extended operation (NMP2 Commitment 36).

The staff reviewed the operating experience stated in the ALRA and interviewed the applicant's

technical staff to confirm that the plant-specific operating experience revealed no degradation

not bounded by industry experience.

After review of industry and plant-specific operating experience and discussions with the

applicant's technical staff the staff conclude that the Boraflex Monitoring Program will manage

adequately the aging effects and aging effects mechanisms identified in the ALRA for which

this AMP is credited.

UFSAR Supplement. In ALRA Section A1.1.5 and in its letter dated November 17, 2005, the

applicant provided the UFSAR supplement for the Boraflex Monitoring Program. The staff

reviewed this section and determined that the information in the UFSAR supplement provides

an adequate summary description of the program, as required by 10 CFR 54.21(d).

Conclusion. On the basis of its review and audit of the applicant's Boraflex Monitoring Program,

the staff determined that those program elements for which the applicant claimed consistency

with the GALL Report are consistent with the GALL Report. Also, the staff has reviewed the

enhancements and confirmed that the implementation of the enhancements prior to the period

of extended operation would result in the existing AMP being consistent with the GALL Report

AMP to which it was compared.The staff concludes that there is reasonable assurance that the

applicant demonstrated that the effects of aging will be adequately managed so that the

intended functions will be maintained consistent with the CLB for the period of extended

operation, as required by 10 CFR 54.21(a)(3). The staff also reviewed the UFSAR supplement

for this AMP and concludes that it provides an adequate summary description of the program,

as required by 10 CFR 54.21(d).

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3.0.3.2.10 Inspection of Overhead Heavy Load and Light Load Handling Systems Program

Summary of Technical Information in the Amended Application. In ALRA Section B2.1.13, the

applicant described the Inspection of Overhead Heavy Load and Light Load Handling Systems

Program, stating that this is an existing program that is consistent, with enhancements, with

GALL AMP XI.M23, "Inspection of Overhead Heavy Load and Light Load (Related to Refueling)

Handling Systems." The Inspection of Overhead Heavy Load and Light Load Handling Systems

Program (referred to herein as the Crane Inspection Program) manages loss of material due to

corrosion of cranes within the scope of license renewal. Program activities include: (1)

performance of various maintenance activities on a specified frequency and (2) pre-operational

inspections of equipment prior to lifting activities. Crane inspection activities are based on

applicable industry standards and the guidance of NUREG-0612.

Staff Evaluation. During its audit and review, the staff confirmed the applicant's claim of

consistency with the GALL Report. Details of the staff's audit evaluation of this AMP are

documented in the Audit and Review Report. The staff reviewed the enhancements and the

associated justifications to determine whether the AMP, with the enhancements, remains

adequate to manage the aging effects for which it is credited.

During the initial audit and review (August 9-13, 2004) the applicant stated in the program

attribute assessment document "Units 1 and 2 Inspection of Overhead Heavy Load and Light

Load Handling Systems Program" (since superseded) that under the GALL Report program

element "parameters monitored/inspected" comparison "the program ensures that crane

operation is within the design limits in regards to the number and magnitude of lifts." The staff

asked the applicant during the initial audit and review to explain how the number and magnitude

of lifts for each crane within the scope of license renewal have been documented historically

and will be documented in the future under a renewed license. The applicant also was asked to

explain how the individual or individuals responsible for ensuring that crane operations are

within crane design limits on the number and magnitude of lifts for license renewal cranes track

and maintain this information on a daily or outage basis.

During the initial audit and review, the applicant stated in response to the staffs questions that

the statement in the program attribute assessment document that the program ensures crane

operation is within the design limits on the number and magnitude of lifts is a qualitative and not

a quantitative review. The applicant stated in the superseded program attribute assessment

document that the cranes at NMP within the scope of license renewal are designed for standby

or infrequent service like most cranes in similar applications. Crane capacity loads may be

handled for initial installation of equipment and for infrequent maintenance. This crane use is

the lightest (Class A) duty cycle according to the Crane Manufacturers Association of America

crane service classifications. The applicant concludes that the infrequent use of the cranes

below their capacity rated by industry experience and engineering judgment meets the

recommendation of GALL AMP XI.M23 for the number and magnitude of lifts and that a

documented history is not required. The staff found that the applicant maintained this same

view of this GALL AMP XI.M23 program element in the ALRA.

The staff found this explanation acceptable because the cranes within the scope of license

renewal are used infrequently. A qualitative review of the number and magnitude of crane lifts is

reasonable because recording of the number and magnitude of every crane lift would be an

undue documentation burden where crane utilization is well below their design life.

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The staff reviewed those portions of the Inspection of Overhead Heavy Load and Light Load

Handling Systems Program for which the applicant claimed consistency with GALL AMP XI.M23

and found them consistent. Furthermore, the staff concludes that the applicant's Inspection of

Overhead Heavy Load and Light Load Handling Systems Program provides reasonable

assurance that aging management of loss of material from corrosion of crane structural

components within the scope of license renewal will be performed. The staff found the

applicant's Inspection of Overhead Heavy Load and Light Load Handling Systems Program

acceptable because it conforms to the recommended GALL AMP XI.M23 with an enhancement.

In the ALRA, the applicant stated that its Inspection of Overhead Load and Light Load Handling

Systems Program is consistent with GALL AMP XI.M23 with an enhancement to meet the

GALL Report "parameters monitored/inspected," "acceptance criteria," and "detection of aging

effects" program elements. The applicant stated that various cranes and hoists are not

inspected for loss of material of the load-bearing components; therefore, an enhancement to

the corresponding preventive maintenance procedure will be made to add a visual inspection

for loss of material of the hoist lifting assembly components (NMP1 Commitment 17 and NMP2

Commitment 16).

As documented in the Audit and Review Report, the applicant stated that each crane within the

scope of license renewal has a procedure which periodically performs an inspection of the

crane. This inspection, however, is not specifically of components for loss of material and

corrosion. Also, the procedures do not identify specifically the effects of wear on the rails in the

rail system. Procedures will be enhanced to add visual inspection for loss of material from

corrosion and wear on the rails in the rail system.

In addition, as documented in the Audit and Review Report, the applicant stated that this

enhancement will add specific inspection steps for general corrosion to the preventive

maintenance procedures for each crane within the scope of license renewal. Adding visual

inspections to the procedures will be adequate to ensure that loss of material is detected before

a loss of intended function. With these additional inspections, the applicant's Inspection of

Overhead Heavy Load and Light Load Handling Systems Program inspection will meet the

program recommendations described in GALL AMP XI.M23. The staff found this enhancement

acceptable. These changes to the applicant's program will provide assurance that aging effects

will be adequately managed.

Operating Experience. In ALRA Section B2.1.13, the applicant explained that it has reviewed

both industry and plant-specific operating experience relating to the Crane Inspection Program.

Review of plant-specific operating experience revealed no failures caused by loss of material in

crane structural components.

The staff also reviewed the summary of specific operating experience as documented in the

Audit and Review Report. The review indicated the Inspection of Overhead Heavy Load and

Light Load Handling Systems Program is effective in identifying crane degradation and

implementing repairs. A review of NMP plant corrective action records revealed that there have

been no failures from loss of material of crane structural components. Any deficiencies in NMP

cranes have been attributed to design flaws, installation deficiencies, adjustments, or improper

maintenance procedures. None of these deficiencies resulted in loss of intended function from

age-related degradation. These findings provided assurance that loss of material of crane and

trolley structural components had not occurred since the inception of the program. After

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enhancement program procedures will be more effective in detecting age-related degradation,

implementing repairs, and maintaining the integrity of NMP load handling systems within the

scope of license renewal to ensure discovery and evaluation of loss of material before a loss of

intended function.

The staff reviewed the operating experience stated in the ALRA and interviewed the applicant's

technical staff to confirm that the plant-specific operating experience revealed no degradation

not bounded by industry experience.

After review of industry and plant-specific operating experience and discussions with the

applicant's technical staff the staff concludes that there is reasonable assurance that the

applicant's Inspection of Overhead Heavy Load and Light Load Handling Systems Program will

manage adequately the aging effects and aging effects mechanisms identified in the ALRA for

which this AMP is credited.

UFSAR and USAR Supplements. In ALRA Sections A1.1.22 and A2.1.22, the applicant

provided the respective UFSAR and USAR supplements for the Inspection of Overhead Heavy

Load and Light Load Handling Systems Program. The staff reviewed these sections and

determined that the information in the supplements provides adequate summary descriptions of

the program, as required by 10 CFR 54.21(d).

Conclusion. On the basis of its review and audit of the applicant's Inspection of Overhead

Heavy Load and Light Load Handling Systems Program, the staff determined that those

program elements for which the applicant claimed consistency with the GALL Report are

consistent with the GALL Report. Also, the staff has reviewed the enhancements and confirmed

that the implementation of the enhancements prior to the period of extended operation would

result in the existing AMP being consistent with the GALL Report AMP to which it was

compared.The staff concludes that there is reasonable assurance that the applicant

demonstrated that the effects of aging will be adequately managed so that the intended

functions will be maintained consistent with the CLB for the period of extended operation, as

required by 10 CFR 54.21(a)(3). The staff also reviewed the UFSAR supplement for this AMP

and concludes that it provides an adequate summary description of the program, as required by

10 CFR 54.21(d).

3.0.3.2.11 Compressed Air Monitoring Program (NMP1 Only)

Summary of Technical Information in the Amended Application. In ALRA Section B2.1.14, the

applicant described the Compressed Air Monitoring Program for NMP1, stating that this is an

existing program that is consistent, with exceptions and enhancements, with GALL

AMP XI.M24, "Compressed Air Monitoring." The Compressed Air Monitoring Program manages

aging effects for portions of the compressed air systems within the scope of license renewal,

including cracking and loss of material due to general corrosion, by controlling the internal

environment of systems and components. Program activities include air quality checks at

various locations to detect contaminants that would affect the system's intended function.

Additional visual inspections are credited for identification and monitoring of degradation for air

compressors, receivers, and air dryers. The Compressed Air Monitoring Program is based on

GL 88-14 and recommendations presented in INPO Significant Operating Event Report 88-01.

The Compressed Air Monitoring Program is only applicable to NMP1 since the components

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requiring aging management for the NMP2 compressed air system are managed under the

10 CFR Part 50, Appendix J Program and the One-Time Inspection Program.

Staff Evaluation. During its audit and review, the staff confirmed the applicant's claim of

consistency with the GALL Report. Details of the staff's audit evaluation of this AMP are

documented in the Audit and Review Report. The staff reviewed the exceptions and

enhancements and the associated justifications to determine whether the AMP, with the

exceptions and enhancements, remains adequate to manage the aging effects for which it is

credited.

In the "Exceptions to NUREG-1801" section of the ALRA the applicant stated that it took

specific exception to any maintenance recommended in EPRI TR-108147, "Compressor and

Instrument Air System Maintenance Guide: Revision to NP-7079," not endorsed also by the

equipment manufacturers and to the pre-service and in-service testing guidelines of ASME

OM-S/G-1998, Part 17, "Performance Testing of Instrument Air Systems Information Notice

Light-Water Reactor Power Plants." As documented in the Audit and Review Report, the staff

asked the applicant to clarify why this exception was not mentioned in the "NUREG-1801

Consistency" section of the ALRA. In its letter dated December 1, 2005, the applicant stated

that it will revise NMP AMP B2.1.14, to read:

The Compressed Air Monitoring Program is an existing program that will be

consistent with NUREG-1801, Section XI.M24 (Compressed Air Monitoring)

(Reference 2), with exceptions, after enhancements are incorporated.

The staff reviewed those portions of the Compressed Air Monitoring program for which the

applicant claimed consistency with GALL AMP XI.M24 and found them consistent. The staff

found the applicant's Compressed Air Monitoring Program acceptable because it conforms to

the recommended GALL AMP XI.M24 with exceptions and enhancements.

During the audit, the applicant stated that its Compressed Air Monitoring Program is consistent

with GALL AMP XI.M24 with an exception. The Compressed Air Monitoring Program takes

exception to the GALL Report "preventive actions" and "detection of aging effects" program

elements. As stated in the ALRA, NMP1 takes a limited exception related to maintenance

suggestions in EPRI NP-7079 and EPRI TR-1 08147 not also endorsed by the manufacturer.

NMP1 takes specific exception to the pre-service and in-service testing guidelines of ASME

OM-S/G-1998, Part 17. It also takes specific exception to the pre-service and in-service testing

guidelines of ASME OM-S/G-1998, Part 17.

The applicant also stated in justification for the GALL Report exception that (1) the maintenance

practices reviewed and enhanced under the NMP1 response to GL 88-14*are adequate to

manage aging without additional testing and (2) there have been no age-related failures of the

compressed air monitoring system under its current program.

As documented in the Audit and Review Report, the staff noted that the applicant did not list

ANSI/ISA-S7.0.01-1996 in NMP AMP B2.1.14. The staff inquired whether the applicant used

this standard for air quality. In its letter dated December 1, 2005, the applicant stated that it will

add the following for clarification:

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NMP also takes exception to the use of ISA-S7.0.01-1996 for air quality.

standards. This is acceptable because the system air quality is monitored and

maintained in compliance with the requirements of ANSI/ISA-S7.3-1975, "Air

Quality Standards for Pneumatic Instruments" which meets or exceeds the

quality requirements for dew point, hydrocarbons, and particulate of Section 4.4

of EPRI TR-1 08147 and ISA-S7.0.01-1996.

The staff agreed with the applicant's assessment because the ANSI/ISA-S7.3-1975 air quality

standard is higher than the ANSI/ISA-S7.0.01-1996 standard.

As documented in the Audit and Review Report, the staff noted that (1) the applicant had

performed a satisfactory design and operations verification of the instrument air system in

response to GL 88-14, (2) the applicant has incorporated the INPO good engineering practice

recommendations on the instrument air system into its maintenance procedures, as described

in the INPO Significant Operating Experience Report (SOER) 88-01, (3) the applicant's air

sampling analysis procedure specifies the quality requirements of dew point, oil, water, and

particle size based on ANSI/ISA-S7.0.01-1975, "Quality Standard for Instrument Air," (4) the

applicant routinely performs preventative maintenance and inspection on the compressor and

carbon steel components to limit the introduction of contaminants into the air supply, and (5) the

applicant regularly tests the active compressed air system valves and skid mounted

compressor components to ensure their operability. All of these activities demonstrate that the

applicant has an adequate preventive maintenance program for inoperability of air-operated

components due to corrosion and the presence of oil, water, rust, and other contaminants. In

addition review of the applicant's operating experience indicated that the its Compressed Air

Monitoring Program has an acceptable record of ensuring maintenance of the design basis

function of the system. Therefore, the staff agreed with the applicant's assessment and

concludes that the applicant's Compressed Air Monitoring Program includes good practice for

general maintenance and inspection of the compressor, receiver, and dryer as addressed in

EPRI TR-108147 and ASME OM-.S/G-1998, Part 17. On these bases the staff found this

exception acceptable.

In the ALRA, the applicant stated that its Compressed Air Monitoring Program is consistent with

GALL AMP XI.M24 with enhancements to meet the GALL Report "scope of program," "preventive actions," "detection of aging effects," "monitoring and trending," and "acceptance

criteria" program elements by revising procedures to address such elements.

" "Scope of program," "preventive action," and "detection of aging effects" program

elements - develop new activities to manage loss of material and SCC, perform periodic

system leak checks, and expand the scope, periodicity, and inspection techniques to

ensure aging management of aging of certain subcomponents of the dryers and

compressors (e.g., valves, heat exchangers) (NMP1 Commitment 18).

" "Monitoring and trending" program element - establish activities that manage the aging

of internal surfaces of carbon steel piping and that require system leak checks to detect

deterioration of the pressure boundaries (NMP1 Commitment 18).

" "Acceptance criteria" program element - expand the acceptance criteria to ensure aging

management of certain subcomponents of the dryers and compressors (e.g., valves,

heat exchangers) (NMP1 Commitment 18).

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As documented in the Audit and Review Report, the applicant stated that these enhancements

are required to develop activities that manage loss of material due to general corrosion of such

carbon steel components upstream of the dryers as piping, receivers, and valves. Other new

required activities will address red brass pipe SCC and perform periodic system leak checks.

Certain existing activities will be revised to expand the scope and frequency of inspections so

that aging of such sub-components of the dryers and compressors as solenoid-operated valves

and heat exchangers is addressed adequately. As documented in the Audit and Review Report,

the staff noted that these additional activities are results of the applicant's ongoing evaluation of

its Compressed Air Monitoring Program to account for internal and external plant operating

experience problems. The staff found these enhancements acceptable. These changes to the

applicant's program will provide assurance that aging effects will be adequately managed.

Operating Experience. In ALRA Section B2.1.14, the applicant explained that it has reviewed

both industry and plant-specific operating experience relating to the Compressed Air Monitoring

Program. Since its inception in 1992, the Compressed Air Monitoring Program has effectively

detected the buildup of corrosion products and prevented component failure. NMP1 has

experienced age related degradation due to stress corrosion cracking in unannealed red brass

piping in areas that may have been chemically contaminated. However, no pneumatic

component within the scope of license renewal has experienced a loss of intended function due

to corrosion, corrosion product buildup, or dirt buildup in the instrument air system.

The applicant also stated in the ALRA that it reviews both industry and plant-specific operating

experience relating to its Compressed Air Monitoring Program and continually adjusts to

account for internal and external plant operating experience issues. After discussions with the

applicant's technical staff and a sampling review of the CR list associated with the applicant's

Compressed Air Monitoring Program the staff concurred that the applicant incorporates the

operating experience into its operations effectively.

The staff reviewed the operating experience stated in the ALRA and interviewed the applicant's

technical staff to confirm that the plant-specific operating experience revealed no degradation

not bounded by industry experience.

After review of industry and plant-specific operating experience and discussions with the

applicant's technical staff, the staff concludes that there is reasonable assurance that the

applicant's Compressed Air Monitoring Program (NMP1 only) will manage adequately the aging

effects and aging effects mechanisms identified in the ALRA for which this AMP is credited.

UFSAR Supplement. In ALRA Section A1.1.14, the applicant provided the UFSAR supplement

for the Compressed Air Monitoring Program. The staff reviewed this section and determined

that the information in the UFSAR supplement provides an adequate summary description of

the program, as required by 10 CFR 54.21(d).

Conclusion. On the basis of its review and audit of the applicant's Compressed Air Monitoring

Program, the staff determined that those program elements for which the applicant claimed

consistency with the GALL Report are consistent with the GALL Report. In addition, the staff

reviewed the exceptions and the associated justifications, and determined that the AMP, with

the exceptions, is adequate to manage the aging effects for which it is credited. Also, the staff

has reviewed the enhancements and confirmed that the implementation of the enhancements

prior to the period of extended operation would result in the existing AMP being consistent with

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the GALL Report AMP to which it was compared.The staff concludes that there is reasonable

assurance that the applicant demonstrated that the effects of aging will be adequately managed

so that the intended functions will be maintained consistent with the CLB for the period of

extended operation, as required by 10 CFR 54.21(a)(3). The staff also reviewed the UFSAR

supplement for this AMP and concludes that it provides an adequate summary description of

the program, as required by 10 CFR 54.21(d).

3.0.3.2.12 BWR Reactor Water Cleanup System Program

Summary of Technical Information in the Amended Application. In ALRA Section B2.1.15, the

applicant described the BWR Reactor Water Cleanup System Program, stating that this is an

existing program that is consistent, with exception, with GALL AMP XI.M25, "BWR Reactor

Water Cleanup System." The BWR Reactor Water Cleanup System Program manages the

effects of SCC or IGSCC on the intended function of austenitic stainless steel piping in the

reactor water cleanup (RWCU) system. This program is based on the NRC criteria related to

inspection guidelines for RWCU piping welds outboard of the containment isolation valve as

delineated in NUREG-0313, Revision 2, and GL 88-01. An exception is taken to the acceptance

criteria program element in that NMP1 utilizes the 1989 edition with no addenda of the ASME

Section Xl code versus the 1995 edition through the 1996 addenda as defined in the GALL.

The design of the NMP2 RWCU system is such that carbon steel piping welds are not required

to be examined in accordance with GL 88-01. The attributes of the BWR Reactor Water

Cleanup System Program related to maintaining reactor coolant water chemistry are included in

the Water Chemistry Control Program.

Staff Evaluation. During its audit and review, the staff confirmed the applicant's claim of

consistency with the GALL Report. Details of the staff's audit evaluation of this AMP are

documented in the Audit and Review Report. The staff reviewed the exception and the

associated justifications to determine whether the AMP, with the exception, remains adequate

to manage the aging effects for which it is credited.

The staff reviewed those portions of the BWR Reactor Water Cleanup System Program for

which the applicant claimed consistency with GALL AMP XI.M25 and found them consistent.

The staff found the applicant's BWR Reactor Water Cleanup System Program acceptable

because it conforms to the recommended GALL AMP XI.M25 with an exception.

In the ALRA, the applicant stated that its BWR Reactor Water Cleanup System Program is

consistent with GALL AMP XL.M25 with an exception. The BWR Reactor Water Cleanup

System Program takes exception to the "acceptance criteria" program element. As stated in the

ALRA, the exception to this program element is that the program described in GALL

AMP XI.M25 cites ASME Section XI requirements covered in the 1995 Edition through the 1996

Addenda for the "acceptance criteria" element. NMP1 uses the 1989 Edition with no addenda.

As documented in the Audit and Review Report, the staff requested that the applicant clarify the

ASME edition that would be used for aging management during the extended period of

operation. The applicant stated that the use of later code editions and addenda of ASME

Section Xl is determined according to 10 CFR 50.55a requirements 12 months before the start

of each 120-month inspection interval subject to limitations and modifications by the staff and

requires NRC approval. The staff found this response acceptable as the applicant clarified that

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the ASME Xl Edition will have to be chosen according to applicable regulations and submitted

for NRC approval. On this basis the staff found this exception acceptable.

Operating Experience. In ALRA Section B2.1.15, the applicant explained that it has reviewed

both industry and plant-specific operating experience relating to cracking in the reactor water

cleanup system. Review of plant-specific operating experience for NMP1 identified that leaks

were experienced in two welds outboard of the second isolation valve. Weld 33-FW-22 had

undergone a localized repair during its original construction and consequently, became more

sensitized. Weld 33-FW-23A is a one of a kind design configuration that promotes very high

stresses due to the fact that it connects very large shells that have different thermal movement

that cannot be accommodated by the short and stiff pipe. In addition, the pipe is subject to

thermal cycling. Both welds were repaired by a full structural weld overlay.

As documented in the Audit and Review Report, the staff reviewed plant-specific experience

documented in a CR and summarized in the RWCU program basis document. The CR

addressed a leak in the RWCU system from a 7/16" axial crack (in a bimetallic weld where

stainless steel piping was replaced with carbon steel). The mechanism was classified as IGSCC

and the leak was repaired with a weld overlay. This type of leak was discussed in GL 88-01. To

confirm that this weld failure was a unique incident the applicant performed additional UT

exams on a sample of three other RWCU welds. The sample size was based on the planned

sample expansion criteria used during outages for RWCU inspections performed to comply with

GL 88-01.

The staff reviewed the operating experience stated in the ALRA and interviewed the applicant's

technical staff to confirm that the plant-specific operating experience revealed no degradation

not bounded by industry experience.

After review of industry and plant-specific operating experience and discussions with the

applicant's technical staff, the staff concludes that there is reasonable assurance that the

applicant's BWR Reactor Water Cleanup System Program will manage adequately the aging

effects and aging effects mechanisms identified in the ALRA for which this AMP is credited.

UFSAR and USAR Supplements. In ALRA Sections A1.1.9 and A2.1.10, the applicant provided

the respective UFSAR and USAR supplements for the BWR Reactor Water Cleanup System

Program. The staff reviewed these sections and determined that the information in the

supplements provides adequate summary descriptions of the program, as required by

10 CFR 54.21(d).

Conclusion. On the basis of its review and audit of the applicant's BWR Reactor Water Cleanup

System Program, the staff determined that those program elements for which the applicant

claimed consistency with the GALL Report are consistent with the GALL Report. In addition, the

staff reviewed the exception and the associated justifications, and determined that the AMP,

with the exception, is adequate to manage the aging effects for which it is credited.The staff

concludes that there is reasonable assurance that the applicant demonstrated that the effects

of aging will be adequately managed so that the intended functions will be maintained

consistent with the CLB for the period of extended operation, as required by

10 CFR 54.21 (a)(3). The staff also reviewed the UFSAR supplement for this AMP and

concludes that it provides an adequate summary description of the program, as required by

10 CFR 54.21(d).

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3.0.3.2.13 Fire Protection Program

Summary of Technical Information in the Amended Application. In ALRA Section B2.1.16, the

applicant described the Fire Protection Program, stating that this is an existing program that is

consistent, with exceptions and enhancements, with GALL AMP XI.M26, "Fire Protection." The

Fire Protection Program provides guidance for performance of periodic visual inspections to

manage aging of the various materials comprising rated fire barriers. These include: (1)

sealants in rated penetration seals (subject to shrinkage due to weathering); (2) concrete and

steel in fire rated walls, ceilings, and floors (subject to loss of material due to flaking and

abrasion; separation and concrete damage due to relative motion, vibration, and shrinkage);

and (3) steel in rated fire doors (subject to loss of material due to corrosion and wear or

mechanical damage). In addition, the program requires testing of the diesel-driven fire pump to

verify that it is performing its intended function. This activity manages aging of the diesel

engine's fuel oil supply line and exhaust system, which may experience loss of material due to

corrosion. Inspection and testing is performed in accordance with the guidance of applicable

standards.

Staff Evaluation. During its audit and review, the staff confirmed the applicant's claim of

consistency with the GALL Report. Details of the staff's audit evaluation of this AMP are

documented in the Audit and Review Report. The staff reviewed the exceptions and

enhancements and the associated justifications to determine whether the AMP, with the

exceptions and enhancements, remains adequate to manage the aging effects for which it is

credited.

The staff reviewed those portions of the Fire Protection Program for which the applicant

claimed consistency with GALL AMP XI.M26 and found them consistent. The staff found the

applicant's Fire Protection Program acceptable because it conforms to the recommended GALL

AMP X1.M26 with exceptions and enhancements.

In the ALRA, the applicant stated that its Fire Protection Program is consistent with GALL

AMP XI.M26 with exceptions. The Fire Protection Program takes exception to the GALL Report "detection of aging effects" program element where it requires bi-monthly inspection of hollow

metal fire doors and monthly inspection of the halon/carbon dioxide suppression system valve

lineup. Rather, NMP is consistent with Interim Staff Guidance (ISG-) 04, "Aging Management of

Fire Protection Systems for License Renewal," on both issues.

In the ALRA, the applicant stated that the current fire doors inspection frequency will be

changed to comply with a plant-specific engineering evaluation of inspection intervals. This

change is consistent with ISG-04, as is states that fire doors are inspected visually on

plant-specific intervals for integrity of door surfaces and for clearances. On this basis the staff

found this exception acceptable.

In the ALRA, the applicant stated that consistent with ISG-04 and the latest regulatory guidance

of GL-86-1 0 valve lineups on the carbon dioxide/halon suppression systems will not be credited

for aging management in its Fire Protection Program. Because ISG-04 states that valve lineup

inspection, charging pressure inspection, and an automatic mode of operation verification are

operational activities pertaining to system or component configurations or properties that may

change and are not related to aging management the staff found this exception acceptable.

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In the ALRA, the applicant further stated that its Fire Protection Program is consistent with

GALL AMP XLM26 with enhancements to the GALL Report "scope of program," "parameters

monitored/inspected," "detection of aging effects," and "acceptance criteria" program elements.

As part of the proposed enhancement the applicant will revise procedures to address the

following elements:

" Incorporate periodic visual inspections of piping and fittings in a non-water environment

(e.g., halon) and carbon dioxide fire suppression systems components to detect

evidence of corrosion and any system mechanical damage that could affect its intended

function (NMP1 Commitment 19, NMP2 Commitment 17).

" Expand the scope of periodic function tests of the diesel-driven fire pump to include

inspection of engine exhaust system components to verify that loss of material is

managed (NMP1 Commitment 19, NMP2 Commitment 17).

Perform an engineering evaluation to determine the plant-specific inspection frequency

of fire doors (NMP1 Commitment 19, NMP2 Commitment 17).

The staff found Commitment 19 of Appendix A1.4 for NMP1 and Commitment 17 of

Appendix A2.4 for NMP2 consistent with ISG-04 which provides a specific frequency for both

inspections and function tests. The staff found that the enhancement adequately manages the

aging effects of piping and fittings in halon and carbon dioxide fire suppression systems

components.

As part of these commitments the scope of periodic functional tests of the diesel-driven fire

pump will be expanded to include inspection of engine exhaust system components. The staff

found that the enhancement adequately manages to maintain the functional reliability of the

diesel-driven fire pump.

As part of these commitments engineering evaluations will determine the plant-specific

inspection frequency of fire doors. The staff determined that though is not consistent with the

GALL Report this enhancement is consistent with ISG-04, which states that hollow metal fire

doors should be inspected on a plant-specific interval and that this interval should be

determined by an engineering evaluation. On this basis the staff found this enhancement

acceptable.

In its letter dated November 17, 2005, the applicant stated that an enhancement to meet the

GALL Report "detection of aging effects" program element revised procedures to address the

following elements:

Halon and carbon dioxide functional test frequencies will be changed to semi-annual in the Fire

Protection Program procedures as an addition to NMP1 Commitment 19 and NMP2

Commitment 17. The staff reviewed this enhancement and found it consistent with the GALL

Report and acceptable.

Operating Experience. In ALRA Section B2.1.16, the applicant explained that it has evaluated

applicable industry operating experience. Applicable guidelines and requirements have been

incorporated into Fire Protection Program implementing procedures. Minor degradation has

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been identified while performing Fire Protection Program activities (e.g., fire barrier penetration

seals found damaged or cracked, fire dampers failed surveillance testing, and fire door

inspections not satisfactory) and corrective actions taken. No significant age-related problems

have been reported for NMP fire protection systems and components managed by the Fire

Protection Program.

The staff reviewed the operating experience stated in the ALRA and interviewed the applicant's

technical staff to confirm that the plant-specific operating experience revealed no degradation

not bounded by industry experience.

After review of industry and plant-specific operating experience and discussions with the

applicant's technical staff the staff concludes that there is reasonable assurance that the

applicant's Fire Protection Program, NMP AMP B2.1.16, will manage adequately the aging

effects identified in the ALRA for which this AMP is credited.

UFSAR and USAR Supplements. In ALRA Sections A1.1.17 and A2.1.17, the applicant

provided the respective UFSAR and USAR supplements for the Fire Protection Program. The

staff reviewed these sections and determined that the information in the supplements provides

adequate summary descriptions of the program, as required by 10 CFR 54.21(d).

Conclusion. On the basis of its review and audit of the applicant's Fire Protection Program, the

staff determined that those program elements for which the applicant claimed consistency with

the GALL Report are consistent with the GALL Report. In addition, the staff reviewed the

exceptions and the associated justifications, and determined that the AMP, with the exceptions,

is adequate to manage the aging effects for which it is credited. Also, the staff has reviewed the

enhancements and confirmed that the implementation of the enhancements prior to the period

of extended operation would result in the existing AMP being consistent with the GALL Report

AMP to which it was compared.The staff concludes that there is reasonable assurance that the

applicant demonstrated that the effects of aging will be adequately managed so that the

intended functions will be maintained consistent with the CLB for the period of extended

operation, as required by 10 CFR 54.21(a)(3). The staff also reviewed the UFSAR supplement

for this AMP and concludes that it provides an adequate summary description of the program,

as required by 10 CFR 54.21(d).

3.0.3.2.14 -Fire Water System Program

Summary of Technical Information in the Amended Application. In ALRA Section B2.1.17, the

applicant described the Fire Water System Program, stating that this is an existing program that

is consistent, with enhancements, with GALL AMP XI.M27, "Fire Water System." The Fire

Water System Program manages aging of water-based fire protection systems due to loss of

material and biofouling. Program activities include periodic maintenance, testing, and inspection

of system piping and components containing water (e.g., sprinklers, nozzles, fittings, valves,

hydrants, hose stations, standpipes). Inspection and testing is performed in accordance with the

guidance of applicable National Fire Protection Association (NFPA) Codes and Standards and

the Nuclear Electric Insurance Limited Members' Manual.

Staff Evaluation. During its audit and review, the staff confirmed the applicant's claim of

consistency with the GALL Report. Details of the staff's audit evaluation of this AMP are

documented in the Audit and Review Report. The staff reviewed the enhancements and the

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associated justifications to determine whether the AMP, with the enhancements, is adequate to

manage the aging effects for which it is credited.

The staff reviewed those portions of the Fire Water System Program for which the applicant

claimed consistency with GALL AMP XI.M27 and found them consistent. The staff found the

applicant's Fire Water System Program acceptable because it conforms to the recommended

GALL AMP XI.M27 with enhancements.

In the ALRA and in its letter dated November 17, 2005, the applicant stated that its Fire Water

System Program is consistent with GALL AMP XI.M27 with enhancements to meet the GALL

Report "scope of program" program element and program description. The enhancement

includes revising procedures to address the following elements:

Incorporate into existing periodic test procedures inspections to detect and manage loss

of material due to corrosion (NMP1 Commitment 20, NMP2 Commitment 18).

Incorporate into sprinkler head replacements or inspections procedures and preventive

maintenance tasks to meet NFPA 25, "Inspection, Testing, and Maintenance of Waterbased Fire Protection System," Section 5.3.1 (2003 Edition) requirements (NMP1

Commitment 20, NMP2 Commitment 18).

This enhancement is stated in Commitment 20 of ALRA Section A1.4 for NMP1 and

Commitment 18 of Section A2.4 for NMP2. The GALL Report recommends that portions of the

fire protection suppression piping located above ground and exposed to water be disassembled

and internally inspected visually once every refueling outage. ISG-04, "Aging Management of

Fire Protection Systems for License Renewal," recommends the use of non-intrusive testing of

the piping system. The incorporation of new inspection and NFPA 25 requirements into existing

procedures will satisfy ISG-04. The staff found this enhancement acceptable.

In addition the applicant stated in its letter dated November 17, 2005, that as an addition to

Commitment 20 of ALRA Section A1.4 and Commitment 18 of ALRA Section A2.4 new

procedures and preventive maintenance tasks for sprinkler head replacements or inspections to

meet NFPA 25 will be added to its Fire Water System Program. The staff reviewed this

enhancement and found it consistent with the GALL Report and acceptable.

In its letter dated November 17, 2005, the applicant also stated that an enhancement in

meeting the GALL Report "preventive actions" program element revises procedures to address

the following element:

Specify periodic component inspections to verify management of loss of material (NMP1

Commitment 20, NMP2 Commitment 18).

In the ALRA, the applicant stated that an enhancement to increase the frequency of inspection

of components will be added to the scope of its Fire Water System Program to ensure further

that loss of material is managed. This improvement of procedures consistent with ISG-04 and

with the GALL Report is stated in NMP1 Commitment 20 and NMP2 Commitment 18. The staff

found this enhancement acceptable. These changes to the applicant's program will provide

assurance that aging effects will be adequately managed.

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In the ALRA and in its letter dated November 17, 2005, the applicant further stated an

enhancement to meet the GALL Report "parameters monitored/inspected" program element to

revise procedures to address the following:

Add procedural guidance for performing visual inspections to monitor internal corrosion

and detect biofouling (NMP1 Commitment 20, NMP2 Commitment 18).

In the ALRA, the applicant stated in Commitment 20 of ALRA Section A1.4 and Commitment 18

of Section A2.4 that an enhancement will be made to add procedural guidance for performing

visual inspections to monitor internal corrosion and detect biofouling for fire protection piping

systems. The applicant also stated in its letter dated November 17, 2005, that the Fire Water

System Program will be enhanced by adding the requirements for procedures and preventive

maintenance tasks to implement sprinkler head replacement or inspections to meet NFPA 25.

The staff reviewed this enhancement and concludes that it will make the applicant's Fire Water

System Program consistent with ISG-04 and NFPA 25 for non-intrusive inspections. ISG-04

states that disassembly of piping may not be the most effective method to detect aging effects.

Each opening of the system introduces oxygen which accelerates the potential for general

corrosion. ISG-04 recommends non-intrusive pipe wall thickness evaluations like volumetric

inspection. ISG-04 also states that the plant maintenance process may include a visual

inspection of the internal surface of the fire protection piping with routine or corrective

maintenance.

In addition the applicant stated in its letter dated November 17, 2005, that new procedures and

preventive maintenance tasks for sprinkler head replacements or inspections will be added to

its Fire Water System Program to meet NFPA 25. On this basis, the staff found this

enhancement sufficient to manage the aging effects of fire protection piping systems.

In the ALRA, the applicant also stated that an enhancement to meet the GALL Report

"detection of aging effects" program element revises procedures to address the following:

" Add specifications to periodically check water-based fire protection systems for

microbiological contamination (NMP1 Commitment 20, NMP2 Commitment 18).

" Measure fire protection system piping wall thickness using non-intrusive techniques

(e.g., volumetric testing) to detect loss of material from corrosion (NMP1 Commitment

20, NMP2 Commitment 18).

In the ALRA, the applicant stated in Commitment 20 of ALRA Section A1.4 and Commitment 18

of ALRA Section A2.4 for NMP2 that requirements are to be added to check the water-based

fire protection systems periodically for microbiological contamination. The staff reviewed this

enhancement and found it consistent with the GALL Report and acceptable.

In the ALRA, the applicant stated in Commitment 20 of ALRA Section A1.4 for NMP1 and

Commitment 18 of ALRA Section A2.4 for NMP2 that measurement of fire protection piping wall

thicknesses using non-intrusive techniques (e.g., volumetric testing) will be implemented. The

staff reviewed this enhancement and found it consistent with ISG-04. The staff found these

enhancements acceptable. These changes to the applicant's program will provide assurance

that the affects of aging will be adequately managed.

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In addition in the ALRA the applicant stated that an enhancement in meeting the GALL Report "monitoring and trending" program element revises procedures to address the following

elements:

Establish an appropriate means of recording, evaluating, reviewing, and trending the

results of visual inspections and volumetric testing. (NMP1 Commitment 20, NMP2

Commitment 18)

In the ALRA in Commitment 20 of ALRA Section A1.4 and Commitment 18 of ALRA

Section A2.4 the applicant stated that an appropriate means of recording, evaluating, reviewing,

and trending the results of visual inspections and volumetric testings will be added to existing

procedures. The staff found this enhancement consistent with ISG-04. An appropriate means of

recording, evaluating, reviewing, and trending the results of visual inspections is consistent with

the GALL Report and an appropriate means of recording, evaluating, reviewing, and trending

the results of volumetric testing is consistent with the ISG-04. On this basis the staff found this

enhancement acceptable. These changes to the applicant's program will provide assurance

that aging effects will be adequately managed.

Furthermore, in the ALRA the applicant stated in Commitment 20 of ALRA Section A1.4 and

Commitment 18 of ALRA Section A2.4 that the enhancement in meeting the GALL Report "acceptance criteria" program element revises procedures to address the following element:

Define acceptance criteria for visual inspections and volumetric testing (NMP1

Commitment 20, NMP2 Commitment 18).

The staff reviewed this enhancement and found it acceptable. The new acceptance criteria will

provide in the inspection procedure parameters more specific than those listed in the GALL

Report, which states that no unacceptable signs of degradation should be observed during

visual assessment of internal system conditions under the program element "acceptance

criteria." The GALL Report does not include volumetric testing; hence, it does not have

acceptance criteria for volumetric testing. The staff found this enhancement acceptable. These

changes to the applicant's program will provide assurance that aging effects will be adequately

managed.

Operating Experience. In ALRA Section B2.1.17, the applicant explained that it has reviewed

both industry and plant-specific operating experience relating to the Fire Water System

Program. A review of the CAP shows that individual components have experienced various

types of non-conformances (e.g., pinhole leaks, pipe wall thinning). Evaluations have

demonstrated that no loss of system function would occur. CRs have been initiated to

document conditions discovered while performing Fire Water System Program activities.

Internal system leakage and failed surveillance tests were often traced to fouling of valve

seating surfaces with sand or silt. Typical resolutions included adding sections of piping to

specific flushing procedures or periodic disassembly and cleaning of components.

The staff reviewed the operating experience stated in the ALRA and interviewed the applicant's

technical staff to confirm that the plant-specific operating experience revealed no degradation

not bounded by industry experience.

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After review of industry and plant-specific operating experience and discussions with the

applicant's technical staff, the staff concludes that there is reasonable assurance that the

applicant's Fire Water System Program will manage adequately the aging effects identified in

the ALRA for which this AMP is credited.

UFSAR and USAR Supplements. In ALRA Sections AI. 1.18 and A2.1.18, the applicant

provided the respective UFSAR and USAR supplements for the Fire Water System Program.

The staff reviewed these sections and determined that the information in the supplements

provides adequate summary descriptions of the program, as required by 10 CFR 54.21(d).

Conclusion. On the basis of its review and audit of the applicant's Fire Water System Program,

the staff determined that those program elements for which the applicant claimed consistency

with the GALL Report are consistent with the GALL Report. Also, the staff has reviewed the

enhancements and confirmed that the implementation of the enhancements prior to the period

of extended operation would result in the existing AMP being consistent with the GALL Report

AMP to which it was compared.The staff concludes that there is reasonable assurance that the

applicant demonstrated that the effects of aging will be adequately managed so that the

intended functions will be maintained consistent with the CLB for the period of extended

operation, as required by 10 CFR 54.21(a)(3). The staff also reviewed the UFSAR supplement

for this AMP and concludes that it provides an adequate summary description of the program,

as required by 10 CFR 54.21(d).

3.0.3.2.15 Fuel Oil Chemistry Program

Summary of Technical Information in the Amended Application. In ALRA Section B2.1.18, the

applicant described the Fuel Oil Chemistry Program, stating that this is an existing program that

is consistent, with exceptions and enhancements, with GALL AMP XI.M30, "Fuel Oil

Chemistry." The Fuel'Oil Chemistry Program manages loss of material due to corrosion that

may result from introduction of contaminants into the plant's fuel oil tanks. Program activities

include: (1) sampling and chemical analysis of the fuel oil inventory at the plant; (2) sampling,

testing, and analysis of new fuel oil as it is unloaded at the plant; and (3) cleaning and

inspection of fuel oil tanks. The Fuel Oil Chemistry Program is based on maintaining fuel oil

quality in accordance with the guidelines of American Society for Testing and Materials (ASTM)

Standards D975, D1796, D2276, and D4057.

Staff Evaluation. During its audit and review, the staff confirmed the applicant's claim of

consistency with the GALL Report. Details of the staff's audit evaluation of this AMP are

documented in the Audit and Review Report. The staff reviewed the exceptions and

enhancements and the associated justifications to determine whether the AMP, with the

exceptions and enhancements, remains adequate to manage the aging effects for which it is

credited.

The staff reviewed those portions of the Fuel Oil Chemistry Program for which the applicant

claimed consistency with GALL AMP XI.M30 and found them consistent. The staff found the

applicant's Fuel Oil Chemistry Program acceptable because it conforms to the recommended

GALL AMP XI.M30, "Fuel Oil Chemistry," with exceptions and enhancements.

In the ALRA, the applicant stated that its Fuel Oil Chemistry Program is consistent with GALL

AMP XI.M30 with exceptions. The Fuel Oil Chemistry Program takes exceptions to the GALL

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Report "parameters monitored/inspected" and "acceptance criteria" program elements. NMP1

and NMP2 take exception to using both ASTM D1796 and ASTM D2709, "Standard Test

Method for Water and Sediment in Middle Distillate Fuels by Centrifuge," to determine the

concentration of water and sediment in the diesel fuel oil tanks. NMP1 and NMP2 use only the

guidance given in ASTM D1796. These standards apply to fuel oils of different viscosities. The

ASTM D1796 standard applies to the diesel fuel used at NMP1 and NMP2. NMP1 and NMP2

take exception to using the modified ASTM D2276 Method A, which specifies a pore size of 3.0

pm. NMP1 and NMP2 use a filter with a pore size of 0.8 pm as specified in ASTM D2276.

On the first exception the staff found that the applicant is using the standard recommended by

the GALL Report and one that the applicant states is appropriate for the viscosity of the fuel oil

in use at the site. As documented in the Audit and Review Report, the staff found the use of

ASTM D1796 acceptable because it is the appropriate testing procedure for the fuel oil in use at

NMP1 and NMP2. The staff determined the applicant's use of a filter pore size of 0.8 microns

instead of the 3.0 micron pore size recommended by the modified ASTM D2276 Method A to be

prudent for monitoring the presence of particulates in the fuel oil. The staff found this exception

in selection of the pore filter size acceptable.

The applicant also stated, by letter dated December 1, 2005, that it will add an exception to the

"preventive actions" program element of the GALL Report. NMP1 and NMP2 take exception to

the addition of fuel oil additives (biocides, stabilizers, and corrosion inhibitors) in the fuel oil

storage tanks. NMP2 monitors fuel quality, in part, through particulate contamination analysis.

The applicant stated that if the results from the particulate analysis exceed acceptance criteria,

then biocides, stabilizers, and/or corrosion inhibitors will be evaluated for addition. The

particulate analysis acceptance criteria combined with the current program, periodic cleaning of

the tanks and removal of water is used to mange the aging effects of concern. NMP1 plans to

initiate the same evaluation, pending the incorporation of an identified enhancement. The staff

found this exception acceptable and adequate for the aging management of the fuel oil storage

tanks.

The applicant also stated in the ALRA that it takes exceptions to the GALL Report "detection of

aging effects" program element. NMP1 and NMP2 take exception to multilevel sampling in the

diesel fuel oil tanks. The physical configuration of the fuel oil tanks does not allow a

representative fuel oil sample to be taken at multiple levels.

As documented in the Audit and Review Report, the applicant clarified that the measurements

are taken at approximately six inches from the tank bottom. The tanks also are drained and

cleaned periodically to reduce the build-up of water or sediment. Because the sample is taken

from near the bottom where water and sediment would accumulate the staff found sampling at

this location a conservative representation of the whole tank contents. On this basis the staff

found this exception acceptable.

In its letter dated November 17, 2005, The applicant also stated that it will add an exception of

the "detection of aging effects" program element of the GALL Report. NMP1 and NMP2 take

exception to performing internal inspections of any fuel oil tank. The applicant stated that after

enhancement, all such tanks will be routinely drained; thereby removing any contaminants from

the tank that would provide an aging mechanism. The staff confirmed the enhancements for

both units and found the exception acceptable.

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The applicant further stated in the ALRA that it takes exception to the GALL Report "parameters

monitored/inspected," "detection of aging effects," and "monitoring and trending" program

elements. NMP1 and NMP2 take exception to periodic sampling of the diesel fuel oil day tanks.

These small tanks have no provision for sampling. Per technical specification surveillance

testing, the lower portion of the diesel fuel oil is drained quarterly in NMP1 and monthly in

NMP2. Such an exception has been accepted in NUREG-1796, "Dresden and Quad Cities

Safety Evaluation Report."

As documented in the Audit and Review Report, the applicant clarified that these are small

tanks, the diesel fire pump day tank approximately 275 gallons and the emergency diesel fuel

oil day tank approximately 400 gallons. In addition per technical specification surveillance

testing the lower portion of the diesel fuel oil in these tanks is drained back to the larger storage

tanks quarterly for NMP1 and monthly for NMP2. Any water in the fuel oil is detected during the

surveillance of the bulk storage tanks. Based on its review of this information the staff

concludes that as the oil in the diesel fuel oil day tanks is sampled periodically when drained

back to the larger storage tank, this exception is acceptable.

In the ALRA, the applicant stated that its Fuel Oil Chemistry Program is consistent with GALL

AMP XI.M30 with additional enhancements to meet the GALL Report "scope of program," "preventive actions," "parameters monitored/inspected," "detection of aging effects," and

"monitoring and trending" by revising procedures to address the following:

• Incorporate periodic tests for microbiological organisms at NMP1.

• Provide guidelines for the appropriate use of biocides, corrosion inhibitors, or fuel

stabilizers to maintain fuel oil quality (NMP1 Commitment 21, NMP2 Commitment 19).

" Add specifications to sample the NMP2 diesel fuel oil storage tanks for water and

sediment at least quarterly per the ASTM standard (NMP2 Commitment 19)

In its letter dated November 17, 2005, the applicant deleted the first enhancement, "incorporate

periodic tests for microbiological organisms at NMP1" because this test already is performed

and the enhancement is not needed.

The staff found these enhancements consistent with the GALL Report recommendations and

therefore acceptable. These changes to the applicant's program will provide assurance that

aging effects will be adequately managed.

In addition in the ALRA the applicant stated that an enhancement to meet the GALL Report "preventive actions" and "detection of aging effects" program elements revises applicable

existing procedures to address the following:

Add specifications to inspect the interior surfaces of the NMP1 emergency diesel fuel oil

tanks and diesel fire pump fuel oil day tank and the NMP2 fuel oil tanks periodically for

evidence of significant degradation, including a specific requirement that the tank

bottom thickness be determined (NMP1 Commitment 21, NMP2 Commitment 19)

In its letter dated November 17, 2005, the applicant deleted the "diesel fire pump fuel oil day

tank" from this enhancement. The staff found this enhancement consistent with the GALL

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Report and therefore acceptable. These changes to the applicant's program will provide

assurance that aging effects will be adequately managed.

In the ALRA, the applicant stated that an enhancement to meet the GALL Report "monitoring

and trending" program element revises procedures to address the following:

Add specifications for quarterly trending of particulate contamination analysis results

(NMP1 Commitment 21, NMP2 Commitment 19).

In its letter dated November 17, 2005, the applicant added the following to the "monitoring and

trending," "parameters monitored and inspected," "preventive actions," and "detection of aging

effects" program elements to the program elements affected:

" An enhancement for quarterly trending of water and sediment ("monitoring and trending"

and "parameters monitored and inspected," NMP1 Commitment 21 and NMP2

Commitment 19).

" An enhancement for periodic opening of the diesel fire pump fuel oil day tank drain

("preventive actions" and "detection of aging effects," NMP1 Commitment 21).

" An enhancement for removal of water if found ("preventive actions" and "detection of

aging effects," NMP1 Commitment 21 and NMP2 Commitment 19).

The staff found these enhancements consistent with the GALL Report and therefore

acceptable. These changes to the applicant's program will provide assurance that aging effects

will be adequately managed.

The enhancement for periodic opening of the diesel fire pump fuel oil day tank drain (NMP1)

supports the exception taken by the applicant from periodic sampling of the diesel fuel oil day

tanks. The staff found the remaining two new enhancements consistent with the GALL Report

and, therefore, acceptable. These changes to the applicant's program will provide assurance

that aging effects will be adequately managed.

In the ALRA, the applicant also stated that an enhancement to meet the GALL Report "acceptance criteria" program element revises procedures to address the following:

Ensure acceptance criteria are specified in the implementing procedures for indications

of potential degradation. (NMP1 Commitment 21, NMP2 Commitment 19)

In the ALRA program description for the Fuel Oil Chemistry Program the applicant stated that

this AMP is to maintain fuel oil quality according to ASTM Standards D975, D1796, D2276 and

D4057. This enhancement is to specify acceptance criteria in the implementing procedures.

The staff found this information consistent with the GALL Report and therefore acceptable On

this basis, the staff found this enhancement acceptable. These changes to the applicant's

program will provide assurance that aging effects will be adequately managed.

Operating Experience. In ALRA Section B2.1.18, the applicant explained it has reviewed both

industry and plant-specific operating experience relating to the Fuel Oil Chemistry Program.

Review of plant-specific operating experience revealed several incidents where contaminants

(e.g., water, particulate) were detected through Fuel Oil Chemistry Program examinations.

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Corrective actions included contamination removal and system/component cleaning. However,

there have been no instances of fuel oil system component failures at NMP attributed to

contamination.

From review of the applicant's operating experience, the staff found evidence that the fuel oil is.

sampled periodically and that when acceptance limits are exceeded appropriate corrective

actions have been taken. The staff found that the applicant's Fuel Oil Chemistry Program is

effective in managing the aging effects and aging effects mechanisms of loss of material from

the presence of contaminants.

The staff reviewed the operating experience stated in the ALRA and interviewed the applicant's

technical staff to confirm that the plant-specific operating experience revealed no degradation

not bounded by industry experience.

During the initial audit and review (August 9-13, 2004), the staff requested that the applicant

provide examples of the tank inspections to verify the effectiveness of the program and to

indicate any aging effects and aging effects mechanisms that were identified. The applicant

stated in response that the most recent emergency diesel generator (EDG) tank inspections

returned normal results. The applicant concluded that initial ultrasound tests of NMP2 fuel oil

tanks had found no undue degradation of the tank wall. Ultrasound tests of the NMP1 tank had

not yet been implemented. The staff reviewed these reports and other documentation and

concludes that no aging of the fuel tanks had been detected.

After review of industry and plant-specific operating experience and discussions with the

applicant's technical staff the staff concludes that there is reasonable assurance that the

applicant's Fuel Oil Chemistry Program will manage adequately the aging effects and aging

effects mechanisms identified in the ALRA for which this AMP is credited.

UFSAR and USAR Supplements..The applicant provided its UFSAR supplement for the Fuel Oil

Chemistry Program in ALRA, Appendix A, Section A1.1.20 for NMP1 stating that the Fuel Oil

Chemistry Program manages loss of material from corrosion that may result from introduction

of contaminants into the plant's fuel oil tanks. Program activities include (1) sampling and

chemical analysis of the fuel oil inventory at the plant, (2) sampling, testing, and analysis of new

fuel oil unloaded at the plant, and (3) cleaning and inspection of fuel oil tanks. The staff

reviewed the ALRA and information provided in supplemental letters and determined that the

information provides adequate summary descriptions of the program as required by

10 CFR 54.21(d).

Conclusion. On the basis of its review and audit of the applicant's Fuel Oil Chemistry Program,

the staff determined that those program elements for which the applicant claimed consistency

with the GALL Report are consistent with the GALL Report. In addition, the staff reviewed the

exceptions and the associated justifications, and determined that the AMP, with the exceptions,

is adequate to manage the aging effects for which it is credited. Also, the staff has reviewed the

enhancements and confirmed that the implementation of the enhancements prior to the period

of extended operation would result in the existing AMP being consistent with the GALL Report

AMP to which it was compared.The staff concludes that there is reasonable assurance that the

applicant demonstrated that the effects of aging will be adequately managed so that the

intended functions will be maintained consistent with the CLB for the period of extended

operation, as required by 10 CFR 54.21(a)(3). The staff also reviewed the UFSAR supplement

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for this AMP and concludes that the supplement provides an adequate summary description of

the program, as required by 10 CFR 54.21(d).

3.0.3.2.16 Reactor Vessel Surveillance Program

Summary of Technical Information in the Amended Application. In ALRA Section B2.1.19, the

applicant described the Reactor Vessel Surveillance Program (RVSP), stating that this is an

existing program that is consistent, with enhancements, with GALL AMP XI.M31, "Reactor

Vessel Surveillance." The applicant indicated that enhancements to the RVSP encompass

revisions to existing activities that are credited for license renewal to ensure the applicable

aging effects are discovered and evaluated. The enhancements will be completed prior to the

period of extended operation. The RVSP manages loss of fracture toughness due to neutron

irradiation embrittlement in the reactor pressure vessel (RPV) beltline material. Program

activities include: (1) periodic withdrawal and testing of surveillance capsules from each RPV;

(2) use of test results and allowable stress loadings for the ferritic RPV materials to determine

operating limits; and (3) comparison with a large industry data set to confirm validity of test

results. Analysis and testing are based on the requirements of 10 CFR 50, Appendix H, and

ASTM Standard E-185.

Staff Evaluation. During its audit and review, the staff confirmed the applicant's claim of

consistency with the GALL Report. Details of the staffs audit evaluation of this AMP are

documented in the Audit and Review Report. The staff reviewed the enhancements to

determine whether the AMP, with enhancements, remains adequate to manage the aging

effects for which it is credited.

In ALRA Section B.2.1.19 the applicant described how this AMP will manage irradiation

embrittlement of the RV through testing that monitors RV beltline materials. The ALRA states

that the RVSP will be enhanced by making it consistent with the BWRVIP integrated

surveillance program (ISP) for periods of extended operation (currently reviewed by the staff as

BWRVIP-1 16) before NMPNS units enter their period of extended operation. The ALRA further

states that the enhanced program will be consistent with GALL AMP XI.M31 described in the

GALL Report. For this AMP the GALL Report recommends further evaluation. The staff also

reviewed the UFSAR supplement to determine whether it provides an adequate description of

the program.

The applicant has implemented the BWRVIP ISP (as documented in the BWRVIP-86-A Report,

"BWR Vessel and Internals Project, Updated BWR Integrated Surveillance Program (ISP)

Implementation Plan") for the period of the current NMPNS operating licenses. The staff

concludes that the BWRVIP ISP in the BWRVIP-86-A Report is acceptable for BWR licensee

implementation provided that all participating licensees use one or more compatible neutron

fluence methodologies acceptable to the staff for determining surveillance capsule and RV

neutron fluences. The staff acceptance of the BWRVIP ISP for the current term is documented

in the staff SE dated February 1, 2002, from Bill Bateman of the NRC to Carl Terry, BWRVIP

Chairman. The BWRVIP-1 16 report provides guidelines for an ISP to monitor neutron

irradiation embrittlement of the RV beltline materials for all United States (US) BWR power

plants for their original 40-year operating terms and their license renewal periods.

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The staff's review of the original LRA Section B2.1.19 identified an area in which additional

information was necessary to complete the review of the applicant's program elements. The

applicant responded to the staff's RAI as discussed below.

In RAI B.2.1.19-1 by letter dated January 13, 2005, the staff requested that the applicant make

a commitment to implement the BWRVIP-1 16 ISP currently under review by the staff or to

submit a plant-specific surveillance program for each NMPNS unit two years before it enters the

extended period of operation.

In its response by letter dated February 14, 2005, the applicant indicated that it will implement

either BWRVIP-1 16 as approved by the staff or if the ISP is not approved two years prior to the

NMPNS units' period of extended operation a plant-specific surveillance program will be

submitted to the NRC. In this response the applicant also stated that it will revise the original

LRA Sections AI. 1.32, A2.1.32, and B2.1.19 as shown in the staff's evaluation of the USAR

supplement. The staff noted that the applicant had made a formal commitment to incorporate

either BWRVIP-1 16 as approved by the staff or a plant-specific surveillance program for each

of the NMPNS units to satisfy the requirements of 10 CFR Part 50, Appendix H (NMPI

Commitment 22 and NMP2 Commitment 20).

The applicant stated that the future withdrawal and testing of the NMP1 and NMP2 surveillance

capsules will be deferred permanently because NMP1 and NMP2 are not host reactors within

the BWRVIP-116 ISP. The applicant further stated that through participation in the BWRVIP

ISP the RVSP will be adjusted to account for industry experience and research and that as

additional operating experience is obtained lessons learned will be used to adjust this program

as needed. Therefore, the staff will require the following license condition:

Implementation of the most recent staff-approved version of the Boiling Water

Reactor Vessels and Internals Project (BWRVIP) Integrated Surveillance

Program (ISP) as the method to demonstrate compliance with the requirements

of 10 CFR Part 50, Appendix H. Any changes to the BWRVIP ISP capsule

withdrawal schedule must be submitted for NRC staff review and approval. Any

changes to the BWRVIP ISP capsule withdrawal schedule which affects the time

of withdrawal of any surveillance capsules must be incorporated into the

licensing basis. If any surveillance capsules are removed without the intent to

test them, these capsules must be stored in manner which maintains them in a

condition which would support re-insertion into the reactor pressure vessel, if

necessary.

The staff found the applicant has demonstrated that the effects of aging from loss of fracture

toughness of the RV beltline materials will be adequately managed with the enhancements so

that the intended functions will be maintained consistently with the CLB for the period of

extended operation as required by 10 CFR 54.21(a)(3).

Operatinq Experience. In ALRA Section B2.1.19, the applicant indicated that NMPNS has

successfully implemented a plant-specific RVSP that is consistent with Regulatory Guide 1.99,

Revision 2, 10 CFR 50, Appendix H, and ASTM Standard E-185. Three surveillance capsules

that were originally installed in the NMPI RV have been removed and tested with satisfactory

results. One of the three surveillance capsules that were originally installed in the NMP2 RV has

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been removed and tested. Data from LaSalle, Units 1 and 2 and Columbia Generating Station

have been used to supplement the NMP2 surveillance data.

The applicant stated that under the ISP, neither NMP1 or NMP2 is identified as a host plant; the

representative materials for the limiting RV plate and weld materials, and their associated

withdrawal schedules are identified in the BWRVIP-116 report. Thus, future withdrawal and

testing of the NMP1 and NMP2 surveillance capsules will be permanently deferred.

The applicant also stated that through participation in the BWRVIP ISP, the RVSP will be

adjusted to account for industry experience and research. The applicant stated that with

additional operating experience lessons learned will be used to adjust this program as needed.

The applicant maintains that the RVSP has been effective in managing loss of fracture

toughness in RV beltline materials.

UFSAR and USAR Supplements. In RAI B2.1.19-1 the staff further requested that the applicant

state, in the UFSAR and USAR its commitment regarding the implementation of BWRVIP-1 16

and in its response to RAI B.2.1.19-1 by letter dated February 14, 2005, the applicant stated

that it will revise the ALRA Sections A1.1.32 and A2.1.32, to include the following:

The reactor vessel surveillance program is an existing program that manages

loss of fracture toughness due to neutron irradiation embrittlement in the reactor

pressure vessel beltline material. Program activities include (1) periodic

withdrawal and testing of surveillance capsules from the RPV; (2) use of test

results and allowable stress loadings from the ferritic RPV materials to determine

operating limits; and (3) comparison with a large industry data set to confirm

validity of test results. Analysis and testing are based on the requirements of

10 CFR 50, Appendix H, and ASTM Standard E-185. NMPNS commits to

implement the Integrated Surveillance Program (ISP) described in BWRVIP-1 16

(if approved by the NRC staff). When the NRC issues a final safety evaluation

for BWRVIP-1 16, NMPNS will address any open items and complete the SER

Action Items. Should BWRVIP-116 not be approved by the NRC, a plant specific

reactor vessel surveillance program will be submitted to the NRC two years prior

to commencement of the period of extended operation.

Enhancements to the RVSP include the following revisions to existing activities credited for

license renewal:

Incorporate the requirements and elements of the ISP, as documented in

BWRVIP-1 16 and approved by NRC, or an NRC-approved plant-specific

program, into the reactor vessel surveillance program, and include a requirement

that if NMPNS surveillance capsules are tested, the tested specimens will be

stored in lieu of optional disposal. When the NRC issues a final safety evaluation

report for BWRVIP-1 16, NMPNS will address any open items and complete the

SER Action items. Should BWRVIP-1 16 not be approved by the NRC, a plant

specific reactor vessel surveillance program will be submitted to the NRC two

years prior to commencement of the period of extended operation.

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Project analyses of upper shelf energy and pressure-temperature limits to 60 years

using methods prescribed by Regulatory Guide 1.99, Revision 2, and include the

applicable bounds of the data, such as operating and neutron fluence.

Enhancements will be completed prior to the period of extended operation.

This information has been incorporated into the ALRA. The staff reviewed the applicant's

proposed revision to ALRA Sections A1.1.32 and A2.1.32 of the UFSAR and USAR

supplements and determined that the applicant has committed to implement an approved

plant-specific RPV surveillance program or the most recent staff-approved version of the

BWRVIP ISP to comply with the requirements of 10 CFR Part 50, Appendix H. Therefore, the

staffs concern described in RAI B.2.1.19-1 is resolved.

The staff reviewed the ALRA and information provided in supplemental letters and determined

that the information provides adequate summary descriptions of the program as required by

10 CFR 54.21(d).

Conclusion. On the basis of its review and audit of the applicant's RVSP and RAI response, the

staff determined that those program elements for which the applicant claimed consistency with

the GALL Report are consistent with the GALL Report. Also, the staff has reviewed the

enhancements and confirmed that the implementation of the enhancements prior to the period

of extended operation would result in the existing AMP being consistent with the GALL Report

AMP to which it was compared.The staff concludes that there is reasonable assurance that the

applicant demonstrated that the effects of aging will be adequately managed so that the

intended functions will be maintained consistent with the CLB for the period of extended

operation, as required by 10 CFR 54.21(a)(3). The staff also reviewed the UFSAR and USAR

supplements for this AMP and concludes that it provides an adequate summary description of

the program, as required by 10 CFR 54.21(d).

3.0.3.2.17 ASME Section Xl Inservice Inspection (Subsection IWE) Program

Summary of Technical Information in the Amended Application. In ALRA Section B2.1.23, the

applicant described the ASME Section XI Inservice Inspection (Subsection IWE) Program,

stating that this is an existing program that is consistent, with an exception and an

enhancement, with GALL AMP XI.S1, "ASME Section Xl, Subsection IWE." The ASME

Section Xl Inservice Inspection (Subsection IWE) Program (referred to herein as the IWE ISI

Program) manages aging effects due to: (1) corrosion of carbon steel components comprising

the NMP1 and NMP2 containment pressure boundaries and (2) degradation of NMP1 and

NMP2 containment pressure-retaining polymers. Program activities include visual examination,

with limited surface or volumetric examinations when augmented examination is required. The

IWE ISI Program is based on the 1998 edition of the ASME Boiler and Pressure Vessel Code,

Section Xl (Subsection IWE) for containment inservice inspection (ISI) with plant-specific

exceptions approved by the staff.

Staff Evaluation. During its audit and review, the staff confirmed the applicant's claim of

consistency with the GALL Report. Details of the staffs audit evaluation of this AMP are

documented in the Audit and Review Report. The staff reviewed the enhancement and the

associated justifications to determine whether the AMP, with the exceptions and enhancement,

remains adequate to manage the aging effects for which it is credited.

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As documented in the Audit and Review Report, the staff asked the applicant to explain why

there is an identified enhancement in the ASME Section Xl ISl (SubSection IWE) Program with

no affected program elements listed. The applicant stated that the reason no elements are

identified is that the enhancement shown is not required to ensure consistency with the GALL

Report but adopted as a function of the applicant's response to a staff request early in the

application review period. To avoid confusion with the specialized definition of "enhancement"

consistent with the GALL Report changes will be incorporated into the ALRA.

In its supplemental letter dated December 1, 2005, the applicant stated that the first sentence in

the second paragraph in ALRA Sections A1.1.2 and A2.1.2 changes the word "enhanced" to

"improved" with the following sentence added at the end of this paragraph: "This improvement

is not required for consistency with the GALL but is an activity NMP is adopting to ensure

consistency with industry practice." The same change is made to ALRA Section. In the ASME

Section Xl ISI (Subsection IWE) Program under the enhancement paragraph a new first

paragraph of "None" is added. The following sentence is added to the beginning of the second

paragraph: "The following improvement is not required for consistency with the GALL Report

but is an activity NMP is adopting to ensure consistency with industry practice." The last

sentence of this paragraph is replaced with the following sentence: "This improvement will be

implemented prior to entry into the period of extended operation." Also the phrase "and requires

enhancements to be consistent with others" is deleted from the GALL Report consistency

Section of the ASME Section Xl ISI (Subsection IWE) Program.

The staff found the applicant's response acceptable. With the clarification statements made by

the applicant no enhancement is required to make the applicant's ASME Section Xl ISI

(Subsection IWE) Program consistent with the GALL Report.

The staff reviewed those portions of the ASME Section XI ISI (Subsection IWE) Program for

which the applicant claimed consistency with GALL AMP XI.S1 and found them consistent with

this GALL Report AMP. The staff found the applicant's ASME Section Xl ISI (Subsection IWE)

Program acceptable because it conforms to the recommended GALL AMP XI.S1 with an

exception.

In the ALRA, the applicant stated that its ASME Section XI ISI (Subsection IWE) Program is

consistent with GALL AMP XI.S1 with exceptions. The ASME Section Xl ISI (Subsection IWE)

Program takes exceptions to the GALL Report "parameters monitored/inspected," "detection of

aging effects," "monitoring and trending," and "acceptance criteria" program elements. The

GALL Report program elements identify both the ASME 1992 Edition with the 1992 Addenda

and the 1995 Edition with the 1996 Addenda as applicable to the NMP1 and NMP2 Application

for Renewed Operating License Appendix B - Aging Management Program ASME

SectionXl-IWE as approved in 10 CFR 50.55a. The NMP IWE ISI Program complies with the

ASME Section Xl 1998 Edition with no Addenda.

In the ALRA, the applicant further stated that the GALL Report program description for this

AMP identifies both the 1992 Edition with the 1992 Addenda and the 1995 Edition with the 1996

Addenda as the applicable editions for the NMP1 and NMP2 ASME Section X1 ISI (Subsection

IWE) Program as approved in 10 CFR 50.55a. The applicant's IWE ISI Program complies with

ASME Section Xl 1998 Edition with no Addenda. Although differences exist between code

editions the applicant's IWE ISI Program complies with an edition of Section XI approved by the

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staff 'for use at NMP. Implementation of guidance from this later code edition meets the

recommendations of the GALL Report.

As documented in the Audit and Review Report, the staff noted that the staff previously found

this exception acceptable because the NMP code of record is an ASME Code version later than

that cited by the GALL Report. The use of the 1998 Edition of the ASME Code was found

acceptable in a letter from the US Nuclear Regulatory Commission to Niagara Mohawk Power

Corporation dated August 17, 2000, with the subject "Nine Mile Point Nuclear Station Unit Nos.

1 and 2 - Relief From the Requirements of 10 CFR 50.55a Related to Containment Inspection

(TAC Nos. MA7116, MA7117, and MA711 8)." The staff also noted that under the applicant's

ASME Code of record for ASME Section X1 ISI (Subsection IWE) a 10-year inspection interval

is valid under the CLB. At present an ASME Section Xl ISI (Subsection IWE) Program is

approved for use on an ASME Code 10-year ISI interval specific basis. However, the applicant

will have to request approval to use the ASME Section XI ISI (Subsection IWE) Program for the

specific intervals during the period of extended operation under 10 CFR 50.55a 12 months prior

to each interval. Therefore, the staff determined that the ASME Section XI Code Edition as

referenced in 10 CFR 50.55a, for which the applicant will request approval 12 months prior to

each inspection interval, is acceptable for the period of extended operation and found this

exception acceptable.

Operatina Experience. In ALRA Section B2.1.23, the applicant explained that it has reviewed

both industry and plant-specific operating experience relating to the iWE ISI Program. Review

of plant-specific operating experience revealed few discrepancies and no age-related

equipment failures. Deficiencies discovered by recent IWE ISI Program examinations included

damage to the NMP1 torus equipment hatch, damage to the NMP1 drywell dome manway

hatch sealing surface, minor corrosion on the NMP1 drywell dome sealing surface, and minor

corrosion on the NMP2 drywell liner. These indications were corrected for NMP1 and NMP2.

As documented in the Audit and Review Report, the staff also reviewed the summary of specific

operating experience for the applicant's ASME Section Xl ISI (Subsection IWE) Program. The

review indicated that the program is effective in identifying age-related degradation,

implementing repairs, and maintaining the integrity of the containment pressure boundaries and

NMP1 and NMP2 containment pressure-retaining polymers.

During the initial audit and review (August 9-13, 2004) NMP1 plant maintenance records

revealed that there have been only a few CRs written and no age-related component failures

following IWE inspections since the inception of the program with deficiencies limited to

damage to the torus equipment hatch, damage to the drywell dome manway hatch sealing

surface, corrosion of the drywell liner, and minor damage or corrosion on the drywell dome

sealing surface. None of these deficiencies resulted in loss of intended function from

age-related degradation. These records provide assurance that containment pressure boundary

degradation has not occurred since the inception of the program. Subsequent to the onsite

audit and review of NMP ALRA, the staff also reviewed the applicant's Inservice Inspection

Owner Activity Report, dated July 23, 2003. In this report, the applicant has stated that, for

NMP1, corrosion was identified over the entire 360 degree circumference of the drywell interior

surface of the liner plate at the 225 foot elevation. The applicant further stated in the report that

(1) a subsequent detailed (D-VT) visual examination (VT-1) was performed and that (2) no

unacceptable degradation in the visible areas of the drywell liner was found and that (3) no

immediate corrective action was taken. The staff has asked the applicant to provide further

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discussion to address the staff concern regarding the loss of material due to corrosion of the

NMP1 drywell. This was designated as Open Item (01) 3.0.3.2.17-1.

On March 27, 2006, the applicant met with the staff to discuss the issue identified in

01 3.0.3.2.17-1, and by letter dated April 4, 2006, the applicant provided its response to

01 3.0.3.2.17-1. In its attachment to the letter, the applicant supplemented the following

background information related to corrosion of NMP1 drywell.

During the 2003 NMP1 refueling outage, a general visual examination of 100 percent of the

accessible portions of the interior surface of the drywell shell was performed. Six localized

areas, coinciding with the area coolers, were observed to have significant corrosion. In

accordance with ASME Section Xl Subsection IWE, a detailed visual examination (VT-1) was

performed of the six localized areas and characterized the corrosion as 'major' (i.e., greater

than 5 percent of the base metal was judged to be lost). A condition report was generated in

accordance with the corrective action program and a rigorous engineering evaluation was

performed.

To ascertain the actual thickness of the drywell shell at these locations, the four most severe

locations were chosen by the IWE responsible engineer to have volumetric (UT) examinations

performed. Four individual UT measurements were taken by cleaning the corrosion from the

base metal, conducting a continuous scan, and recording the lowest value. The results of the

UT examinations ranged from 1.106" to 1.131". The IWE Responsible Engineer compared

these results against the minimum design value of 1.049" and concluded that the drywell shell

was acceptable for continued service.

Subsequent to the evaluations performed during the 2003 refueling outage, an engineering

calculation was performed that projected the time necessary to reach minimum design

thickness for the drywell shell. Using the volumetric results (min. 1.106") and minimum design

value (1.049"), the available margin was determined to be 57 mils. Using the originally assumed

corrosion allowance (62.5 mils over 40 years), it was calculated that it would take 36 years from

2003 to reach the minimum design thickness. This projects out to be the year 2039, which is

10 years beyond the end of the period of extended operation (2029).

Another method, using a newer approved corrosion rate, was also used to project the year that

minimum wall thickness would be reached for the drywell shell. NMP uses a corrosion rate of

1.26 mils/yr in the Torus Corrosion Monitoring Program to evaluate volumetric examination

results. This value is documented in a 1994 NRC safety evaluation report. The use of this

corrosion rate is appropriate since the material of the drywell shell is essentially the same as

the material for the torus shell for the purposes of corrosion resistance. The drywell shell is

made of ASTM-212, Gr. B carbon steel whereas the torus shell is made of ASTM-201, Gr. B.

The environment in the torus is also the same as, or more severe than, the drywell

environment. The torus is approximately half full of demineralized water and the remainder is a

nitrogen inerted atmosphere. The drywell is entirely a nitrogen inerted atmosphere. Therefore,

since the materials are essentially the same and the environments are also, it is appropriate to

use an approved corrosion rate for the torus for the drywell shell. Performing the calculation,

57 mils of margin divided by 1.26 mils/yr. corrosion rate, yields 45 years until the minimum

design thickness of the drywell shell is reached (19 years beyond the end of the period of

extended operation).

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Based on the above, the applicant concluded that the NMP1 drywell shell could perform its

intended function following the 2003 refueling outage and beyond the period of extended

operation. However, the applicant had also concluded that continued monitoring, in addition to

the ASME Section Xl Subsection IWE Program, of the drywell shell was necessary. The

applicant formalized the continuing monitoring program as "Drywell Supplemental Inspection

Program." The following is the staff evaluation of the AMP program elements.

(1) Scope of Program - The scope of the NMP1 Drywell Supplemental Inspection Program

includes the areas characterized as having major corrosion (rust) on the NMP1 drywell

shell in the NMP Owner Activity Report dated July 23, 2003. These six areas are

localized and located near and underneath the drywell area coolers on the 225'

elevation. This program provides aging management activities to the six localized areas

in addition to the activities required by the ASME Section Xl Inservice Inspection

(Subsection IWE) Program.

Based on the information provided in the applicant's background information, the staff

found the scope of the program, as described herein, acceptable.

(2) Preventive Actions - There are no predetermined preventive actions associated with this

program. However, NMP engineering may require preventive actions in the future as

part of the evaluation of examination results.

If the future examinations dictate that preventive actions (e.g., appropriate coating), are

needed, the applicant will consider such actions. The staff agrees with the applicant's

assessment of this element.

(3) Parameters Monitored or Inspected - The six localized areas of the carbon steel drywell

shell are examined for evidence of loss of material due to corrosion.

In response to the staffs query about the examination of the shell at the junction of the

concrete floor and the drywell shell, which has been found as a site for corrosion at

other plants, the applicant asserted that the examination of this joint is part of the IWE

Inspection Program (i.e. AMP B.2.1.33). The staff found the applicant's response and

the program element as described in this supplementary AMP acceptable, as this

program is only applicable to the corrosion degradation found during its 2003 inspection.

(4) Detection of Aging Effects - Loss of material will be detected by performing a volumetric

(ultrasonic thickness measurement) examination. This exam will be conducted during

the*2007 refueling outage. Future performances will be based on the results obtained,

as described under the Corrective Actions attribute.

The staff found the actions to be taken by the applicant, as shown in the table,

commensurate with the as found corrosion rate, appropriate and acceptable.

(5) Monitoring and Trending - The condition of the localized area wall thickness of the

drywell shell is monitored by virtue of the volumetric exam. Trending of the wall

thickness results will be performed to determine a rate of material loss and to project the

application of that rate to the drywell shell thickness value until the end of the period of

extended operation.

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The staff found the applicant's program regarding monitoring and trending of the as

found corrosion appropriate and acceptable.

(6) Acceptance Criteria - The acceptance criteria will be based upon the calculated

corrosion rate and the projected wall thickness at the end of the period of extended

operation. The corrosion rate criteria are based on maintaining a wall thickness of

greater than the minimum design value. The following table correlates corrosion rates,

projected wall thickness at the end of the period of extended operation, and actions that

will be taken above those actions required by the ASME Section XI Subsection IWE

requirements. The values in the tables, except the corrosion rates, are calculated using

the lowest wall thickness reading (1.106") obtained during the 2003 refueling outage.

For wall thicknesses greater than 1.106" in 2003, these values are conservative.

"Corrosion:Rate Wall Thickness @ Margin to Design 'Years to Reach -Actions Beyond

,-::(mils/year) End of PEO (mils) -Minimum Design IWE

(inches) Thickness ' Requirements.

< 0.30 > 1.098 > 49 > 190 None

0.30-0.61 1.090- 1.098 41 -49 93- 190 Confirming UT

every 10 years

0.62- 1.25 1.074- 1.090 25-41 45-93 Confirming UT

every 6 years

1.26-2.2 1.049 - 1.074 0-25 26-45 Confirming UT

every 4 years and

implement a

,mitigative

strategy

> 2.2 < 1.049 0 <2 6 Confirming UT

every 2 years and

implement a

mitigative

I _strategy

Based on the history of corrosion found in NMP1 torus in the late 1980s, the applicant

had elicited a corrosion rate of 1.26 mils/year. In the drywell, at the time of detecting

corrosion, i.e., in 2003, the applicant could not predict corrosion rates. The table above

envelopes corrosion rates lesser than the torus corrosion rate, and the last row depicts

the potential worst case. Therefore, the staff found actions required under various

corrosion rates appropriate and acceptable.

(7) Corrective Actions - Actions to be implemented beyond those required by the ASME

Section XI Subsection IWE Program are delineated in the table above. A mitigative

strategy could include application of a protective coating, repair or replacement of

affected sections, or other actions deemed appropriate by the NMP IWE responsible

engineer. The Corrective Action Program meets the requirements of 10 CFR Part 50,

Appendix B.

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As indicated in the staff evaluation of element "Acceptance Criteria," the mitigative

strategy, and possible remedial actions proposed in this element are appropriate and

acceptable.

(8) Confirmation Process - When acceptance criteria are not met, corrective actions are

determined in accordance with the Corrective Action Program. Confirmation that the

corrective actions have been completed and are effective will be documented in

accordance with the requirements of 10 CFR Part 50, Appendix B.

The element meets the requirement of 10 CFR Part 50, Appendix B.

(9) Administrative Controls - The above stated actions to manage the corrosion of six

localized areas on the NMP1 drywell shell will be controlled and documented in the NMP

ASME Section Xl Subsection IWE Program Plan.

The method of keeping control of the activities performed under this AMP is appropriate

and acceptable.

(10) Operating Experience - NMPNS has an existing effective program that continuously

reviews internal and external operating experience to determine its applicability and

adjusts inspection plans accordingly. The operating experience program will continue to

be used to improve the NMP1 Drywell Supplemental Inspection Program.

The applicant's commitment to keep track of the external operating experience, and

modifying the AMP, as necessary, is appropriate and acceptable.

Based on the review of the applicant's supplemental aging management program and the

applicant's IWE Inspection Program (i.e., AMP B.2.1.33) for monitoring the NMP1 drywell

corrosion, the staff concludes that there is reasonable assurance that is there is reasonable

assurance that the NMP1 containment drywell integrity will be maintained during the period of

extended operation. Therefore, Open 01 3.0.3.2.17-1 is now considered closed.

In addition during the initial audit and review NMP2 plant maintenance records revealed that

there has been only one CR written and no age-related component failures following IWE

inspections since the inception of the program. In 2000 minor corrosion was discovered and

removed from the drywell liner with no loss of integrity. These records provided assurance that

containment pressure boundary degradation had not occurred since the inception of the

program.

The staff reviewed the operating experience stated in the ALRA and interviewed the applicant's

technical personnel to confirm that the plant-specific operating experience revealed no

degradation not bounded by industry experience.

After review of industry and plant-specific operating experience and discussions with the

applicant's technical personnel the staff concludes that there is reasonable assurance that the

applicant's ASME Section XI ISI (Subsection IWE) Program will manage adequately the aging

effects and aging effects mechanisms identified in the ALRA for which this AMP is credited.

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UFSAR and USAR Supplements. The applicant provided its UFSAR supplement for the ASME

Section Xl Inservice Inspection (Subsection IWE) Program in ALRA Appendix A, Section A1.1.2

for NMP1 stating that the ASME Section XI Inservice Inspection (Subsection IWE) Program

(referred to herein as the IWE Inservice Inspection Program) manages aging effects and aging

effects mechanisms due to (1) corrosion of carbon steel components comprising the

containment pressure boundary and (2) degradation of containment pressure-retaining

polymers. Program activities include visual examinations with limited surface or volumetric

examinations when augmented examination is required. The IWE Inservice Inspection Program

is based on the 1998 Edition of the ASME Boiler and Pressure Vessel Code Section XI

(Subsection IWE) for containment inservice inspection with plant-specific exceptions to the

evaluation in the GALL Report (which covers ASME Section Xl requirements from both the

1992 Edition with the 1992 Addenda and the 1995 Edition with the 1996 Addenda) approved by

the staff. The NMP1 ASME Section Xl Inservice Inspection (Subsection IWE) Program will be

enhanced to add an augmented VT-1 visual examination of the NMP1 containment penetration

bellows. This inspection will be performed using enhanced techniques qualified for detecting

SCC per NUREG-1611, "Aging Management of Nuclear Power Plant Containments for License

Renewal," Table 2, Item 12.

In addition the applicant provided its USAR supplement for the ASME Section Xl ISI

(Subsection IWE) Program in ALRA Appendix A Section A2.1.2 for NMP2 stating that the

program manages aging effects and aging effects mechanisms from (1) corrosion of carbon

steel components comprising the containment pressure boundary and (2) degradation of

containment pressure-retaining polymers. Program activities include visual examinations with

limited surface or volumetric examinations when augmented examination is required. The IWE

ISI Program is based on the 1998 Edition of the ASME Boiler and Pressure Vessel Code,

Section Xl (Subsection IWE) for containment ISI with plant-specific exceptions to the evaluation

in the GALL Report (which covers ASME Section Xl requirements from both the 1992 Edition

with the 1992 Addenda and the 1995 Edition with the 1996 Addenda) approved by the staff.

The NMP2 ASME Section Xl ISI (Subsection IWE) Program will be enhanced to add an

augmented VT-1 visual examination of the NMP2 containment penetration bellows. This

inspection will be performed using enhanced techniques qualified for detecting SCC per

NUREG-1611, Table 2, Item 12.

As documented in the Audit and Review Report, the staff asked the applicant to explain why

there is an enhancement in ALRA Section B2.1.23 for its ASME Section XI ISI (Subsection

IWE) Program with no affected program elements listed. The applicant stated that there are no

elements identified because the enhancement shown is not required to ensure consistency with

the GALL Report has been adopted in response to a staff request early in the application review

period. To avoid confusion with the specialized definition of "enhancement" consistent with the

GALL Report changes will be incorporated into the ALRA.

In its letter dated December 1, 2005, the applicant stated that the first sentence in the second

paragraph in ALRA Section A1.1.2 changes the word "enhanced" to "improved" with the

following sentence added at the end of this paragraph: "This improvement is not required for

consistency with the GALL but is an activity NMP is adopting to ensure consistency with

industry practice." The same change is made to ALRA Section A2.1.2.

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The staff found the applicant's response acceptable. With the clarification made by the

applicant there is no enhancement required to make the applicant's ASME Section Xl ISI

(Subsection IWE) Program consistent with the GALL Report.

The staff reviewed these sections and information In the ALRA and determined that the

information in the supplements provide adequate summary descriptions of the program as

required by 10 CFR 54.21(d).

Conclusion. On the basis of its review and audit of the applicant's ASME Section Xl Inservice

Inspection (Subsection IWE) Program, the staff determined that those program elements for

which the applicant claimed consistency with the GALL Report are consistent with the GALL

Report. In addition the staff reviewed the exceptions and the associated justifications, and

determined that the AMP, with the exceptions, is adequate to manage the aging effects for

which it is credited. Also, the staff has reviewed the enhancement and confirmed that the

implementation of the enhancement prior to the period of extended operation would result in the

existing AMP being consistent with the GALL Report AMP to which it was compared.The staff

concludes that there is reasonable assurance that the applicant has demonstrated that the

effects of aging will be adequately managed so that the intended functions will be maintained

consistent with the CLB for the period of extended operation, as required by

10 CFR 54.21(a)(3). The staff also reviewed the UFSAR and USAR supplements for this AMP

and concludes that it provides an adequate summary description of the program, as required by

10 CFR 54.21(d).

3.0.3.2.18 ASME Section Xl Inservice Inspection (Subsection IWL) Program (NMP2 Only)

Summary of Technical Information in the Amended Application. In ALRA Section B2.1.24, the

applicant described the ASME Section Xl Inservice Inspection (Subsection IWL) Program for

NMP2, stating that this is an existing program that is consistent, with exception, with GALL

AMP XI.S2, "ASME Section Xl, Subsection IWL." The ASME Seclion Xl Inservice Inspection

(Subsection IWL) Program (referred to herein as the IWL ISI Program) manages aging of

concrete in the NMP2 containment wall, base mat, and drywell floor. Program activities include

general visual examination of all accessible concrete surface areas, with provisions for detailed

visual examination when deterioration and distress of suspect areas is detected. The IWL ISI

Program is based on the 1998 edition of the ASME Boiler and Pressure Vessel Code,

Section Xl (Subsection IWL) for containment inservice inspection with plant-specific exceptions

approved by the NRC. This program applies to concrete elements of BWR Mark II and III

containment structures. NMP1 is a BWR Mark I containment, therefore, this program does not

apply to NMPI.

Staff Evaluation. During its audit and review, the staff confirmed the applicant's claim of

consistency with the GALL Report. Details of the staff's audit evaluation of this AMP are

documented in the Audit and Review Report. The staff reviewed the exception and the

associated justification to determine whether the AMP, with the exception, remains adequate to

manage the aging effects for which it is credited.

As documented in the Audit and Review Report, the staff asked the applicant to explain why in

NMP AMP B2.1.24 under the consistency paragraph "IWE" is shown in the first sentence

instead of "IWL." The applicant responded that this typographical error should have been "IWL,"

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not "IWE." In its letter dated December 1, 2005, the applicant stated that in NMP AMP B2.1.24

under the consistency paragraph the typographical error "IWE" has been changed to UIWL."

The staff found the applicant's response acceptable. With the correction of "IWE" to "IWL" the

sentence agrees with the NMP AMP described in the ASME Section XI Inservice Inspection

(Subsection IWL) Program.

The staff reviewed those portions of the ASME Section Xl ISl (Subsection IWL) Program (Unit 2

only) for which the applicant claimed consistency with GALL AMP XI.S2 and found them

consistent. The staff found the applicant's ASME Section Xl ISl (Subsection IWL) Program

(Unit 2 only) acceptable because it conforms to the recommended GALL AMP XI.S2 with

exception.

In the ALRA, the applicant stated that its ASME Section Xl ISI (Subsection IWL) Program takes

exception to the GALL Report "parameters monitored/inspected," "detection of aging effects," "monitoring and trending," and "acceptance criteria" program elements. The GALL Report

program elements identify both the ASME 1992 Edition with the 1992 Addenda and the 1995

Edition with the 1996 Addenda as applicable editions for the NMP2 Application for Renewed

Operating License Appendix B - Aging Management Program ASME Section XI-IWL as

approved in 10 CFR 50.55a. The NMP IWL ISI Program complies with the ASME Section Xl

1998 Edition with no addenda.

The applicant stated in the ALRA that the GALL Report program description for this AMP

identifies both the 1992 Edition with the 1992 Addenda and the 1995 Edition with the 1996

Addenda as applicable editions for its ASME Section Xl ISl (Subsection IWL) Program as

approved in 10 CFR 50.55a. The applicant's IWL ISI Program complies with the ASME

Section Xl 1998 Edition with no addenda. Although differences exist between code editions the

applicant's IWL ISI Program complies with an edition of Section XI approved by the NRC for

use at NMP. Implementation according to this later code edition meets the recommendation of

the GALL Report description.

As documented in the Audit and Review Report, the staff previously found this exception

acceptable because the code of record for NMP2 is an ASME Code version later than that cited

by the GALL Report. The use of the 1998 Edition of the ASME Code was found acceptable in a

letter from the US Nuclear Regulatory Commission to Niagara Mohawk Power Corporation

dated August 17, 2000, with the subject "Nine Mile Point Nuclear Station, Unit Nos. 1 and 2 -

Relief From the Requirements of 10 CFR 50.55a Related to Containment Inspection (TAC Nos.

MA7116, MA7117, and MA7118)." The staff also noted that under the applicant's ASME code of

record for ASME Section XI ISI (Subsection IWL) a 10-year inspection interval is valid under the

CLB. At present an ASME Section Xl ISI (Subsection IWL) program is approved for use on an

ASME Code 10-year ISI interval-specific basis. However, the applicant will have to request

approval to use the ASME Section XI ISI (Subsection IWL) program for the specific intervals

during the period of extended operation under 10 CFR 50.55a 12 months prior to each interval.

Therefore, the staff determined that the ASME Section XI Code Edition as referenced in

10 CFR 50.55a, for which the applicant will request approval 12 months prior to each inspection

interval is acceptable for the period of extended operation and found this exception acceptable.

Operating Experience. In ALRA Section B2.1.24, the applicant explained that it has reviewed

both industry and plant-specific operating experience relating to the IWL ISI Program. Review

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of plant-specific operating experience revealed no CRs written as a result of IWL IS! Program

inspections since program inception.

During the initial audit and review, (August 9-13, 2004) the staff reviewed operating experience

for the applicant's ASME Section Xl ISI (Subsection IWL) Program (Unit 2 only). The review

indicated that the applicant's program is effective in maintaining the integrity of the containment

concrete with processes in place to identify age-related degradation and implement repairs.

As documented in the Audit and Review Report, the staff also reviewed the summary of specific

operating experience for the applicant's ASME Section Xl ISI (Subsection IWL) Program. The

review indicated that there have been no CRs written following IWL inspections since the

inception of the program and provided assurance that containment degradation has not

occurred since the inception of the program.

The staff reviewed the operating experience stated in the ALRA and interviewed the applicant's

technical personnel to confirm that the plant-specific operating experience revealed no

degradation not bounded by industry experience.

After review of industry and plant-specific operating experience and discussions with the

applicant's technical personnel the staff concludes that there is reasonable assurance that the

applicant's ASME Section Xl IS1 (Subsection IWL) Program (Unit 2 Only) will manage

adequately the aging effects and aging effects mechanisms identified in the ALRA for which

this AMP is credited.

USAR Supplement. In ALRA Section A2.1.4, the applicant provided the USAR supplement for

the ASME Section XI Inservice Inspection (Subsection IWL) Program. The staff reviewed this

section and determined that the information in the USAR supplement provides an adequate

summary description of the program, as required by 10 CFR 54.21(d).

Conclusion. On the basis of its review and audit of the applicant's ASME Section XI Inservice

Inspection (Subsection IWL) Program, the staff determined that those program elements for

which the applicant claimed consistency with the GALL Report are consistent with the GALL

Report. In addition 'the staff reviewed the exception and the associated justification, and

determined that the AMP, with the exception, is adequate to manage the aging effects for which

it is credited. The staff concludes that the applicant has demonstrated that the effects of aging

will be adequately managed so that the intended functions wil be maintained consistent with

the CLB for the period of extended operation, as required by 10 CFR 54.21(a)(3). The staff also

reviewed the USAR supplement for this AMP and concludes that it provides an adequate

summary description of the program, as required by 10 CFR 54.21 (d).

3.0.3.2.19 ASME Section Xl Inservice Inspection (Subsection IWF) Program

Summary of Technical Information in the Amended Application. In ALRA Section B2.1.25, the

applicant described the ASME Section Xl Inservice Inspection (Subsection IWF) Program,

stating that this is an existing program that is consistent, with exception, with GALL AMP XI.S3,

"ASME Section Xl, Subsection IWF." The ASME Section XI Inservice Inspection

(Subsection IWF) Program (referred to herein as the IWF ISI Program) manages aging of

carbon steel component and piping supports, including ASME Class MC supports, due to

general corrosion and wear. Program activities include visual examination to determine the

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general mechanical and structural condition of components and their supports. The IWF

Inservice Inspection Program is based on the 1989 edition of the ASME Boiler and Pressure

Vessel Code, Section XI (Subsection IWF) for inservice inspection of supports and implements

the alternate examination requirements of ASME Code Case N-491-1.

Staff Evaluation. During its audit and review, the staff confirmed the applicant's claim of

consistency with the GALL Report. Details of the staff's audit evaluation of this AMP are

documented in the Audit and Review Report. The staff reviewed the exception and the

associated justification to determine whether the AMP, with the exception, remains adequate to

manage the aging effects for which it is credited.

The staff reviewed those portions of the ASME Section Xl ISI (Subsection IWF) Program for

which the applicant claimed consistency with GALL AMP XI.S3 and found them consistent. The

staff found the applicant's ASME Section Xl ISI (Subsection IWF) Program acceptable because

it conforms to the recommended GALL AMP XI.S3 with exception.

In the ALRA, the applicant stated that its ASME Section XI ISI (Subsection IWF) Program is

consistent with GALL AMP XI.S3 with exception to the GALL Report "scope of program," "parameters monitored/inspected," and "acceptance criteria" program elements. The GALL

Report program elements identify the ASME 1989 Edition through the 1995 Edition and

Addenda through the 1996 Addenda as applicable to the NMP1 and NMP2 Application for

Renewed Operating License Appendix B - Aging Management Program ASME Section XI-IWF

as approved in 10 CFR 50.55a. The NMP IWF ISI Program complies with the ASME Section Xl

1989 Edition with no addenda.

In the ALRA, the applicant stated that the NRC previously found this exception acceptable

because the code of record for NMP IWF inspections is the 1989 version of the ASME Code

found acceptable in two letters from the US Nuclear Regulatory Commission to Niagara

Mohawk Power Corporation dated October 5, 2000 and March 3, 2000. The subject of the

October 5, 2000, letter was "Nine Mile Point Nuclear Station, Unit No. 1 - Reliefs for the Third

10-Year Inservice Inspection Program Plan, Revision I (TAC No. MA7129)." The subject of the

March 3, 2000, letter was "Nine Mile Point Nuclear Station, Unit No. 2 - Reliefs for the Second

10-Year Inservice Inspection Program Plan, Revision I (TAC No. MA6273)." The staff also

noted that under the applicant's ASME code of record for ASME Section Xl ISI (Subsection

IWF) a 10-year inspection interval is valid under the CLB. At present an ASME Section Xl ISI

(Subsection IWF) Program is approved for use on an ASME Code 10-year ISI interval specific

basis. However, the applicant will have to request approval to use the ASME Section XI ISI

(Subsection IWF) Program for the specific intervals during the period of extended operation

under 10 CFR 50.55a 12 months prior to each interval. Therefore, the staff determined that the

ASME Section Xl Code Edition as referenced in 10 CFR 50.55a, for which the applicant will

request approval 12 months prior to each inspection interval is acceptable for the period of

extended operation and found this exception acceptable.

As documented in the Audit and Review Report, the staff noted that the GALL Report AMP

program identifies the ASME 1989 Edition through the 1995 Edition and addenda through the

1996 Addenda as applicable to applicant's ASME Section Xl ISI (Subsection IWF) Program as

approved in 10 CFR 50.55a. The applicant's IWF ISI Program complies with the ASME

Section XI 1989 Edition with no addenda. Although differences exist between code editions the

applicant's IWF ISI Program complies with an edition of Section Xl approved by the staff for use

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at NMP. Implementation according to this code edition meets the recommendation of the GALL

Report description.

Operatinq Experience. In ALRA Section B2.1.25, the applicant explained that it has reviewed

both industry and plant-specific operating experience relating to the IWF Inservice Inspection

Program. Review of plant-specific operating experience revealed no age-related failures of any

supports within the scope of the IWF Inservice Inspection Program.

As documented in the Audit and Review Report, the staff also reviewed the summary of specific

operating experience for its ASME Section Xl ISI (Subsection IWF) Program. Review of the

summary indicated that the applicant did not identify any age-related ASME Code Class 1, 2, 3,

and MC component support failures. During the initial audit and review (August 9-13, 2004)

NMP1 plant maintenance records revealed that there have been no age-related failures of any

supports in the program and internal audits have revealed only administrative deficiencies that

did not affect the ability of any support to perform its intended function. One CR which

demonstrated the effectiveness of inspection techniques in use at NMP1 reported a support

that may have lost a degree of freedom from the improper application of paint. Further

investigation revealed the support maintained its intended function with no age-related

degradation. Other CRs documented deficiencies discovered and corrected through site quality

assurance and CAPs. No improperly managed age-related degradation was discovered, thus

providing assurance that support degradation had not occurred since the inception of the

program.

During the initial audit and review (August 9-13, 2004) NMP2 plant maintenance records also

revealed that there have been no age-related failures of any supports in the program, and

internal audits have revealed only administrative deficiencies that did not affect the ability of any

support to perform its intended function. One CR demonstrating effective inspection techniques

in use at NMP2 reported a support with a gap between the inner nut and clamp. The pipe clamp

bolts were tightened to their original design specification and the support was found to be

operable so there was no loss of intended function. Other CRs documented deficiencies

discovered and corrected through site quality assurance and CAPs. No improperly managed

age-related degradation was discovered, thus providing assurance that support degradation

had not occurred since the inception of the program.

The staff reviewed the operating experience stated in the ALRA and interviewed the applicant's

technical personnel to confirm that the plant-specific operating experience reveals no

degradation not bounded by industry experience.

After review of industry and plant-specific operating experience and discussions with the

applicant's technical personnel the staff concludes that the applicant's ASME Section Xl ISI

(Subsection IWF) Program will manage adequately the aging effects and aging effects

mechanisms identified in the ALRA for which this AMP is credited.

UFSAR and USAR Supplements. In ALRA Sections Al.1.3 and A2.1.3, the applicant provided

the respective UFSAR and USAR supplements for the ASME Section XI Inservice Inspection

(Subsection IWF) Program. The staff reviewed these sections and determined that the

information in the supplements provide adequate summary descriptions of the program, as

required by 10 CFR 54.21(d).

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Conclusion. On the basis of its review and audit of the applicant's ASME Section Xl Inservice

Inspection (Subsection IWF) Program, the staff determined that those program elements for

which the applicant claimed consistency with the GALL Report are consistent with the GALL

Report. In addition the staff reviewed the exception and the associated justifications, and

determined that the AMP, with the exception, is adequate to manage the aging effects for which

it is credited.The staff concludes that there is reasonable assurance that the applicant

demonstrated that the effects of aging will be adequately managed so that the intended

functions will be maintained consistent with the CLB for the period of extended operation, as

required by 10 CFR 54.21(a)(3). The staff also reviewed the UFSAR and USAR supplements

for this AMP and concludes that they provide an adequate summary description of the program,

as required by 10 CFR 54.21(d).

3.0.3.2.20 Masonry Wall Program

Summary of Technical Information in the Amended Application. In ALRA Section B2.1.27, the

applicant described the Masonry Wall Program, stating that this is an existing program that is

consistent, with enhancements, with GALL AMP XI.S5, "Masonry Wall Program." The Masonry

Wall Program manages aging effects so that the evaluation basis established for each masonry

wall within the scope of license renewal remains valid through the period of extended operation.

The Masonry Wall Program is based on the structures monitoring requirements of

10 CFR 50.65. Implementation of the Masonry Wall Program is discussed in the program

description for the Structures Monitoring Program.

Staff Evaluation. During its audit and review, the staff confirmed the applicant's claim of

consistency with the GALL Report. Details of the staff's audit evaluation of this AMP are

documented in the Audit and Review Report. The staff reviewed the enhancements and the

associated justifications to determine whether the AMP, with the enhancements, remains

adequate to manage'the aging effects for which it is credited.

Because the applicant chose to implement its Masonry Wall Program through its Structures

Monitoring Program the staff evaluations are combined with the evaluations of the Structures

Monitoring Program in SER Section 3.0.3.2.21.

Operatinq Experience. Refer to SER Section 3.0.3.2.21.

UFSAR and USAR Supplements. In ALRA Sections A1.1.23 and A2.1.23, the applicant

provided the respective UFSAR and USAR supplements for the Masonry Wall Program. The

staff reviewed these sections and determined that the information in the supplements provide

adequate summary descriptions of the program, as required by 10 CFR 54.21(d).

Conclusion. On the basis of its review and audit of the applicant's Masonry Wall Program, the

staff determined that those program elements for which the applicant claimed consistency with

the GALL Report are consistent with the GALL Report. Also, the staff has reviewed the

enhancements and confirmed that the implementation of the enhancements prior to the period

of extended operation would result in the existing AMP being consistent with the GALL Report

AMP to which it was compared.The staff concludes that there is reasonable assurance that the

applicant demonstrated that the effects of aging will be adequately managed so that the

intended functions will be maintained consistent with the CLB for the period of extended

operation, as required by 10 CFR 54.21(a)(3). The staff also reviewed the UFSAR and USAR

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supplements for this AMP and concludes that they provide an adequate summary description of

the program, as required by 10 CFR 54.21(d).

3.0.3.2.21 Structures Monitoring Program

Summary of Technical Information in the Amended Application. In ALRA Section B2.1.28, the

applicant described the Structures Monitoring Program, stating that this is an existing program

that is consistent, with enhancements, with GALL AMP XI.S6, "Structures Monitoring Program."

The Structures Monitoring Program manages aging of structures, structural components, and

structural supports within the scope of license renewal. The program provides for periodic visual

inspections, surveys, and examination of all safety related buildings (including the primary

containment and substructures within the primary containment) and various other buildings

within the scope of license renewal. Program activities identify degradation of materials of

construction, which include structural steel, concrete, masonry block, and sealing materials.

While not credited for mitigation of aging, protective coatings are also inspected under this

program. The Structures Monitoring Program, which was initially developed to meet the

regulatory requirements of 10 CFR 50.65, implements guidance provided in RG 1.160,

NUMARC 93-01, and NEI 96-03.

Staff Evaluation. During its audit and review, the staff confirmed the applicant's claim of

consistency with the GALL Report. Details of the staff's audit evaluation of this AMP are

documented in the Audit and Review Report. The staff reviewed the enhancements and the

associated justifications to determine whether the AMP, with the enhancements, remains

adequate to manage the aging effects for which it is credited.

During the initial audit and review (August 9-13, 2004) the staff asked the applicant to explain

the design of the foundations for its structures within license renewal and whether any have

porous concrete subfoundations. In addition the staff requested the applicant to explain if any

license renewal structures have settlement issues and if there is a site de-watering system.

As documented in the Audit and Review Report, the applicant stated in response to the staffs

questions that the foundations for the structures within the scope of license renewal are

reinforced concrete on bedrock. Porous concrete sub-foundation construction was not used at

NMP. The applicant also responded that settlement is not an aging effect or aging effect

mechanism at NMP and that there is no site de-watering system.

GALL AMP XI.S5 under the "detection of aging effects" program element states that the

frequency of inspection is selected to ensure no loss of intended function between inspections.

The inspection frequency may vary from wall to wall depending on the significance of cracking

in the evaluation basis. Unreinforced masonry walls not contained by bracing warrant the most

frequent inspection because cracks may invalidate the existing evaluation basis. The applicant

stated in its Masonry Wall Program basis document that the inspection frequency of six years

for the unreinforced walls is consistent with the GALL Report. However, this inspection

frequency is the same as that for reinforced masonry walls as discussed in the applicant's

program basis document.

In addition as documented in the Audit and Review Report, the staff asked the applicant to

explain how the same inspection frequency for all reinforced, unreinforced, and braced masonry

walls within the scope of license renewal is consistent with the GALL Report. The applicant

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responded that it will require as part of its Masonry Wall Program (as managed by its Structures

Monitoring Program) that unreinforced masonry walls without bracing be inspected for cracking

more frequently than reinforced or braced masonry walls.

In its letter dated December 1, 2005, the applicant added to the ALRA a commitment to

enhance its Masonry Wall Program (as managed by its Structures Monitoring Program) based

on the GALL Report text in the program element, "detection of aging effects." The program

enhancement will provide guidance for inspecting NMP1 unreinforced or unbraced masonry

walls within the scope of license renewal more frequently than reinforced masonry walls. The

ALRA sections affected are A1.1.34, A1.4, and B2.1.28 (NMP1 Commitment 39).

The staff found the applicant's response acceptable. With the commitment to inspect

unreinforced masonry walls more frequently the applicant's Structural Monitoring Program is

now consistent with the "detection of aging effects" program element of GALL AMP XI.S5.

As further documented in the Audit and Review Report, the staff noted that the applicant's

Structures Monitoring Program basis document lists wood in air as one of the NMP1

component/commodity groups managed by the program. The staff requested the applicant to

explain why wood was not listed under the program description in ALRA Section A1.1.34 and

NMP AMP B2.1.28 as one of the construction materials inspected for degradation by the

program. The applicant responded that it would add wood to the list of materials for NMP1 in

the program description of ALRA Sections B2.1.28 and A1.1.34.

In its letter dated December 1, 2005, the applicant stated that ALRA Section A1.1.34 had been

revised to add NMP1 wooden structure to the list of construction materials in the first paragraph

and that ALRA Section B2.1.28 had been revised by adding NMP1 wooden structure to the list

of construction materials in the first paragraph under the program description.

The staff found the applicant's response acceptable. With the addition of wood to ALRA

Sections A1.1.34 and B2.1.28 the applicant's Structures Monitoring Program in the ALRA is

now in agreement with the program basis document.

The staff reviewed those portions of the Structures Monitoring Program for which the applicant

claimed consistency with GALL AMP XI.S5 and GALL AMP XI.S6, and found them consistent.

The staff found the applicant's Structures Monitoring Program acceptable because it conforms

to the recommended GALL AMP XI.S5, "Masonry Wall Program," and GALL AMP XI.S6,

"Structures Monitoring Program," with enhancements.

In the ALRA, the applicant stated that its Structures Monitoring Program is consistent with

GALL AMP XI.S6 with an enhancement. As stated In the ALRA, the enhancement in meeting

the GALL Report program elements is to expand scope and make revisions to activities (i.e.,

procedures) credited for license renewal to ensure that aging effects and aging effects

mechanisms are discovered and evaluated (NMP1 Commitment 26, NMP2 Commitment 24).

In the ALRA, the applicant stated that its Structures Monitoring Program will be expanded to

include within the scope of license renewal the following listed activities or components not

currently within the scope of 10 CFR 50.65:

(a) NMP2 fire-rated assemblies and watertight penetration visual inspections,

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(b) NMP2 masonry walls in the turbine building and service water tunnel serving a

fire barrier function, and

(c) the steel electrical transmission towers required for the station blackout (SBO)

and recovery paths for NMP1 and NMP2.

Also parameters monitored during structural inspections will be expanded to include those

relevant to aging effects and aging effects mechanisms for structural bolting. This enhancement

affects the "parameters monitored/inspected," "detection of aging effects," and acceptance

criteria" program elements of the GALL Report. In addition regularly scheduled ground water

monitoring will ensure that a benign environment is maintained, this enhancement affects the

"parameters monitored/inspected" and "detection of aging effects" program elements of the

GALL Report.

The staff determined that with these additional inspections of SCs the applicant's Structures

Monitoring Program will meet the recommendation of GALL AMP XI.S6. The applicant identified

commitments to the NRC with these enhancements relative to GALL AMP XI.S6. Because

inspection of these additional structural components will make the applicant's program

consistent with GALL AMP XI.S6 the staff found these enhancements acceptable. These

changes to the applicant's program will provide assurance that the effects of aging will be

adequately managed.

Operating Experience. In ALRA Section B2.1.28, the applicant explained it has reviewed both

industry and plant-specific operating experience relating to the Structures Monitoring Program.

Since implementation of inspections under the Structures Monitoring Program, minor cracking

has been identified in various concrete structures and slight (but stable) ground water leaks

have occurred in some tunnels. However, a review of plant-specific operating experience

revealed no cases of structural failure caused by unidentified degradation. Similarly, no

structural deficiencies have been identified in flood control structures.

As documented in the Audit and Review Report, the staff also reviewed the summary of specific

operating experience for the applicant's Structures Monitoring Program. The review indicated

that the applicant's Structures Monitoring Program is effective in identifying structural

degradation, implementing corrective actions, and trending parameters for NMP structures

within the scope of license renewal. When degradation has been identified corrective actions

have been implemented to ensure that the integrity of the affected structure is maintained

without loss of intended function.

The staff reviewed the operating experience stated in the ALRA and interviewed the applicant's

technical personnel to confirm that the plant-specific operating experience revealed no

degradation not bounded by industry experience.

As stated in the Audit and Review Report, NMP1 and NMP2 plant maintenance/ inspection

records revealed that since implementation the applicant's Structures Monitoring Program has

been effective identifying structural degradation before a loss of intended function occurs.

Several CRs have identified minor cracking in concrete structures including the service water

pipe tunnel. Because the service water pipe tunnel is susceptible to small wall cracks allowing

leakage of ground water the staff requested the applicant to discuss the results of the latest

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inspections of the tunnel and how often these inspections were done. The applicant stated in

response that the repaired areas referenced in the service water pipe tunnel CR had been

inspected recently and that there continued to be no entry of ground water in the areas

repaired. The frequency of inspections following the repairs has varied. Initially repair

inspections were monthly, then quarterly, then annually. Inspections of the tunnel are now

scheduled for every refueling outage.

In addition during the initial audit and review the staff asked the applicant to explain if there is

any rust staining in the tunnel, indicating corrosion of rebar in the concrete, the reason for not

performing any external waterproofing repairs to the tunnel. The applicant responded that

inspections of accessible areas adjacent to inaccessible areas can indicate the condition of the

inaccessible areas. Rust stains have not been identified on the internal surface of the concrete

adjacent to the areas of leakage through the tunnel concrete walls. Therefore, it is reasonable

to conclude that degradation of the reinforcing steel is not occurring. Waterproof coating of the

exterior surface of the structure is not required due to successful repairs to water penetration

paths from the inside the structure.

Furthermore, during the initial audit and review the staff asked the applicant to explain how the

design of the service water pipe tunnel keep the flood depth under three inches if ground water

entered again and the sump pumps failed as reported in the CR. The applicant stated that the

tunnel is sectioned by various curbs and elevations. If the sumps failed in the tunnel water

would flow over the curb and into another sump.

The applicant was also asked at the time to discuss results of the latest inspections for the

normal switchgear building, service water tunnels, and the radwaste building for below grade

exterior walls where groundwater also has entered. The applicant stated that the latest

inspections have not identified significant water entry for the structures within the scope of

license renewal.

Based on the initial audit and review that the applicant's Structures Monitoring Program

procedures provide for buried structures that when inaccessible areas are excavated or

exposed if practical an inspection of these structures will be performed and findings included in

the program's database.

After review of industry and plant-specific operating experience and discussions with the

applicant's technical personnel the staff concludes that there is reasonable assurance that the

applicant's Structures Monitoring Program will manage adequately the aging effects and aging

effects mechanisms identified in the ALRA for which this AMP is credited.

UFSAR and USAR Supplements. In ALRA Sections A1.1.34 and A2.1.34, the applicant

provided the respective UFSAR and USAR supplements for the Structures Monitoring Program.

The staff reviewed these sections and determined that the information in the supplements

provide adequate summary descriptions of the program, as required by 10 CFR 54.21(d).

Conclusion. On the basis of its review and audit of the applicant's Structures Monitoring

Program, the staff determined that those program elements for which the applicant claimed

consistency with the GALL Report are consistent with the GALL Report. Also, the staff has

reviewed the enhancements and confirmed that the implementation of the enhancements prior

to the period of extended operation would resultin the existing AMP being consistent with the

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GALL Report AMP to which it was compared.The staff concludes that there is reasonable

assurance that the applicant has demonstrated that the effects of aging will be adequately

managed so that the intended functions will be maintained consistent with the CLB for the

period of extended operation, as required by 10 CFR 54.21(a)(3). The staff also reviewed the

UFSAR and USAR supplements for this AMP and concludes that they provide an adequate

summary description of the program, as required by 10 CFR 54.21 (d).

3.0.3.2.22 Non-EQ Electrical Cables and Connections Used in Instrumentation Circuits

Program

Summary of Technical Information in the Amended Application. In ALRA Section B2.1.30, the

applicant described the Non-EQ Electrical Cables and Connections Used in Instrumentation

Circuits Program, stating that this is an existing program that is consistent, with enhancements,

with GALL AMP XI.E2, "Electrical Cables and Connections Not Subject to 10 CFR 50.49

Environmental Qualification Requirements Used in Instrumentation Circuits." The Non-EQ

Electrical Cables Used in Instrumentation Circuits Program manages aging of cables and

connections exposed to adverse localized temperature and radiation environments that could

result in loss of insulation resistance. It applies to accessible and inaccessible electrical cables

that are not in the EQ Program and are used in circuits with sensitive, high-voltage, low-level

signals such as radiation monitoring, nuclear instrumentation, and other such cables subject to

AMR that are sensitive to a reduction in insulation resistance. Activities include routine

calibration tests of instrumentation loops or direct testing of the cable system in those cases

where cable testing is conducted as an alternate to surveillance testing, and in either case are

implemented through the Surveillance Testing and Preventive Maintenance Programs. Testing

is based on requirements of the particular calibrations, surveillances, or testing performed on

the specific instrumentation circuit or cable and is implemented through the NMP work control

system. Where cable testing is conducted as an alternate to surveillance testing the acceptance

criteria for each test will be defined by the specific type of test performed and the specific cable

tested.

Staff Evaluation. During its audit and review, the staff confirmed the applicant's claim of

consistency with the GALL Report. Details of the staffs audit evaluation of this AMP are

documented in the Audit and Review Report. The staff reviewed the enhancements and the

associated justification to determine whether the AMP, with the enhancements, remains

adequate to manage the aging effects for which it is credited.

The staff reviewed nuclear engineering reports (NERs) for NMP1 and NMP2. The staff found

inconsistency between NMP1 and NMP2 non-EQ Electrical Cables and Connections Used in

Instrumentation Circuits Program scopes. For example, the scope for NMP1 includes power

range monitoring (PRM) and intermediate range monitoring (IRM) circuitry. However, the AMP

scope for NMP2 includes only the IRM circuit. As documented in the Audit and Review Report,

the staff requested that the applicant review the NERs and clarify the differences between the

scoping of the two units. The applicant clarified differences between the scoping of NMP1 and

NMP2. The applicant indicated that some cables are not within the scope of the Non-EQ

Electrical Cables and Connections Used in Instrumentation Circuits Program because these

cables are in the EQ Program and therefore not within the scope of Non-EQ Electrical Cables

and Connections Used in Instrumentation Circuits Program. The applicant also informed the

staff that as a result of responding to the staffs request it reviewed the NERs and found a

discrepancy in the safety classification between NMP1 and NMP2. The applicant informed the

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staff that it would initiate a CR to document the discrepancy between NMP1 and NMP2 and

revise the NMP1 and NMP2 NERs and the programbasis document. The staff found the

applicant's response acceptable. The staff reviewed the applicant's revised program basis

document and NERs and concludes that the scope of cables in the Non-EQ Electrical Cables

and Connections Used in Instrumentation Circuits Program is acceptable.

As documented in the Audit and Review Report, the staff also requested that the applicant

verify tests performed by procedures including the entire loop (cables and connections) credited

in the Non-EQ Electrical Cables and Connections Used in Instrumentation Circuits Program

basis document. The applicant responded that the credited procedure steps listed in its

program basis document (GALL Report program element "acceptance criteria") were reviewed

to ensure that all cables and connections of the system were tested. The applicant verified for

each procedure credited that all cables and connections within the scope of GALL AMP XI.E2

are tested. The staff found the applicant's response acceptable.

The staff reviewed those portions of the Non-EQ Electrical Cables and Connections Used in

Instrumentation Circuits Program for which the applicant claimed consistency with GALL

AMP XI.E2 and found them consistent. The staff found the applicant's Non-EQ Electrical

Cables and Connections Used in Instrumentation Circuits Program acceptable because it

conforms to the recommended GALL AMP XI.E2 with enhancements.

In the ALRA, the applicant stated that its Non-EQ Electrical Cables and Connections Used in

Instrumentation Circuits Program is consistent with GALL AMP XI.E2 with enhancements to the

GALL Report "detection of aging effects" program element by reviews of calibration or

surveillance data for indications of aging degradation affecting instrument circuit performance.

The first reviews will be completed prior to the period of extended operation and every ten years

thereafter. A review of the calibration and surveillance results can indicate aging effects and

aging effects mechanisms by monitoring key parameters and providing instrumentation circuit

performance data reviewed at the time of the calibrations and surveillances, thereby providing

reasonable assurance that severe aging degradation will be detected prior to loss of the cables'

intended function. Where a calibration or surveillance program does not include the cabling

system in the testing circuit alternatives like insulation resistance tests or other testing effective

in determining cable insulation condition or deterioration of the insulation system will be

performed. The first test will be completed prior to the period of extended operation. Test

frequency will be based on engineering evaluation but will be at least once every 10 years

(NMP1 Commitment 28, NMP2 Commitment 26).

As documented in the Audit and Review Report, the staff concludes that these enhancements

will not impact adversely the ability of this AMP to manage the effects of aging as either of the

two methods is acceptable to detect aging degradation. Calibration results or surveillance

testing program findings are evaluated to detect cable aging degradation. Direct testing of the

cable system will be effective in determining the condition of cable insulation. On this basis, the

staff found this enhancement acceptable because changes to the applicant's program will

provide assurance that the effects of aging will be adequately managed.

Operating Experience. In ALRA Section B2.1.30, the applicant explained that it has reviewed

both industry and plant-specific operating experience relating to the Non-EQ Electrical Cables

Used in Instrumentation Circuits Program. Review of plant-specific operating experience

revealed documentation of cable degradation identified through routine calibration testing that is

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similar to the industry operating experience (e.g., degraded cables for temperature instruments,

degraded shielding for drywell instrument cables).

The staff reviewed the operating experience stated in the ALRA and interviewed the applicant's

technical personnel to confirm that the plant-specific operating experience revealed no

degradation not bounded by industry experience.

After review of industry and plant-specific operating experience and discussions with the

applicant's technical personnel the staff concludes that there is reasonable assurance that the

applicant's Non-EQ Electrical Cables Used in Instrumentation Circuits Program will manage

adequately the aging effects and aging effects mechanisms identified in the ALRA for which

this AMP is credited.

UFSAR and USAR Supplements. In ALRA Sections A1.1.25 and A2.1.25, the applicant

provided the respective UFSAR and USAR supplements for the Non-EQ Electrical Cables and

Connections Used in Instrumentation Circuits Program. The staff reviewed these sections and

determined that the information in the supplements provide adequate summary descriptions of

the program, as required by 10 CFR 54.21(d).

Conclusion. On the basis of its review and audit of the applicant's Non-EQ Electrical Cables and

Connections Used in Instrumentation Circuits Program, the staff determined that those program

elements for which the applicant claimed consistency with the GALL Report are consistent with

the GALL Report. Also, the staff has reviewed the enhancements and confirmed that the

implementation of the enhancements prior to the period of extended operation would result in

the existing AMP being consistent with the GALL Report AMP to which it was compared.The

staff concludes that there is reasonable assurance that the applicant has demonstrated that the

effects of aging will be adequately managed so that the intended functions will be maintained

consistent with the CLB for the period of extended operation, as required by

10 CFR 54.21(a)(3). The staff also reviewed the UFSAR and USAR supplements for this AMP

and concludes that they provide an adequate summary description of the program, as required

by 10 CFR 54.21(d).

3.0.3.2.23 Bolting Integrity Program

Summary of Technical Information in the Application. In ALRA Section B2.1.36, and as

supplemented by letter dated November 17, 2005, the applicant described the Bolting Integrity

Program, stating that this is an existing program that is consistent with enhancements and an

exception to GALL AMP XI.M 18, "Bolting Integrity." The Bolting Integrity Program manages

aging effects due to loss of preload, cracking and loss of material from bolting within the scope

of license renewal including SR bolting, bolting for NSSS component supports, bolting for other

pressure-retaining components, and structural bolting. Program activities include periodic

inspections of bolting for indication of loss of preload, cracking and loss of material due to

corrosion, etc. This program is based on the guidelines delineated in NUREG-1339, "Resolution

of Generic Safety Issue 29: Bolting Degradation or Failure in Nuclear Power Plants," and the

guidance contained in EPRI NP-5769, "Degradation and Failure of Bolting in Nuclear Power

Plants," with exceptions noted in NUREG-1 339 for safety-related bolting and EPRI TR-1 04213,

"Bolted Joint Maintenance and Applications Guide," for other bolting. The Bolting Integrity

Program is implemented through the ASME Section XI ISI (Subsection IWB, IWC, IWD)

Program, ASME Section XI Inservice Inspection (Subsection IWE) Program, ASME Section Xl

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Inservice Inspection (Subsection IWF) Program, Structures Monitoring Program, Preventive

Maintenance Program, and Systems Walkdown Program.

Staff Evaluation. In ALRA Section B.2.1.36, "Bolting Integrity Program," and by letter dated

November 17, 2005, the applicant described its AMP to manage effects of aging in bolting. The

applicant states that this AMP when enhanced will be consistent with GALL AMP XI.M18 with

an exception.

As stated in ALRA Section B2.1.36, enhancements to the Bolting Integrity Program include

establishing an augmented inspection program for high-strength bolts in nuclear steam supply

system (NSSS) supports and revisions to activities credited for license renewal.

Program Elements Affected - Documents will be prepared or revised to address the

following elements:

Scope of Program - The Structures Monitoring, Preventive Maintenance, and Systems

Walkdown Programs will be enhanced to include requirements to inspect bolting for loss

of preload, cracking, and loss of material, as applicable. References to the bolting

integrity program and industry guidance will be included in NMP administrative and

implementing program documents.

Detection of Aging Effects - An augmented inspection program for high-strength (actual

yield strength > 150 ksi) bolts will be established to prescribe the examination

requirements of Tables IWB-2500-1 and IWC-2500-1 of ASME Section XI for

high-strength bolts in the Class 1 and Class 2 component supports, respectively.

The applicant stated that the enhancements will be completed prior to the period of extended

operation (NMP1 Commitment 33 and NMP2 Commitment 31).

As stated in the applicant's letter dated November 17, 2005, an exception to GALL Report

Section XI.M18, "Bolting Integrity," was added for its reference to the 1995 Edition-1996

Addenda of the ASME Code.

The program described in GALL AMP XI.M18 under "detection of aging effects" cites ASME

Section XI requirements covered in the 1995 Edition through the 1996 Addenda. The code of

record for NMP1 and NMP2 is the 1989 Code with no addenda; this is an exception to the

GALL Report.

For SR bolting the applicant relies on the NRC recommendations and guidelines of

NUREG-1339 and industrys technical basis for material selection and testing, bolting preload

control, ISI, plant operation and maintenance, and evaluation of structural integrity of bolted

joints outlined in EPRI NP-5769 with the exceptions noted in NUREG-1339. This guidance is

consistent with GALL AMP XI.M1 8 and the staff found it acceptable.

With regard to other bolting the applicant states that it will comply with the aging management

attributes of EPRI TR-104213. The staff found that for other bolting the applicant's Bolting

Integrity Program will be consistent with the recommendations in the GALL Report and will

meet the standards of EPRI TR-104213 with the inclusion of enhancements.

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The first enhancement to the Bolting Integrity Program is that the applicant will establish an

augmented inspection program for high-strength (actual yield stirength > 150 ksi) bolts. The

staff noted that this augmented program will prescribe the examination requirements of

Tables IWB-2500-1 and IWC-2500-1 of ASME Section XI for high-strength bolts in the Class I

and Class 2 component supports, respectively. The second enhancement is that the Structures

Monitoring, Preventive Maintenance and Systems Walkdown Programs will be enhanced to

include requirements to inspect bolting for loss of preload, cracking, and loss of material. The

last enhancement is that references to the Bolting Integrity Program and industry guidance will

be included in NMPNS program documents. The staff noted that the existing Bolting Integrity

Program with these enhancements will be consistent with GALL AMP X1.M18.

Previously the staff has accepted the use of periodic ISI of closure bolting as an acceptable

AMP for loss of mechanical closure integrity as failure of the mechanical joint indicated by

leakage can be attributed to loss of material, cracking of bolting materials, or loss of preload.

The staff determined that periodic ASME Section XI ISI and plant preventive maintenance

programs as described in NUREG-1339 and EPRI NP-5769 can be relied upon effectively to

detect loss of closure integrity for bolted assemblies. Therefore, the applicant's program for loss

of mechanical closure integrity is adequate for managing aging effects of loss of material

cracking and loss of preload. The staff finds that the applicant with its enhancements to the

Bolting Integrity Program has demonstrated its compliance with all the attributes of GALL

AMP XI.M18 for bolting within the scope of license renewal including safety-related bolting,

bolting for NSSS component supports, and bolting for other pressure-retaining components.

The applicant in its letter dated November 17, 2005, indicated that an exception had been

added to the Bolting Integrity Program. The exception was with respect to the reference to the

1995 Edition-1996 Addenda of the ASME Code in GALL Report Section XI.M18. However, the

Code of record for NMP1 and NMP2 is the 1989 Code with no addenda, an exception to the

GALL Report. The staff compared the examination requirements of Tables IWB-2500-1 and

IWC-2500-1 in the 1995 Edition through the 1996 Addenda against those of the 1989 Edition

and found them to be consistent with the exception of the examination requirement for the RV

closure head nuts. The staff noted that the examination requirement in the 1989 Code Edition

for the RV closure head nuts is more conservative than that required in the 1995 Edition

through the 1996 Addenda. Furthermore, the staff noted that the RV closure head nuts will be

managed by the applicant's Reactor Head Closure Studs Program (ALRA Section B2.1.3),

which is assessed in SER Section 3.0.3.2.3. Therefore, the staff finds the applicant's Bolting

Integrity Program with the enhancements and exception acceptable. The staff concludes that

by implementing the Bolting Integrity Program, which is consistent with the GALL Report with

an exception, the aging effects on the bolting within the scope of license renewal including SR

bolting, bolting for NSSS component supports, and bolting for other pressure-retaining

components, will be adequately managed for the extended period of operation.

Operating Experience. In ALRA Section B2.1.36, the applicant indicated that it has reviewed

both industry and plant-specific operating experience related to the Bolting Integrity Program

and is aware of the types of bolting issues that have been reported and documented in the

industry. The applicant also indicated that the lessons learned from industry experiences have

been incorporated into the NMPNS bolting practices such that this program has adequately

detected bolting integrity issues and has been effective in correcting issues prior to the loss of

intended function. This program is adjusted continually to account for industry experience and

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research. The applicant also indicated that with additional operating experience lessons learned

will be used to adjust the Bolting Integrity Program as needed.

The applicant stated that the Bolting Integrity Program has been effective in managing the

aging effects of bolting within the scope of license renewal including SR bolting, bolting for

NSSS component supports, and bolting for other pressure-retaining components.

UFSAR and USAR Suoplements. In ALRA Sections A1.1.38 and A2.1.37, the applicant

provided the respective UFSAR and USAR supplements for the Bolting Integrity Program. The

staff reviewed the following UFSAR and USAR supplement summary description for the Bolting

Integrity Program:

The Bolting Integrity Program manages aging effects due to loss of preload,

cracking and loss of material of bolting within the scope of license renewal

including safety-related bolting, bolting for NSSS component supports, bolting for

other pressure retaining components, and structural bolting. Program activities

include periodic inspections of bolting for indication of loss of preload, cracking

and loss of material due to corrosion, rust, etc.

This program is based on the guidelines of NUREG-1339 and the guidance of EPRI NP-5769

with exceptions noted in NUREG-1 339 for safety-related bolting and EPRI TR-1 04213 for other

bolting.

The Bolting Integrity Program is implemented through the ASME Section XA

inservice Inspection (Subsections IWB, IWC, IWD) Program, ASME Section Xl

Inservice Inspection (Subsection IWE) Program, ASME Section Xl Inservice

Inspection (Subsection IWF) Program, Structures Monitoring Program,

Preventive Maintenance Program, and Systems Walkdown Program.

Enhancements to the Bolting Integrity Program include:

Establish an augmented inspection program for high-strength (actual yield

strength > 150 ksi) bolts. This augmented program will prescribe the examination

requirements of Tables IWB-2500-1 and IWC-2500-1 of ASME Section Xl for

high-strength bolts in the Class I and Class 2 component supports, respectively.

The Structures Monitoring, Preventive Maintenance and Systems Walkdown

Programs will be enhanced to include requirements to inspect bolting for indication

of loss of preload, cracking and loss of material, as applicable.

Include in NMP administrative and implementing program documents references to

the Bolting Integrity Program and industry guidance.

Enhancements will be completed prior to the period of extended operation.

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The applicant stated that the exception to the NMP1 and NMP2 Bolting Integrity Program

includes:

Add an exception to GALL Report Program XI.M18 for its reference to the 95-96

Addenda of the ASME Code.

The applicant's UFSAR and USAR supplement summary descriptions for the Bolting Integrity

Program appropriately describe the implementation of relevant programs that would enable the

applicant to manage effectively the aging effect due to loss of material, cracking, and loss of

preload of the bolts at the NMPNS units for the extended period of operation.

Conclusion. On the basis of its review and audit of the applicant's Bolting Integrity Program, the

staff determined that those program elements for which the applicant claimed consistency with

the GALL Report are consistent with the GALL Report. Also, the staff has reviewed the

enhancements and confirmed that the implementation of the enhancements prior to the period

of extended operation would result in the existing AMP being consistent with the GALL Report

AMP to which it was compared.The staff concludes that there is reasonable assurance that the

applicant has demonstrated that the effects of aging will be adequately managed so that the

intended functions will be maintained consistent with the CLB for the period of extended

operation, as required by 10 CFR 54.21(a)(3). The staff also reviewed the UFSAR and USAR

supplements for this AMP and concludes that they provide an adequate summary description of

the program, as required by 10 CFR 54.21(d).

3.0.3.2.24 BWR Control Rod Drive Return Line (CRDRL) Nozzle Program

Summary of Technical Information in the Amended Application. In ALRA Section B2.1.37, the

applicant described the BWR Control Rod Drive Return Line (CRDRL) Nozzle Program, stating

that this is an existing program that is consistent, with exceptions, with GALL AMP XI.M6,

"BWR Control Rod Drive Return Line Nozzle." The NMP1 CRDRL Nozzle is examined

according to ASME Code, Section XI, program which satisfies the requirements in GALL

AMP XI.M1, "ASME Section XI Inservice Inspection, Subsections IWB, IWC and IWD." This

program is updated in accordance with 10 CFR 50.55(a). Augmented examinations

incorporated into the ISI program plan that implemented the requirements of NUREG-0619,

"BWR Feedwater Nozzle and Control Rod Drive Return Une Nozzle Cracking," November

1980, have been superseded by ASME Section XI, Appendix VIII, "Performance Demonstration

for Ultrasonic Examination Systems" (1995 Edition with the 1996 Addenda). NMP2 cut and

capped the CRD return nozzle prior to commercial operation. The capped NMP2 CRD return

nozzle was therefore not subject to the augmented examination requirements described in

NUREG-0619. The NMP2 CRDRL Nozzle Program is implemented through ASME Section XI,

Subsection IWB, Table IWB 2500-1 (1989 edition no addenda) and ASME Section XI,

Appendix VIII, "Performance Demonstration for Ultrasonic Examination Systems" (1995 Edition

with the 1996 Addenda).

Staff Evaluation. During its audit and review, the staff confirmed the applicant's claim of

consistency with the GALL Report. Details of the staff's audit evaluation of this AMP are

documented in the Audit and Review Report. The staff reviewed the exceptions and the

associated justifications to determine whether the AMP, with the exceptions, remains adequate

to manage the aging effects for which it is credited.

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The staff reviewed those portions of the BWR CRDRL Nozzle Program for which the applicant

claimed consistency with GALL AMP XI.M6 and found them consistent. The staff found the

applicant's BWR CRDRL Program acceptable because it conforms to the recommended GALL

AMP XI.M6 with exceptions.

In the ALRA, the applicant stated that its BWR CRDRL Nozzle Program is consistent with GALL

AMP XI.M6 with an exception to the Program Description in GALL AMP XI.M6 involving the

ASME Code edition used as the basis for the Section Xl requirements. GALL AMP XI.M6

identifies the 1995 Edition (including the 1996 Addenda) of ASME Section Xl as the basis for

the GALL CRDRL Nozzle Program. The NMP ISI Program will not comply with the edition and

addenda of ASME Section Xl cited in the GALL Report because the program is updated to the

latest edition and addenda of ASME Section XI as mandated by 10 CFR 50.55a prior to the

start of each inspection interval. The acceptability of the NMP1 CRDRL Nozzle Program in

meeting the augmented inspection requirements established in NUREG-0619 is documented in

NRC Safety Evaluation Report dated February 5, 1999.

In the ALRA, the applicant stated that the exceptions were found acceptable in the February 5,

1999, NRC Safety Evaluation Report. As mandated by 10 CFR 50.55a, UT examinations are

performed according to the ASME Section Xl Appendix VIII 1995 Edition with the 1996

Addenda. As documented in the Audit and Review Report, the staff also noted that the

applicant's ASME code of record for ASME Section Xl ISI (Subsections IWB, IWC, and IWD) is

valid for a 10-year inspection interval under the CLB. At present an ASME Section Xl IS[

(Subsection IWB, IWC, and IWD) program is approved for use on an ASME Code 10-year ISI

interval-specific basis. However, the applicant will have to request 12 months prior to each

interval approval to use the ASME Section XI ISI (Subsection IWB, IWC, and IWD) Program for

the specific intervals during the period of extended operation under 10 CFR 50.55a,. Therefore,

the staff determined that the ASME Section Xl Code Edition as referenced in 10 CFR 50.55a in

effect 12 months prior to each inspection interval is acceptable for the period of extended

operation and the staff found this exception acceptable.

In addition in the ALRA, the applicant stated that it takes exceptions to the GALL Report

"detection of aging effects," "monitoring and trending," and "acceptance criteria" program

elements. The three exceptions to GALL AMP XI.M6 are (1) the NMP ISI Program does not

comply with the specified edition and addenda of ASME Section XI cited in the GALL Report

because the program is updated to the latest edition and addenda of ASME Section Xl as

mandated by 10 CFR 50.55a prior to the start of each inspection interval, (2) the NMP program

uses enhanced UT inspection techniques instead of PT inspections to satisfy the

recommendations of NUREG-0619 (now superseded by Appendix VIII to ASME Section XI,

Division 1, 1995 Edition with the 1996 Addenda), and (3) the NMP program uses an inspection

frequency of every 10 years versus every sixth refueling outage or 90 startup/shutdown cycles

specified in NUREG-0619.

In the ALRA, the applicant stated that it has evaluated each of these exceptions and

determined that its CRDRL Nozzle Program adequately manages the effects of aging on the

CRDRL. The applicant evaluated each of these exceptions and determined that its CRDRL

Nozzle Program is consistent with GALL AMP XI.M6. After review of operating experience for

the applicant's BWR CRDRL Nozzle Program, the staff found this exception acceptable.

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Operating Experience. In ALRA Section B2.1.37, the applicant explained that UT examinations

of the Unit 1 CRDRL nozzle performed during refueling outages using automated test

equipment qualified according to Appendix VIII to ASME Section Xl, Division 1, 1995 Edition

with the 1996 Addenda, found no indications. The UT examination using automated test

equipment has been demonstrated to be capable of reliably detecting flaws greater than or

equal to a 0.25 inch depth. No industry experience was identified that indicates that existing

programs and practices will not be effective in the timely identification of CRDRL nozzle

cracking.

The staff reviewed the operating experience stated in the ALRA and interviewed the applicant's

technical personnel to confirm that the plant-specific operating experience revealed no

degradation not bounded by industry experience.

After review of industry and plant-specific operating experience and discussions with the

applicant's technical personnel, the staff concludes that there is reasonable assurance that the

applicant's BWR CRDRL Nozzle Program will manage adequately the aging effects and aging

effects mechanisms identified in the ALRA for which this AMP is credited.

UFSAR Supplement. In ALRA Section A1.1.39, the applicant provided the UFSAR supplement

for the BWR CRDRL Nozzle Program. The staff reviewed this section and determined that the

information in the supplement provides an adequate summary description of the program, as

required by 10 CFR 54.21(d).

Conclusion. On the basis of its review and audit of the applicant's BWR CRDRL Nozzle

Program, the staff determined that those program elements for which the applicant claimed

consistency with the GALL Report are consistent with the GALL Report. In addition the staff

reviewed the exceptions and the associated justifications, and determined that the AMP, with

the exceptions, is adequate to manage the aging effects for which it is credited.The staff

concludes that there is reasonable assurance that the applicant has demonstrated that the

effects of aging will be adequately managed so that the intended functions will be maintained

consistent with the CLB for the period of extended operation, as required by

10 CFR 54.21(a)(3). The staff also reviewed the UFSAR supplement for this AMP and

concludes that it provides an adequate summary description of the program, as required by

10 CFR 54.21(d).

3.0.3.2.25 Protective Coating Monitoring and Maintenance Program

Summary of Technical Information in the Amended Application. In ALRA Section B2.1.38, the

applicant described the Protective Coating Monitoring and Maintenance Program, stating that

this is an existing program that is consistent, with exceptions and enhancements, with GALL

AMP XI.S8, "Protective Coating Monitoring and Maintenance Program." The Protective Coating

Monitoring and Maintenance Program is described in the NMP1 and NMP2 responses to

GL 98-04, "Potential for Degradation of the Emergency Core Cooling System and the

Containment Spray System after a Loss-Of-Coolant Accident because of Construction and

Protective Coating Deficiencies and Foreign Material in Containment." The program was

developed according to ANSI N1 01.4-1972 referenced in RG 1.54, June 1973, along with

ANSI/ASME NQA-1-1983. The NMP program is a "comparable program" as described in GALL,

Chapter XI, Program XI.S8, Protective Coating Monitoring and Maintenance Program, which is

an acceptable AMP for license renewal. The program applies to Service Level 1 protective

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coatings inside the NMP1 primary containment and items within the torus [outside surface of

the vent (ring) header and downcomer, inside surface of the vent piping, ring header, vent

header junctions, and downcomers] and the NMP2 primary containment. The NMP2

suppression pool (wetwell) is not included because it is primarily stainless steel and does not

have Service Level 1 coatings. Coating conditions monitored by this program include blistering,

cracking, peeling, loose rust, and physical/mechanical damage. When localized degradation of

a coating is identified, the affected area is evaluated by engineering and is scheduled for repair,

replacement, or removal, as needed. The condition assessments and resulting repair,

replacement, or removal activities ensure that the amount of coatings subject to detachment

from the substrate during a loss of coolant accident (LOCA) is minimized to ensure

post-accident operability of the emergency core cooling system (ECCS) suction strainers.

Staff Evaluation. During its audit and review, the staff confirmed the applicant's claim of

consistency with the GALL Report. Details of the staffs audit evaluation of this AMP are

documented in the Audit and Review Report. The staff reviewed the exceptions and

enhancements and the associated justifications to determine whether the AMP, with the

exceptions and enhancements, remains adequate to manage the aging effects for which it is

credited.

The staff reviewed those portions of the Protective Coating Monitoring and Maintenance

Program for which the applicant claimed consistency with GALL AMP XI.S8 and found them

consistent. The staff found the applicant's Protective Coating Monitoring and Maintenance

Program acceptable because it conforms to the recommended GALL AMP XI.S8, "Protective

Coating Monitoring and Maintenance Program," with exceptions and enhancements.

In the ALRA, the applicant stated that its Protective Coating Monitoring and Maintenance

Program is consistent with GALL AMP XI.S8 with an exception to the GALL Report "preventive

actions" and "operating experience" program elements. The Protective Coating Monitoring and

Maintenance Program is not credited in the ALRA for the prevention of corrosion of carbon

steel components in the containment; however, the program monitors for rust not intact as a

potential debris source for ECCS suction strainers. Therefore, as documented in the Audit and

Review Report, the applicant stated that operating experience pertaining to only the

degradation of coatings and their potential clogging of the ECCS strainers is relevant to license

renewal.

The staff found this exception acceptable because the applicant's Protective Coating Monitoring

and Maintenance Program indeed is not credited in the amended license renewal application for

the prevention of corrosion of carbon steel components in the NMP1 or NMP2 containment.

Other NMP AMPs are credited in the ALRA for the detection of loss of material by corrosion of

carbon steel components in the NMP1 or NMP2 containment. The applicant's Protective

Coating Monitoring and Maintenance Program is credited in the ALRA only for ensuring that the

amount of coatings subject to detachment from the substrate during a LOCA is minimized for

post-accident operability of the ECCS suction strainers.

The applicant also stated in the ALRA that it takes exceptions to the GALL Report "parameters

monitored/inspected," "detection of aging effects," "monitoring and trending," and "acceptance

criteria" program elements. The Protective Coating Monitoring and Maintenance Program will

be enhanced following the guidance within ASTM D 5163-05a, "Standard Guide for Establishing

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Procedures to Monitor the Performance of Coating Service Level 1 Coatings Systems in an

Operating Nuclear Power Plant," instead of ASTM D 5163-96 as specified in GALL AMP XI.S8.

In the ALRA, the applicant stated that the use of the guidance from ASTM D 5163-05a instead

of ASTM D 5163-96 is acceptable because ASTM D 5163-05a is the most recently issued

standard and incorporates the latest industry guidance on protective coatings. In addition, as

documented in the Audit and Review Report, the applicant stated that ASTM D 5163-05a will be

utilized because this consensus standard was revised to correct previous errors embedded

within the qualification standards. The newer standard provides guidance on the qualification of

the individual(s) performing the actual coatings condition assessment while the GALL

Report-referenced standard is silent on that qualification. The older standard recommends that

inspectors and inspection coordinators be Level II Coatings Inspectors. This is an inappropriate

recommendation for the inspection coordinator since the Level II inspector qualification

requirement is invoked only for those enforcing compliance with 10 CFR 50 Appendix B

Criterion IX (Special Processes) by coating film thickness readings (required when performing

qualitative follow-up inspections) and inspections while restoring a coating system but not by

condition assessments which the coordinator facilitates.

The staff found this exception acceptable because other than the improvement changes

between ASTM D 5163-05a and ASTM D 5163-96 discussed by the applicant the documents

are essentially the same. A terminology paragraph has been added to ASTM D 5163-05a which

shifts the paragraph numbering scheme by one. The element referenced in GALL AMP XI.S8 to

the paragraph numbers in ASTM D 5163-96 would have a different paragraph number

referenced in ASTM D 5163-05a but there is little or no change to the content of the ASTM.

standard.

The applicant also stated In the ALRA that it takes exception to the GALL Report "acceptance

criteria" program element. The Protective Coating Monitoring and Maintenance Program will

vary the guidance of ASTM D 5163-05a paragraphs 10.2.2 and 10.2.3 on the measurement of

cracks and peeling coating. Rather, the applicant will use visual methods to estimate the size of

any defective areas. Once an area with cracks, peeling, or delaminated coating has been

detected visual estimation will quantify the surface area. Conservative estimates will be made

using known structural dimensions. This technique is acceptable for the purposes of quantifying

the total amount of degraded coatings.

The staff found the applicant's explanation for the exceptions acceptable in that taking definitive

measurements of cracking, peeling, or delaminated coatings in the NMP1 and NMP2

containments is an unnecessary burden which adds no value. Once a coatings area has been

identified as degraded an experienced coatings person can use visual estimation techniques to

quantify the square footage. Conservative estimates of the size of these areas will result in a

conservative total amount of degraded coatings that then can be compared to the total amount

of permitted degraded coatings to ensure post-accident operability of the ECCS suction

strainers. Conservative estimates of the amount of degraded coatings ensure actual margin for

ECCS suction strainer operability. Should the conservative estimate of degraded coatings

exceed the permitted amount more definitive measurements then could be taken or coating

repairs immediately undertaken.

No credit for coatings is taken in the prevention of corrosion; therefore, ASTM D 5163-96 is

used instead of ASTM D 5163-05a because of improvement changes, and visual estimation

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techniques are conservative. The siaff's review of operating experience for the applicant's

Protective Coating Monitoring and Maintenance Program found these exceptions to be

acceptable.

In the ALRA, the applicant stated that its Protective Coating Monitoring and Maintenance

Program is consistent with GALL AMP XI.S8 with an enhancement to meet the GALL Report "parameters monitored/inspected," "detection of aging effects," "monitoring and trending," and "acceptance criteria" program elements. Program administrative controls will be enhanced to

incorporate specific details consistent with requirements in ASTM D 5163-05a (NMP1

Commitment 34, NMP2 Commitment 32).

In the ALRA, the applicant stated that its Protective Coating Monitoring and Maintenance

Program administrative controls will be enhanced to specify the visual examination of coated

surfaces for any visible defects including blistering, cracking, flaking, peeling, and physical or

mechanical damage. Also program administrative controls will be enhanced to (1) inspect

coatings every refueling outage versus every 24 months, (2) set minimum qualifications for

inspection personnel, inspection coordinators, and inspection results evaluators, (3) perform

thorough visual inspections in areas noted as deficient concurrently with general visual

inspections, and (4) specify the types of instruments and equipment that may be used for

inspections. In addition program administrative controls will be enhanced to require (1) reviews

of the previous two monitoring reports before the condition assessment and (2) guidelines for

prioritization of repair areas to be monitored until they are repaired. Finally, program

administrative controls will be enhanced to require inspection results evaluators td determine

which areas are unacceptable and to initiate corrective action.

The staff determined that enhancement of the administrative controls for the applicant's

Protective Coating Monitoring and Maintenance Program is consistent with the specific GALL

Report referenced recommendations of ASTM D 5163-96 (now ASTM D 5163-05a after

exception) and will ensure the amount of Service Level 1 coatings inside the NMP1 primary

containment and on surfaces within the torus (outside surface of the vent (ring) header and

downcomer, inside surface of the vent piping, ring header, vent header junctions, and

downcomers) and inside the NMP2 primary containment subject to detachment from the

substrate during a LOCA is minimized for post-accident operability of the ECCS suction

strainers. In addition the staff determined that by revising the program administrative controls

for these specific items the program will be consistent with the recommendations in GALL

AMP XI.S8 considering the exception to the use of the 1996 Edition of ASTM D 5163. Because

adding these specific administrative controls will make the applicant's program consistent with

GALL AMP XI.S8 the staff found this enhancement acceptable. These changes to the

applicant's program will provide assurance that the effects of aging will be adequately

managed.

Operating Experience. In ALRA Section B2.1.38, the applicant explained that the Protective

Coating Monitoring and Maintenance Program is not credited in the ALRA for prevention of

corrosion of carbon steel. NMP has implemented a Protective Coating Monitoring and

Maintenance Program consistent with the response to GL 98-04. The response to GL 98-04

described program attributes, including design and licensing basis, procurement, control of

coating application, quality assurance, monitoring, and maintenance of Service Level 1

coatings. Industry operating experience events pertaining to Service Level 1 coatings are

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evaluated for applicability to NMP. If determined to be applicable, these events are entered into

the site CAP for determining any required corrective or preventive actions.

As documented in the Audit and Review Report, the staff also reviewed the summary of specific

operating experience. The staff determined that the applicant's Protective Coating Monitoring

and Maintenance Program has been effective in detecting degraded coatings at various areas

within the NMP1 and NMP2 primary containments during refueling outages. To find some areas

of degraded coatings in containments during refueling outages is typical of industry experience.

Once the degraded coating areas were detected the applicant's CAP then either removed the

degraded coatings, repaired the degraded coatings, or deferred repair while maintaining the

total below the permitted amount subject to detachment from the substrate during a LOCA to

ensure post-accident operability of the ECCS suction strainers.

The staff reviewed the operating experience stated in the ALRA and interviewed the applicant's

technical personnel to confirm that the plant-specific operating experience revealed no

degradation not bounded by industry experience.

After review of industry and plant-specific operating experience and discussions with the

applicant's technical personnel the staff concludes that there is reasonable assurance that the

applicant's Protective Coating Monitoring and Maintenance Program will manage adequately

the aging effects and aging effects mechanisms identified in the ALRA for which this AMP is

credited.

UFSAR and USAR Supplements. In ALRA Sections A1.1.40 and A2.1.38, the applicant

provided the respective UFSAR and USAR supplements for the Protective Coating Monitoring

and Maintenance Program. The staff reviewed these sections and determined that the

information in the supplements provide adequate summary descriptions of the program, as

required by 10 CFR 54.21(d).

Conclusion. On the basis of its review and audit of the applicant's Protective Coating Monitoring

and Maintenance Program, the staff determined that those program elements for which the

applicant claimed consistency with the GALL Report are consistent with the GALL Report. In

addition the staff reviewed the exceptions and the associated justifications, and determined that

the AMP, with the exceptions, is adequate to manage the aging effects for which it is credited.

Also, the staff has reviewed the enhancements and confirmed that the implementation of the

enhancements prior to the period of extended operation would result in the existing AMP being

consistent with the GALL Report AMP to which it was compared.The staff concludes that there

is reasonable assurance that the applicant has demonstrated that the effects of aging will be

adequately managed so that the intended functions will be maintained consistent with the CLB

for the period of extended operation, as required by 10 CFR 54.21(a)(3). The staff also

reviewed the UFSAR and USAR supplements for this AMP and concludes that they provide an

adequate summary description of the program, as required by 10 CFR 54.21(d).

3.0.3.2.26 Fatigue Monitoring Program

Summary of Technical Information in the Amended Application. In ALRA Section B3.2, the

applicant described the Fatigue Monitoring Program, stating that this is an existing program that

is consistent, with enhancements, with GALL AMP X.M1, "Metal Fatigue of Reactor Coolant

Pressure Boundary." The Fatigue Monitoring Program (FMP) manages the fatigue life of reactor

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coolant pressure boundary components by tracking and evaluating key plant events. Events

were selected based upon plant-specific evaluations of the most fatigue-limited locations for

critical components, including those discussed in NUREG/CR-6260. The FMP monitors

operating transients to-date, calculates cumulative usage factors to-date, and directs

performance of engineering evaluations to develop preventive and mitigative measures in order

not to exceed the design limit on fatigue usage. The effects of reactor coolant environment will

be considered through the evaluation of, as a minimum, those components selected in

NUREG/CR-6260 using the appropriate environmental fatigue factors. The FMP provides an

analytical basis for confirming that the number of cycles established by the analysis of record

will not be exceeded before the end of the period of extended operation. In order to determine

cumulative usage factors (CUFs) more accurately, the FMP will implement FatiguePro fatigue

monitoring software.

Staff Evaluation. During its audit and review, the staff confirmed the applicant's claim of

consistency with the GALL Report. Details of the staff's audit evaluation of this AMP are

documented in the Audit and Review Report. The staff reviewed the enhancements and the

associated justifications to determine whether the AMP, with the enhancements, remains

adequate to manage the aging effects for which it is credited.

The staff reviewed those portions of the FMP for which the applicant claimed consistency with

GALL AMP X.M1 and found them consistent. The staff found the applicant's Fatigue Monitoring

Program acceptable because it conforms to the recommended GALL AMP X.M1, "Metal

Fatigue of Reactor Coolant Pressure Boundary," with enhancements.

In the ALRA, the applicant stated that FMP is consistent with GALL AMP X.M1 with

enhancements. As stated In the ALRA, the enhancement in meeting the GALL Report "preventive actions" program element revises applicable existing procedures to ensure that the

procedures address the following:

The FMP will be enhanced with guidance for the use of the FatiguePro software

package and updated methodology for environmental fatigue factors in

establishing updated fatigue life calculations for components.

((NMP1 Commitment 5, NMP2 Commitment 4)

In the ALRA, the applicant stated that the FMP will provide guidance for the use of FatiguePro

and methodology for calculation of environmental fatigue factors.

As documented in the Audit and Review Report, the staff evaluated the applicant's existing

FMP and noted that it had identified correctly the need for more sophisticated methods to

determine adequate margin to fatigue limits. Improved calculation of environmental fatigue

factors is also necessary. The staff determined that the use of FatiguePro is an appropriate

method to improve monitoring and, taken together with improved methodology for calculation of

environmental fatigue factors, will provide assurance that fatigue damage will be adequately

managed and found this enhancement acceptable. These changes to the applicant's program

will provide assurance that the effects of aging will be adequately managed.

In addition in the ALRA, the applicant stated that enhancements in meeting the GALL Report "parameters monitored/inspected" program element revises procedures to address the

following:

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Safety relief valve actuations will be added to the list of key plant events

(transients) that are monitored for NMP1 (NMP1 Commitment 11).

For the critical reactor vessel component locations, shown in Table 4.3-3 (NMP1) and

Table 4.3-4 (NMP2) of the ALRA, additional usage will be added to the baseline CUF using one

of the methods described in ALRA Section 4.3. (NMP Commitment 6 and NMP2

Commitment 5)

Transients contributing to fatigue usage of the feedwater system nozzles will be tracked by the

FMP with additional usage added to the baseline CUF using the stress based fatigue described

in ALRA Section 4.3. (NMP Commitment 7 and NMP2 Commitment 7)

Develop a baseline CUF for the specified portions of the following systems: (1) feedwater/high

pressure coolant injection, (2) core spray, (3) reactor water cleanup (piping inside the reactor

coolant pressure boundary), and (4) reactor recirculation (and associated shutdown cooling

systems lines). If the baseline CUF for a specified portion of a system exceeds 0.4, the limiting

locations may require additional monitoring to demonstrate compliance over the period of

extended operation. (NMP Commitment 8)

Assess the impact of the reactor coolant environment on a sample of critical component

locations, including locations equivalent to those identified in NUREG/CR-6260, as part of the

FMP. These locations will be evaluated by applying environmental correction factors to existing

and future fatigue analyses. (NMP1 Commitment 9 and NMP2 Commitment 10)

The FMP will track transients specific to the emergency cooling system with additional usage

added to the baseline CUF for the emergency condensers as described in ALRA 4.3 (NMP1

Commitment 10)

Enhance the FMP to (1) ensure that fatigue usage of the torus attached piping and other torus

locations does not exceed the design limits, add electromatic relief valve lifts as a transient to

be counted by the FMP and (2) add the two highest usage torus attached piping locations, the

12-inch core spray suction line fo core spray pump 111 that enters the torus at penetration

XS-337 and the 3-inch containment spray line that enters the torus at penetration XS-326 as

fatigue monitoring locations. (NMP1 Commitment 11)

For the bounding locations for ASME Class 1 systems, transients contributing to fatigue usage

will be tracked by the FMP with additional usage added to the baseline CUF using the design

cycle based fatigue method described in ALRA Section 4.3. If a bounding location with a current

CUF value less than or equal to 0.1 could have its CUR value exceed 0.1 before the end of the

period of extended operation, then the impact on the original break postulation calculations will

be assessed. (NMP2 Commitment 6)

If fatigue monitoring of ASME Class 1 piping (described in ALRA Section 4.3.2) indicates higher

fatigue usage than expected, non-ASME Class piping will be evaluated for possible fatigue

concerns. (NMP2 Commitment 8)

Revise or evaluate the CUF evaluations for the shroud, core support plate and studs, and jet

pumps to remove conservatism and/or encompass the period of extended operation (e.g., a

more extensive fatigue analysis of the jet pumps will be performed). (NMP2 Commitment 9)

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For penetrations listed in ALRA Table 4.6-4, transients contributing to fatigue usage will be

tracked by the FMP with additional usage added to the baseline CUF using the cycle based

fatigue method described in ALRA Section 4.3. (NMP2 Commitment 11)

In the ALRA, the applicant stated that safety relief valve actuations will be added to the list of

key plant events monitored for NMP1. (Such actuations are already monitored for NMP2). The

acceptability of this enhancement is discussed by the staff in SER Section 4 in the evaluation of

RAI 4.6.2-1.

The staff reviewed the rest of enhancements to the "parameters monitored/inspected" program

elements of the GALL Report. Based on the review, the staff found that the additional

enhancements adequately monitors all plant transients that cause cyclic strains, which could

contribute to the fatigue usage factor. Therefore, the staff found these enhancements

acceptable.

Operating Experience. In ALRA Section B3.2, the applicant explained that it has reviewed both

industry and plant-specific operating experience relating to the FMP. In instances where the

potential existed to exceed CUFs before the end of plant life, the engineering analyses showed

that actual margins were larger than initially estimated. A result of these fatigue evaluations was

the recognition that the FMP could benefit from the use of analytical fatigue software such as

FatiguePro. CRs written in 2003 identified opportunities for programmatic improvement. This

led to the establishment of a comprehensive FMP document, additional reviews of cycle records

with an emphasis on NMP1, and a proposal for the implementation of fatigue analysis software.

The staff reviewed the operating experience stated in the ALRA and interviewed the applicant's

technical personnel. At NMP there are components at or near the limit of the allowed cycle

count established under the original TLAA. Evaluations confirm that for all locations, even the

most limiting, significant margin remains below a CUF=1.0 and the proposed program will

enable the applicant to keep within that limit.

After review of industry and plant-specific operating experience and discussions with the

applicant's technical personnel, the staff concludes that there is reasonable assurance that the

applicant's Fatigue Monitoring Program will manage adequately the aging effects and aging

effects mechanisms identified in the ALRA for which this AMP is credited.

UFSAR and USAR Supplements. In ALRA Sections A1.1.16 and A2.1.16, the applicant

provided the respective UFSAR and USAR supplements for the Fatigue Monitoring Program.

The staff reviewed these se~tions and determined that the information in the supplements

provide adequate summary descriptions of the program, as required by 10 CFR 54.21(d).

Conclusion. On the basis of its review and audit of the applicant's Fatigue Monitoring Program,

the staff determined that those program elements for which the applicant claimed consistency

with the GALL Report are consistent with the GALL Report. Also, the staff has reviewed the

enhancements and confirmed that the implementation of the enhancements prior to the period

of extended operation would result in the existing AMP being consistent with the GALL Report

AMP to which it was compared.The staff concludes that there is reasonable assurance that the

applicant has demonstrated that the effects of aging will be adequately managed so that the

intended functions will be maintained consistent with the CLB for the period of extended

operation, as required by 10 CFR 54.21 (a)(3). The staff also reviewed the UFSAR and USAR

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supplements for this AMP and concludes that they provide an adequate summary description of

the program, as required by 10 CFR 54.21(d).

3.0.3.2.27 Non-EQ Inaccessible Medium Voltage Cables Program (NMP2 Only)

Summary of Technical Information in the Amended Application: In the NMP ALRA Appendix B,

the applicant deleted Section 62.1.31, "Non-EQ Inaccessible Medium Voltage Cables

Program," which was submitted in the original LRA. In ALRA Table 3.6.1, "Summary of Aging

Management Program for the Electrical and I&C Systems Components Evaluated In Chapter VI

of NUREG-1801," the applicant stated that NMP1 has no inaccessible medium-voltage cables

within scope of license renewal. It also stated that NMP2 has no inaccessible medium-voltage

cables within the scope of license renewal, meeting the GALL Report program criteria requiring

aging management.

Staff Evaluation: During its AMP and AM audits (weeks of September 19 and October 24, 2005)

at NMPNS the staff reviewed engineering report NER-2E-032, "Identification of NMP2 Non-EQ

Inaccessible Medium Voltage Cables in the Scope of the License Renewal Program," and found

at least one underground cable within the scope of license renewal requiring an AMP. Upon this

finding the staff requested the applicant whether there are other medium voltage cables (e.g.,

2kV to 35 kV) within the scope of license renewal for both NMP1 and NMP2 energized greater

than 25 percent of the time and located underground. The staff also requested that the

applicant specifically address in its response such cable installed for plant service water

systems. In its letter dated December 1, 2005, the applicant stated that NMP1 has no

inaccessible medium-voltage cables within the scope of license renewal exposed to significant

moisture simultaneously with significant voltage. The only medium-voltage cables at NMP1

installed underground and energized greater 25 percent of the time are used to power systems

not within the scope of license renewal or to power equipment not related to any plant systems.

The applicant stated-that the normal service water system pump motors are powered via

medium-voltage cables routed in cable trays, wall sleeves, or conduit installed inside the NMP1

turbine building and screen house, not underground. The emergency service water system

pump motors are powered via low-voltage (<2kV) cables and, therefore, these cables are not

within the scope of the GALL XI.E3 program.

For NMP2 the applicant stated that it has inaccessible medium-voltage cables within the scope

of license renewal as these cables are exposed to significant moisture simultaneously with

significant voltage when energized. The applicant identified 18 NMP2 cables (including service

water pump cables) within the scope of license renewal and thus requiring an AMP to manage

aging effects. The service water system pump motors are powered via medium-voltage cables

from the safety-related 4.16 kV switchgears. These cables are routed underground in duct

lines. Because these cables are installed underground and the service water system pump

motors are energized greater than 25 percent of the time these cables require aging

management and thus are in the scope of the GALL XI.E3 program. In this letter the applicant

also stated that it will revise NER-2E-032 to identify medium-voltage cables requiring aging

management, develop an AMP and the plant-specific database for the GALL AMP XI.E3, and

revise the ALRA to incorporate GALL AMP XI.E3. The staff found the applicant's response

acceptable.

The applicant further stated in its letter dated December 1, 2005, that the Non-EQ Inaccessible

Medium Voltage Cables Program is credited with managing aging effects through periodic

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maintenance activities that minimize or prevent the exposure of in-scope cables to significant

moisture or standing water. An adverse variation in environment would be significant if it could

increase the rate of aging of a component appreciably or have an immediate adverse effect on

operability. In this aging management program, periodic actions such as inspecting for water

collection in cable manholes, are taken to prevent cables from being exposed to significant

moisture. Additionally, in-scope medium-voltage cables exposed to significant moisture and

significant voltage are tested for the condition of the conductor insulation. The specific type of

test would be power factor, partial discharge, or other testing both state of the art and

consistent with the latest industry guidance for detecting deterioration of the insulation system

due to wetting as described in EPRI TR-103834-P1-2. This program considers the technical

information and guidance of NUREG/CR-5643, IEEE Std. P1205, SAND96-0344, and EPRI

TR-1 09619.

In the ALRA Section B2.1.30 the applicant stated that the Non-EQ Inaccessible

Medium-Voltage Cables Program will be consistent with GALL AMP XI.E3 and the most recent

industry and regulatory precedence after enhancements are incorporated.

The specific testing for the in-scope medium-voltage cables associated with motors was

detailed in procedure S-EPM-MPM-V080. Currently credited methods include polarization index

and hi-pot testing. The specific testing associated with the cables supplying the auxiliary

transformers will be detailed in an enhancement to procedure S-EPM-GEN-700. The staff

reviewed procedure S-EPM-MPM-V080 and in discussion with the applicant the staff expressed

a concern that hi-pot testing may affect the life of medium-voltage cables adversely. In

response to the staffs concern in the letter dated December 1, 2005, the applicant stated that it

will develop a new testing procedure specific to those cables requiring aging management

under this program. The specific type of test will be a proven test for detecting deterioration of

the insulation system as described in EPRI TR-103834-P1-2, power factor, partial discharge, or

other testing state of the art and consistent with the latest industry guidance at the time the test

is performed.

The applicant also made the following commitment

NMP2 Commitment 38:

Enhance the Inaccessible Medium-Voltage Cables not Subject to 10 CFR 50.49

Environmental Qualification Requirements Program as follows: (1) Expand the scope of

the existing procedure to provide for manhole inspections and water removal, (2)

develop a new testing procedure specific to those cables requiring aging management

under this program. The specific type of test performed will be a proven test for

detecting deterioration of the insulation system due to wetting as described in EPRI

TR-103834-P1-2, such as power factor, partial discharge, or other testing that is both

state of the art and consistent with the latest industry guidance at the time the test is

performed, (3) establish requirement to test cables subject to aging management prior

to, and every 10 years during the period of extended operation, and (4) establish

maintenance requirement to inspect and remove water, as necessary, from manholes

serving cables subject to aging management. The inspection frequency will be based

upon actual plant experience with water accumulation in the manhole, but in any event,

will be at least once every two years. The first inspection will be completed prior to the

period of extended operation.

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The staff found the applicant's response and commitment acceptable because the testing

methods, preventive actions taken, and the testing frequency are consistent with the updated

GALL AMP XI.E3.

For the program elements of the Non-EQ Inaccessible Medium-Voltage Cables Program stated

by the applicant to be consistent with GALL AMP XI.E3 the staff determined that these conform

to the corresponding GALL AMP XI.E3 program elements and acceptance criteria.

The applicant stated in December 1, 2005, letter that four enhancements to GALL Report

AMP XI.E3 program description, "parameters monitored/inspected," "preventive actions," and

"detection of aging effects" program elements will be implemented: Expand the scope of the

existing manhole inspection procedure to include cables within the scope of the program.

Develop a new testing procedure specific to cables requiring aging management under this

program. The specific type of test performed will be power factor, partial discharge, or other

testing state of the art at the time the test is performed and consistent with the latest industry

guidance for detecting deterioration of the insulation system as described in EPRI

TR-103834-P1-2. Establish maintenance requirements to test cables subject to aging

management prior to and every 10 years during the period of extended operation. Establish a

maintenance requirement to inspect for and remove water as necessary from manholes serving

cables subject to aging management. The inspection frequency will be based on actual plant

experience with water accumulation in the manhole but in any event will be at least once every

two years. The first inspection will be completed prior to period of extended operation.

The staff found the enhancements stated by the applicant acceptable because they will not

adversely impact the ability of this AMP to manage the affects of aging. Periodic actions as

inspecting for water collection in cable manholes and draining water as needed are taken to

prevent cable exposure to significant moisture. These preventive actions are not sufficient to

assure that water is not trapped elsewhere in the raceways. In addition in-scope, medium

voltage cables exposed to significant moisture and significant voltage are tested for the

condition of the conductor insulation. The specific type of test will be power factor, partial

discharge, and polarization index as described in EPRI TR-103834-Pl-2, or other state of the

art proven test for detecting deterioration of the insulation system due to wetting. For these

reasons the staff found the enhancements acceptable.

Operating Experience. The applicant stated in ALRA Section B2.1.31 that NMPNS has

reviewed both industry and plant-specific operating experience relating to the Non-EQ

Inaccessible Medium Voltage Cables Program. Although infrequent there have been some

failures of medium voltage cables at other plants due to moisture intrusion. There have been no

such events at NMP2 but industry studies suggest that a regular cable testing program can

detect degradation of non-EQ inaccessible medium voltage cables before there is an insulation

failure.

The staff reviewed the operating experience stated in the ALRA and interviewed the applicant's

technical personnel to confirm that the plant-specific operating experience revealed no

degradation not bounded by industry experience.

After review of the above operating experience and on discussions with the applicant's technical

personnel the staff concludes that there is reasonable assurance that the applicant's Non-EQ

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Inaccessible Medium-Voltage Cables Program adequately manage the aging effects and aging

effects mechanisms identified in the ALRA for which this AMP is credited.

USAR Supplement. In its letter dated December 1, 2005, the applicant proposed its USAR

supplement for the non-EQ inaccessible medium voltage cables program in ALRA

Section A2.1.26 for NMP2. The applicant stated that the Non-EQ Inaccessible Medium Voltage

Cables Program provides reasonable assurance that the intended function of inaccessible

medium-voltage cables not subject to 10 CFR 50.49 environmental qualification requirements

and exposed to adverse localized environments caused by moisture while energized will be

maintained consistent with the CLB through the period of extended operation. An adverse local

environment is a condition in a limited plant area significantly more severe than the specified

service environment for the cable. An adverse variation in environment is significant if it could

appreciably increase the rate of aging of a component or have an immediate adverse effect on

operability. In this aging management program such periodic actions as inspecting for water

collection in cable manholes and draining water as needed are taken to prevent cable exposure

to significant moisture. Additionally, in-scope medium-voltage cables exposed to significant

moisture and significant voltage are tested for the condition of the conductor insulation. The

specific type of test performed will be power factor, partial discharge as described in EPRI

TR-103834-P1-2, or other state of the art testing at the time the test is performed proven for

detecting deterioration of the insulation system due to wetting. The program considered the

technical information and guidance provided in applicable industry publications.

Enhancements to the non-EQ inaccessible medium voltage cables program include:

* Expand the scope of the existing procedures to manhole inspection and water removal.

" Develop new testing procedures specific to those cables requiring aging management

under this program. The specific type of test will be power factor, partial discharge, or

other testing both state of the art and consistent with the latest industry guidance at the

time the test is performed proven for detecting deterioration of the insulation system due

to wetting as described in EPRI-TR-103834-P1-2.

Establish maintenance to test cables subject to aging management prior to and every 10

years during the period of extended operation.

Establish maintenance requirement to inspect for and remove water as necessary from

manholes serving cables subject to aging management. The inspection frequency will

be based on actual plant experience with water accumulation in the manhole but in any

event will be at least once every two years. The first inspection will be completed prior to

the period or extended operation.

Enhancements will be implemented prior to entering the period of extended operation.

The staff reviewed these USAR supplements and confirmed that they provide an adequate

summary description of the program as identified in the SRP-LR FSAR supplement table and

as required by 10 CFR 54.21(d).

Conclusion. On the basis of its audit and review of the applicant's Non-EQ Inaccessible

Medium-Voltage Cables program the staff determined that those program elements for which

the applicant claimed consistency with the GALL Report are indeed consistent. In addition the

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staff reviewed the enhancements to the GALL Report and confirmed that the implementation of

enhancements prior to the period of extended operation would make the AMP consistent with

the GALL Report AMP to which it was compared.The staff concludes that there is reasonable

assurance that the applicant has demonstrated that the effects of aging will be adequately

managed so that the intended function will be maintained consistently with the CLB during the.

period of extended operation as required by 10 CFR 54.21(a)(3). The staff also reviewed the

proposed USAR supplements for this AMP and concludes that they provide an adequate

summary description of the program as required by 10 CFR 54.21(d).

3.0.3.3 AMPs That Are Not Consistent with or Not Addressed in the GALL Report

In ALRA Appendix B, the applicant identified that the following AMPs were plant-specific:

* Preventive Maintenance Program

* Systems Walkdown Program

* Non-Segregated Bus Inspection Program

* Fuse Holder Inspection Program

* Non-EQ Electrical Cable Metallic Connections Inspection Program

* Wooden Power Pole Inspection Program (NMP2 Only)

* Torus Corrosion Monitoring Program (NMP1 Only)

For AMPs that are not consistent with or not addressed by the GALL Report, the staff

performed a complete review of the AMPs to determine if they were adequate to monitor or

manage aging. The staff's review of these plant-specific AMPs is documented in the following

sections of this SER.

3.0.3.3.1 Preventive Maintenance Program

Summary of Technical Information in the Amended Application. In ALRA Section B2.1.32, the

applicant described the Preventive Maintenance Program, stating that this is an existing,

plant-specific program. The Preventive Maintenance Program consists of the appropriate ten

elements described in SRP-LR Appendix A. The Preventive Maintenance Program manages

aging effects for SSCs within the scope of licence renewal. The program provides for

performance of various maintenance activities on a specified frequency based on vendor

recommendation and operating experience..

The key elements of aging management activities in the Preventive Maintenance Program are

described. The applicant's evaluations of each key element against the appropriate ten

elements defined in SRP-LR Appendix A also are provided.

The Preventive Maintenance Program manages aging effects of SSCs within the scope of

license renewal not managed by other AMPs. The scope of the program includes but is not

limited to valve bodies, heat exchangers, expansion joints, tanks, ductwork, fan/blower

housings, dampers, and pump casings.

Additional details of the program scope are addressed in the basis document for the Preventive

Maintenance Program kept onsite. With regard to the "preventive actions" element of the

program the applicant stated that although routine maintenance is largely preventive only the

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condition monitoring aspects of Preventive Maintenance Program activities are credited for

license renewal. For example, when a piping system is opened to conduct preventive

maintenance on a valve a visual inspection of the valve body or piping may be specified. Such

activities do not prevent aging effects but detect degraded conditions that affect the ability of

the component to perform its intended function. Consequently, there are no specific preventive

actions associated with this program.

The applicant states that aging effects of concern will be detected by visual inspection and

examination of component surfaces for evidence of defects and age-related degradation.

With regard to acceptance criteria the applicant states that the Preventive Maintenance

Program establishes specific acceptance criteria for each component inspected. The

acceptance criteria are related to the aging effects requiring management and are dependent

on each individual inspection or examination of the aging effect managed.

The program documentation has specific requirements for CRs in the CAP. The NMPNS

Quality Assurance Program Topical Report documents a commitment to the corrective action

criteria of 10 CFR Part 50. The CAP includes the detection and correction of conditions adverse

to quality and the detection, cause determination, correction, and prevention of recurrence of

conditions significantly adverse to quality.

The Quality Assurance Program Topical Report documents the confirmation process for

NMPNS under the corrective action criterion. At NMPNS the confirmation process is

implemented through corrective action effectiveness reviews and is performed for conditions

significantly adverse to quality and selected hardware-related conditions adverse to quality. The

CAP includes but is not limited to SR, NSR, and fire protection SSCs. Therefore, those SSCs

within the scope of license renewal are addressed as part of the current CAP.

The applicant states that NMPNS has reviewed both industry and plant-specific operating

experience relating to the Preventive Maintenance Program as part of a process to optimize

maintenance practices. Review of plan-specific operating experience revealed CRs initiated

after Preventive Maintenance Program examinations. In cases where age-related degradation

was detected the reported conditions (e.g., corrosion of motor-operated valves, piping, heat

exchanger internals) were resolved through implementation of the work order process prior to

loss of an intended function.

The Preventive Maintenance Program is adjusted continually to account for industry experience

and research. As additional operating experience is obtained lessons learned are used to adjust

this program as needed.

The applicant states that there are no exceptions to the SRP-LR and that the enhancements to

the Preventive Maintenance Program encompass revisions to existing activities credited for

license renewal to ensure that aging effects are discovered and evaluated. These

enhancements expand the scope of the Preventive Maintenance Program to encompass

activities for certain additional components requiring aging management and explicitly define

the aging management attributes including systems and the component types and

commodities.

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Other elements are: (1) preventive actions which would be revised to list activities credited for

aging management, (2) the element "parameters monitored/inspected" would be revised to

specifically list parameters monitored, (3) the element "detection of aging effects" would be

reviewed to specifically list the aging effects, (4) the element "monitoring and trending" would

establish a requirement that inspection data be monitored, and (5) the element "acceptance

criteria" would be revised to establish detailed specific acceptance criteria.

According to the applicant the enhancements would be completed prior to the period of

extended operation. The applicant stated that the Preventive Maintenance Program has been

effective in maintaining the intended functions of long-lived passive SSCs. The effectiveness of

the Preventive Maintenance Program is also reflected in the level of system/equipment

availability documented by maintenance rule periodic assessments.

Staff Evaluation. In accordance with 10 CFR 54.21 (a)(3), the staff reviewed the information

included in ALRA Section B2.1.32, regarding the applicant's demonstration of the Preventive

Maintenance Program to ensure that the effects of aging, as discussed above, will be

adequately managed so that the intended functions will be maintained consistent with the CLB

for the period of extended operation.

The staff reviewed the Preventive Maintenance Program against the AMP elements found in

SRP-LR Section A.1.2.3 and SRP-LR Table A.1-1 and focused on how the program manages

aging effects through the effective incorporation of 10 elements (i.e., program scope, preventive

actions, parameters monitored or inspected, detection of aging effects, monitoring and trending,

acceptance criteria, corrective actions, confirmation process, administrative controls, and

operating experience).

The applicant indicated that the corrective actions, confirmation process, and administrative

controls are parts of the site-controlled quality assurance program. The staffs evaluation of the

quality assurance program is addressed in SER Section 3.0.4. The remaining seven elements

are discussed below.

(1) Scope of Program - The applicant stated in ALRA Section B2.1.32 that the Preventive

Maintenance Program manages aging effects of many SSCs within the scope of license

renewal not managed by other AMPs. The scope of the program includes but is not

limited to valve bodies, heat exchangers, expansion joints, tanks, ductwork, fan/blower

housings, dampers, and pump casings.

Additional details of the program scope are discussed in the basis document for the

Preventive Maintenance Program. The applicant states that there are no exceptions to

the SRP-LR and the enhancements to the Preventive Maintenance Program revise

activities credited for license renewal to ensure detection and evaluation of aging

effects. These enhancements would expand the Preventive Maintenance Program to

activities for certain additional components requiring aging management and define the

aging management attributes of systems and the component types and commodities

included in the program.

The staff confirmed that this element satisfies the criterion of SRP-LR Section A.1.2.3.1.

The staff concludes that this program attribute is acceptable.

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(2) Preventive Actions - The applicant stated in ALRA Section B2.1.32 that although routine

maintenance is largely preventive in nature only the condition monitoring aspects of

Preventive Maintenance Program activities are credited for license renewal. For

example, when a piping system is opened to conduct preventive maintenance on a valve

a visual inspection of the valve body or piping may be specified. Such activities do not

prevent aging effects but will detect degraded conditions affecting the ability of the

component to perform its intended function. Consequently, there are no specific

preventive actions for this program. Enhancements to this element would specifically list

those activities credited for aging management. Additional details of this element are

discussed in the basis document for the Preventive Maintenance Program.

The staff confirmed that this program element satisfies the criterion of SRP-LR

Section A.1.2.3.2. The staff concludes that this program attribute is acceptable.

In RAI B2.1.32-1 dated November 17, 2004, the staff stated that the descriptions of several

elements in the Preventive Maintenance Program were too brief and general for the staff to

review the program's effectiveness and adequacy. Therefore, the staff requested that the

applicant provide more specific detailed information for the following four elements of the AMP

according to the guidelines of SRP-LR Appendix A.

(1) Element (3) - Parameters Monitored/Inspected

(2) Element (4) - Detection of Aging Effects

(3) Element (5) - Monitoring and Trending (specified schedule)

(4) Element (6) - Acceptance Criteria

In addition the staff requested the applicant to provide specific information related to these four

listed elements of the Preventive Maintenance Program for the management of aging effects of

two specific components, (1) piping and fittings in the NMP2 Control Building HVAC System

(original LRA Table 3.3.2.B1-9) and (2) valves in the NMP1 Radioactive Waste System (original

LIRA Table 3.3.2.A-14), to demonstrate the effectiveness and adequacy of this Preventive

Maintenance Program.

The applicant provided its response by letter dated December 21, 2004, and the staffs

evaluation of elements (3) through (6) is as follows.

(3) Parameters Monitored/Inspected - In the original LRA Section B2.1.32, the applicant

stated that inspection and testing activities monitor various parameters, including

surface condition, for evidence of defects and age-related degradation.

In its response to the staff RAI B2.1.32-1 dated November 17, 2004, with regard to this

element, the applicant stated that there are no prevention, mitigation, or performance

monitoring activities in the Preventive Maintenance Program credited for license

renewal. Rather, condition monitoring activities inspect for visual signs of degradation or

test for leaks. Surface conditions of components are monitored through visual inspection

and examination for evidence of defects and age-related degradation. Components in

selected portions of systems are monitored through visual inspection. The inspections

detect aging effects which if left unmanaged would lead to degradation of the

components' intended functions. Examples of components, inspections, and parameters

monitored under the Preventive Maintenance Program are as follow:

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Unit :Component(s) Inspection .'-Parameter Procedure

TypelParameter. -

I Fuel Pool heat Visual/ Evidence of various NI-MM-0054-405

exchanger tubes and Condition forms of corrosions

tube sheets

I Various carbon steel Visual/ Evidence of Various N1-MM-GEN-200

valve internals and Condition forms of internal

externals and/or external

corrosion

1 Reactor Building and Visual! Evidence of various NI-MM-GEN-005

Dry Well Sump Pump Condition forms of internal

corrosion

I RX Building Emergency Visual/ Evidence of corrosion N1-MM-GEN-551

Ventilation and Control Condition of carbon steel;

Room Emergency cracking, hardening

Ventilation Fan shrinkage and loss of

strength of polymers

1 Unit 1 Reactor Building Visual/ Evidence of general N1-TSP-202-O01

Charcoal Filter Housing Condition corrosion of housing

internals

1 13.8 & 4.16KV Visual/ Presence of motor S-EMP-GEN-081

Motors Condition cooler fouling

2 Ventilation Visual/ Presence of general N2-EPM-GEN-V786

Heaters Condition corrosion on heater

internals

2 Condition and various Visual/ Internal inspection for N2-EPM-GEN-V786

forms of Condition general corrosion of

corrosion2Motor damper and actuator

Operated Actuators

and Dampers

2 Air Handling Unit Visual/ Inspection of signs of NS-MPM-GEN-SA562

Cooling Cools Condition & fouling, and testing for & N2-MPM-HVC-V554

Test/Refrigerant leakage

I Leakage

Most Preventive Maintenance Program implementing procedures require enhancement

to include/annotate parameters credited for aging management..

The applicant also provided the specific inspection methods for detection of aging

effects related to two specific components, (1) piping and fittings in the NMP2 Control

Building HVAC System (original LRA Table 3.3.2.B-9) and (2) valves in the NMP1

Radioactive Waste System (original LRA Table 3.3.2.A-14), to demonstrate the

effectiveness and adequacy of this Preventive Maintenance Program.

The staff confirmed that after completion of the enhancements this program element will

satisfy the criterion of SRP-LR Section A.1.2.3.3. The staff concludes that this program

attribute is acceptable.

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(4) Detection of Aging Effects - In the original LRA Section B2.1.32 the applicant stated that

the aging effects of concern will be detected by visual inspection and examination of

component surfaces for evidence of defects and age-related degradation.

In response to RAI B2.1.32-1 on this element the applicant stated that:

The aging effects requiring management for the components within the

scope of the Preventive Maintenance Program are detected by visual

inspection and examination of surfaces of components for evidence of

defects and age-related degradation. The activities that are performed to

detect aging effects requiring management are identified in the specific

PM procedures that perform the PM. The procedures are developed

based on vendor recommendations and operating experience that forms

the basis for the inspections performed and the frequency of the

inspections such that aging effects are detected prior to a loss of the

components' intended functions. NMPNS administrative procedures

provide for overall control of the Preventive Maintenance Program and

identification of how PMs are to be established, documented, scheduled,

and optimized for the benefit of equipment and system reliability. Most

Preventive Maintenance Program procedures will require an

enhancement to include/annotate the aging effect being detected.

The applicant also provided the specific inspection methods for detection of the aging

effects related to two specific components, (1) piping and fittings in the NMP2 Control

Building HVAC System (original LRA Table 3.3.2.B-9) and (2) valves in the NMP1

Radioactive Waste System (original LRA Table 3.3.2.A-14), to demonstrate the

effectiveness and adequacy of this Preventive Maintenance Program.

The staff confirmed that after completion of the enhancements this program element will

satisfy the criterion of SRP-LR Section A.1.2.3.4. The staff concludes that this program

attribute is acceptable.

(5) Monitoring and Trending - In original LRA Section B2.1.32 the applicant stated that the

Preventive Maintenance Program is condition-monitoring performed on a specified

schedule. After inspection results are documented they are reviewed and evaluated.

In response to RAI B2.1.32-1 on this element the applicant stated:

The Preventive Maintenance Program is a condition-monitoring program

executed on a specified schedule. Results of the tasks performed are

documented in the corresponding implementing procedures. These

procedures include a review and evaluation of the results. The Preventive

Maintenance Program requires an enhancement to specifically include

monitoring and trending, as appropriate, for age-related degradation.

The applicant also provided the specific monitoring and trending attributes for the

management of aging effects related to the two specific components, (1) piping and

fittings in the NMP2 Control Building HVAC System (original LRA Table 3.3.2.B-9) and

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(2) valves in the NMP1 Radioactive Waste System (original LRA Table 3.3.2.A-14), to

demonstrate the effectiveness and adequacy of this Preventive Maintenance Program.

The staff confirmed that after completion of the enhancements this program element will

satisfy the criteria of SRP-LR Section A.1.2.3.5. The staff concludes that this program

attribute is acceptable.

(6) Acceptance Criteria - In the original LRA Section B2.1.32 the applicant stated that the

Preventive Maintenance Program establishes specific acceptance criteria for each

component inspected. The acceptance criteria are related to the aging effects requiring

management and dependent on each individual inspection and examination of the aging

effect managed.

In its response to RAI B2.1.32-1, dated December 21. 2004, the applicant stated:

Acceptance criteria for visual inspection and examination of components

are provided in the Preventive Maintenance Program implementing

procedures. The acceptance criteria are related to the aging effects

requiring management and are dependent on each individual inspection

and examination considering the aging effect being managed.

Implementing procedures will be enhanced to include more specific and

detailed acceptance criteria, as appropriate. This program attribute will be

consistent with the generic attribute description in Appendix A of

NUREG-1800 upon program enhancements.

The applicant also provided the acceptance criteria for the management of aging effects

related to the two specific components, (1) piping and fittings in the NMP2 Control

Building HVAC System (original LRA Table 3.3.2.B-9) and (2) valves in the NMP1

Radioactive Waste System (original LRA Table 3.3.2.A-14), to demonstrate the

effectiveness and adequacy of this Preventive Maintenance Program.

The staff confirmed that after completion of the enhancements this program element will

satisfy the criteria of SRP-LR Section A.1.2.3.6. This information has been incorporated

in the ALRA. The staff concludes that this program attribute is acceptable.

(10) Operating Experience - The applicant stated in ALRA Section B2.1.32 that it has

reviewed both industry and plant-specific operating experience relating to the Preventive

Maintenance Program as part of a process to optimize maintenance practices. Review

of plan-specific operating experience revealed CRs initiated after Preventive

Maintenance Program examinations. Where age-related degradation was detected the

reported conditions (e.g., corrosion of motor-operated valves, piping, heat exchanger

internals) were resolved through implementation of the work order process prior to loss

of an intended function.

The Preventive Maintenance Program is adjusted continually to account for industry

experience and research. With additional operating experience lessons learned will be

used to adjust this program as needed.

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The staff confirmed that this program element satisfies the criteria of SRP-LR

Section A.1.2.3.10. The staff concludes that this program attribute is acceptable.

The applicant stated that enhancements to the Preventive Maintenance Program will be made

to revise existing procedures. These enhancements would provide the level of detail and

specificity needed for staff review of the Preventive Maintenance Program. They would affect

the main program elements including "scope of program," "preventive actions," "parameters

monitored," "detection of aging effects," "monitoring and trending," and "acceptance criteria."

These enhancements are scheduled to be completed prior to the period of extended operation.

The staff views these as major enhancements which would require review and approval prior to

implementation of the Preventive Maintenance Program.

In RAI B2.1.32-2, dated November 17, 2004, the staff requested that the applicant provide a

commitment that these enhancements would be completed on a schedule of sufficient time for

staff review and approval prior to the period of extended operation.

In its response, by letter dated December 21, 2004, the applicant stated that this staff concern

also was raised during the review of the AMPs by the audit team and the audit question was

documented as AMP Issue 30 of the Audit and Review Report. The applicant provided the

response that was given to Issue 30 as follows:

As with any commitment NMPNS makes to the NRC, the resolution and/or

implementation are subject to review by the NRC. Specifically for new aging

management programs (AMP), the NRC can utilize Inspection Procedure 71003

Post-Approval Site Inspection for License Renewal, to verify that outstanding

commitments have been met. This procedure also includes specific wording

whereby the assistance of NRRJDRIP/RLEP can be utilized to ensure the

licensee commitments have been met. Currently there is no specific notification

to the NRC required when a commitment has been satisfied. Consistent with the

industry, NMP would prefer that any review of new AMPs be conducted as part

of the inspection process.

The applicant further stated that:

The commitment to enhance appropriate maintenance procedures that exist

within the Preventive Maintenance Program is made commensurate with the

inclusion of statements to that effect within Appendices A and B of the [original]

LRA. Enhancements Will be reviewed and approved using approved NMPNS

administrative procedures. Once made, all maintenance activity enhancements

will be readily available for review by the NRC prior to the period of extended

operation.

The staff reviewed the applicant's response and found that the applicant has provided adequate

assurance for the completion as well as review and approval of the enhancements prior to the

period of extended operation. Enhancements to the Preventive Maintenance Program are

NMP1 Commitment 29 and NMP2 Commitment 27. Based on the review and information

provided in the ALRA the staff concern in RAI B2.1.32-2 is resolved.

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UFSAR and USAR Supplements. In ALRA Sections A1.1.30 and A2.1.30, the applicant

provided the respective UFSAR and USAR supplements for the Preventive Maintenance

Program. The staff reviewed these sections and determined that the information in the

supplements provide adequate summary descriptions of the program, as required by

10 CFR 54.21(d).

Conclusion. On the basis of its review and audit of the applicant's Preventive Maintenance

Program, the staff concludes that the applicant demonstrated that the effects of aging will be

adequately managed so that the intended functions will be maintained consistent with the CLB

for the period of extended operation, as required by 10 CFR 54.21(a)(3). The staff also

reviewed the UFSAR and USAR supplements for this AMP and concludes that they provide an

adequate summary description of the program, as required by 10 CFR 54.21(d).

3.0.3.3.2 Systems Walkdown Program

Summary of Technical Information in the Amended Application. In ALRA Section B2.1.33, the

applicant described the Systems Walkdown Program, stating that this is an existing,

plant-specific program. The Systems Walkdown Program manages aging effects for accessible

external surfaces of systems and components within the scope of license renewal. The aging

effects of concern are material degradation and loss of material from external surfaces of

pumps, valves, piping, bolts, heat exchangers, tanks, HVAC components, and other

components. The program also identifies adverse conditions that can lead to aggressive

environments for systems or components within the scope of license renewal. Program

activities include system engineer walkdowns (i.e., field evaluations of system components to

assess material condition), documentation and evaluation of inspection results, and appropriate

corrective actions.

In the ALRA, the applicant stated that the key elements of aging management activities used in

the Systems Walkdown Program are the results of an evaluation of each key element against

the appropriate ten elements described in SRP-LR Appendix A with enhancements that include

revisions to existing activities credited for license renewal to ensure the applicable aging effects

are detected and evaluated. Enhancements are scheduled for completion prior to the period of

extended operation.

The applicant stated that recording and reporting visually detectable degradation have been

parts of good engineering practice at NMPNS for many years and will continue under the

Systems Walkdown Program, which has been effective in maintaining the intended functions of

long-lived passive SSCs. The applicant stated that the Systems Walkdown Program has been

enhanced since its inception and further improvements will be implemented prior to the period

of extended operation.

Staff Evaluation. In accordance with 10 CFR 54.21 (a)(3), the staff reviewed the information

included in ALRA Section B2.1.33, regarding the applicant's demonstration of the Systems

Walkdown Program to ensure that the effects of aging, as discussed above, will be adequately

managed so that the intended functions will be maintained consistent with the CLB for the

period of extended operation.

In RAI B2.1.33-1 dated November 17, 2004, the staff noted that the applicant stated in the

original LRA that this System Walkdown Program manages aging effects for accessible

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external surfaces of selected SSCs within the scope of license renewal. It was not clear to the

staff whether all carbon steel components listed in the program or just the samples are covered

by this AMP. Therefore, the staff requested that the applicant clarify the reference to "selected

SSCs" within the scope of license renewal. Furthermore, with respect to the program

description paragraph of Section B2.1.33, the staff requested that the applicant clarify the

phrase "other carbon steel components" and explain why "mechanical penetrations" are

excluded from components listed in the program description.

In its response by letter dated December 17, 2004, the applicant listed NMP1 and NMP2

systems which include components within the scope of license renewal and which credit the

Systems Walkdown Program for managing the aging of external surfaces. The applicant stated

that because not all components in a system may be in-scope the term "selected" is used to

differentiate between those in-scope and those out-of-scope. For each of the systems listed the

determination of which component types are "selected" is shown in the applicable original LRA

aging management review section. The applicant also stated that there are no structures within

the scope of license renewal that credit the Systems Walkdown Program for managing aging

effects.

The applicant stated that the "Program Description" paragraph of the original LRA

Section B2.1.33 includes the statement, "The specific aging effect of concern is loss of material

from external surfaces of... other carbon steel components." This phrase is intended to capture

generically system components or subcomponents not specifically listed. Examples of "other

carbon steel components" are flanges, tees, reducers, and pipe caps. Mechanical penetrations

at NMP1 and NMP2 are managed under the Structures Monitoring Program and the ASME

Section Xl ISI (Subsections IWE and IWL) Programs rather than by the Systems Walkdown

Program.

The applicant noted that for the NMP1 Reactor Vessel Instrumentation System although the

Systems Walkdown Program is credited correctly in original LRA Section 3.1.2.A.3 it was

omitted inadvertently from original LRA Table 3.1.2.A-3 (page 3.1-54 of the revised Section 3.1

submitted by NMPNS letter NMP1L 1892 dated December 6, 2004). The correction to

Table 3.1.2.A-3 is provided in the applicant's December 17, 2004, submittal. The staff found the

applicant's response acceptable. Therefore, the staff's concern described in RAI B2.1.33-1 is

resolved.

The staff evaluated key elements of aging management activities of the Systems Walkdown

Program against the appropriate ten elements described in SRP-LR Appendix A, including the

enhancements to the existing activities. The staff reviewed the Systems Walkdown Program

against the AMP elements found in SRP-LR Section A.1.2.3, and SRP-LR Table A.1-1 and

focused on how the program manages aging effects through the effective incorporation of 10

elements (i.e., "program scope," "preventive actions," "parameters monitored or inspected,"

"detection of aging effects," "monitoring and trending," "acceptance criteria," "corrective

actions," "confirmation process," "operating experience," and "operating experience").

The applicant indicated that the "corrective actions," "confirmation process," "and

"administrative controls," are parts of the site-controlled quality assurance program. The staffs

evaluation of the quality assurance program is addressed in SER Section 3.0.4. The remaining

seven elements are addressed here.

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(1) Scope of Program - In the original LRA Section B2.1.32, the applicant stated that the

scope of the Systems Walkdown Program is accessible external surfaces of structures

and components within the scope of license renewal and subject to AMR. The

inspections will look for loss of material, material degradation, and leakage.

In RAI B2.1.33-1 dated November 17, 2004, the staff requested that the applicant

identify the systems and structures within the scope of license renewal to which this

AMP applies at NMPNS.

In its December 17, 2004, response to RAI B2.1.33-1 the applicant listed NMP1 and

NMP2 systems as follow:

NMP1 Systems

" Compressed Air System

• Control Room Heating, Ventilating, and Air Conditioning (HVAC)

" Control Rod Drive

* Core Spray System

" Condensate System

" Containment System

* Containment Spray

" City Water System

• Reactor Water Cleanup

• Emergency Diesel Generator

" Emergency Cooling

• Fire Detection and Protection

* Spent Fuel Pool Filtering and Cooling

* Feedwater/high Pressure Coolant Injection

• Hydrogen Water Chemistry

• Main Generator and Auxiliary System

Main Steam

* Miscellaneous Non-contaminated Vents and Drains

• Neutron Monitoring

* Reactor Building HVAC

" Reactor Building Closed Loop Cooling

" Radwaste Building Hvac

" Radwaste System

• Reactor Vessel Instrumentation

* Shutdown Cooling

" Sampling System

* Service Water

" Turbine Building Hvac

" Turbine Building Closed Loop Cooling Water

NMP2 Systems

* Alternate Decay Heat Removal System

" Compressed Air System

" Reactor Building Closed-loop Cooling Water

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• Containment Atmosphere Monitoring

* Condensate System

* Main Condenser Air Removal

* Primary Containment Purge

* High-pressure Core Spray

* Low-pressure Core Spray

• Domestic Water System

* Air Startup - Standby Diesel Generator

* Standby Diesel Generator Fuel Oil Storage and Transfer

* Generator Standby Lube Oil System

* Standby Diesel Generator Protection (Generator) System

* Floor and Equipment Drains

* Engine-driven Fire Pump - Fuel Oil

• Fire Protection Halon

* Cardox Fire Protection - Low Pressure C02

• Fire Protection - Water

* Feedwater System

* Standby Gas Treatment

* Design Basis Accident (DBA) Hydrogen Recombiner

* Control Building Air-conditioning

* Glycol Heating

* Hot Water Heating

* Auxiliary Service Building Air-conditioning

* Control Building Chilled Water

* Chilled Water - Ventilation

* Diesel Generator Building Ventilation

* Reactor Building Ventilation

* Yard Structure Ventilation

* Reactor Core Isolation Cooling

* Reactor Vessel Instrumentation

* Main Steam

* Moisture Separator and Reheater System

* Makeup Water System

• Reactor Recirculation System

* Residual Heat Removal

* Reactor Pressure Vessel

* Spent Fuel Pool Cooling and Cleanup

* Process Sampling System

• Service Water

* Seal Water System

* Reactor Water Cleanup

For the enhancement of this AMP the applicant stated in the original LRA that it will

state the aging management attributes explicitly, including the systems and component

types/commodities included in the program.

In the updated response to RAI B2.1.33-1 dated August 12, 2005, the applicant pointed

out that portions in its previous response had been superseded by responses dated July

14, 2005, to staff RAIs 2.1-4, 2.2-3 and 3.1.2.C.4-1 dated February 23, 2005. The

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complete revised list of NMP1 and NMP2 systems that credit the System Walkdown

Program for aging management is provided here and also has been incorporated in the

ALRA section number (italics indicate added systems).

NMP1 System: ALRA Section

" Circulating Water

• City Water

• Compressed Air

" Condensate and Condensate Transfer

* Condenser Air Removal and Off-gas

• Containment Spray

• Containment System

• Control Rod Drive

• Control Room HVAC

* Core Spray

" Diesel Generator Building Ventilation

* Electric Steam Boiler

* Emergency Cooling

* Emergency Diesel Generator

* Feedwater/high Pressure Coolant Injection

• Fire Detection and Protection

" (Hydrogen Water Chemistry - deleted from list)

• Liquid Poison

* Main Generator and Auxiliary

" Main Steam

" Main Turbine andAuxiliary

" Misc Non-contaminated Vents & Drains

" Moisture Separator Reheater Steam

* Neutron Monitoring

• Radwaste Building HVAC

* Radwaste System

" Reactor Building Closed Loop Cooling

• Reactor Building HVAC

• Reactor Vessel Instrumentation

* Reactor Recirculation System

" Reactor Water Cleanup

• Sampling System

• Service Water

" Shutdown Cooling

* Spent Fuel Pool Filtering and Cooling

* Turbine Building Closed Loop Cooling

* Turbine Building HVAC

3.3.2.A.1

3.3.2.A.2

3.3.2.A.3

3.4.2.A.1

3.4.2.A5

3.2.2.A.1

3.3.2.A4

3.1.2.A.5

3.3.2.A.5

3.2.2.A.2

3.3.2.A.6

3.3.2.A.24

3.2.2.A3

3.3.2.A.7

3.4.2.A.2

3.3.2.A8

3.3.2.A. 10

3.4.2.A.3

3.4.2.A.4

3.4.2.A.6

3.3.2.A.1 1

3.4.2.A. 7

3.3.2.A.12

3.3.2.A.13

3.3.2.A.14

3.3.2.A.15

3.3.2.A.16

3.1.2.A3

3.1.2.A.4

3.3.2.A. 17

3.3.2.A.18

3.3.2.A.19

3.3.2.A.20

3.3.2.A.21

3.3.2.A.22

3.3.2.A.23

NMP2 Systems: ALRA Section

Air Startup - Standby Diesel Generator

Alternate Decay Heat Removal

Auxiliary Boiler

3.3.2.B.1

3.3.2.13.2

3.3.2.B.33

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• Auxiliary Service Building Hvac 3.3.2.8.3

• Circulating Water 3.3.2.B.34

* (Chilled Water Ventilation - deleted from list)

• Compressed Air 3.3.2.B.5

* Condensate System 3.4.2.B.2

• (Containment Atmosphere Monitoring - deleted from list)

• Control Building Chilled Water 3.3.2.B.8

• Control Building HVAC 3.3.2.B.9

• Control Rod Drive 3.1.2.B.5

* Diesel Generator Building Ventilation 3.3.2.B.10

* Domestic Water 3.3.2.B. 11

• Engine-driven Fire Pump Fuel Oil 3.3.2.B.12

• Extraction Steam & Feedwater Heater Drains 3.4.2.B.6

• Feedwater 3.4.2.B.3

• Fire Detection and Protection 3.3.2.B.13

Floor and Equipment Drains 3.3.2.B.14

* Generator Standby Lube Oil 3.3.2. B. 15

* (Glycol Heating - deleted from list)

• High Pressure Core Spray 3.2.2.B.2

• Hot Water Heating 3.3.2.B. 17

• Hydrogen Recombiner System 3.2.2.B.1

• Low Pressure Core Spray 3.2.2.B.3

* Main Condenser Air Removal 3.4.2.3.1

• Main Steam 3.4.2.3.4

* Makeup Water 3.3.2.B. 18

• Moisture Separator and Reheater 3.4.2.B.5

• Primary Containment Purge 3.3.2.B.20

• (Process Sampling - deleted from list)

• Radioactive Liquid Waste Management 3.3.2.B.36

• Reactor Building Closed Loop Cooling 3.3.2.B.22

• Reactor Building HVAC 3.3.2.B.23

* Reactor Core Isolation Cooling 3.2.2.8.4

• (Reactor Pressure Vessel - deleted from list)

* Reactor Pressure Vessel Instrumentation 3.1.2.B.3

• (Reactor Recirculation - deleted from list)

* Reactor Water Cleanup 3.3.2.B.24

* Residual Heat Removal 3.2.2.8.5

* Roof Drainage System 3.3.2.B.37

• Sanitary Plumbing and Drains 3.3.2.B.38

• (Seal Water - deleted from list)

• Service Water 3.3.2.8.26

• Spent Fuel Pool Cooling and Cleanup 3.3.2.8.27

* Standby Diesel Generator Fuel Oil 3.3.2.8.28

• Standby Diesel Generator Protection 3.3.2.B.29

• Standby Gas Treatment 3.2.2.8.6

• Turbine Building Closed Loop Cooling 3.3.2.B.40

* Turbine Main System 3.4.2.B.7

• Water Treatment 3.3.2.B.35

• Yard Structures Ventilation 3.3.2.1.31

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The staff reviewed the amended information in the ALRA and considers the scope of the

program to be defined clearly and acceptable. Therefore, the staff's concern described

in RAI B2.1.33-1 is resolved.

The staff confirmed that this element satisfies the criterion of SRP-LR Section A.1.2.3.1.

The staff concludes that this program attribute is acceptable.

(2) Preventive Actions - In the original LRA Section B2.1.33 the applicant stated that the

Systems Walkdown Program mitigates degradation through regular inspection of

in-scope components and detection of degraded conditions that could affect the ability

of components to perform intended functions. There are no specific preventive actions

associated with this program other than the detection of the aging effects of concern

before damage to a component or pressure boundary occurs. The staff concurred that

no preventive actions are required for this condition monitoring program.

The staff also reviewed ALRA and confirmed that this program element satisfies the

criterion of SRP-LR Section A.1.2.3.2. The staff concludes that this program attribute is

acceptable.

(3) Parameters Monitored/Inspected - In original LRA Section B2.1.33 the applicant stated

that system engineers conduct visual inspections of assigned SSCs and document the

presence of corrosion and other signs of deterioration.

In RAI B2.1.33-2 dated November 17, 2004, the staff stated that in the "parameters

monitoredlinspected" program element "other signs of deterioration" was not clear.

Therefore, the staff requested that the applicant describe those other aging effects and

explain how they can be detected.

In its December 17, 2004, response to RAI B2.1.33-2 the applicant stated that the

phrase "other signs of deterioration" is intended to encompass the condition of coatings

(material degradation), leakage and indications of leakage as stated under the

"Enhancements" heading of original LRA Section B2.1.33, as well as cracking,

elastomer degradation, and weathering. The applicant stated that in incorporating this

enhancement into the implementing procedure it intends to utilize the guidance of EPRI

reports on identification of aging as part of the training of system engineers. These

industry guidelines provide the basis for the identification of aging effects and will

provide the system engineers with the necessary knowledge to identify "other signs of

deterioration." (EPRI reports 1007932, "Identification and Detection of Aging Issues,"

1007933, "Aging Assessment Field Guide," and 1009743, "Aging Identification and

Assessment Checklist - Mechanical Components.")

In the updated response to RAl B2.1.33-2 dated August 12, 2005, the applicant pointed

out that no change to RAI response is required. Thus AMP B2.1.33, Systems Walkdown

Program, was modified after RAI response and Section B2.1.33 under the "parameters

monitored/inspected" heading of the ALRA has been reworded to state:

System engineers conduct visual inspections of accessible portions of

credited systems and components WSLR. Visible degradation,

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anomalous indications, or adverse conditions are documented and

evaluated. Adverse conditions that can lead to aggressive environments

for in scope components, such as evidence of leakage, wetted insulation,

or degraded non-safety related or out of scope piping or anchor points

attached to in-scope portions, are also monitored.

The applicant stated that although the paragraph has been reworded for clarification the

response to RAI B2.1.33-2 dated December 17, 2004, remains valid.

The staff found the parameters considered in the program implementation to be

according to general industry practice and acceptable. Therefore, the staff's concern

described in RAI B2.1.33-2 is resolved.

The staff confirmed that this program element satisfies the criterion of SRP-LR

Section A.1.2.3.3 and concludes that this program attribute is acceptable.

(4) Detection of Aging Effects - In original LRA Section B2.1.33 the applicant stated that the

aging effects of concern will be detected and documented through visual inspections

during system walkdowns. The frequency of inspections is at least once per refuel cycle

for each structure and system. This frequency is sufficient since the aging effects

typically are caused by long-term degradation. The staff considers this approach to

detection of aging effects for accessible external surfaces of selected SSCs within the

scope of license renewal at NMPNS acceptable.

In RAI B2.1.33-4 dated November 17, 2004, the staff requested that the applicant

discuss the basic approaches and programs used to manage aging effects for

inaccessible external surfaces of SSCs within the scope of license renewal.

In its response by letter dated December 17, 2004, the applicant stated that the

Systems Walkdown Program relies on visual inspections of accessible external surfaces

to detect aging effects. The evidence of aging, however, may apply to both accessible

and inaccessible component surfaces depending on the material of the component and

the environment to which it is exposed. Personnel performing inspections will be trained

in this program element to ensure that age related degradation is properly identified.

The applicant further indicated that any evidence of aging on accessible external

surfaces generally indicates the condition of inaccessible external surfaces and is

considered an effective indicator for managing inaccessible surfaces. As part of the

enhancement to the "parameters monitored/inspected" attribute described in original

LRA Section B2.1.33 to "provide guidance for assessment of identified deterioration" the

applicant confirmed that it will include direction to evaluate potentially susceptible

inaccessible areas when evidence of aging is detected. The staff agreed with this

enhancement procedure.

In the updated response to RAI B2.1.33-4 dated August 12, 2005, the applicant pointed

out that no change to the RAI response was required because the Systems Walkdown

Program was modified and incorporated into the ALRA after the RAI response with no

change in intent. ALRA Section B2.1.33 under the program description heading has

been reworded to state:

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The Systems Walkdown Program is an existing plant-specific program

that consists of the ten'elemrhts described in Appendix A of

NUREG-1800 (Reference 1). The Systems Walkdown Program manages

aging effects for accessible external surfaces of systems and

components WSLR at NMPNS. The aging effects of concern are material

degradation and loss of material from external surfaces of pumps, valves,

piping, bolts, heat exchangers, tanks, HVAC components, and other

components. The program also identifies adverse conditions that can

lead to aggressive environments for systems or components within the

scope of LR. Program activities include system engineer walkdowns (i.e.,

field evaluations of system components to assess material condition),

documentation and evaluation of inspection results, and appropriate

corrective actions.

The applicant stated that although the paragraph has been reworded to provide

clarification the response to RAI B2.1.33-4 dated December 17, 2004, remains valid.

The staff reviewed information in the ALRA and found the applicant's approaches to

detecting and managing aging effects for accessible and inaccessible surfaces of SSCs

within the scope of license renewal reasonable and acceptable. Therefore, the staffs

concern described in RAI B2.1.33-4 is resolved.

The staff confirmed that this program element satisfies the criterion of SRP-LR

Section A.1.2.3.4 and concludes that this program attribute is acceptable.

(5) Monitoring and Trending - In the original LRA Section B2.1.33 the applicant stated that

the Systems Walkdown Program describes the monitoring and assessment of SSCs but

has no requirements for monitoring and trending of applicable parameters. The staff

agreed that system engineers will document the aging effects of the assigned SSCs and

that trending is not required.

The staff confirmed that this program element satisfies the criteria of the GALL Report

and SRP-LR Section A. 1.2.3.5 and concludes that this program attribute is acceptable.

(6) Acceptance Criteria - In original LRA Section B2.1.33 the applicant stated that the

Systems Walkdown Program includes specific acceptance criteria for applicable

parameters. A list of walkdown attributes is available to system engineers for use in

developing walkdown checklists.

In RAI B2.1.33-3 dated November 17, 2004, the staff requested that the applicant

provide more detailed information according to the guidelines delineated in SRP-LR

Appendix A to describe the acceptance criteria for the program.

In its December 17, 2004, response to RAI B2.1.33-3 the applicant stated that the

"acceptance criteria" program element in original LRA Section B2.1.33 states that, "A list

of walkdown attributes is available to system engineers for use in developing walkdown

checklists." This statement acknowledged that system engineers conduct walkdowns for

a variety of reasons (i.e., maintenance rule assessments, system readiness reviews,

pre-outage reviews, license renewal, et cetera). The system engineer adapts the

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general checklist to focus on attributes applicable to the walkdown. The applicant stated

that the license renewal walkdown focuses on attributes applicable to aging. The

applicant further stated that the current program administrative procedure

(S-TDP-REL-0101, Systems Walkdown Program) states that "evidence of aging shall be

documented on a CR and recorded on the System Walkdown Report" (CR is the

NMPNS document for entering issues into the CAP). The applicant stated that as part of

the enhancement to the "acceptance criteria" attribute of original LRA Section B2.1.33 it

intends to use EPRI reports on detection of aging issues to train system engineers to

recognize evidence of (acceptance criteria for) various aging effects. These EPRI

reports are listed above under "parameters monitored/inspected" (NMP1

Commitment 30, NMP2 Commitment 28). The staff found the applicant's approach to

detection of evidence of aging and implementation of corrective measures reasonable.

In the updated response to RAI B2.1.33-3 dated August 12, 2005, the applicant stated

that the original response to this RAI remains valid and unchanged by the ALRA

reworded to state that incorporation of acceptance criteria into the program procedures

is an enhancement and that the updated RAI response provides additional information

for use.

The staff confirmed that this program element satisfies the criteria of SRP-LR

Section A.1.2.3.6 and concludes that this program attribute is acceptable. Therefore, the

staffs concern described in RAI B2.1.33-3 is resolved.

(10) Operating Experience - In ALRA Section B2.1.33, the applicant explained that the

Systems Walkdown Program has relied upon system health reports to document the

overall material condition of various plant systems. As such, operating experience has

been incorporated into the system health reports and not directly into the Systems

Walkdown Program. Enhancements will be made to this program to include previous

operating experience and to ensure future operating experience is properly

incorporated. A review of the corrective action history related to material condition

demonstrates the past usefulness of walkdowns in identifying visually detectable

age-related degradation (e.g., general corrosion of bolting, supports, and component

surfaces). As additional operating experience is obtained, lessons learned will be used

to adjust the System Walkdown Program as needed.

The staff confirmed that this program element satisfies the criteria of the GALL Report

and SRP-LR Section A.1.2.3.10 and concludes that this program attribute is acceptable.

UFSAR and USAR Supplements. In ALRA Sections A1.1.35 and A2.1.35, the applicant

provided the respective UFSAR and USAR supplements for the Systems Walkdown Program.

The staff reviewed these sections and determined that the information in the supplements

provide adequate summary descriptions of the program, as required by 10 CFR 54.21(d).

Conclusion. On the basis of its review and audit of the applicant's Systems Walkdown Program,

the staff concludes that the applicant demonstrated that the effects of aging will be adequately

managed so that the intended functions will be maintained consistent with the CLB for the

period of extended operation, as required by 10 CFR 54.21(a)(3). The staff also reviewed the

UFSAR and USAR supplements for this AMP and concludes that they provide an adequate

summary description of the program, as required by 10 CFR 54.21 (d).

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3.0.3.3.3 Non-Segregated Bus Inspection Program

Summary of Technical Information in the Amended Application. In ALRA Section B2.1.34, the

applicant described the Non-Segregated Bus Inspection Program, stating that this is an

existing, plant-specific program. The Non-Segregated Bus Inspection Program inspects

components and materials internal to the non-segregated bus ducts that connect the reserve

auxiliary transformers to the 4160V buses required for the recovery of offsite power to both

units following an SBO event. Based upon the most recent industry and regulatory license

renewal precedence, this program also includes bus ducts associated with power boards

feeding components within the scope of license renewal. They are normally energized, and

therefore, the bus duct insulation material will experience temperature rise due to energization,

which may cause age-related degradation during the extended period of operation.

Staff Evaluation. In accordance with 10 CFR 54.21 (a)(3), the staff reviewed the information

included in ALRA Section B2.1.34, regarding the applicant's demonstration of the

Non-Segregated Bus Inspection Program to ensure that the effects of aging, as discussed

above, will be adequately managed so that the intended functions will be maintained consistent

with the CLB for the period of extended operation.

The staff reviewed the Non-Segregated Bus Inspection Program against the AMP elements of

SRP-LR Section A.1.2.3 and SRP-LR Table A.1-1 and focused on how the program manages

aging effects through the effective incorporation of 10 elements (i.e., "program scope," "preventive actions," "parameters monitored or inspected," "detection of aging effects," "monitoring and trending," "acceptance criteria," "corrective actions," "confirmation process," "administrative controls," "and operating experience").

(1) Scope of Program - In ALRA Section B2.1.34, the applicant stated that this program

applies to the bus ducts within the scope of license renewal, i.e., nonsegregated bus

ducts that connect the reserve auxiliary transformers to the 4160V buses required for

the recovery of offsite power to both units following an SBO event as well those

associated with power board feeding components within the scope of license renewal.

The staff confirmed that this program element satisfies the criterion of SRP-LR

Section A.1.2.3.1 and concludes that this program attribute is acceptable.

(2) Preventive Actions - In ALRA Section B2.1.34 the applicant stated that in this inspection

program and no actions are taken to prevent or mitigate aging degradation.

The staff confirmed that this program element satisfies the criterion of SRP-LR

Section A. 1.2.3.2 and concludes that this program attribute is acceptable.

(3) Parameters Monitored/Inspected - In ALRA Section B2.1.34 the applicant stated that a

sample of accessible bolted connections (bus joints and ending devices) for proper

torque or the resistance of bolted joints will be checked using a micro-ohm meter of

sufficient current capacity suitable for checking bus bar connections. This program also

inspects the internal portions of accessible bus ducts for cracks, corrosion, foreign

debris, dust buildup, and water intrusion. The bus insulation system is inspected for

signs of embrittlement, cracking, melting, swelling, or discoloration which may indicate

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overheating or age-related degradation. The internal bus supports (insulators) will be

inspected for structural integrity and cracking.

Generally vendors do not recommend re-torque of bolted connections unless the joint

requires service or the bolted connections are clearly loose. The torque required to turn

the fastener in the tightening directions (restart torque) is not a good indicator of the

preload once the fastener is in service. After relaxation of the parts of the joint the final

loads are likely to be lower than the installed loads and thus, as documented in the Audit

and Review Report, the staff asked the applicant to justify technically how re-torquing of

bolted connections indicates preload once the fastener is in service.

In response to this request the applicant informed the staff that it will revise ALRA

Sections A1.1.27, A2.1.27, and B2.1.34 to delete the torque test/torque checks and

include as an alternative to thermography or connection resistance measurement of

bolted connection a visual inspection for the accessible bolted connections covered with

heat sink tape, sleeving, insulating boots, etc. (NMP1 Commitment 31, NMP2

Commitment 29). The staff found the applicant's response acceptable because

thermography, resistance checks, or visual inspections of bolted connections covered

with heat sink tape, sleeving, or insulating boots will provide reasonable assurance that

bolted connections are not loosened by ohmic heating. The staff also determined that

the six-year inspection frequency is adequate to prevent bus duct failures as industry

experience shows that aging degradation is a slow process. In its letter dated

December 1, 2005, the applicant stated that it will revise the ALRA to incorporate the

changes.

The staff confirmed that this program element satisfies the criterion of GALL Report and

SRP-LR Section A.1.2.3.3 and concludes that this program attribute is acceptable.

(4) Detection of Aging Effects - In ALRA Section B2.1.34 the applicant stated that visual

inspections of internal portions of bus ducts detect cracks, corrosion, debris, dust, and

evidence of water intrusion and that visual inspections of the bus insulating system

detect embrittlement, cracking, melting, swelling, and discoloration. Visual inspections of

bus supports (insulators) detect cracking and lack of structural integrity. Internal portions

of bus ducts, the bus insulation system, and the bus supports (insulators) are inspected

visually approximately every six years. Thermography or connection resistance

measurment of the bus ducts or a torque test of a sample of accessible bolted

connections will be performed approximately every six years. An initial inspection will be

completed before the end of the initial 40-year license term. This period is adequate to

identify failures of the bus ducts as experience shows that aging degradation is a slow

process. A six-year inspection frequency will provide during a 20-year period up to three

data points which can be used to characterize the degradation rate. If unacceptable

degradation is found as indicated by either increased resistance or visual anomalies the

inspections will be expanded to determine the extent of the condition.

As documented in the Audit and Review Report dated January 18, 2006, the applicant

agreed to address the staffs concern and remove the torque test/torque check options

as reported in Element 3. The applicant will determine sample size by accepted industry

practice or vendor recommendation.

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The staff determined that this program element satisfies the criteria of

Appendix A. 1.2.3.4 of the SRP-LR. Visual inspection of the bus insulating system will

detect embrittlement, cracking, melting, swelling, and discoloration which are aging

effects and aging effects mechanisms of insulation materials from heating.

Thermography or connection resistance measurement of bolted connections will detect

bolting loosening from thermal cycling. The staff also determined that the proposed

frequency is acceptable because the expected aging degradation is a slow process.

The staff confirmed that this program element satisfies the criterion of SRP-LR

Section A.1.2.3.4 and concludes that this program attribute is acceptable.

(5) Monitoring and Trending - In ALRA Section B2.1.34 the applicant stated that monitoring

and trending are not included as part of this program because the ability to trend

inspection results is limited by available data; however, inspection results will be used to

characterize degradation rates. This exception is consistent with latest industry and

regulatory license renewal precedence. Existing inspection procedures will be enhanced

to expand visual inspections of the bus duct support and insulation systems. Also, new

provisions will be made for either periodic low-range resistance checks of the bus ducts

or torque of a statistical sample of accessible bolted connections. The staff found that

the absence of trending for testing is acceptable as the test is performed every six years

and the staff saw no need for such activities.

The staff confirmed that this program element satisfies the criteria of the GALL Report

and SRP-LR Section A.1.2.3.5 and concludes that this program attribute is acceptable.

(6) Acceptance Criteria - In ALRA Section B2.1.34 the applicant stated that bolted

connections must meet the manufacturer's minimum torque specifications or the lowresistance value of the bus ducts must be appropriate for the application. Bus ducts are

to be free from unacceptable visual indications of surface anomalies that suggest

conductor insulation degradation. Additional acceptance criteria include no indication of

unacceptable corrosion, cracking, foreign debris, excessive dust buildup, or moisture

intrusion. Any condition or situation that if not corrected could lead to a loss of intended

function is considered unacceptable.

As documented in the Audit and Review Report, the staff expressed its concern during

the staff audit about re-torquing of the bolted connections. The applicant informed the

staff that it will revise the acceptance criteria to delete the torque test/torque check

option and include as an alternative to thermography or connection resistance

measurement of bolted connections a visual inspection of the accessible bolted

connections covered with heat shrink tape, sleeving insulating, boots, etc. (NMP1

Commitment 31, NMP2 Commitment 29). In its letter dated November 17, 2005,, the

applicant stated that it has added an enhancement for program document to define

acceptance criteria for inspection of the bus duct, their support and insulation system,

the low range ohmic checks of connections. This revision resolved the staffs concern.

The staff reviewed this program element to determine whether it satisfies the criteria of

SRP-LR Appendix A.1.2.3.6. The staff found the acceptance criteria acceptable as the

low resistance value of the bus ducts must be appropriate for the application. Bus ducts

are to be free from unacceptable visual indications of surface anomalies that suggest

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conductor insulation degradation. Additional acceptance criteria include no indication of

unacceptable corrosion, cracking, foreign debris, excessive dust buildup, or moisture

intrusion.

The staff confirmed that this program element satisfies the criteria of SRP-LR

Section A.1.2.3.6 and concludes that this program attribute is acceptable.

(7) Corrective Actions - The staff's review of the adequacy of the applicant's 10 CFR 50

Appendix B Program associated with this program element is addressed in SER

Section 3.0.4.

The staff reviewed other aspects of this program element to determine whether it

satisfies the criteria of Appendix A.1.2.3.7 of the SRP-LR. The applicant stated that

corrective actions are documented using the CR process. The Quality Assurance

Program Topical Report (Appendix B to "Nine Mile Point Nuclear Station Unit 1 Final

Safety Analysis Report (Updated)" and Appendix B to "Nine Mile Point Nuclear Station

Unit 2 Updated Safety Analysis Report") documents the applicant's commitment to the

corrective action criteria of 10 CFR 50 Appendix B, "Quality Assurance Criteria for

Nuclear Power Plants and Fuel Reprocessing Plants." The applicant's CAP includes the

detection and correction of conditions adverse to quality and the identification, cause

determination, correction, prevention of recurrence of conditions significantly adverse to

quality. GALL AMP XI.E4, which incorporated ISG-17, "Proposed Aging Management

Program (AMP) XI.E4, 'Periodic Inspection of Bus Ducts,'" under corrective actions,

states that further investigation and evaluation are performed when acceptance criteria

are not met. Corrective actions may include but are not limited to cleaning, drying,

increasing inspection frequency, replacing, or repairing the affected metal-enclosed bus

components. If an unacceptable condition or situation is detected a determination is

made whether the same condition or situation applies to other accessible or inaccessible

areas. The applicant's CAP does not address the specific requirement of GALL

AMP XI.E4. As documented in the Audit and Review Report the staff requested that the

applicant revise NMP AMP B2.1.34 to add specific requirements or justify why these

corrective actions are not necessary. The applicant informed the staff that it will revise

NMP AMP B2.1.34 by adding the following to the "corrective actions" program element:

Further investigation and evaluation are performed when the

acceptance criteria are not met. Corrective actions may include

but are not limited to cleaning, drying, increased inspection

frequency, replacement, or repair of the affected bus duct

components. If an unacceptable condition or situation is identified,

a determination is made to whether the same condition or

situation is applicable to other accessible or inaccessible bus

duct/components.

The staff found the applicant's response acceptable because it is consistent with the

corrective actions in GALL AMP XI.E4. In its letter dated December 1, 2005, the

applicant stated that it will revise the ALRA to incorporate the changes and on this basis

the staff found this program element acceptable.

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(8) Confirmation Process - The staff's review of the adequacy of the applicant's 10 CFR 50

Appendix B Program associated with this program element is addressed in SER

Section 3.0.4.

The staff reviewed other aspects of this program element to determine whether it

satisfies the criteria of Appendix A.1.2.3.8 of the SRP-LR. The staff found the applicant's

confirmation process meets the requirements of 10 CFR Part 50 Appendix B.

(9) Administrative Controls - The staffs review of the adequacy of the applicant's

10 CFR 50, Appendix B Program associated with this program element is addressed in

SER Section 3.0.4.

The staff reviewed other aspects of this program element to determine whether it

satisfies the criteria of Appendix A.1.2.3.9 of the SRP-LR. The staff found the applicant's

administrative controls meet the requirements of 10 CFR Part 50 Appendix B.

(10) Operating Experience - In ALRA Section B2.1.34 the applicant explained that

inspections of the bus ducts within the scope of license renewal have not revealed any

age-related degradation that could cause a loss of intended function.

The staff reviewed the operating experience stated in the ALRA and interviewed the

applicant's technical personnel to confirm that the plant-specific operating experience

revealed no degradation not bounded by industry experience.

After review of industry and plant-specific operating experience and discussions with the

applicant's technical personnel the staff confirmed that the operating experience

program element satisfies the criteria defined SRP-LR Section A.1.2.3.10 and concludes

that this program attribute is acceptable.

UFSAR and USAR Supplements. The applicant provided its UFSAR and USAR supplements

for the Non-Segregated Bus Inspection Program in ALRA Appendix A Section A1.1.27 for

NMP1 and A2.1.27 for NMP2 stating that its Non-Segregated Bus Inspection Program

manages aging effects and aging effects mechanisms for components and materials internal to

the nonsegregated bus ducts that connect the reserve auxiliary transformer to the 4160V buses

required for the recovery of offsite power following an SBO event. Based upon the most recent

industry and regulatory license renewal precedence, this program also includes normally

energized bus ducts associated with board-feeding components within the scope of license

renewal. These normally-energized components are not subject to the environmental

qualification requirements of 10 CFR 50.49 but can be affected by elevated temperatures prior

to the end of the period of extended operation. Program activities include visual inspections of

internal portions of the bus ducts to detect cracks, corrosion, debris, dust, and moisture; visual

inspections of the bus insulating system to detect embrittlement, cracking, melting, swelling,

and discoloration; visual inspections of bus supports (insulators) to detect cracking and lack of

structural integrity; and a torque test or a resistance test of a sample of accessible bolted

connections. The program incorporates applicable technical information and guidance from

industry. Analytical trending is not included in this activity because the ability to trend inspection

results is limited. This omission is an exception to the "monitoring and trending" element in

Appendix A.1.2.3.5 of the SPR-LR. Enhancements to the applicant's Non-Segregated Bus

Inspection Program include expanded visual inspections of the bus ducts, their supports, and

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insulation systems as well as low range resistance checks of the bus ducts or torque checks

from a statistical sample of accessible bolted connections. Enhancements will be implemented

prior to the period of extended operations.

Generally vendors do not recommend re-torque of bolted connections unless the joint requires

service or the bolted connections are clearly loose. The torque required to turn the fastener in

the tightening directions (restart torque) is not a good indicator of preload once the fastener is

in service. After relaxation of the parts of the joint the final loads are likely to be lower than the

installed loads. As documented in the Audit and Review Report, the staff requested that the

applicant justify technically how re-torquing of bolted connections indicates preload once the

fastener is in service. In response to this request the applicant informed the staff that it will

revise ALRA Sections Al.1.27, A2.1.27, and B2.1.34 to delete the torque test/torque checks

and include as an alternative to thermography or connection resistance measurement of bolted

connections visual inspection of the accessible bolted connections covered with heat sink tape,

sleeving, insulating boots, etc. (NMP1 Commitment 31, NMP2 Commitment 29). The staff found

the applicant's response acceptable because thermography, resistance check, or visual

inspection of bolted connections covered with heat sink tape,. sleeving, or insulating boots will

provide reasonable assurance that bolted connections are not loose from ohmic heating. In its

letter dated December 1, 2005, the applicant stated that it had revised the ALRA to incorporate

such changes.

Conclusion. On the basis of its review and audit of the applicant's Non-Segregated Bus

Inspection Program, the staff concludes that the applicant demonstrated that the effects of

aging will be adequately managed so that the intended functions will be maintained consistent

with the CLB for the period of extended operation, as required by 10 CFR 54.21 (a)(3). The staff

also reviewed the UFSAR and USAR supplements for this AMP and concludes that they

provide an adequate summary description of the program, as required by 10 CFR 54.21(d).

3.0.3.3.4 Fuse Holder Inspection Program

Summary of Technical Information in the Amended Application. In ALRA Section B2.1.35, the

applicant described the Fuse Holder Inspection Program, stating that this is a new,

plant-specific program. Fuse holders/blocks are classified as a specialized type of terminal

block because of the similarity in design and construction. The fuse holders are typically

constructed of blocks of rigid insulating material, such as phenolic resins. Metallic clamps are

attached to the blocks to hold each end of the fuse. The clamps can be spring-loaded clips that

allow the fuse ferrules or blades to slip in, or they can be bolt lugs, to which the fuse ends are

bolted. The clamps are typically made of copper. The aging of the fuse holder insulation

material will be managed under the program for Electrical Cables and Connections Not Subject

to 10 CFR 50.49 Environmental Qualification Requirements. The Fuse Holder Inspection

Program includes the following aging stressors: moisture, fatigue, ohmic heating, mechanical

stress, vibration, thermal cycling, electrical transients, chemical contamination, oxidation, and

corrosion. In-scope fuse holders are tested to provide a direct indication of the condition of the

metallic clamps. Fuses may be tested using either thermography or contact resistance.

In the ALRA, the applicant states that only fuse holders located outside active devices and not

part of larger assemblies are included in the program. The applicant also stated that the fuse

holders are typically constructed of blocks of rigid insulating material like phenolic resins.

Metallic clamps are attached to the blocks to hold each end of the fuse. The clamps can be

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spring-loaded clips that allow the fuse ferrules or blades to slip in or they can be lugs to which

the fuse ends are bolted. The clamps are made typically of copper. In ALRA Table 3.6.2.C-1

the applicant categorized the fuse holder components into insulator materials and copper alloy

clamps in the Material column. The applicant stated that the aging of the fuse holder insulation

material will be managed under Non-EQ Electrical Cables and Connection Program (ALRA

Section B2.1.29), which was evaluated in SER Section 3.6.2.1. The metallic clamps of the fuse

holders are evaluated in this section. The applicant stated in Table 3.6.2.C-1 that the metallic

clamps of the fuse holders are subject to the Fuse Holder Inspection Program. The applicant

further identified in ALRA Table 3.6.2.C-1 loss of electrical continuity as the AERM.

The applicant stated that the aging of the fuse holder copper alloy clamps will be managed

under a new program called Fuse Holder Inspection Program as addressed in this SER section

3.0.3.3.4

Staff Evaluation. In accordance with 10 CFR 54.21(a)(3), the staff reviewed the information

included in ALRA Section B2.1.35, regarding the applicant's demonstration of the Fuse Holder

Inspection Program to ensure that the effects of aging, as discussed above, will be adequately

managed so that the intended functions will be maintained consistent with the CLB for the

period of extended operation. Details of staff evaluation AMP B2.1.35 are as follows:

The staff reviewed the Fuse Holder Inspection Program against the AMP elements found in

SRP-LR Section A.1.2.3 and SRP-LR Table A.1-1 focusing on how the program manages

aging effects through the effective incorporation of 10 elements (i.e., "program scope," "preventive actions," "parameters monitored or inspected," "detection of aging effects," "monitoring and trending," "acceptance criteria," "corrective actions," "confirmation process," 'administrative controls," "and "operating experience").

The applicant indicated that corrective actions, confirmation process, and administrative

controls are part of the site-controlled quality assurance program. The staffs evaluation of the

quality assurance program is addressed in SER Section 3.0.4. The remaining seven elements

are addressed here:

(1) Scope of Program - In ALRA Section B2.1.35 the applicant stated that this program

applies to metallic clamps of fuse holders located outside active devices that have aging

effects requiring aging management. This application is acceptable to the staff because

it is consistent with the GALL Report and complements the information provided by the

applicant for insulator material.

The staff confirmed that this element satisfies the criterion of SRP-LR Section A.1.2.3.1

and concludes that this program attribute is acceptable.

(2) Preventive Actions - In ALRA Section B2.1.35 the applicant stated that the Fuse Holder

Inspection Program monitors conditions and requires regular inspection of the in-scope

components and identification of degraded conditions that would affect the ability of the

components to perform intended functions. Consequently, no specific preventive actions

are associated with this program other than identification of the aging effects of concern

before a loss of intended function occurs. The staff did not identify the need for any

preventive action except condition monitoring including thermography or contact

resistance checks.

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The staff confirmed that the "preventive actions" program element satisfies the criterion

of SRP-LR Section A.1.2.3.2 and concludes that this program attribute is acceptable.

(3) Parameters Monitored/Inspected - In ALRA Section B2.1.35 the applicant stated that

monitored parameters will include high resistance of the metallic clamp (or clip) portion

of the fuse holder to detect fatigue caused by ohmic heating, thermal cycling, electrical

transients, mechanical stress, chemical contamination, corrosion, and oxidation. The

staff agreed that testing clamp resistance using thermography or contact resistance

effectively ensures that the fuse holder clamps will perform their intended function for

the extended period of operation.

The staff confirmed that this program element satisfies the criterion of SRP-LR

Section A.1.2.3.3 and concludes that this program attribute is acceptable.

(4) Detection of Aging Effects - In ALRA Section B2.1.35 the applicant stated that the fuse

holders will be tested at least every 10 years by thermography, contact resistance, or

other appropriate testing methods. The initial inspection will be prior to the period of

extended operation and thereafter a 10-year inspection frequency will be used to

provide at least two data points during the 20-year period of extended operation. The

staff agreed that the aging degradation of fuse holder clamps is a slow process and that

a 10-year inspection frequency is adequate to prevent failures of fuse holder clamps.

The staff confirmed that this program element satisfies the criterion of SRP-LR

Section A.1.2.3.4 and concludes that this program attribute is acceptable.

(5) Monitoring and Trending - In ALRA Section B2.1.35 the applicant stated that monitoring

and trending are not included in this program because the parameters monitored may

vary depending upon the test method used. The staff concurred with this policy because

thermography or connection resistance test will be performed at 10-year intervals,

appropriate methods can be used for subsequent tests, and so long the test results

confirm no loosening of the fuse holder clamps there is no need for monitoring and

trending the test results.

The staff confirmed that this program element satisfies the criteria of SRP-LR

Section A.1.2.3.5 and concludes that this program attribute is acceptable.

(6) Acceptance Criteria - In ALRA Section B2.1.35 the applicant stated that the acceptance

criteria for each fuse holder clamp will depend on the specific test performed and the

specific fuse holder clamp tested. As explained in the "monitoring and trending" program

element, the staff concurred that acceptance criteria should depend on the type of test

and the type of clamp.

The staff confirmed that this program element satisfies the criteria of SRP-LR

Section A.1.2.3.6 and concludes that this program attribute is acceptable.

(10) Operating Experience - In ALRA Section B2.1.35 the applicant stated that the Fuse

Holder Inspection Program is a new program at NMPNS and, therefore, no

programmatic operating experience is available. However, the applicant stated that

operating experienced lessons learned will be used to adjust this program as needed.

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The applicant committed to develop the Fuse Holder Inspection Program with

specifications stated in ALRA Section B2.1.35 (NMP1 Commitment 32 and NMP2

Commitment 30). The staff agreed that the proposed program will provide reasonable

assurance of detection of loosening of fuse holder clamps prior to significant

degradation.

The staff confirmed that this program element satisfies the criteria of SRP-LR

Section A.1.2.3.10 and concludes that this program attribute is acceptable.

UFSAR and USAR Supplements. In ALRA Sections A1.1.21 and A2.1.21, the applicant

provided the respective UFSAR and USAR supplements for the Fuse Holder Inspection

Program. The staff reviewed these sections and determined that the information in the

supplements provide adequate summary descriptions of the program, as required by

10 CFR 54.21(d).

Conclusion. On the basis of its review and audit of the applicant's Fuse Holder Inspection

Program, the staff concludes that the applicant demonstrated that the effects of aging will be

adequately managed so that the intended functions will be maintained consistent with the CLB

for the period of extended operation, as required by 10 CFR 54.21(a)(3). The staff also

reviewed the UFSAR and USAR supplements for this AMP and concludes that they provide an

adequate summary description of the program, as required by 10 CFR 54.21(d).

3.0.3.3.5 Non-EQ Electrical Cable Metallic Connections Inspection Program

Summary of Technical Information in the Amended Application. In ALRA Section B2.1.39, the

applicant described the Non-EQ Electrical Cable Metallic Connections Inspection Program,

stating that this is a new, plant-specific program. Most electrical connections involve insulating

material and metallic parts. This program will address the aging effects of the metallic parts

used to connect cable conductors to other cables or electrical devices. The Non-EQ Electrical

Cables and Connections Program will address the aging effects of the cable insulation material.

The electrical connections used in nuclear power plants include: splices (butt or bolted),

crimp-type ring lugs, and terminal blocks. The aging stressors to these connections addressed

by this program include: thermal cycling, ohmic heating, electrical transients, vibration, chemical

contamination, corrosion, and oxidation. The specific mechanism for each of these aging

stressors is described in the most recent industry and regulatory license renewal precedence.

The specific test performed will be determined prior to the initial test, and will be a proven test

for detecting loose connections, such as thermography, contact resistance testing, or other

appropriate testing. The applicant indicated that this program will be implemented prior to the

period of extended operation (NMP1 Commitment 35, NMP2 Commitment 33).

Staff Evaluation. In accordance with 10 CFR 54.21(a)(3), the staff reviewed the information

included in ALRA Section B2.1.39, regarding the applicant's demonstration of the Non-EQ

Electrical Cable Metallic Connections Inspection Program against the AMP elements of SRP-LR

Section A.1.2.3 and SRP-LR Table A.1-1 focusing on how the program manages aging effects

through the effective incorporation of 10 elements (i.e., "program scope," "preventive actions," "parameters monitored or inspected," "detection of aging effects," "monitoring and trending,"

"acceptance criteria," "corrective actions," "confirmation process," "administrative controls," "and

"operating experience").

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The applicant indicated that corrective actions, confirmation process, and administrative

controls are parts of the site-controlled quality assurance program. The staffs evaluation of the

quality assurance program is addressed in SER Section 3.0.4. The remaining seven elements

are addressed here.

(1) Scope of Program - In ALRA Section B2.1.39 the applicant stated that this program

applies to the metallic portion of non-EQ electrical cable connections. The staff found

the "scope of the program" acceptable as consistent with the GALL Report and

complementary to the information provided by the applicant for conductor insulation for

electrical cables and connectors.

The staff confirmed that this program element satisfies the criterion of SRP-LR

Section A.1.2.3.1 and concludes that this program attribute is acceptable.

(2) Preventive Actions - In ALRA Section B2.1.39, the applicant stated that the Non-EQ

Electrical Cable Metallic Connections Inspection Program requires regular inspection of

in-scope components and detection of degraded conditions that would affect the ability

of components to perform intended functions. No specific preventive actions are

associated with this program except identification of the aging effects of concern before

a loss of intended function occurs. The staff did not identify the need for any preventive

action except the condition monitoring program.

The staff confirmed that this program element satisfies the criterion of SRP-LR

Section A.1.2.3.2 and concludes that this program attribute is acceptable.

(3) Parameters Monitored/Inspected - In ALRA Section B2.1.39 the applicant stated that

monitored parameters will include testing representative samples for loosening of bolted

connections. The sample will be assessed on application voltage (high, medium, and

low voltage systems), circuit loading, and location (high temperature, high humidity,

vibration, etc.). The staff agreed that testing of representative samples using

thermography or contact resistance effectively ensures performance of conductor

connector intended function for the extended period of operation.

The staff confirmed that this program element satisfies the criterion of SRP-LR

Section A.1.2.3.3 and concludes that this program attribute is acceptable.

(4) Detection of Aging Effects - In ALRA Section B2.1.39 the applicant stated that loosening

of the electrical connections can be caused by one or more aging stressors, namely,

thermal cycling, ohmic heating, electrical transients, vibrations, chemical contamination,

corrosion, and oxidation. The applicant stated that one or more of the proven tests,

thermography, contact resistence, or other appropriate testing, will be performed case

by case.

The applicant stated that the initial inspection of this program will be performed prior to

the period of the extended operation and that thereafter a 10-year inspection frequency

will be used to provide at least two data points during the 20-year period of extended

operation. The applicant stated that for the slow degradation of the Non-EQ electrical

cable connections the 10-year test frequency for this program is adequate. The staff

agreed that industry experience shows that aging degradation of cable connections is a

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slow process and 10-year inspection frequency is adequate to prevent failures of cable

connections. The staff also agreed that thermography or connection resistance

measurement is effective in detecting connection degradation.

The staff confirmed that this program element satisfies the criterion of SRP-LR

Section A.1.2.3.4 and concludes that this program attribute is acceptable.

(5) Monitoring and Trending - In ALRA Section B2.1.39 the applicant stated that monitoring

and trending are not included in this program because the parameters monitored may

vary depending upon the test method. The staff concurred with this because the

thermography or connection resistance tests will be performed at 10-year intervals,

different methods can be used for subsequent tests, and so long as the test results

confirm no loosening of bolted connections there is no need for monitoring and trending

the test results.

The staff confirmed that this program element satisfies the criteria of SRP-LR

Section A.1.2.3.5 and concludes that this program attribute is acceptable.

(6) Acceptance Criteria - In ALRA Section B2.1.39 the applicant stated that the acceptance

criteria for each conductor connector will depend on the specific test used and the

specific conductor connector tested. The staff concurred that acceptance criteria should

depend on the type of test and the type of the conductor connector.

The staff confirmed that this program element satisfies the criteria of SRP-LR

Section A.1.2.3.6 and concludes that this program attribute is acceptable.

(10) Operating Experience - In ALRA Section B2.1.39 the applicant stated that the Non-EQ

Electrical Cable Metallic Connections Inspection Program is new at NMP; therefore, no

programmatic operating experience is available. As operating experience is obtained

lessons learned will be used to adjust this program as needed.

The staff confirmed that this program element satisfies the criteria of the GALL Report

and SRP-LR Section A.1.2.3.10 and concludes that this program attribute is acceptable.

UFSAR and USAR Supplements. In ALRA Sections A1.1.41 and A2.1.39, the applicant

provided the respective UFSAR and USAR supplements for the Non-EQ Electrical Cable

Metallic Connections Inspection Program. The staff reviewed these sections and determined

that the information in the supplements provide adequate summary descriptions of the program,

as required by 10 CFR 54.21(d).

Conclusion. After review of the applicant's Non-EQ Electrical Cable Metallic Connections

Inspection Program, the staff concludes that the applicant demonstrated that the effects of

aging will be adequately managed so that the intended functions will be maintained consistent

with the CLB for the period of extended operation, as required by 10 CFR 54.21 (a)(3). The staff

also reviewed the UFSAR and USAR supplements for this AMP and concludes that they

provide an adequate summary description of the program, as required by 10 CFR 54.21(d).

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3.0.3.3.6 Wooden Power Pole Inspection Program (NMP2 Only)

Summary of Technical Information in the Amended Application. In ALRA Section B2.1.40, the

applicant described the Wooden Power Pole Inspection Program for NMP2, stating that this is a

new, plant-specific program. The Wooden Power Pole Inspection Program manages the aging

of wooden power poles that are within the scope for license renewal because they provide

structural support for the transmission lines in the recovery path for station blackout. Qualified

personnel perform inspections, conducted prior to the period of extended operation and every

10 years thereafter, that manage material loss, degradation, and physical damage. Activities

include visual inspections of the entire structure, including cross members and hardware, pole

soundings, circumferential measurements, and below grade inspections. If necessary, core

boring, application of preservatives, and pesticide treatments are performed if soundings

suggest degradation has occurred. Corrective actions may include pole reinforcement or

replacement. The program inspection activities ensure that in-scope electrical support

structures retain their intended functions between inspection cycles.

Staff Evaluation. In accordance with 10 CFR 54.21 (a)(3), the staff reviewed the information

included in ALRA Section B2.1.40, regarding the applicant's demonstration of the Wooden

Power Pole Inspection Program to ensure that the effects of aging, as discussed above, will be

adequately managed so that the intended functions will be maintained consistent with the CLB

for the period of extended operation.

The applicant stated that the new plant-specific Wooden Power Pole Inspection Program

(NMP2 Commitment 34) that will manage the aging of wooden power poles within the scope of

license renewal because they provide structural support for the transmission lines in the SBO

recovery path.

The staff understands that the applicant's Wooden Power Pole Inspection Program is a

sub-program of its Structures Monitoring Program. In Appendices A and B of the ALRA for the

applicant's Masonry Wall Program, also a Structures Monitoring Program sub-program, this

relationship is addressed. In ALRA Section A2.1.40 for the Wooden Power Pole Program this

relationship with the applicant's Structures Monitoring Program is not addressed. As

documented in the Audit and Review Report, the staff requested the applicant to explain the

inconsistency.

In its letter dated December 1, 2005, the applicant stated that ALRA Sections A2.1.40 and

B2.1.40 had been modified at the end of the first paragraph by adding: "The Wooden Power

Pole Inspection Program is implemented by the Structures Monitoring Program for managing

specific aging effects." Also the applicant stated that the Wooden Power Pole Inspection

Program had been modified at the end of the program description paragraph by adding: "The

Wooden Power Pole Inspection Program is implemented by the Structures Monitoring Program

(B2.1.28) for managing specific aging effects."

The staff reviewed information provided in the ALRA and supplemental letters and found it

acceptable. With the clarifying statements added by the applicant to ALRA Sections A2.1.40

and B2.1.40 the relationship between its Wooden Power Pole Inspection Program and its

Structures Monitoring Program is addressed.

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The staff reviewed the Wooden Power Pole Inspection Program against the AMP elements of

SRP-LR Section A.1.2.3, and SRP-LR Table A.1-1 focusing on how the program will manage

aging effects through the effective incorporation of 10 elements (i.e., "program scope," "preventive actions," "parameters monitored or inspected," "detection of aging effects," "monitoring and trending," "acceptance criteria," "corrective actions," "confirmation process," "administrative controls," "and "operating experience") addressed here.

(1) Scope of Program - In ALRA Section B2.1.40 the applicant stated that this program

applies to wooden power poles relied upon for SBO recovery within the scope of license

renewal and subject to and AMR. The program includes visual inspections of the entire

structure, pole sounding and circumference measurements, below-grade inspections,

any necessary core boring, preservative application, and pesticide treatments.

The staff confirmed that this element satisfies the criterion of SRP-LR Section A.1.2.3.1

and concludes that this program attribute is acceptable.

(2) Preventive Actions - In ALRA Section B2.1.40 the applicant stated that this program

monitors conditions as described in SRP-LR Appendix A.1.1. The program provides for

timely detection of loss of material and degradation and physical damage, not

preventive or mitigating actions.

As documented in the Audit and Review Report, the staff noted that at ALRA page

B2-89 under scope of program for NMP AMP B2.1.40 the applicant states that the

program includes visual inspections of the entire structure, pole sounding and

circumference measurements, below-grade inspections, any necessary core boring,

preservative application, and pesticide treatments. However, the applicant stated in the

preceding paragraph that the Wooden Power Pole Inspection Program monitors

conditions and does not support preventive or mitigating actions. The staff requested

the applicant to explain why preservative applications are not preventive actions and

pesticide treatments are not mitigating actions.

In its letter dated December 1, 2005, the applicant stated that preservative applications

and pesticide treatments will enhance the lives of the poles by minimizing their

deterioration; however; the license renewal AMP is not based on these actions and does

not credit them. The aging management monitors conditions. The inspection frequency,

repair, and replacement of poles are based on the condition of the poles at the time of

inspection.

The staff reviewed the applicant's response and found it acceptable. Although

application of preservatives and pesticides to the wooden power poles is part of the

Wooden Power Pole Inspection Program license renewal aging management is not

based on these actions. For any one pole decreasing the inspection frequency to less

than every ten years and repairing or replacing it depends on the condition of the pole at

the time of the condition monitoring inspection. Application of preservatives or pesticides

is relied upon to prevent aging effects/mechanisms of the wooden power poles under

license renewal.

The staff determined that this program element satisfies the criterion of SRP-LR

Appendix A.1.2.3.2 and that inspections under the applicant's Wooden Power Pole

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Inspection Program only monitor the condition of the wooden power poles and perform

no preventive or mitigating action for aging effects and aging effects mechanisms. On

this basis, the staff found the applicant's preventive actions acceptable.

(3) Parameters Monitored/Inspected - In ALRA Section B2.1.40 the applicant stated that

wooden power poles will be inspected for material loss, degradation, and physical

damage. Techniques include visual examinations of the entire structure including cross

members and hardware, pole soundings, circumferential measurements, and belowgrade inspections. If necessary core boring, preservative applications, and pesticide

treatments are performed if soundings suggest degradation. Visual inspections check

the pole for physical or mechanical damage that can affect the life of the pole (lean or

tilt, splitting or cracked tops, changes to grade, and shell or butt rot and decay).

Excavations will be performed to a depth of approximately 18 inches to detect loss of

material or degradation or damage. Pole sounding will be performed by a qualified

inspector at various pole locations to detect internal rot/decay, insect damage or

infestations, or hollow areas. Core boring of the pole may be performed based on the

inspection and sounding results to detect internal decay, insect infestation, or hollow

areas. If insect infestation is found the area will be treated with a fumigant prior to

plugging of the bored core region. Preservative treatment of the excavated surfaces

(including moisture barrier/wrapping) also will be performed prior to recovering. Effective

circumference measurements evaluate the pole-loading capacity.

The program also monitors proper pole tagging and labeling .with treatment information

and application dates.

The staff determined that this program element satisfies the criterion of SRP-LR

Appendix A.1.2.3.3 and that the applicant has identified clearly the parameters of

wooden power poles that need inspection for aging effects and aging effects

mechanisms affecting the ability of the wooden power poles to perform their intended

function. Visual examinations of the entire wooden power pole structure with core boring

and soundings as needed will check each pole for physical or mechanical damage that

can affect the life of the pole. Parameters monitored include lean or tilt, splitting or

cracked tops, changes to buried depth, shell or butt rot or decay, internal rot/decay,

insect damage or infestations, circumferential measurements, and hollow areas. For

these reasons the staff found the applicant's "parameters monitored or inspected"

program element acceptable.

(4) Detection of Aging Effects - In ALRA Section B2.1.40 the applicant stated that the

inspections in the new program shall be by qualified personnel on components within

the scope of license renewal within five years of the expiration of the current operating

license. Subsequent visual inspections and testing for the wooden poles will be every

ten years. This frequency is based on industry experience, which shows that although

the typical wooden pole life is expected to be 30 to 40 years routine inspection and

treatment can extend this life by 50 percent or more. Typical industry inspection

frequencies for wooden poles currently range from 8 tol5 years.

The 10-year visual inspections and testing will detect degradation and identify

deficiencies before there is a loss of intended function. All inspections will provide the

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level of detail and examination necessary to ensure that intended functions are

preserved through each subsequent inspection cycle.

The staff determined that this program element satisfies the criteria of SRP-LR

Appendix A.1.2.3.4 and that the applicant has identified the frequency of inspection of

the wooden power poles as within five years of the expiration of the current operating

license and every 10 years after based on industry experience. Every wooden power

pole within the scope of license renewal will be inspected. Visual examinations of the

entire wooden power pole structure with core boring and soundings as needed are

adequate methods to gather data on the condition of the wooden power poles. For these

reasons the staff found the applicant's "detection of aging effects" program element

acceptable.

(5) Monitoring and Trending - In ALRA Section B2.1.40 the applicant stated that this

program shall retain all previous inspection records. These are plant records available

for review during the subsequent inspection cycle. Reviews of previous inspection

results will provide for trending of long-term degradation or deterioration. This

information also could help in evaluating the potential for degradation before the next

inspection.

Additionally, the program shall provide for appropriate engineering reviews of the

inspection results. Although the inspections may be performed by an outside vendor or

contractor or by the applicant's personnel in-house reviews of the results will confirm

that the wooden poles are capable of continuing to perform their intended functions

through the next inspection cycle.

The staff determined that for visual inspection this program element satisfies the criteria

of SRP-LR Appendix A.1.2.3.5. The staff found that the applicant intends to retain all

inspection records under its Wooden Power Pole Inspection Program. Reviews of

previous inspections will be done so that long-term degradation can be trended.

In-house reviews of the results shall be performed to confirm that the wooden poles are

capable of continuing to perform their intended functions through the next inspection

cycle. For these reasons the staff found the applicant's "monitoring and trending"

program element acceptable.

(6) Acceptance Criteria - In ALRA Section B2.1.40 the applicant stated that this program will

specify qualification and experience requirements in the inspection, treatment, and

reinforcement of wooden power poles for personnel performing inspections. For

inspections contracted to outside vendors or contractors all required qualifications

including minimum years of experience, pesticide applicator licenses or certifications,

and wood treatment and fumigant qualifications are specified. All work by the applicant

or vendor/contractor shall be performed to the criteria or standards stated in the NMP

activity and through site-specific procedures.

The program will detail the inspection methods with any applicable acceptance/rejection

criteria. Any pole found to have loss of material, degradation, or physical damage will be

assessed and treated. The capability of a degraded pole to continue performing

load-carrying intended functions will be evaluated. Additionally, the program will identify

and label wooden poles warranting immediate rejection due to dangerous conditions as

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well as those with serious but lesser defects requiring repair, reinforcement, or

nonemergent replacement. All poles classified as rejected or dangerous will be labeled

or tagged during the inspection denoting the degradation severity level.

The staff reviewed this program element to determine whether it satisfies the criteria of

SRP-LR Appendix A.1.2.3.6. The staff determined that the applicant intends under its

Wooden Power Pole Inspection Program to specify the inspection methods and any

applicable acceptance/rejection criteria. In addition detailed qualification and experience

requirements will be developed for personnel performing the inspections. The inspection

results will be used to evaluate the capability of a degraded pole to continue performing

its load-carrying intended functions. For these reasons the staff found the applicant's

acceptance criteria acceptable.

(7) Corrective Actions - The adequacy of the applicant's 10 CFR 50 Appendix B Program

associated with this program element reviewed by the staff is addressed in SER

Section 3.0.4.

In ALRA Section B2.1.40 the applicant stated that the Quality Assurance Program

Topical Report documents its commitment to the corrective action criteria of 10 CFR 50

Appendix B. The applicant's Wooden Power Pole Inspection Program will direct the use

of the site CAP when conditions adverse to quality are identified. These actions include

evaluations of adverse or degraded conditions and wooden pole reinforcement or

replacement.

The staff reviewed other aspects of this program element to determine whether it

satisfies the criteria of SRP-LR Appendix A.1.2.3.7. The staff determined that the

applicant intends to take action to correct conditions adverse to wooden power pole

quality by performing evaluations for wooden pole reinforcement or replacement. For

these reasons the staff found the applicant's corrective actions acceptable.

(8) Confirmation Process - The adequacy of the applicant's 10 CFR 50 Appendix B

Program associated with this program element reviewed by the staff is addressed in

SER Section 3.0.4

In ALRA Section B2.1.40 the applicant stated that the Quality Assurance Program

Topical Report documents the confirmation process for it under the corrective action

criterion. The applicant's confirmation process is implemented through corrective action

effectiveness reviews and is performed for selected hardware-related and other

conditions significantly adverse to quality. The applicant's CAP includes but is not limited

to SR, NSR, and fire protection SSCs. Therefore, those SSCs within the scope of

license renewal are addressed as part of the applicant's current CAP.

The staff confirmed that this program element satisfies the criteria of SRP-LR

Section A.1.2.3.8 and concludes that this program attribute is acceptable.

(9) Administrative Controls - The adequacy of the applicant's 10 CFR 50 Appendix B

Program associated with this program element reviewed by the staff is addressed in

SER Section 3.0.4.

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In ALRA Section B2.1.40 the applicant stated that its Wooden Power Pole Inspection

Program will be implemented through procedures subject to the 10 CFR 50 Appendix B

administrative controls program. The administrative controls for NMP are discussed in

its Conduct of Operations description and the Quality Assurance Program Topical

Report

The staff reviewed other aspects of this program element to determine whether it

satisfies the criteria of SRP-LR Appendix A.1.2.3.9 and determined that the applicant's

Wooden Power Pole Inspection Program has regulatory and administrative controls

providing a formal review and approval process of the program. For these reasons the

staff found the applicant's administrative controls acceptable.

(10) Operating Experience - In ALRA Section B2.1.40 the applicant stated that the Wooden

Power Pole Inspection Program is defined and implemented for license renewal; thus,

there is no plant-specific operating experience. Review of corrective action process

reports yielded nothing applicable to wooden pole aging or degradation. Inspection

scheduling and performance as discussed in the other SRP-LR attributes will provide

plant-specific inspection data and experience prior to the end of the current operating

period.

The staff recognized that the applicant's CAP which records internal and external plant

operating experience will ensure that operating experience is reviewed and incorporated

in the future for objective evidence to support the conclusion that the effects of aging

are adequately managed.

After discussions with the applicant's technical personnel the staff concludes that the

applicant's Wooden Power Pole Inspection Program (NMP2 Only) will manage

adequately the aging effects and aging effects mechanisms identified in the ALRA for

which this AMP is credited.

The staff confirmed that this program element satisfies the criteria of SRP-LR

Section A.1.2.3.10 and concludes that this program attribute is acceptable.

USAR Supplement. In ALRA Section A2.1.40, the applicant provided the USAR supplement for

the Wooden Power Pole Inspection Program. The staff reviewed this section and determined

that the information in the USAR supplement provide an adequate summary description of the

program, as required by 10 CFR 54.21(d).

Conclusion. On the basis of its review and audit of the applicant's Wooden Power Pole

Inspection Program, the staff concludes that the applicant demonstrated that the effects of

aging will be adequately managed so that the intended functions will be maintained consistent

with the CLB for the period of extended operation, as required by 10 CFR 54.21 (a)(3). The staff

also reviewed the USAR supplement for this AMP and concludes that they provide an adequate

summary description of the program, as required by 10 CFR 54.21(d).

3.0.3.3.7 Torus Corrosion Monitoring Program (NMP1 Only)

Summary of Technical Information in the Amended Application. In ALRA Section B3.3, the

applicant described the Torus Corrosion Monitoring Program for NMP1, stating that this is an

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existing, plant-specific program. The Torus Corrosion Monitoring Program credited for aging

management of the NMP1 suppression chamber (torus). This program is based on a prior

commitment to periodically monitor torus condition as described in an NRC SER dated

August 11, 1994 (NUDOCS: 80615:233-244). The staff reviewed the ALRA to determine

whether the applicant has demonstrated that the Torus Corrosion Monitoring Program will

manage adequately the aging effects of the NMP1 torus during the period of extended

operation as required by 10 CFR 54.21 (a)(3).

The applicant states in the ALRA that the Torus Corrosion Monitoring Program manages

corrosion of the NMP1 torus through inspection and analysis. This program is designed to

ensure that the torus shell and support structure minimum thickness limits are not exceeded.

This program provides for the following inspection and analysis methods:

" determination of torus shell thickness through UT measurement

" determination of corrosion rate through analysis of material coupons

" visual inspection of accessible external surfaces of the torus support structure for

corrosion

Observations of the torus shell and support structure conditions ensure that timely action can

be taken to correct degradation that could lead to loss of intended function. The minimum

allowable torus wall thickness is established as 0.431 inches. This program requires in addition

to wall thickness measurements determination of corrosion rates from inspection results and

the remaining corrosion allowance. The aging evaluation that specifies minimum wall thickness

for the NMP1 torus shell is a TLAA for license renewal. The Torus Corrosion Monitoring

Program ensures that the NMP1 torus wall and support structure thickness limits are not

exceeded. This program applies only to NMP1 because NMP2 is a Mark II containment with no

torus.

Staff Evaluation. In accordance with 10 CFR 54.21(a)(3), the staff reviewed the information

included in ALRA Section B3.3, regarding the applicant's demonstration of the Torus Corrosion

Monitoring Program to ensure that the effects of aging, as discussed above, will be adequately

managed so that the intended functions will be maintained consistent with the CLB for the

period of extended operation.

The staff reviewed the Torus Corrosion Monitoring Program against the AMP elements found in

SRP-LR Section A.1.2.3 and SRP-LR Table A.1-1 focusing on how the program manages

aging effects through the effective incorporation of 10 elements (i.e., "program scope," "preventive actions," "parameters monitored or inspected," "detection of aging effects," "monitoring and trending," "acceptance criteria," "corrective actions," "confirmation process," "administrative controls," "and "operating experience").

The applicant indicated that the corrective actions, confirmation process, and administrative

controls are parts of the site-controlled quality assurance program. The staffs evaluation of the

quality assurance program is addressed in SER Section 3.0.4. The remaining seven elements

are discussed here.

(1) Scope of Program - In ALRA Section B3.3 the applicant stated that the NMP1 Torus

Corrosion Monitoring Program determines torus shell thickness through UT

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measurement, determination of corrosion rate through analysis of material coupons, and

visual inspection of accessible external surfaces of the torus support structure for

corrosion. The staff found the scope of the Torus Corrosion Monitoring Program

acceptable because it is comprehensive in its surveillance of the torus and its support

structure.

The staff confirmed that this element satisfies the criterion of SRP-LR Section A.1.2.3.1

and concludes that this program attribute is acceptable.

(2) Preventive Actions - In ALRA Section B3.3 the applicant stated that the Torus Corrosion

Monitoring Program monitors conditions and requires no specific preventive actions.

The staff agreed that the purpose of the program is to monitor material thickness and

corrosion rate to ensure that the torus shell and support structure meet the qualification

bases and that no preventive actions are required for this program.

The staff confirmed that this program element satisfies the criterion of SRP-LR

Section A.1.2.3.2 and concludes that this program attribute is acceptable.

(3) Parameters Monitored or Inspected - In ALRA Section B3.3 the applicant stated that the

torus wall thickness is measured through UT measurements and torus coupon activities.

The condition of the torus external supports is monitored by visual inspection. The staff

found that the applicant has selected parameters to be inspected or monitored that can

provide evidence of corrosion to ensure that timely action can be taken to correct

degradation that could threaten the minimum material thickness requirement.

The staff confirmed that this program element satisfies the criterion of SRP-LR

Section A.1.2.3.3 and concludes that this program attribute is acceptable.

(4) Detection of Aging Effects - In ALRA Section B3.3 the applicant stated that torus wall

UT measurements are obtained at approximately six-month intervals over a predefined

grid system and that corrosion sample coupons are analyzed during each refueling

outage. Corrosion rates are determined through analysis of both data sets and the most

conservative corrosion rate for a particular torus bay is used to evaluate aging of the

structure. The staff found that monitoring in this manner ensures the torus shell material

will meet the minimum required wall thickness and that any degradation is detected

before a loss of intended function.

The staff confirmed that this program element satisfies the criterion of SRP-LR

Section A.1.2.3.4 and concludes that this program attribute is acceptable.

(5) Monitoring and Trending - In ALRA Section B3.3 the applicant stated that

measurements are performed on a predefined schedule that allows for analysis of the

corrosion and thickness data for the torus shell over time. The UT results and corrosion

data are trended for future reference. Analysis determines the most conservative value

for the corrosion rate. Visual inspection findings for the external support structure are

compared to previous inspection results. The staff found that the overall monitoring and

trending techniques proposed by the applicant manage the applicable aging effects

effectively and are acceptable.

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The staff confirmed that this program element satisfies the criteria of SRP-LR

Section A.1.2.3.5 and concludes that this program attribute is acceptable.

(6) Acceptance Criteria - In ALRA Section B3.3 the applicant stated that the Torus

Corrosion Monitoring Program establishes acceptance criteria for local thickness,

average thickness, and corrosion rate of the torus wall. The minimum wall thickness and

corrosion rate limits are defined to ensure that wall thickness meets its required value

until the next scheduled inspection. The external support structures also are evaluated

to ensure that the intended functions are not lost prior to the next scheduled inspection.

The staff found these criteria acceptable as consistent with the criteria of the staffs

August 11, 1994, SER. The criteria ensure that the torus will continue to meet ASME

code requirements that the average minimum wall thickness of the torus shell be not

less than 0.431 inch.

The staff confirmed that this program element satisfies the criteria of SRP-LR

Section A.1.2.3.6 and concludes that this program attribute is acceptable.

(10) Operating Experience - In ALRA Section B3.3 the applicant stated that torus wall

thinning was observed in the late 1980s following an extended plant shutdown. The

applicant stated that the wall thinning was attributed to the layup conditions inside the

torus during the extended shutdown. To cope with this plant-specific experience the staff

approved the NMP1 Torus Corrosion Monitoring Program in the SER dated August 25,

1992. The program later was updated and the staff evaluation of the updated program

was documented in the SER dated August 11, 1994. The applicant stated that review of

plant-specific operating experience revealed no discrepancies in the Torus Corrosion

Monitoring Program examinations. The applicant also stated that the Torus Corrosion

Monitoring Program is adjusted continually to account for industry experience and

research. The staff reviewed past inspection reports which indicate no significant

changes in the torus wall corrosion rate. Following this review the staff found that this

program will manage adequately aging effects on the torus wall and torus support

structure.

The staff confirmed that this program element satisfies the criteria of SRP-LR

Section A.1.2.3.10 and concludes that this program attribute is acceptable.

UFSAR Supplement. In ALRA Section A1.1.36, the applicant provided the UFSAR supplement

for the Torus Corrosion Monitoring Program. The staff reviewed this section and determined

that the information in the UFSAR supplement provides an adequate summary description of

the program, as required by 10 CFR 54.21(d).

Conclusion. On the basis of its review and audit of the applicant's Torus Corrosion Monitoring

Program, the staff concludes that the applicant demonstrated that the effects of aging will be

adequately managed so that the intended functions will be maintained consistent with the CLB

for the period of extended operation, as required by 10 CFR 54.21(a)(3). The staff also

reviewed the UFSAR supplement for this AMP and concludes that it provides an adequate

summary description of the program, as required by 10 CFR 54.21(d).

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3.0.4 Quality Assurance Program Attributes Integral to Aging Management Programs

Pursuant to 10 CFR 54.21(a)(3), a license renewal applicant is required to demonstrate that the

effects of aging on structures and components subject to an AMR will be adequately managed

so that their intended functions will be maintained consistent with the CLB for the period of

extended operation. SRP-LR, Branch Technical Position RLSB-1, "Aging Management Review -

Generic," describes ten attributes of an acceptable AMP. Three of these ten attributes are

associated with the quality assurance activities of corrective action, confirmation processes,

and administrative controls. Table A. 1-1, "Elements of an Aging Management Program for

License Renewal," of Branch Technical Position RLSB-1 provides the following description of

these quality attributes:

" corrective actions - including root cause determination and prevention of recurrence,

should be timely

" confirmation process - should ensure that preventive actions are adequate and that

appropriate corrective actions have been completed and are effective

" administrative controls - should provide a formal review and approval process

SRP-LR, Branch Technical Position IQMB-1, "Quality Assurance For Aging Management

Programs," notes that those aspects of the aging management program that affect quality of

safety-related structures, systems, and components are subject to the quality assurance

requirements of 10 CFR Part 50 Appendix B. Additionally, for NSR structures and components

subject to an AM the existing 10 CFR Part 50 Appendix B QA program may be used by the

applicant to address the elements of corrective actions, the confirmation process, and

administrative controls. Branch Technical Position IQMB-1 provides the following guidance with

regard to the quality assurance attributes of AMPs:

" SR structures and components are subject to 10 CFR Part 50 Appendix B requirements,

which are adequate to address all quality-related aspects of an aging management

program consistent with the CLB of the facility for the period of extended operation.

" For NSR structures and components that are subject to an AMR for license renewal, an

applicant has an option to expand the scope of its 10 CFR Part 50 Appendix B program

to include these structures and components to address corrective actions, the

confirmation process, and administrative controls for aging management during the

period of extended operation. In this case, the applicant should document such a

commitment in the NMP1 UFSAR and NMP2 USAR supplements according to

10 CFR 54.21(d).

3.0.4.1 Summary of Technical Information in the Amended Application

In the original LIRA and ALRA Appendix B.1.3, "Quality Assurance Program and Administrative

Controls," the applicant described the quality attributes of the plant-specific AMPs. The

applicant stated that the 10 CFR Part 50 Appendix B program provides corrective actions,

confirmation processes, and administrative controls for LR AMPs. Additionally, the scope of the

program includes both SR and NSR SSCs subject to an AM for license renewal. In the original

LIRA and ALRA Section B.1.3, the applicant provided the following generic description of the

quality attributes common to all the plant-specific AMPs:

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Corrective Actions - A single corrective actions process is applied regardless of the

safety classification of the structure or component. Corrective actions are implemented

through the initiation of a CR according to plant procedures established under

10 CFR 50 Appendix B. Site documents that implement aging management activities for

license renewal will direct that a CR be prepared according to those procedures

whenever unacceptable conditions are found (i.e., the acceptance criteria are not met).

Equipment deficiencies are corrected through the initiation of a Work Order (WO)

according to plant procedures. Although equipment deficiencies may initially be

documented by a WO the corrective action process specifies that a CR also be initiated

if required.

Confirmation Process - The focus of the confirmation process is on the follow-up actions

that must be taken to verify effective implementation of corrective actions. The measure

of effectiveness is in correcting the adverse condition and preventing recurrence of

conditions significantly adverse to quality. Plant procedures include provisions for timely

evaluation of adverse conditions and implementation of any corrective actions required

including root cause determinations and prevention of recurrence. These procedures

provide for tracking, coordinating, monitoring, reviewing, verifying, validating, and

approving effective corrective actions to ensure that they are taken. The CR process

also monitors for potentially adverse trends. An adverse trend due to recurring adverse

conditions will result in a CR. Aging management activities required for license renewal

also would uncover any unacceptable condition due to ineffective corrective action.

Administrative Controls - Administrative controls provide information on procedures and

other forms of administrative control documents as well as guidance on classification

documents into document types.

3.0.4.2 Staff Evaluation

The staff reviewed the applicant's AMPs described in the original LRA and ALRA Appendices A,

"Safety Analysis Report Supplement," and B, "Aging Management Programs and Activities."

This review was to assure that the aging management activities were consistent with the staff's

guidance of SRP-LR Section A.2, "Quality Assurance for Aging Management Programs (Branch

Technical Position IQMB-1 )," on quality assurance attributes of AMPs.

The staff's evaluation found the descriptions and applicability of the plant-specific AMPs and

their associated quality attributes, provided in the original LRA and ALRA Section B13.3,

consistent with the staff's position on quality assurance for aging management. However, the

applicant has not described sufficiently the use of the quality assurance program and its

associated attributes (corrective action, confirmation process, and administrative controls) in the

narrations of AMPs in the original LRA and ALRA Sections Al, "NMP1 Updated Final Safety

Analysis Report (UFSAR) Supplement," and A2, "NMP2 Updated Safety Analysis Report

(USAR) Supplement"

In RAI 2.1-8 dated November 22, 2004 the staff requested that the applicant supplement the

descriptions in Sections Al and A2 to include a description including references to pertinent

guidance as necessary of the quality assurance program attributes credited for the programs

described in the original LRA and ALRA Section B13.3. The descriptions in ALRA Sections Al

and A2 should provide sufficient information for the staff to determine if the quality attributes for

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the ALRA Sections Al and A2 AMPs are consistent with the review acceptance criteria'of

SRP-LR Section A.2, "Quality Assurance for Aging Management Programs (Branch Technical

Position IQMB-1 )."

In response to RAI 2.1-8 by letter dated December 22, 2004, the applicant stated, in part, that

the original LRA Sections A1.2 and A2.5 were added to reflect the application of the quality

assurance program to the attributes of corrective action, confirmation, and document control.

Specifically, the additions in each section contained the following description along with

descriptions of each of the elements.

The quality assurance program implements the requirements of 10 CFR 50 Appendix B and is

consistent with the summary in SRP-LR Appendix A.2, "Standard Review Plan for the Review of

License Renewal Applications for Nuclear Power Plants," published July 2001. The "corrective

action," "confirmation process," and "administrative controls" elements of the quality assurance

program are applicable to both SR and NSR SSCs subject to an AM.

Furthermore, the applicant provided the staff with an ALRA submittal dated July 14, 2005, with

additional details on the application of the quality assurance program to these three attributes.

The staff confirmed that the ALRA description was consistent with the prior response to the

request for additional information and the results of the staffs audit of the scoping and

screening methodology. On the basis of the supplemental information provided by the applicant

in response to the staffs request for information and the incorporation of that information into

the ALRA submittal the staff found that the applicant has addressed the request for additional

information adequately. Therefore, the staff's concern is resolved.

3.0.4.3 Conclusion

The applicant described the quality attributes of the programs and activities for managing

aging effects for both SR and NSR SSCs within the scope of license renewal and stated that

the 10 CFR Part 50 Appendix B quality assurance program provides "corrective actions," "confirmation processes," and "administrative controls." The staff concludes that the quality

attributes of the applicant's AMPs, as described in the original LRA and ALRA Appendices A

and B, are consistent with 10 CFR 54.21(a)(3). Therefore, the applicant's quality assurance

description for its AMPs is acceptable.

3.1 Aging Management of Reactor Vessel, Internals, and Reactor Coolant

Systems

3.1A NMPI Aging Management of Reactor Vessel, Internals, and Reactor Coolant

Systems

This section of the SER documents the staffs review of the applicant's AMR results for the

reactor vessel, internals, and reactor coolant systems components and component groups

associated with the following NMP1 systems:

* reactor pressure vessel

* reactor pressure vessel internals

* reactor pressure vessel instrumentation system

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" reactor recirculation system

" control rod drive system

3.1A.1 Summary of Technical Information in the Amended Application

In ALRA Section 3.1, the applicant provided AMR results for the reactor vessel, internals, and

reactor coolant systems components and component groups. In ALRA Table 3.1.1.A, "NMP1

Summary of Aging Management Programs for the Reactor Vessel, Internals, and Reactor

Coolant Systems Evaluated in Chapter IV of NUREG-1801 ," the applicant provided a summary

comparison of its AMRs with the AMRs evaluated in the GALL Report for the reactor vessel,

internals, and reactor coolant systems components and component groups.

The applicant's AMRs incorporated applicable operating experience in the determination of

AERMs. These reviews included evaluation of plant-specific and industry operating experience.

The plant-specific evaluation included reviews of condition reports and discussions with

appropriate site personnel to identify AERMs. The applicant's review of industry operating

experience included a review of the GALL Report and operating experience issues identified

since the issuance of the GALL Report.

3.1A.2 Staff Evaluation

The staff reviewed ALRA Section 3.1 to determine if the applicant provided sufficient

information to demonstrate that the effects of aging for the reactor vessel, internals, and reactor

coolant systems components that are within the scope of license renewal and subject to an

AMR will be adequately managed so that the intended functions will be maintained consistent

with the CLB for the period of extended operation, as required by 10 CFR 54.21(a)(3).

The staff performed an onsite audit of AMRs to confirm the applicant's claim that certain

identified AMRs were consistent with the GALL Report. The staff did not repeat its review of the

matters described in the GALL Report; however, the staff did verify that the material presented

in the ALRA was applicable and that the applicant had identified the appropriate GALL AMRs.

The staff's evaluations of the AMPs are documented in SER Section 3.0.3. Details of the staffs

audit evaluation are documented in the Audit and Review Report and are summarized in SER

Section 3.1A.2.1.

In the onsite audit, the staff also selected AMRs that were consistent with the GALL Report and

for which further evaluation is recommended. The staff confirmed that the applicant's further

evaluations were consistent with the acceptance criteria in SRP-LR Section 3.1.2.2. The staff's

audit evaluations are documented in the Audit and Review Report and are summarized in SER

Section 3.1A.2.2.

In the onsite audit, the staff also conducted a technical review of the remaining AMRs that were

not consistent with, or not addressed in, the GALL Report. The audit and technical review

included evaluating whether all plausible aging effects were identified and evaluating whether

the aging effects listed were appropriate for the combination of materials and environments

specified. The staff's audit evaluations are documented in the Audit and Review Report and are

summarized in SER Section 3.1A.2.3. The staffs evaluation of its technical review is also

documented in SER Section 3.1A.2.3.

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Finally, the staff reviewed the AMP summary descriptions in the UFSAR supplement to ensure

that they provided an adequate description of the programs credited with managing or

monitoring aging for the reactor vessel, internals, and reactor coolant systems components.

Table 3.1A-1 below provides a summary of the staff's evaluation of NMP1 components, aging

effects and aging effects mechanisms , and AMPs listed in ALRA Section 3.1, that are

addressed in the GALL Report.

Table 3.1A-1 Staff Evaluation for NMP1 Reactor Vessel, Internals, and Reactor Coolant

Systems Components in the GALL Report

Component Group -Aging Effectl "AMP in GALL AMP In ALRA;" ::tStaff Evaluation:: Mechanism Report __,_____________ ________________

Reactor coolant Cumulative fatigue TLAA, evaluated in TLAA This TLAA is

pressure boundary damage accordance with evaluated in

components 10 CFR 54.21(c) Section 4.3, Metal

(Item Number Fatigue Analysis

3.1.1 .A-01)

Steam generator Loss of material Inservice Not applicable,

shell assembly due to pitting and inspection; water PWR only

(Item Number crevice corrosion chemistry

3.1.1.A-02)

Isolation condenser Loss of material Inservice Preventive Consistent with

(Item Number due to general, inspection; water Maintenance GALL with

3.1.1.A-03) pitting, and crevice chemistry Program (B2.1.32), exception, which

corrosion ASME Sections XI recommends further

Inservice Inspection evaluation (See

(Subsections IWB, Section 3.1A.2.2.2)

IWC, IWD) Program

(B2.1.1), Water

Chemistry Control

Program (B2.12)

Pressure vessel Loss of fracture TLAA, evaluated in TLAA This TLAA is

ferritic materials toughness due to accordance with evaluated in

that have a neutron neutron irradiation Appendix G of Section 4.2,

fluence greater than embrittlement 10 CFR 50 and Reactor Vessel

101, n/cm2 RG 1.99 Neutron

(E > 1 MeV) Embrittlement

(Item Number Analysis

3.1.1.A-04)

Reactor vessel Loss of fracture Reactor vessel Reactor Vessel Consistent with

beltline shell and toughness due to surveillance Surveillance GALL, which

welds neutron irradiation Program (B2.1.19) recommends further

(Item Number embrittlement evaluation (See

3.1.1.A-05) Section 3.1A.2.2.3)

Westinghouse and Loss of fracture Plant-specific Not applicable,

B&W baffle/former toughness due to PWR only

bolts (Item Number neutron irradiation

3.1.1.A-06) embrittlement and

void swelling

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,Component Group ,,Aging Effect/! ý, AMP in'GALL AMP in ALRA"-: Staff Evaluation,

...Mechanism -,.- "Report ,

Small-bore reactor Crack initiation and Inservice ASME Section XI Consistent with

coolant system and growth due to SCC, inspection; water Inservice Inspection GALL, which

connected systems intergranular SCC, chemistry; one-time (Subsections IWB, recommends further

piping and thermal and inspection IWC, IWD) Program evaluation (See

(Item Number mechanical loading (B2.1.1); Water Section 3.1A.2.2.4)

3.1.1 .A-07) Chemistry Control

Program (B2.1.2);

One-Time

Inspection Program

(B2.1.20)

Jet pump sensing Crack initiation and Plant-specific ASME Sections XI Consistent with

line, and reactor growth due to SCC, Inservice Inspection GALL, which

vessel flange leak intergranular stress (Subsections IWB, recommends further

detection line corrosion cracking IWC, IWD) Program evaluation (See

(Item Number (IGSCC), or cyclic (B2.1.1), Water Section 3.1A.2.2.4)

3.1.1.A-08) loading Chemistry Control

Program (B2.1.2),

One-Time

Inspection Program

(B2.1.20)

Isolation condenser Crack initiation and Inservice ASME Sections XI Consistent with

(Item Number growth due to stress inspection; water Inservice Inspection GALL, which

3.1.1.A-09) corrosion cracking chemistry (Subsections IWB, recommends further

(SCC) or cyclic IWC, IWD) Program evaluation (See

loading (B2.1.1), Water Section 3.1A.2.2.4)

Chemistry Control

Program (B2.1.2),

Preventive

Maintenance

Program (82.1.32)

Vessel shell Crack growth due to TLAA Not applicable,

(Item Number cyclic loading PWR only

3.1.1.A-10)

Reactor internals Changes in Plant-specific Not applicable,

(Item Number dimension due to PWR only

3.1.1.A-11) void swelling

PWR core support Crack initiation and Plant-specific Not applicable,

pads, instrument growth due to SCC PWR only

tubes (bottom head and/or primary

penetrations), water stress

pressurizer spray corrosion cracking

.heads, and nozzles (PWSCC)

for the steam

generator

instruments and

drains

(Item Number

3.1.1.A-12) _ I II

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Complonent Group Aging Effectl -AMP in GALL :AMP in ALRA Staff Evaluation

Mechanism . Report'. ____.... ________ _________.. .__

Cast austenitic Crack initiation and Plant-specific Not applicable,

stainless steel growth due to SCC PWR only

(CASS) reactor

coolant system

piping

(Item Number

3.1.1.A-13)

Pressurizer Crack initiation and Inservice Not applicable,

instrumentation growth due to inspection; water PWR only

penetrations and PWSCC chemistry

heater sheaths and

sleeves made of

Ni-alloys

(Item Number

3.1.1.A-14)

Westinghouse and Crack initiation and Plant-specific Not applicable,

B&W baffle former growth due to SCC PWR only

bolts and IASCC

(Item Number 3.1.1 .A-15)_________

Westinghouse and Loss of preload due Plant-specific Not applicable,

B&W baffle former to stress relaxation PWR only

bolts

(Item Number

3.1.1.A-16)

Steam generator Loss of section Plant-specific Not applicable,

feedwater thickness due to PWR only

impingement plate erosion

and support

(Item Number

3.1.1.A-17)

(Alloy 600) Steam Crack initiation and Steam generator Not applicable,

generator tubes, growth due to tubing integrity; PWR only

repair sleeves; and PWSCC, outside water chemistry

plugs diameter stress

(Item Number corrosion cracking

3.1.1.A-1 8) (ODSCC), and/or

intergranular attack

(IGA) or loss of

material due to

wastage and pitting

corrosion, and

fretting and wear, or

deformation due to

corrosion at tube

support plate

intersections

Tube support lattice Loss of section Plant-specific Not applicable,

bars made of thickness due to PWR only

carbon steel FAC

(Item Number

3.1.1.A-19)

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Component Group Aging Effec•t - AMP In GALL AMP in ALRA ".Staff Evaluation

-. ~Mechanism Reor e 

Carbon steel tube Ligament cracking Plant-specific Not applicable,

support plate due to corrosion PWR only

(Item Number

3.1.1 .A-20)

Steam generator Loss of material Combustion Not applicable,

feedwater inlet ring due to engineering (CE) PWR only

and supports flow-corrosion steam generator

(Item Number feedwater ring

3.1.1.A-21) inspection

Reactor vessel Crack initiation and Reactor head Reactor Head Consistent with

closure studs and growth due to SCC closure studs Closure Studs GALL, which

stud assembly and/or IGSCC Program (82.13) recommends no

(Item Number further evaluation

3.1.1.A-22) (See Section

3.1A.2.1.1)

CASS pump casing Loss of fracture Inservice inspection ASME Section XI Consistent with

and valve body toughness due to Inservice Inspection GALL, which

pump casing and thermal aging (Subsections IWB, recommends no

valve body embrittlement IWC, IWD) Program further evaluation

(Item Number (B2.1.1) (See Section

3.1.1.A-23) 3.1A.2.1)

CASS piping Loss of fracture Thermal aging Not applicable

(item Number toughness due to embrittlement of (CASS piping does

3.1.1.A-24) thermal aging CASS - not exist)

embrittlement

BWR piping and Wall thinning due to Flow-accelerated Flow-Accelerated Consistent with

fittings; steam flbw-accelerated corrosion Corrosion Program GALL, which

generator corrosion (B2.1.9) recommends no

components further evaluation

(Item Number .(See Section

3.1.1.A-25) 3.1A.2.1)

Not applicable,

PWR only.

Reactor coolant Loss of material Bolting integrity Bolting Integrity Consistent with

pressure boundary due to wear, loss of Program (B2.1.36) GALL, which

(RCPB) valve preload due to recommends no

closure bolting, stress relaxation; further evaluation

manway and crack initiation and (See Section

holding bolting, and growth due to cyclic 3.1A.2.1)

closure bolting in loading and/or SCC

high pressure and Not applicable,

high temperature PWR only.

systems

(Item Number

3.1.1.A-26)

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Component Group Aging Effect/ AMP in GALLI_ .:;"'AMPin ALRAI Staff Evaluation

Mechanism Report . __-, .. _.._-_. ..

Feedwater and Crack initiation and Feedwater nozzle; BWR Feedwater Consistent with

control rod drive growth due to cyclic CRD return line Nozzle Program GALL, which

(CRD) return line loading nozzle (12.1.5), BWR recommends no

nozzles Control Rod Drive further evaluation

(Item Number Return Line (See Section

3.1.1.A-27) (CRDRL) Nozzle 3.1A.2.1.6)

Program (B2.1.37)

Vessel shell Crack initiation and BWR vessel ID Water Chemistry Consistent with

attachment welds growth due to SCC, attachment welds; Control Program GALL, which

(Item Number IGSCC water chemistry (82.1.2), BWR recommends no

3.1.1 .A-28) Vessel ID further evaluation

Attachment Welds (See Section

(B2.1.4) 3.1A.2.1)

Nozzle safe ends, Crack initiation and BWR stress Water Chemistry Consistent with

recirculation pump growth due to SCC, corrosion cracking; Control Program GALL, which

casing, connected IGSCC water chemistry (12.1.2), BWR recommends no

systems piping and Stress Corrosion further evaluation

fittings, body and Cracking Program (See

bonnet of valves (12.1.6) Sections 3.1A.2.1)

(Item Number

3.1.1.A-29)

Penetrations Crack initiation and BWR penetrations; Water Chemistry Consistent with

(Item Number growth due to SCC, water chemistry Control Program GALL, which

3.1.1.A-30) IGSCC, cyclic (82.1.2), BWR recommends no loading Vessel Internals further evaluation

Program (82.1.8), (See Section

BWR Penetrations 3.1A.2.1.3)

Program (82.1.6)

Core shroud and Crack initiation and BWR vessel Water Chemistry Consistent with

core plate, support growth due to SCC, internals; water Control Program GALL, which

structure, top guide, IGSCC, IASCC chemistry (82.1.2), BWR recommends no

core spray lines and Vessel Internals further evaluation

spargers, jet pump Program (B2.1.8) (See Section

assemblies, control 3.1A.2.1)

rod drive housing,

nuclear

instrumentation

guide tubes

(Item Number

3.1.1.A-31)

Core shroud and Crack initiation and ASME Section XI BWR Vessel Consistent with

core plate access growth due to SCC, inservice Internals Program GALL with

hole cover (welded IGSCC, IASCC inspection; water (B2.1.8), Water exceptions (access

and mechanical chemistry Chemistry Control hole cover does not

covers) Program (B2.12) exist in NMP1)

(Item Number (See Section

3.1.1.A-32) 3.1A.2.1)

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Component Group'. rýýAging Effect/!: AMP In GALL, AMP in ALRA" --Staff Evaluation

*i • <o)i,•71' Mechanism Report , __-_ _____--__ __" _ __ _ _ _

Jet pump assembly Loss of fracture Thermal aging and BWR Vessel Consistent with

castings; orificed toughness due to neutron irradiation Internals Program GALL (See Section

fuel support thermal aging and embrittlement (B2.1.8) 3.1A.2.1.5)

(Item Number neutron irradiation

3.1.1.A-33) embrittlement Not applicable for

jet pump

components

Unclad top head Loss of material Inservice Not applicable

and nozzles due to general, inspection; water (NMP1 does not

(Item Number pitting, and crevice chemistry have unclad top

3.1.1.A-34) corrosion head enclosure and

nozzles)

CRD nozzle Crack initiation and Ni-alloy nozzles and Not applicable,

(Item Number growth due to penetrations; water PWR only

3.1.1.A-35) PWSCC chemistry

Reactor vessel Crack initiation and Inservice Not applicable,

nozzles safe ends growth due to cyclic inspection; water . PWR only

and CRD housing; loading, and/or SCC chemistry

reactor coolant and PWSCC

system components

(except CASS and

bolting)

(Item Number

3.1.1.A-36)

Reactor vessel Loss of fracture Thermal aging and Not applicable,

internals CASS toughness due to neutron irradiation PWR only

components thermal aging, embrittlement

(Item Number neutron irradiation

3.1.1.A-37) embrittlement, and

void swelling

External surfaces of Loss of material Boric acid corrosion Not applicable,

carbon steel due to boric acid PWR only

components in corrosion

reactor coolant

system pressure

boundary

(Item Number

3.1.1.A-38)

Steam generator Loss of material Inservice inspection Not applicable,

secondary due to erosion PWR only

manways and

handholds (CS)

(Item Number

3.1.1.A-39)

Reactor internals, Loss of material Inservice inspection Not applicable,

reactor vessel due to wear PWR only

closure studs, and

core support pads

(Item Number

3.1.1 .A-40)

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Component Group -:',Aging Effect.. AMP In GALL- '-AMP In ALRA"ý rStaff Evaluation.

Mechanism . Report _..____"__"__-__

Pressurizer integral Crack initiation and Inservice inspection Not applicable,

support growth due to cyclic PWR only

(Item Number loading

3.1.1.A-41)

Upper and lower Loss of preload due Inservice Not applicable,

internals assembly to stress relaxation inspection; loose PWR only

(Westinghouse) part and/or neutron

(Item Number noise monitoring

3.1.1.A-42)

Reactor vessel Loss of fracture PWR vessel Not applicable,

internals in fuel toughness due to internals; water PWR only

zone region [except neutron irradiation chemistry

Westinghouse and embrittlement, and

Babcock & Wilcox void swelling

(B&W) baffle bolts]

(Item Number

3.1.1 .A-43)

Steam generator Crack initiation and Inservice Not applicable,

upper and lower growth due to SCC, inspection; water PWR only

heads; tubesheets; PWSCC, IASCC chemistry

primary nozzles and

safe ends

(item Number

3.1.1 .A-44)

Vessel internals Crack initiation and PWR vessel Not applicable,

(except growth due to SCC internals; water PWR only

Westinghouse and and IASCC chemistry

B&W baffle former

bolts)

(Item Number

3.1.1.A-45)

Reactor internals Loss of preload due Inservice Not applicable,

(B&W screws and to stress relaxation inspection; loose PWR only

bolts) part monitoring

(item Number

3.1.1.A-46)

Reactor vessel Loss of material Reactor head Not applicable,

closure studs and due to wear closure studs PWR only

stud assembly

(Item Number

3.1.1.A-47)

Reactor internals Loss of preload due Inservice Not applicable,

(Westinghouse to stress relaxation inspection; loose PWR only

upper and lower part monitoring

internal assemblies;

CE bolts and tie

rods)

(Item Number

3.1.1.A-48)

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The staff's review of the NMP1 component groups followed one of several approaches. One

approach, documented in SER Section 3.1A.2.1, discusses the staff's review of the AMR

results for components in the reactor vessel, internals, and reactor coolant systems that the

applicant indicated are consistent with the GALL Report and do not require further evaluation.

Another approach, documented in SER Section 3.1A.2.2, discusses the staffs review of the

AMR results for components in the reactor vessel, internals, and reactor coolant systems that

the applicant indicated are consistent with the GALL Report and for which further evaluation is

recommended. A third approach, documented in SER Section 3.1A.2.3, discusses the staff's

review of the AMR results for components in the reactor vessel, internals, and reactor coolant

systems that the applicant indicated are not consistent with, or not addressed in, the GALL

Report. The staffs review of AMPs that are credited to manage or monitor aging effects of the

reactor vessel, internals, and reactor coolant systems components is documented in SER

Section 3.0.3.

3.1A.2.1 AMR Results That Are Consistent with the GALL Report

Summary of Technical Information in the Amended Application. In ALRA Section 3.1.2.A, the

applicant identified the materials, environments, and AERMs. The applicant identified the

following programs that manage the aging effects related to the reactor vessel, internals, and

reactor coolant systems components:

" ASME Section XI Inservice Inspection (Subsections IWB, IWC, IWD) Program

" Water Chemistry Control Program

• Reactor Head Closure Studs Program

• BWR Vessel ID Attachment Welds Program

* BWR Feedwater Nozzle Program

* BWR Stress Corrosion Cracking Program

" BWR Penetrations Program

" BWR Vessel Internals Program

" Flow-Accelerated Corrosion Program

* Reactor Vessel Surveillance Program

" One-Time Inspection Program

* Selective Leaching of Materials Program

" Systems Walkdown Program

* Bolting Integrity Program

" BWR Control Rod Drive Return Line (CRDRL) Nozzle Program

Staff Evaluation. In ALRA Tables 3.1.2.A-1 through 3.1.2.A-5, the applicant provided a

summary of AMRs for the reactor vessel, internals, and reactor coolant systems components,

and identified which AMRs it considered to be consistent with the GALL Report.

For component groups evaluated in the GALL Report for which the applicant has claimed

consistency with the GALL Report, and for which the GALL Report does not recommend further

evaluation, the staff performed an audit and review to determine whether the plant-specific

components contained in these GALL Report component groups were bounded by the GALL

Report evaluation.

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The applicant provided a note for each AMR line item. The notes indicate how the information in

the tables aligns with the information in the GALL Report. The staff audited those AMRs with

Notes A through E, which indicate that the AMR is consistent with the GALL Report.

Note A indicates that the AMR line item is consistent with the GALL Report for component,

material, environment, and aging effect. In addition, the AMP is consistent with the AMP

identified in the GALL Report. The staff audited these line items to verify consistency with the

GALL Report and the validity of the AMR for the site-specific conditions.

Note B indicates that the AMR line item is consistent with the GALL Report for component,

material, environment, and aging effect. In addition, the AMP takes some exceptions to the

AMP identified in the GALL Report. The staff audited these line items to verify consistency with

the GALL Report. The staff verified that the identified exceptions to the GALL AMPs had been

reviewed and accepted by the staff. The staff also determined whether the AMP identified by

the applicant was consistent with the AMP identified in the GALL Report and whether the AMR

was valid for the site-specific conditions.

Note C indicates that the component for the AMR line item, although different from, is

consistent with the GALL Report for material, environment, and aging effect. In addition, the

AMP is consistent with the AMP identified by the GALL Report. This note indicates that the

applicant was unable to find a listing of some system components in the GALL Report.

However, the applicant identified a different component in the GALL Report that had the same

material, environment, aging effect, and AMP as the component that was under review. The

staff audited these line items to verify consistency with the GALL Report. The staff also

determined whether the AMR line item of the different component was applicable to the

component under review and whether the AMR was valid for the site-specific conditions.

Note D indicates that the component for the AMR line item, although different from, is

consistent with the GALL Report for material, environment, and aging effect. In addition, the

AMP takes some exceptions to the AMP identified in the GALL Report. The staff audited these

line items to verify consistency with the GALL Report. The staff verified whether the AMR line

item of the different component was applicable to the component under review. The staff

verified whether the identified exceptions to the GALL AMPs had been reviewed and accepted

by the staff. The staff also determined whether the AMP identified by the applicant was

consistent with the AMP identified in the GALL Report and whether the AMR was valid for the

site-specific conditions.

Note E indicates that the AMR line item is consistent with the GALL Report for material,

environment, and aging effect, but a different aging management program is credited. The staff

audited these line items to verify consistency with the GALL Report. The staff also determined

whether the identified AMP would manage the aging effect consistent with the AMP identified

by the GALL Report and whether the AMR was valid for the site-specific conditions.

The staff conducted an audit and review of the information provided in the ALRA, as

documented in the Audit and Review Report dated January 5, 2006. The staff did not repeat its

review of the matters described in the GALL Report; however, the staff did verify that the

material presented in the ALRA was applicable and that the applicant identified the appropriate

GALL Report AMRs. The staffs evaluation is discussed below.

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3.1A.2.1.1 Crack Initiation and Growth Due to SCC and/or IGSCC

In the discussion section of ALRA Table 3.1.1.A, Item 3.1.1.A-22, the applicant stated that loss

of material due to general corrosion of closure head studs and nuts will be managed using the

Reactor Head Closure Studs Program. As documented in the Audit and Review Report, the

staff noted that ALRA Table 3.1.1.A, Item 3.1.1.A-22 applies to managing the aging effect and

aging effect mechanism of cracking and requested that the applicant provide clarification

In its letter dated December 1, 2005, the applicant responded revising the ALRA Table 3.1.1.A,

Item 3.1.1.A-22 discussion column by deleting the reference to managing loss of material and

crediting the aging effect and aging effect mechanism of crack initiation and growth due to

SCC. The staff found this change consistent with the GALL Report and therefore acceptable.

In its review, the staff found that the applicant had addressed the aging effect and aging effect

mechanism appropriately as recommended by the GALL Report.

3.1A.2.1.2 Loss of Material Due to Wear; Loss of Preload Due to Stress Relaxation; Crack

Initiation and Growth Due to Cyclic Loading and/or SCC

In the discussion section of ALRA Table 3.1.1.A, Item 3.1.1 .A-26, the applicant stated that loss

of material due to wear; loss of preload due to stress relaxation, crack initiation and growth due

to cyclic loading and/or SCC of the reactor coolant pressure boundary (RCPB) valve closure

bolting, manway and holding bolting, and closure bolting in high-pressure and high-temperature

systems will be managed using the Bolting Integrity Program. As documented in the Audit and

Review Report, the staff asked the applicant why Note E is used in ALRA Tables 3.1.2.A-3 and

3.1.2.A-5 when closure bolting will be managed with the applicant's Bolting Integrity Program.

In a letter dated December 1, 2005, the applicant stated that Note E in ALRA Tables 3.1.2.A-3

and 3.1.2.A-5 will be changed to Note B. The staff found this change consistent with the GALL

Report and, therefore, acceptable.

In its review the staff found that the applicant had addressed the aging effect and aging effect

mechanism appropriately as recommended by the GALL Report.

3.1A.2.1.3 Crack Initiation and Growth Due to SCC, IGSCC, and/or Cyclic Loading

In the discussion section of ALRA Table 3.1.1 .A, Item 3.1.1 .A-30 the applicant stated that crack

initiation and growth due to SCC, IGSCC, and/or cyclic loading of penetrations will be managed

using the Water Chemistry Control Program and BWR Vessel Internals Program. The applicant

also stated that aging of the CRD stub tube penetrations is managed according to BWRVIP-47,

"BWR Lower Plenum Inspection and Flaw Evaluation Guidelines," of the applicant's BWR

Vessel Internals Program and plant-specific commitments contained in the NRC safety

evaluation dated March 25, 1987.

In RAI 3.1.2-1 dated January 13, 2005, the staff requested that the applicant address the

difference between the altemative repair roll/expansion techniques and acceptable ASME Code

weld repair methods for NMP1 CRD stub tube penetrations experiencing leakage.

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In its response by letter dated February 14, 2005, the applicant stated, "NMP committed to

implement a strategy whereby during the period of extended operation a leaking control rod

drive (CRD) stub tube penetration would be roll repaired. If following the roll repair, this stub

tube was to leak within acceptable limits, then a weld repair would be effected no later than one

operating cycle following discovery of the leakage." In the original LRA, the applicant stated that

it will follow the status of the proposed ASME Code change as to roll/expansion techniques of

CRD stub tubes and will implement the final code change or provide an alternative plan for the

NMP1 period of extended operation at least one year prior to the expiration of the current

operating license (NMP1 Commitment 36).

As documented in the Audit and Review Report, the staff noted that the wording in ALRA

Table 3.1.1.A, Item 3.1.1.A-1 and in the applicant's response to RAI 3.1.2-1 imply that NMP1

will operate with CRD stub tube leakage for one operating cycle (two years). The staff did not

consider this implication acceptable for the period of extended operation. The safety evaluation

dated March 25, 1987, allowing NMP1 to operate with CRD stub tube leakage was acceptable

only as a temporary repair. Specifically, Item (6) of the staffs conclusions in the safety

evaluation stated, "The proposed leakage criteria provides sufficient time to complete the final

development of the prototype mechanical seal and associated tooling and investigate other

methods such as weld repair."

In a-RAI 3.1.2-1 dated November 2, 2005, the staff requested that the applicant justify the CRD

stub tube leakage repair operation.

In its response by letter dated November 30, 2005, the applicant stated that it had removed the

statement of plant-specific commitments contained in the NRC safety evaluation dated

March 25, 1987, and replaced it with the following statements:

If the 10/19/05 draft of Code Case N-730 is approved by the ASME, NMP1 will

implement the final code case as conditioned by the NRC. If the code case is not

approved by the ASME, NMP1 will seek NRC approval of the 10/19/05 code

case draft on a plant specific basis as conditioned by the NRC.

During the period of extended operation, should a CRD stub tube rolled in

accordance with the provisions of the code case resume leaking, NMP will

implement one of the following zero leakage permanent repair strategies prior to

startup from the outage in which the leakage was detected:

1. A welded repair consistent with BWRVIP-58-A, "BWRVIP Internal

Access Weld Repair" and Code Case N-606-1, as endorsed by

the NRC in Regulatory Guide 1.147.

2. A variation of the welded repair geometry specified in

BWRVIP-58-A subject to the approval of the NRC using Code

Case N-606-1.

3. A future developed mechanical/welded repair method subject to

the approval of the NRC.

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The staff reviewed the applicant's response and found it consistent with the GALL Report and,

therefore, acceptable.

In ALRA Table 3.1.2.A-1, the applicant stated that crack initiation and growth due to SCC,

IGSCC, and/or cyclic loading of penetrations will be managed using the Water Chemistry

Control Program, BWR Penetrations Program, and BWR Vessel Internals Program. As

documented in the Audit and Review Report, the staff asked the applicant to clarify which

components were managed by its BWR Vessel Internals Program. The applicant responded

that the component type penetrations discussed on ALRA Table 3.1.2.A-1 include the CRD stub

tube and flux monitor penetrations covered by BWRVIP-47.

The staff noted that GALL AMP XI.M8, "BWR Penetration Program," covers BWRVIP-27, which

addresses the standby liquid control system nozzle or housing, and BWRVIP-49, which

provides guidance for instrument penetrations. As documented in the audit and review, the

applicant responded that the CRD stub tube and flux monitor penetrations are managed by

BWRVIP-47, which is part of the BWR Vessel Internals Program. The applicant also responded

that its Water Chemistry Control Program is applicable to all vessel penetrations; therefore, the

line in the ALRA crediting the applicant's BWR Vessel Internals Program also should include

the applicant's Water Chemistry Control Program.

In its letter dated December 1, 2005, the applicant supplemented its ALRA with the following

changes: (1) the discussion column for ALRA Table 3.1.1.A, Item 3.1.1.A-30 was revised to add

the flux monitor penetrations managed by the applicant's BWR Vessel Internals Program; (2)

the line item entry for the BWR Vessel Internals Program for penetrations in ALRA

Table 3.1.2A-1 was revised to include the Water Chemistry Control Program. The staff

reviewed the applicant's response and found it consistent with the GALL Report and, therefore,

acceptable. Therefore, the staffs concern described in a-RAI 3.1.2-1 is resolved.

In its review the staff found that the applicant had addressed the aging effect and aging effect

mechanism appropriately as recommended by the GALL Report.

3.1A.2.1.4 Crack Initiation and Growth Due to SCC, IGSCC and/or IASCC

In the discussion section of ALRA Table 3.1.1.A, Item 3.1.1.A-31 the applicant stated that crack

initiation and growth due to SCC, IGSCC, and/or IASCC of the core shroud and core plate,

support structure, top guide, core spray lines and spargers, control rod drive housing, and

nuclear instrumentation guide tubes will be managed using the Water Chemistry Control

Program and BWR Vessel Internals Program. As documented in the Audit and Review Report,

the staff noted that in ALRA Table 3.1.2.A-2, for example, the applicant's use of Note D, which

is credited for the control rod guide tube (CRGT), is not appropriate when comparing CRGTs

with the GALL Report and asked the applicant to clarify why Note D is used.

The applicant responded that Note D should be replaced with Note B. Note B is used because

the applicant takes exception for its Water Chemistry Control Program. The latest version of the

water chemistry guidelines will be implemented in lieu of the guideline provided in BWRVIP-29

(TR-1 03515), -BWR Water Chemistry Guidelines - Normal and Hydrogen Water Chemistry."

The staff found this implementation acceptable as consistent with the definition of Note B as

identified in Nuclear Energy Institute (NEI) 95-10.

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In ALRA Table 3.1.2.A-2 the applicant stated that core shroud head bolts and collars will be

managed by its BWR Vessel Internals Program with Note D. The staff review found no specific

BWR Vessel Internals Program report for this component type. As documented in the Audit and

Review Report, the staff asked the applicant to provide additional information as to how its

BWR Vessel Internals Program will manage this item along with details of how the applicant

inspects core shroud head bolts based on operating experience. The applicant explained that

its BWR Vessel Internals Program manages aging of core shroud head bolts and collars. The

applicant's BWR Vessel Internals Program includes inspection of NSR components that could

impact plant operations. These inspections rely heavily on industry operating experience and

such vendor information as GE Nuclear Energy SlLs. Based on industry operating experience

(SIL 433 and SIL 433 Supplement 1) the applicant's BWR Vessel Internals Program includes a

UT inspection program for the shroud head bolts and collars susceptible to IGSCC. Additionally,

plant-specific operating experience (SIL 554) already has found evidence of fretting wear of the

locking pins and improperly locked shroud head bolts. For these reasons the applicant

implemented its BWR Vessel Internals Program to manage aging of core shroud head bolts

and collars. As documented in the Audit and Review Report, the staff reviewed the applicant's

program basis document and determined that aging of core shroud head bolts and collars is

adequately managed using the applicant's BWR Vessel Internals Program.

In ALRA Table 3.1.2.A-2 the applicant credited its BWR Vessel Internals Program for managing

aging of the liquid poison spray line and sparger. As documented in the Audit and Review

Report, the staff noted that there was no specific BWRVIP report for this component type and

asked the applicant to clarify how BWRVIP manages the item with no report for it.

As documented in the Audit and Review Report, the applicant stated that BWRVIP-27, "BWR

Vessel and Internals Project, BWR Standby Liquid Control System/Core Plate AP Inspection

and Flaw Evaluation Guidelines," and BWRVIP-47-A, "BWR Lower Plenum Inspection and Flaw

Evaluation Guidelines," are in the basis documents for management of spray line and sparger

aging. The basis for BWRVIP-27 aging management is that the spray line connection to the

vessel requires inspection while the sparger does not. Both components, however, fall within

BWRVIP-47-A baseline requirements. BWRVIP-47-A requires baseline inspection of all

components located below the core plate when access is provided. In addition the NRC

approval letter of BWRVIP-47-A required at a minimum visual inspection of 5 percent of all

welds or components within the first six years of the period, including the liquid poison line and

sparger below the core plates. The staff found this basis consistent with the recommendation of

the GALL Report and, therefore, acceptable.

In its review the staff found that the applicant had addressed the aging effect and aging effect

mechanism appropriately as recommended by the GALL Report.

3.1A.2.1.5 Loss of Fracture Toughness Due to Thermal Aging and Neutron Irradiation

Embrittlement

In the discussion section of ALRA Table 3.1.1.A, Item 3.1.1.A-33 the applicant stated that this

item is not applicable for the jet pump components as NMP1 has no jet pumps. Aging

management of the orificed fuel supports is conducted according to BWRVIP-47 using GALL

AMP XI.M9, "BWR Vessel Internals Program."

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The GALL Report recommends GALL AMP XI.M13, "Thermal Aging and Neutron Irradiation

Embrittlement," to manage the aging effect and aging effect mechanism of loss of fracture

toughness due to thermal aging and neutron embrittlement. In a letter dated November 17,

2005, the applicant revised its AMP B2.1.8, "BWR Vessel Internals Program," to address the

management of loss of fracture toughness due to neutron fluence and thermal embrittlement for

CASS components. The staffs review and evaluation of the applicant's BWR Vessel Internals

Program are documented in SER Sections 3.0.3.2.6. The staff found the applicant's BWR

Vessel Internals Program acceptable for managing the loss of fracture toughness because the

applicant stated that it will meet the GALL AMP XI.M13 recommendations.

In its review the staff found that the applicant had addressed the aging effect and aging effect

mechanism appropriately as recommended by the GALL Report.

3.1A.2.1.6 Crack Initiation and Growth Due to Cyclic Loading

In the discussion section of ALRA Table 3.1.I.A, Item 3.1.1.A-27 the applicant stated that

NMP1 manages aging of feedwater nozzles with the BWR Feedwater Nozzle Program,

consistently with GALL AMP XI.M5, "Feedwater Nozzle." The applicant also stated that GALL

AMP X1 .M5 is credited with managing cracking of feedwater nozzle thermal sleeves due to

SCC. The absence of nozzle cracking proves that the thermal sleeve intended function is not

degraded. In addition the applicant stated that for CRDRL nozzles NMP1 manages aging with

the BWR CRDRL Nozzle Program, which is consistent with GALL AMP XI.M6, "BWR Control

Rod Drive Return Line Nozzle." The applicant also credited GALL AMP X1 .M6 with managing

CRDRL nozzle thermal sleeves cracking due to SCC. The applicant stated that the absence of

nozzle cracking proves that the thermal sleeve intended function is not degraded. In a letter

dated September 15, 2005, the applicant stated that its BWR Feedwater Nozzle and BWR

CRDRL Nozzle Programs had been removed as the programs credited for the feedwater nozzle

and CRDRL nozzle thermal sleeves.

As documented in the Audit and Review Report, the staff asked the applicant to address the

aging management for the thermal sleeves. In a letter dated December 1, 2005, the applicant.

responded that it will use inspections performed under the BWR Vessel Internals Program

using surrogate components more readily accessible for examination. For NMP1 the surrogate

components will be the feedwater sparger end bracket welds. In this letter the applicant also

provided its basis for choosing the feedwater sparger end bracket welds:

The NMP1 feedwater nozzle thermal sleeves are fabricated from nickel-based

Alloy 600 (Inconel 600). A full penetration weld joins the thermal sleeve to the

outboard end of the carbon steel feedwater sparger. This weld was made with

Alloy 82 and Alloy 182 weld fillers. The thermal-sleeve to sparger weld, or the

heat affected zone in the Alloy 600 base material, is considered the most likely

location for IGSCC in the thermal sleeve.

The applicant added that each feedwater sparger is supported by end brackets which provide a

spring force that helps hold the thermal sleeve in place. The feedwater sparger end bracket

welds consist of three welds, the sparger arm to sparger end plate welds (Weld #1), sparger

end plate to bracket end plate weld (Weld #2), and the sparger bracket end plate to end bracket

assembly welds (Weld #3), which are dissimilar metal welds that use Alloy 182 or 82 weld

fillers.

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In addition the applicant stated that SCC of the feedwater thermal sleeves or the associated

welds is possible but is considered less likely than for other welds with the same weld filler as

the feedwater sparger because the inconel-to-carbon steel welds are heat-treated shop welds

and not creviced. Service experience has demonstrated that Alloy 82 is resistant to IGSCC in

BWR coolant. Alloy 182 is less resistant to IGSCC than Alloy 82 but has performed acceptably.

with aggravating factors like lack of fusion or a creviced condition. These conditions are more

likely in field welds. The Alloy 600-to-carbon steel welds in the thermal sleeve are fullpenetration welds and do not create a creviced condition. Additionally, the thermal sleeve

assembly was heat-treated after welding. The #1 end bracket welds use Alloy 182 filler metal in

a mildly creviced condition, making them more susceptible to IGSCC than the thermal

sleeve-to-sparger welds. Additionally, the #1 welds are exposed on the outer diameter to

reactor coolant chemistry which has a higher ECP and thus is more likely to cause IGSCC than

feedwater, which has a much lower ECP. Therefore, the applicant stated, if cracking is not

found in the #1 welds inspection of the thermal sleeve-to-sparger welds is not necessary.

Furthermore, the applicant stated that the most susceptible of the three feedwater sparger end

bracket welds (Weld #2) are subject to EVT-1 under BWRVIP. If cracking is found in these

welds the other end bracket welds (#1 and #3) are inspected. If cracking is found in the less

susceptible end bracket welds the necessity to inspect the thermal sleeve-to-sparger welds will

be evaluated. The applicant's BWR Vessel Internals Program will, therefore, be credited with

managing cracking of the thermal sleeve as the susceptibility of the critical thermal sleeve weld

to IGSCC is bounded by other welds inspected under the applicant's BWR Vessel Internals

Program. In its letter dated December 1, 2005, the applicant revised the ALRA to add an EVT-1

examination of the NMP1 feedwater sparger brackets as an enhancement to the BWR Vessel

Internals Program to address this issue. The staff reviewed the applicant's response and found

it acceptable because the applicant demonstrated that inspection of surrogate components

bounds the feedwater thermal sleeve.

In a letter dated December 1, 2005, the applicant also provided operating experience to

address the CRDRL nozzle thermal sleeves as follows:

The inspections of the CRDRL nozzle and safe-ends in 1978 identified IGSCC

cracking of the safe-end material, but did not identify fatigue-related cracking.

The CRDRL safe-end and the thermal sleeve were replaced in 1978 with design

changes to improve resistance to both IGSCC and fatigue. The replacement

thermal sleeve material is IGSCC resistant low carbon Type 316L stainless steel

material. The thermal sleeve is welded to the safe-end with low carbon Type

308L weld filler. To reduce the probability of fatigue, the thermal sleeve pipe

protrudes 7 inches out from the flow shield which promotes mixing away from the

vessel wall thus preventing thermal cycling at the vessel wall and at the flow

shield.

The applicant stated that as a result of industry operating experience from 2002 and 2003 it

completed detailed thermal fatigue assessments and augmented inspections of the safe-end,

the thermal sleeve attachment weld to the safe-end, and the thermal sleeve weld to the flow

shield. These inspections were performed in 2004 and 2005. The inspections to date have

detected no IGSCC or thermal fatigue-related cracking. Because the 2003 operating

experience identified cracking of the thermal shield flow baffle on the thermal shield additional

EVT-ls of the thermal shield to flow shield weld from the vessel ID are planned for 2007 and at

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a 10-year frequency thereafter consistent with the ISI inspection interval. This EVT-1

examination of the CRDRL thermal sleeve flow shield weld visible from the vessel ID during

each ISI interval is consistent with the frequency adopted for the feedwater nozzle surrogate

weld location on the feedwater end brackets.

In addition the applicant stated that a one-time UT of the CRDRL safe-end base metal was

performed in 2004 under the NMP augmented ISI program 26 years of operation after the 1978

replacement (three outages prior to the license renewal term). This inspection detected no

IGSCC or thermal fatigue cracking of the safe-end location. The inspection was a manual

performance demonstration initiative (PDI) qualified inspection and the PDI mockup included

the thermal sleeve attachment weld to the safe-end. The exam records note the presence of

the thermal sleeve attachment weld. This exam is considered sufficient to detect significant

circumferential IGSCC cracking of the thermal sleeve at the thermal sleeve attachment weld;

however, consistent with the surrogate weld inspection methodology employed for the

feedwater nozzle thermal sleeve, the EVT-1 inspection of the thermal sleeve flow shield weld

also will be used as a surrogate weld inspection location for the thermal sleeve to safe-end

attachment weld.

In addition to the inspections, the applicant added, temperature monitoring for thermal cycling

was performed to confirm that the CRD return flow rates were sufficient at NMP1 to ensure that

no unstable thermal cycling from hot reactor water return flow occurs at NMPI. The testing and

analyses confirmed the sufficiency of the CRD return flow for stable return line conditions with

no reverse flow,

The overall assessment, according to the applicant, was that the safe-end and thermal sleeve

replacement with IGSCC-resistant materials and the one-time UT of the thermal sleeve

attachment weld after 26 years confirms that the thermal sleeve attachment weld is not a highrisk IGSCC location. In addition the thermal monitoring of this location and the inspection after

26 years of operation also confirmed that no high-cycle thermal fatigue conditions at this

location could create high thermal cycle fatigue-related cracking.

Furthermore, the applicant continued, the analyses and one-time inspections in 2004-2005 are

adequate to detect potential cracking from either IGSCC or fatigue of the CRDRL nozzle

thermal sleeve to safe-end attachment weld. Even though IGSCC is considered a low

probability for this location because of the materials of construction the BWRVIP program will

include an enhancement starting in 2007. An EVT-1 inspection of the thermal shield to flow

shield weld from the vessel ID will be performed at that time and at a 10-year frequency

consistently with the ISl interval.

The applicant also stated that in addition to the condition of the flow shield weld this EVT-1

inspection of the thermal sleeve flow shield weld will be a surrogate inspection of the thermal

sleeve to the safe-end attachment weld. In its letter dated December 1, 2005, the applicant

revised its ALRA as follows:

1. ALRA Sections A1.1.12, A1.4, and B2.1.8 were revised to incorporate the

commitment [NMP1 Commitment 40) to perform the EVT-1 inspection of

the thermal shield to flow shield weld starting in 2007 and proceeding at a

10-year frequency consistent with the ISI inspection interval thereafter.

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2. ALRA Table 3.1.1.A-1, Item 3.1.1.A-27 and ALRA Table 3.1.2.A-1 were

revised to reflect the changes.

The staff reviewed the applicant's response and found it acceptable as the applicant's surrogate

weld inspection, in addition to the results of its one-time inspections in 2004 to 2005, provide

adequate aging management for the CRDRL thermal sleeve.

In its review the staff found that the applicant had addressed the aging effect and aging effect

mechanism appropriately for NMP1 CRDRL nozzle thermal sleeves to meet the

recommendation of the GALL Report.

Conclusion. The staff evaluated the applicant's claim of consistency with the GALL Report. The

staff also reviewed information pertaining to the applicant's consideration of recent operating

experience and proposals for managing associated aging effects. On the basis of its review, the

staff concludes that the AMR results, which the applicant claimed to be consistent with the

GALL Report, are consistent with the AMRs in the GALL Report. Therefore, the staff concludes

that there is reasonable assurance that the applicant had demonstrated that the effects of aging

for these components will be adequately managed so that their intended function(s) will be

maintained consistent with the CLB for the period of extended operation, as required by

10 CFR 54.21(a)(3).

3.1A.2.2 AMR Results That are Consistent with the GALL Report, for Which Further

Evaluation is Recommended

Summary of Technical Information in the Amended Application. In Section 3.1.2.C of its letter

dated August 19, 2005, the applicant provided further evaluation of aging management, for

NMPNS, as recommended by the GALL Report for the reactor vessel, internals, and reactor

coolant systems components. The applicant provided information concerning how it will manage

the following aging effects:

" cumulative fatigue damage

" loss of material due to pitting and crevice corrosion

* loss of fracture toughness due to neutron irradiation embrittlement

• crack initiation and growth due to thermal and mechanical loading or stress corrosion

cracking

" crack growth due to cyclic loading

• changes in dimension due to void swelling

• crack initiation and growth due to stress corrosion cracking or primary water stress

corrosion cracking

" crack initiation and growth due to stress corrosion cracking or irradiation-assisted stress

corrosion cracking

• loss of preload due to stress relaxation

* loss of section thickness due to erosion

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crack initiation and growth due to PWSCC, ODSCC, or intergranular attack or loss of

material due to wastage and pitting corrosion or loss of section thickness due to fretting

and wear or denting due to corrosion of carbon steel tube support plate

" loss of section thickness due to flow-accelerated corrosion

" ligament cracking due to corrosion

• loss of material due to flow-accelerated corrosion

Staff Evaluation. For component groups evaluated in the GALL Report for which the applicant

has claimed consistency with the GALL Report, and for which the GALL Report recommends

further evaluation, the staff audited and reviewed the applicant's evaluation to determine

whether it adequately addressed the issues that were further evaluated. In addition, the staff

reviewed the applicant's further evaluations against the criteria contained in SRP-LR

Section 3.1.2.2. Details of the staff's audit are documented in the staff's Audit and Review

Report. The staffs evaluation of the aging effects is discussed in the following sections.

3.1A.2.2.1 Cumulative Fatigue Damage

In Section 3.1.2.C.1 of its letter dated August 19, 2005, the applicant stated that fatigue is a

TLAA as defined in 10 CFR 54.3. Applicants must evaluate TLAAs in accordance with

10 CFR 54.21 (c)(1). SER Section 4.3 documents the staffs review of the applicant's evaluation

of this TLAA.

As documented in the Audit and Review Report, the staff noted that on ALRA Table 3.1.2.A-2

fatigue damage of CRD assemblies (including drive mechanism and housing) will be managed

through the TLAA but in ALRA Sections B.2.1-8 the applicant stated that there were no TLAAs.

The staff asked the applicant to explain how the specified components are managed for NMP1.

The applicant responded that the only reactor vessel internals components for NMP1 with

calculations or analyses meeting TLAA criteria are the core shroud tie rod assemblies, the

clamps, and the CRD assemblies (including drive mechanism and housing). The tie rod

assemblies and clamps are repairs for horizontal and vertical core shroud welds which had

ASME Ill-type stress and fatigue analyses performed during the design process. The pressure

boundary portion of the CRD assemblies was evaluated for fatigue. A cumulative usage factor

was determined for the CRD penetration including the stub tube, CRD housing, and the stub

tube-to-vessel weld and housing-to-stub tube weld. The AMR for the stub tube is addressed in

ALRA Table 3.1.2.A-1. The applicant also responded that for reactor vessel internals

components where there is no analysis meeting TLAA criteria the AMP column of ALRA

Table 3.1.2.A-2 will be modified to replace "TLAA evaluated in accordance with 10 CFR

54.21(c)" with "None." A plant-specific note referencing the relevant BWRVIP inspection and

evaluation guideline or other basis for not managing fatigue will be added to ALRA

Table 3.1.2.A-2 for each component with "None" in the AMP column for the aging effect and

aging effect mechanism of cumulative fatigue damage or where the TLAA is applicable only to

a subset of the component type.

In its letter dated December 1, 2005, the applicant responded by revising ALRA

Tables 3.1.2.A-2 and 3.1.2.B-2 to address this issue. The staff determined that a high

cumulative fatigue usage factor indicates a high potential for crack initiation. Although the

applicant's response removed the aging effect of cumulative fatigue damage for those

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components identified in the December 1, 2005 letter the aging effect of cracking is adequately

managed through other AMPs.

The staff reviewed the response and found the applicant's action consistent with the GALL

Report and therefore acceptable.

3.1A.2.2.2 Loss of Material Due to Pitting and Crevice Corrosion

The staff reviewed Section 3.1.2.C.2 of the applicant's letter dated August 19, 2005, against the

criteria in SRP-LR Section 3.1.2.2.2.

In Section 3.1.2.C.2 of.a letter dated August 19, 2005, the applicant addressed loss of material

of isolation condenser components due to general pitting and crevice corrosion.

SRP-LR Section 3.1.2.2.2.2 states that loss of material due to pitting and crevice corrosion

could occur in BWR isolation condenser components. The existing program relies on control of

reactor water chemistry to mitigate corrosion and on ASME Sections Xl ISI. However, the

existing program should be augmented to detect loss of material due to pitting or crevice

corrosion. The GALL Report recommends an augmented program to include temperature and

radioactivity monitoring of the shell-side water and eddy current testing of tubes to ensure that

the component's intended function will be maintained during the period of extended operation.

The applicant stated in Section 3.1.2.C.2 of its letter dated August 19, 2005, that NMP1 has

emergency (isolation) condensers (ECs). The design of the emergency condensers features

end bells welded to the EC shell that are not designed to be removed; therefore, eddy current

testing of the tubing is not possible. Loss of material is managed by a combination of several

programs. The Water Chemistry Control Program controls chemical contaminants in both the

tube and shell side water to prevent conditions that would promote pitting and crevice corrosion.

The EC tube side, which is ASME Class 2, is subject to a system inservice pressure test under

the ASME Section Xl (Subsections IWB, IWC, and IWD) ISI Program. The pressure test would

detect a tube leak caused by pitting or crevice corrosion. The EC shell is ASME Class 3 and

subject to a functional test under the applicant's Inservice Pressure Testing Program, which is

part of its ASME Sections XI (Subsections IWB, IWC, and IWD) ISI Program. The functional

test would detect loss of material due to pitting and crevice corrosion if the corrosion caused a

through-wall leak of the EC shell.

In Section 3.1.2.C.2 of its letter dated August 19, 2005, the applicant also stated that for

additional verification that a tube leak does not exist NMP1 will implement an online tube

leakage test. The test will be performed by isolating the makeup and drain valves to the

emergency condenser tube side and monitoring the shell side level for 24 to 48 hours for any

increase in water level on the shell side indicating tube leakage. The online test will be

incorporated as a new activity in the Preventive Maintenance Program and will be implemented

prior to the period of extended operation.

The staffs review and evaluations of the applicant's Water Chemistry Control and ASME

Sections Xl (Subsections IWB, IWC, and IWD) ISI and Preventive Maintenance Programs are

documented in SER Sections 3.0.3.2.2, 3.0.3.2.1, and 3.0.3.3.1, respectively.

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The applicant further stated in Section 3.1.2.C.2 of its letter dated August 19,2005, that its

Preventive Maintenance Program is also credited for managing loss of material due to pitting

and crevice corrosion because it includes the temperature monitoring of the emergency cooling

system including the heat exchangers. Continuous radiation monitoring of the EC shell side

vents also would indicate a tube leak.

In addition in Section 3.1.2.C.2 of its letter dated August 19, 2005, the applicant stated that

because none of the activities would detect loss of material due to pitting and crevice corrosion

before a leak occurred these activities will be supplemented by a visual inspection for cracking

and loss of material of the accessible outer surfaces of the peripheral tubes, tube sheet, and

emergency condenser shell. This activity also will be incorporated into the applicant's

Preventive Maintenance Program.

As documented in the Audit and Review Report dated January 18, 2006, the staff noted that

inaccessibility alone cannot justify exemption from inspection where required for aging

management and operating experience (documented in IEB 76-01, "BWR Isolation Condenser

Tube Failure") indicates tube cracking as an issue. As documented in the Audit and Review

Report, the staff asked the applicant to provide additional justification addressing this issue.

The applicant responded that the aging management activities provide adequate assurance

with no need for eddy current testing that any tube degradation in the isolation condensers will

not lead to a loss of intended function. These activities include water chemistry control,

temperature monitoring of the shell side and tube side water, continuous radioactivity

monitoring of the condenser vent line, periodic performance testing, and a future on-line tube

leakage test. NMP1 has experienced tube leakage previously and replaced the whole tube

bundle with upgraded material in 1997. A keep-fill modification also was installed to eliminate

the stressor which caused the tube failures. Therefore, the applicant continued because the

original isolation condenser tubes lasted 28 years with an aging stressor the new tubes are

expected to perform their intended function through the period of extended operation with

improved material and upgraded system design and monitoring.

As documented in the Audit and Review Report dated January 18, 2006, the staff during its

audits in the week of September 19, 2005, asked the applicant to provide its basis for not

performing eddy current testing. In its letter dated December 1, 2005, the applicant provided its

basis as follows:

1) Monitoring and detection of conditions in the steam inlet (tube side) and shell

side of the isolation condensers ensures conditions will not re-occur.

a) Water temperature

b) Water chemistry (conductively, chloride, nitrates, sulfates)

2) A commitment has been made to perform a tube leak test at operating pressure

to detect small leaks (NMP1 Commitment 29 and NMP2 Commitment 27).

The staff reviewed the applicant's nuclear commitment tracking list to confirm that the online

tube leakage test will be implemented as a new activity in the Preventive Maintenance Program

as indicated in Commitment 29 of ALRA Section A1.4. The staff reviewed the applicant's

response and determined that NMP1 isolation condenser tube aging is adequately managed

and that the tubes will be able to perform their intended function for at least an additional 23

years to the end of the period of extended operation.

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Based on the programs identified above, the staff concludes that there is reasonable assurance

that the applicant has met the criteria of SRP-LR Section 3.1.2.2.2. For those line items that

apply to Section 3.1.2.C.2 of the applicant's letter dated August 19, 2005, the staff determined

that the information in the application is consistent with the GALL Report and the applicant had

demonstrated that the effects of aging will be adequately managed so that the intended

function(s) will be maintained consistent with the CLB during the period of extended operation,

as required by 10 CFR 54.21 (a)(3).

3.1A.2.2.3 Loss of Fracture Toughness due to Neutron Irradiation Embrittlement

The staff reviewed Section 3.1.2.C.3 of the applicant's letter dated August 19, 2005 against the

criteria in SRP-LR Section 3.1.2.2.3.

In Section 3.1.2.C.3 of its letter dated August 19, 2005, the applicant addressed loss of fracture

toughness due to neutron irradiation embrittlement of the reactor vessel.

SRP-LR Section 3.1.2.2.3 states that certain aspects of neutron irradiation embrittlement are

TLAAs as defined in 10 CFR 54.3 and that TLAAs must be evaluated in accordance with

10 CFR 54.21(c)(1). SER Section 4.2 documents the staffs review of the applicant's evaluation

of this TLAA.

SRP-LR Section 3.1.2.2.3 states that a loss of fracture toughness due to neutron irradiation

embrittlement could occur in the reactor vessel.

The Reactor Vessel Surveillance Program monitors neutron irradiation embrittlement of the

reactor vessel.

In ALRA Table 3.1.2.A-1 the applicant stated that loss of fracture toughness of vessel shells

(beltline, lower shell, upper nozzle shell and upper RPV shell, and vessel shell welds including

attachment welds) will be managed using its Reactor Vessel Surveillance Program. As

documented in the Audit and Review Report, the staff asked the applicant to clarify which areas

have neutron fluence exceeding 1 E17 n/cm2 (E>1 MeV).

The applicant responded that vessel shells - beltline and vessel shells - lower and the beltline

welds have a neutron fluence exceeding 1E17 n/cm2. Aging of these components is managed

by the applicant's Reactor Vessel Surveillance Program. The component type, attachment

welds, does not need to be managed by the applicant's Reactor Vessel Surveillance Program

because even though these welds receive a neutron fluence greater than or equal to 1E17

n/cm2 they are not ferritic material. The applicant modified ALRA Table 3.1.2.A-1 to reflect

those components managed through its Reactor Vessel Surveillance Program. The staff found

this management consistent with the GALL Report and therefore acceptable. In a letter dated

December 1, 2005, the applicant revised its ALRA Table 3.1.2.A-1 to address this issue. The

staffs review and evaluation of the applicant's Reactor Vessel Surveillance Program are

documented in SER Sections 3.0.3.2.16.

Based on the programs identified above, the staff concludes that there is reasonable assurance

that the applicant has met the criteria of SRP-LR Section 3.1.2.2.3. For those line items that

apply to Section 3.1.2.C.3 of the applicant's letter dated August 19, 2005, the staff determined

that the information in the application is consistent with the GALL Report and the applicant had

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demonstrated that the effects of aging will be adequately managed so that the intended

function(s) will be maintained consistent with the CLB during the period of extended operation,

as required by 10 CFR 54.21 (a)(3).

3.1A.2.2.4 Crack Initiation and Growth Due to Thermal and Mechanical Loading or Stress

Corrosion Cracking

The staff reviewed Section 3.1.2.C.4 of the applicant's letter dated August 19, 2005 against the

criteria in SRP-LR Section 3.1.2.2.4.

In Section 3.1.2.C.4 of a letter dated August 19, 2005, the applicant addressed crack initiation

and growth due to thermal and mechanical loading or SCC (including IGSCC) that could occur

in small-bore reactor coolant systems and connected system piping less than nominal pipe size

(NPS) 4.

SRP-LR Section 3.1.2.2.4 states that crack initiation and growth due to thermal and mechanical

loading or SCC (including IGSCC) could occur in small-bore reactor coolant systems and

connected system piping less than NPS 4. The existing program relies on ASME Section Xl ISI

and on control of water chemistry to mitigate SCC. The GALL Report recommends that a

plant-specific destructive examination or a nondestructive examination (NDE) that permits

inspection of the inside surfaces of the piping be conducted to ensure that cracking has not

occurred and that the component intended function will be maintained during the extended

period. The AMPs should be augmented to verify that service-induced weld cracking is not

occurring in the small-bore piping less than NPS 4 including pipe, fittings, and branch

connections. A one-time inspection of a sample of locations is an acceptable method to ensure

that the aging effect and aging effect mechanism is not occurring and that the component's

intended function will be maintained during the period of extended operation.

In the ALRA, the applicant also stated that for NMP1 aging of the subject small-bore piping is

managed by the ASME Section Xl (Subsections IWB, IWC, and IWD) ISI Program, Water

Chemistry Control Program, and One-Time Inspection Program.

Additionally, the applicant stated in Section 3.1.2.C.4 of its letter dated August 19, 2005, that for

small-bore piping and fittings in the NMP1 CRD system not part of its ASME Section Xl

(Subsections IWB, IWC, and IWD) ISI Program, it credits only its Water Chemistry Control and

One-Time Inspection Programs for aging management.

The applicant further stated in Section 3.1.2.C.4 of its letter dated August 19, 2005, that for the

small-bore piping whether included in its ASME Sections X1 (Subsections IWB, IWC, and IWD)

ISI Program or not the inspections conducted under its One-Time Inspection Program will

consist of either NDEs using methods with demonstrated capability to detect cracks on the

inside surfaces of the piping or destructive examinations. Both nondestructive and destructive

examinations will be of a sample of the piping.

In ALRA Table 3.1.2.A-5 the applicant stated that aging of CASS valves will be managed using

its ASME Section Xl (Subsections IWB, IWC, and IWD) ISI, One-Time Inspection, and Water

Chemistry Control Programs. The intended functions of the CASS valve are leakage boundary

(spatial) (LBS) and structural integrity attached (SIA). As documented in the Audit and Review

Report, the staff noted that LBS and SIA apply only to NSR components. The applicant was

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informed and replied that its statement was an editorial mistake. The applicant revised ALRA

Table 3.1.2.A-5 to assign its ASME Section XI (Subsections IWB, IWC, and IWD) ISI,

One-Time Inspection, and Water Chemistry ContrOl Programs to manage aging of the pressure

boundary valves and its One-Time Inspection and Water Chemistry Control Programs to

manage aging of the LBS and SIA valves. In a letter dated December 1, 2005, the applicant

revised ALRA Table 3.1.2.A-5 to address this issue. The staff found this revision consistent with

the GALL Report and therefore acceptable.

The staff's review and evaluation of the applicant's ASME Sections XI (Subsection IWB, IWC,

and IWD) ISI, One-Time Inspection, and Water Chemistry Control Programs are documented in

SER Sections 3.0.3.2.1, 3.0.3.1.4 and 3.0.3.2.2, respectively.

In addition the staff reviewed ALRA Sections 3.1.2.C.4 against the criteria in SRP-LR

Section 3.1.2.2.4.2.

Also in Section 3.1.2.C.4 of its letter dated August 19, 2005, the applicant addressed crack

initiation and growth due to thermal and mechanical loading or SCC (including IGSCC) that

could occur in BWR vessel flange leak detection lines and BWR jet pump sensing lines.

SRP-LR Section 3.1.2.2.4 also states that crack initiation and growth due to thermal and

mechanical loading or SCC (including IGSCC) could occur in the BWR vessel flange leak

detection line and the BWR jet pump sensing line. The GALL Report recommends that a

plant-specific aging management program be evaluated to mitigate or detect crack initiation and

growth due to SCC of vessel flange leak detection lines.

The applicant stated in the letter dated August 19, 2005, that for NMP1 cracking of the vessel

flange leak detection lines is managed by the ASME Section Xl (Subsections IWB, IWC, and

IWD) ISI Program, One-Time Inspection Program, and Water Chemistry Control Program. The

inspections conducted under the applicant's One-Time Inspection Program consist of either

NDEs using methods with a demonstrated capability to detect cracks on the inside surfaces of

the piping or destructive examinations. Both nondestructive and destructive examinations will

be of a sample of the piping.

The applicant also stated in Section 3.1.2.C.4 of its letter dated August 19, 2005, that NMP1

has no jet pump sensing line; therefore, the aging effect and aging effect mechanism of jet

pump sensing lines cracking is not applicable to NMPI.

In ALRA Table 3.1.2.A-1, the applicant stated that aging of wrought austenitic stainless steel

(WASS) valves will be managed by its ASME Section Xl (Subsection IWB, IWC, and IWD) ISI,

One-Time Inspection, and Water Chemistry Control Programs. The intended functions of the

component are LBS and SIA associated with NSR components. As documented in the Audit

and Review Report, the staff asked the applicant to explain why NSR components are

managed by ASME ISI and why ALRA Table 3.1.1.A, Item 3.1.1 .A-08 was determined to belong

to this component type if it is NSR. The applicant stated that small-bore valves associated with

the vessel flange leak detection lines are NSR for NMP1. These lines/valves have an ISI

pressure test performed when there is an RFO; hence, WASS valves are managed by the

applicant's ASME Section Xl (Subsections IWB, IWC, and IWD) ISI Program. The staff found

this management acceptable as consistent with the GALL Report.

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The staff's review and evaluation of the applicant's ASME Section Xl (Subsections IWB, IWC,

and IWD) ISI, One-Time Inspection, and Water Chemistry Control Programs are documented in

SER Sections 3.0.3.2.1, 3.0.3.1.4 and 3.0.3.2.2, respectively.

In addition the staff reviewed ALRA Section 3.1.2.C.4 against the criteria of SRP-LR

Section 3.1.2.2.4.3.

Also in Section 3.1.2.C.4 of the letter dated August 19, 2005, the applicant addressed crack

initiation and growth due to thermal and mechanical loading or SCC (including IGSCC) that

could occur in BWR isolation condenser components. SRP-LR Section 3.1.2.2.4.3 states that

crack initiation and growth due to thermal and mechanical loading or SCC (including IGSCC)

could occur in BWR isolation condenser components. The program relies on control of reactor

water chemistry to mitigate SCC and on ASME Section Xl ISI; however, the program should be

augmented to detect cracking due to SCC or cyclic loading. The GALL Report recommends an

augmented program to include temperature and radioactivity monitoring of the shell-side water

and eddy current testing of tubes to ensure that the component's intended function will be

maintained during the period of extended operation.

The applicant stated in Section 3.1.2.C.4 of its letter dated August 19, 2005, that NMP1 has

ECs. The EC design features end bells welded to the EC shell not designed to be removed;

therefore, eddy current testing of the tubing is not possible. Cracking is managed by several

programs. The Water Chemistry Control Program controls chemical contaminants in both tube

and shell side water to prevent conditions that would promote cracking. The EC tube side,

which is ASME Class 2, is subject to a system inservice pressure test under the ASME

Section XI (Subsections IWB, IWC, and IWD) ISI Program. The pressure test detects tube

leaks caused by cracking. The EC shell is ASME Class 3 and subject to a functional test under

the applicant's Inservice Pressure Testing Program which is part of its ASME Section Xl

(Subsections IWB, IWC, and IWD) ISI Program. The functional test would detect cracking due

to SCC or cyclic loading if the crack caused a through-wall leak of the EC shell.

In Section 3.1.2.C.4 of its letter dated August 19, 2005, the applicant also stated that for

additional confirmation of no tube leaks NMP1 will implement an online tube leakage test. The

test will isolate the makeup and drain valves to the EC tube side and monitor the shell side

water level for 24 to 48 hours. A water level rise on the shell side during the test would indicate

tube leakage. The online test will be incorporated as a new activity in the Preventive

Maintenance Program. The new activity will be implemented prior to the period of extended

operation.

In addition the applicant stated in Section 3.1.2.C.4 of its letter dated August 19, 2005, that its

Preventive Maintenance Program is also credited for detecting cracking because it includes the

temperature monitoring of the emergency cooling system including the heat exchangers.

Temperature monitoring can indicate tube leaks quickly. Continuous radiation monitoring of the

EC shell side vents also would detect a tube leak.

In Section 3.1.2.C.4 of its letter dated August 19, 2005, the applicant also stated that because

none of these activities would detect drack initiation or SCC before a leak occurred they will be

supplemented by a visual inspection for cracking from the accessible outer surfaces of the

peripheral tubes, tube sheet, and EC shell. This inspection also will be incorporated into the

applicant's Preventive Maintenance Program.

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The staffs review and evaluation of the applicant's Water Chemistry Control, ASME Section Xl

(Subsections IWB, IWC, and IWD) ISI, and Preventive Maintenance Programs are documented

in SER Sections 3.0.3.2.2, 3.0.3.2.1 and 3.0.3.3.1, respectively.

As documented in the Audit and Review Report dated January 18, 2006, the staff noted that

inaccessibility alone cannot justify exemption from inspection required for aging management

and operating experience (documented in Inspection and Enforcement Bulletin (IEB) 76-01,

"BWR Isolation Condenser Tube Failure") indicates cracking as an issue. As documented in the

Audit and Review Report, the staff asked the applicant to provide additional justification to

address this issue. The applicant responded that the aging management activities provide

adequate assurance with no need for eddy current testing that any tube degradation in the

isolation condensers Will not lead to a loss of intended function. These activities include water

chemistry control, temperature monitoring of the shell side and tube side water, continuous

radioactivity monitoring of the condenser vent line, periodic performance testing, and a future

on-line tube leakage test. NMP1 experienced tube leakage previously and replaced the whole

tube bundle with upgraded material in 1997. A keep fill modification also was installed to

eliminate the stressor which caused the tube failures. Therefore, the applicant continued in

response, because the original isolation condenser tubes lasted 28 years with an aging stressor

the new tubes are expected to perform their intended function through the period of extended

operation with improved material, upgraded system design, and monitoring.

As documented in the Audit and Review Report dated January 18, 2006, the staff asked the

applicant during its audits in the week of September 19, 2005, to provide its basis for not

performing eddy current testing. In a letter dated December 1, 2005, the applicant provided its

basis:

1) Condition and stresses that are precursors to SCC of tubes have been

eliminated by:

a) Lowering temperature of the tubes primary and shell side water

b) Maintaining shell side water chemistry

c) Maintaining BWR primary water chemistry

2) The susceptibility of the tubes to SCC has been improved by design changes to:

a) Replace the tube bundle material with Type 316 stainless steel (low

carbon)

b) Install a keep fill system to maintain steam water interface above top of

tube bundle (no thermal cycles)

3) Monitoring and detecting in the steam inlet (tube) side and shell side of the

isolation condensers ensure that conditions will not recur

a) Water temperature

b) Water chemistry (conductively, chloride, nitrates, sulfates)

4) A commitment has been made to perform a tube leak test at operating pressure

to detect small leaks.

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The staff reviewed the applicant's nuclear commitment tracking list to confirm that the online

tube leakage test will be implemented as anew activity in the Preventive Maintenance Program

as stated in NMP1 Commitment 29. The staff reviewed the'applicant's response and

determined that NMP1 isolation condenser tube aging is adequately managed and that the

tubes will be able to perform their intended function at least an additional 23 years to the end of

the period of extended operation.

Based on the programs identified above, the staff concludes that there is reasonable assurance

that the applicant has met the criteria of SRP-LR Section 3.1.2.2.4. For those line items that

apply to Section 3.1.2.C.4 of the applicant's letter dated August 19, 2005, the staff determined

that the information in the application is consistent with the GALL Report and the applicant had

demonstrated that the .effects of aging will be adequately managed so that the intended

function(s) will be maintained consistent with the CLB during the period of extended operation,

as required by 10 CFR 54.21 (a)(3).

3.1A.2.2.5 Crack Growth due to Cyclic Loading (NMP1)

The staff reviewed Section 3.1.2.C.5 of the applicant's letter dated August 19, 2005, against the

criteria in SRP-LR Section 3.1.2.2.5.

In Section 3.1.2.C.5 of letter dated August 19, 2005, the applicant stated that this aging effect

applies to PWRs only.

SRP-LR Section 3.1.2.2.5 states that crack growth due to cyclic loading could occur in the

reactor vessel shell and the reactor coolant system piping and fittings. SRP-LR Table 3.1-1

states that further evaluation for this aging effect is only applicable to PWR plants.

The staff found that this aging effect is not applicable to NMP1.

3.1A.2.2.6 Changes in Dimension due to Void Swelling

The staff reviewed Section 3.1.2.C.6 of the applicant's letter dated August 19, 2005, against the

criteria in SRP-LR Section 3.1.2.2.6.

In Section 3.1.2.C.6 of letter dated August 19, 2005, the applicant stated that this aging effect

applies to PWRs only.

SRP-LR Section 3.1.2.2.6 states that changes in dimension due to void swelling could occur in

reactor internal components. SRP-LR Table 3.1-1 states that further evaluation for this aging

effect is only applicable to PWR plants.

The staff found that this aging effect is not applicable to NMPI.

3.1A.2.2.7 Crack Initiation and Growth due to Stress Corrosion Cracking or Primary Water

Stress Corrosion Cracking

The staff reviewed Section 3.1.2.C.7 of the applicant's letter dated August 19, 2005, against the

criteria in SRP-LR Section 3.1.2.2.7.

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In Section 3.1.2.C.7 of letter dated August 19, 2005, the applicant stated that this aging effect

applies to PWRs only. .

SRP-LR Section 3.1.2.2.7 states that crack initiation and growth due to SCC and PWSCC could

occur: (1) in PWR core support pads (or core guide lugs), instrument tubes (bottom head

penetrations), pressurizer spray heads, and nozzles for the steam generator instruments and

drains; (2) in PWR CASS reactor coolant system piping and fittings and pressurizer surge line

nozzles; and (3) in PWR pressurizer instrumentation penetrations and heater sheaths and

sleeves made of Ni alloys. SRP-LR Table 3.1-1 states that further evaluation for this aging

effect is only applicable to PWR plants.

The staff found that this aging effect is not applicable to NMP1.

3.1A.2.2.8 Crack Initiation and Growth due to Stress Corrosion Cracking or Irradiation-Assisted

Stress Corrosion Cracking

The staff reviewed Section 3.1.2.C.8 of the applicant's letter dated August 19, 2005, against the

criteria in SRP-LR Section 3.1.2.2.8.

In Section 3.1.2.C.8 of letter dated August 19, 2005, the applicant stated that this aging effect

applies to PWRs only.

SRP-LR Section 3.1.2.2.8 states that crack initiation and growth due to SCC or IASCC could

occur in baffle/former bolts in Westinghouse and B&W reactors. SRP-LR Table 3.1-1 states

that further evaluation for this aging effect is only applicable to PWR plants.

The staff found that this aging effect is not applicable to NMP1.

3.1A.2.2.9 Loss of Preload due to Stress Relaxation

The staff reviewed Section 3.1.2.C.9 of the applicant's letter dated August 19, 2005, against the

criteria in SRP-LR Section 3.1.2.2.9.

In Section 3.1.2.C.9 of letter dated August 19, 2005, the applicant stated that this aging effect

applies to PWRs only.

SRP-LR Section 3.1.2.2.9 states that loss of preload due to stress relaxation could occur in

baffle/former bolts in Westinghouse and B&W reactors. SRP-LR Table 3.1-1 states that further

evaluation for this aging effect is only applicable to PWR plants.

The staff found that this aging effect is not applicable to NMPI.

3.1A.2.2.10 Loss of Section Thickness due to Erosion

The staff reviewed Section 3.1.2.C.10 of the applicant's letter dated August 19, 2005, against

the criteria in SRP-LR Section 3.1.2.2.10.

In Section 3.1.2.C.10 of letter dated August 19, 2005, the applicant stated that this aging effect

applies to PWRs only.

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SRP-LR Section 3.1.2.2.10 states that loss of section thickness due to erosion could occur in

steam generator feedwater impingement plates and supports. SRP-LR Table 3.1-1 states that

further evaluation for this aging effect is only applicable to PWR plants.

The staff found that this aging effect is not applicable to NMP1.

3.1A.2.2.11 Crack Initiation and Growth due to PWSCC, ODSCC, or Intergranular Attack or

Loss of Material due to Wastage and Pitting Corrosion or Loss of Section Thickness due to

Fretting and Wear or Denting due to Corrosion of Carbon Steel Tube Support Plate

The staff reviewed Section 3.1.2.C.1 1 of the applicant's letter dated August 19, 2005, against

the criteria in SRP-LR Section 3.1.2.2.11.

In Section 3.1.2.C.1 1 of letter dated August 19, 2005, the applicant stated that this aging effect

applies to PWRs only.

SRP-LR Section 3.1.2.2.11 states that crack initiation and growth due to PWSCC, ODSCC, or

IGA or loss of material due to wastage and pitting corrosion or deformation due to corrosion

could occur in alloy 600 components of the steam generator tubes, repair sleeves and plugs.

SRP-LR Table 3.1-1 states that further evaluation for this aging effect is only applicable to PWR

plants.

The staff found that this aging effect is not applicable to NMP1.

3.1A.2.2.12 Loss of Section Thickness due to Flow-accelerated Corrosion

The staff reviewed Section 3.1.2.C.12 of the applicant's letter dated August 19, 2005, against

the criteria in SRP-LR Section 3.1.2.2.12.

In Section 3.1.2.C.12 of letter dated August 19, 2005, the applicant stated that this aging effect

applies to PWRs only.

SRP-LR Section 3.1.2.2.12 states that loss of section thickness due to flow-accelerated

corrosion could occur in tube support lattice bars made of carbon steel. SRP-LR Table 3.1-1

states that further evaluation for this aging effect is only applicable to PWR plants.

The staff found that this aging effect is not applicable to NMP1.

3.1A.2.2.13 Ligament Cracking due to Corrosion

The staff reviewed Section 3.1.2.C.13 of the applicant's letter dated August 19, 2005, against

the criteria in SRP-LR Section 3.1.2.2.13.

In Section 3.1.2.C.13 of letter dated August 19, 2005, the applicant stated that this aging effect

applies to PWRs only.

SRP-LR Section 3.1.2.2.13 states that ligament cracking due to corrosion could occur in carbon

steel components in the steam generator tube support plate. SRP-LR Table 3.1-1 states that

further evaluation for this aging effect is only applicable to PWR plants.

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The staff found that this aging effect is not applicable to NMP1.

3.1A.2.2.14 Loss of Material due to Flow-accelerated Corrosion

The staff reviewed Section 3.1.2.C.14 of the applicant's letter dated August 19, 2005, against

the criteria in SRP-LR Section 3.1.2.2.14.

In Section 3.1.2.C.14 of letter dated August 19, 2005, the applicant stated that this aging effect

applies to PWRs only.

SRP-LR Section 3.1.2.2.14 states that loss of material due to flow-accelerated corrosion could

occur in feedwater inlet ring and supports. SRP-LR Table 3.1-1 states that further evaluation for

this aging effect is only applicable to PWR plants.

The staff found that this aging effect is not applicable to NMP1.

3.1A.2.2.15 Quality Assurance for Aging Management of Nonsafety-Related Components

SER Section 3.0.4 provides the staff's evaluation of the applicant's quality assurance program.

Conclusion. On the basis of its review, for component groups evaluated in the GALL Report for

which the applicant has claimed consistency with the GALL Report, and for which the GALL

Report recommends further evaluation, the staff determined that the applicant adequately

addressed the issues that were further evaluated. The staff found that the applicant had

demonstrated that the effects of aging will be adequately managed so that the intended

functions will be maintained consistent with the CLB for the period of extended operation, as

required by 10 CFR 54.21(a)(3).

3. 1A.2.3 AMR Results That Are Not Consistent with or Not Addressed in the GALL

Report

Summary of Technical Information in the Amended Application. In ALRA Tables 3.1.2.A-1

through 3.1.2.A-5, the staff reviewed additional details of the results of the AMRs for material,

environment, AERM, and AMP combinations that are not consistent with the GALL Report, or

that are not addressed in the GALL Report..

In ALRA Tables 3.1.2.A-1 through 3.1.2.A-5, the applicant indicated, via Notes F through J, that

the combination of component type, material, environment, and AERM does not correspond to

a line item in the GALL Report, and provided information concerning how the aging effect will

be managed. Specifically, Note F indicates that the material for the AMR line item component is

not evaluated in the GALL Report. Note G indicates that the environment for the AMR line item

component and material is not evaluated in the GALL Report. Note H indicates that the aging

effect for the AMR line item component, material, and environment combination is not evaluated

in the GALL Report. Note I indicates that the aging effect identified in the GALL Report for the

line item component, material, and environment combination is not applicable. Note J indicates

that neither the component nor the material and environment combination for the line item is

evaluated in the GALL Report.

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Staff Evaluation. For component type, material, and environment combinations that are not

evaluated in the GALL Report, the staff reviewed the applicant's evaluation to determine

whether the applicant had demonstrated that the effects of aging will be adequately managed

so that the intended function(s) will be maintained consistent with the CLB during the period of

extended operation. The staffs evaluation is discussed in the following sections.

The staffs review as provided in the following sections of this safety evaluation is limited to

those components not consistent with or not addressed in the GALL Report for the following

systems in the NMP1 reactor coolant system (RCS) group, the RPV, RPV internals, RPV

instrumentation system, and CRD system. The assessment for the NMP1 RPV valves, reactor

recirculation system components, and the CRD system valves are addressed in SER

Section 3.1A.2.3.4.

3.IA.2.3.1 Reactor Vessel, Internals, and Reactor Coolant System - NMPI Reactor Pressure

Vessel - Summary of Aging Management Evaluation -ALRA Table 3.1.2A-1

The NMP1 RPV contains and supports the reactor core, reactor internals, and the reactor

coolant/moderator. The RPV forms part of the reactor coolant pressure boundary (RCPB) and

serves as a barrier against leakage of radioactive materials to the drywell. The NMP1 RPV is a

vertical, cylindrical pressure vessel with hemispherical heads. The cylindrical shell and

hemispherical heads are fabricated from low-alloy carbon steel clad on the interior with

stainless steel weld overlay. The top head secured to the vessel with studs and nuts includes

two concentric seal-rings between the vessel head flange and the vessel flange to prevent

reactor coolant leakage. The top head leak detection line taps off of the vessel head between

the seal rings to detect leakage if the inner seal-ring fails. The top head also includes nine

safety valves that prevent overpressurization of the RPV. The vessel shell and bottom head

include penetration nozzles for the various systems that comprise the RCPB including the CRD

housing and in-core instrumentation thimbles. The RPV is supported by a steel skirt welded to

the bottom head. The base of the skirt is supported circumferentially by a ring girder and sole

plate fastened to a concrete foundation which carries the load of the reactor building foundation

slab.

Summary of Technical Information in the Application. The applicant's plant-specific AMRs for

the RPV components are listed in ALRA Table 3.1.2.A-1. The specific RPV components for

NMPI that have AMR results not consistent with or not addressed in the GALL Report and

within the scope of ALRA Table 3.1.2.A-1 include:

" RPV core differential pressure, CRD stub tube, flux monitor, instrumentation, and vessel

drain penetrations

• RPV support skirt and attachment welds

" RPV top head closure studs and nuts

* RPV valves

The applicant identified the materials of fabrication for these RPV components as carbon steel

and low alloy steel. The applicant identified the applicable environments for these RPV

components as containment air, non-borated water, and treated water (including steam).

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The applicant credited the FAC Program with managing loss of material for the RPV core

differential pressure, CRD stub tube, flux monitor, instrumentation, and vessel drain

penetrations. The ASME Section XI (Subsections IWB, IWC, and IWD) ISI Program is credited

for the managing loss of material for the RPV support skirt and attachment welds. The Water

Chemistry Control Program and the One-Time Inspection Program are credited for managing

the loss of material for the RPV valves. The applicant credited the Reactor Head Closure Studs

Program with managing loss of material for the RPV top head closure studs and nuts. In

addition, the applicant credited TLAA 4.3, "Thermal Fatigue," with managing cumulative fatigue

damage of the RPV top head closure studs and nuts. The applicant credited the Selective

Leaching of Materials Program and the Water Chemistry Control Program with managing loss

of material for the CRD system valves.

Staff Evaluation. The staff reviewed ALRA Table 3.1.2.A-1, which summarizes the results of

AMR evaluations for the RPV component groups. The staff's assessment of the RPV

components not consistent with or not addressed in the GALL Report for NMP1 is provided in

this section. The assessment for the NMP1 RPV valves is provided in SER Section 3.1A.2.3.4.

RPV Core Differential Pressure, CRD Stub Tube, Flux Monitor, Instrumentation, and Vessel

Drain Penetrations

Identification of Aging Effects - In ALRA Table 3.1.2.A-1, the applicant indicated that loss of

material due to FAC is an aging effect for the core differential pressure, CRD stub tube, flux

monitor, instrumentation, and vessel drain penetrations fabricated from carbon or low-alloy steel

and exposed to a treated water or steam in a high-temperature environment.

FAC is a phenomenon in which repetitive cycles of corrosion and erosion cause wall thinning of

carbon or low-alloy steel components exposed to high temperature, high velocity water or

water-steam environments. Normally, FAC occurs only if the environmental temperatures are

above 200 OF. The rate of metal loss depends on a complex interplay of many factors like water

chemistry, material composition, and hydrodynamics.

The staff determined that the applicant indicated adequately that loss of material due to FAC is

an AERM for the core differential pressure, CRD stub tube, flux monitor, instrumentation, and

vessel drain penetrations exposed to these environments. This aging effect is not addressed in

the GALL Report Volume 2 for these components, materials, and environments; therefore, the

staff found the applicant's approach acceptable because it is conservative relative to the GALL

Report Volume 2 and is consistent with the EPRI Report, "Recommendations for an Effective

Flow-Accelerated Corrosion Program."

Aging Management Programs - In ALRA Table 3.1.2.A-1, the applicant credits the FAC

Program with aging management of the core differential pressure, CRD stub tube, flux monitor,

instrumentation, and vessel drain penetrations for loss of material due to FAC. Even though the

GALL Report Volume 2 does not address an AMP for these components, materials, and

environments, it does recommend crediting the Flow-Accelerated Corrosion Program with

managing wall thinning of carbon steel piping and fitting components due to FAC; therefore, the

staff found the applicant's proposal conservative relative to the GALL Report Volume 2, and

acceptable. The applicant's FAC Program is an AMP entirely consistent with GALL

AMP XI.M17. The staffs evaluation of the FAC Program is in SER Section 3.0.3.1.3.

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RPV SuDoort Skirt and Attachment Welds

Identification of Aging Effects - In ALRA Table 3.1.2.A-1, the applicant indicated that loss of

material due to general corrosion is an aging effect for RPV support skirt and attachment welds

fabricated from carbon or low-alloy steel and exposed to an environment of "air with thermal

fatigue." The applicant definition of "air with thermal fatigue" is "this environment is applied to

components exposed to air, that are also subject to thermal cycles of sufficient magnitude for

thermal fatigue to be a concern." The air environment is the containment air surrounding the

RPV and the support skirt.

GALL Report Volume 2 does not identify loss of material due to general corrosion as an aging

effect in carbon and l6w-alloy steel when these materials are exposed to an environment of

containment air; however, carbon and low-alloy steel may rust or corrode in air with elevated

humidity. The staff concludes that the applicant has addressed this issue conservatively;

therefore, the staff found the applicant's identification of this AERM acceptable for the RPV

support skirt and attachment welds.

Aging Management Programs - In ALRA Table 3.1.2.A-1, the applicant credits the ASME

Section XI (Subsections IWB, IWC, and IWD) ISI Program with aging management of the RPV

support skirt and attachment welds for loss of material due to general corrosion. By letter dated

November 22, 2005, the staff indicated that it agreed with the applicant in crediting the ASME

Section XI (Subsections IWB, IWC, and IWD) ISI Program with managing the RPV attachment

welds for loss of material due to general corrosion; however, the staff requested that the

applicant address why the ASME Section Xl (Subsections IWB, IWC, and IWD) ISI Program

was credited with managing the RPV support skirt for loss of material due to general corrosion.

Instead, the staff recommended that this aging effect in the RPV support skirt be managed by

the ASME Section Xl (Subsection IWF) ISI Program because the RPV support skirt is an ASME

Class MC support By letter dated December 5, 2005, the applicant revised Table 3.1.2.A-1 to

indicate that the AERM of loss of material of the RPV support skirt would be managed by the

ASME Section Xl (Subsection IWF) ISI Program. The staff found the applicant's response

acceptable because the RPV support skirt is an ASME Class MC component and, therefore, is

managed appropriately by the ASME Section Xl (Subsection IWF) ISI Program.

GALL Report Volume 2 does not identify an AMP for managing loss of material due to general

corrosion for these components, materials, and environments. The staff found the applicant's

proposal conservative relative to the GALL Report Volume 2 and, therefore, acceptable. The

applicant's ASME Section Xl (Subsections IWB, IWC, and IWD) ISI Program is an AMP

consistent with GALL AMP XI.M1 with exceptions. The staff's evaluation of the ASME

Section Xl (Subsections IWB, IWC, and IWD) ISI Program is in SER Section 3.0.3.2.1. The

applicant's ASME Section Xl (Subsection IWF) Program is an AMP consistent with GALL

AMP XI.S3 with exceptions. The staff's evaluation of the ASME Section Xl (Subsection IWF)

Program is in SER Section 3.0.3.2.19.

RPV Top Head Closure Studs and Nuts

Identification of Aging Effects - In ALRA Table 3.1.2.A-1, the applicant indicated that loss of

material due to general, crevice, and pitting corrosion is an aging effect applicable to the RPV

top head closure studs and nuts fabricated from carbon or low-alloy steel and exposed to an

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environment of non-borated water systems with operating temperatures > 212 OF leaking fluid

(i.e., leakage of the reactor coolant).

GALL Report Volume 2 identifies crack initiation and growth, SCC and IGSCC as aging effects

for RPV top head closure studs and nuts fabricated from carbon or low alloy steel exposed to

air, leaking reactor coolant water, or steam at 288 °C, but does not identify loss of material due

to crevice, general, and pitting corrosion as aging effects in carbon and low-alloy steel exposed

to leakage of the non-borated reactor coolant or the steam environment. However, carbon and

low-alloy steel may rust or corrode when exposed to aqueous liquids. The staff concludes that

the applicant has conservatively addressed this issue; therefore, the staff found the applicant's

identification of this AERM acceptable.

Also, in ALRA Table 3.1.2.A-1, the applicant indicated that cumulative fatigue damage is an

aging effect applicable to the RPV top head closure studs and nuts because of thermal cycling

of heatup and cooldown and other transient operating conditions of these components. The

staff found this indication acceptable because it meets the provisions in SRP-LR Chapter

3.1-1800 Revision I Report for assessing cumulative fatigue damage in ASME Code Class I

components. SER Section 4.3 discusses the staff's assessment of those plant components

required to have thermal fatigue analyses for license renewal.

Aging Management Programs - In ALRA Table 3.1.2.A-1, the applicant credits the Reactor

Head Closure Studs Program with aging management of loss of material due to general, pitting,

and crevice corrosion of the RPV top head closure studs and nuts. Even though the GALL

Report Volume 2 does not identify an AMP for these components, materials, and environments

the staff found the applicant's proposal conservative relative to the GALL Report Volume 2 and,

therefore, acceptable. The applicant's Reactor Head Closure Studs Program is an AMP

consistent with an exception with GALL AMP XI.M3. The staffs evaluation of the Reactor Head

Closure Studs Program is in SER Section 3.0.3.2.3.

In ALRA Table 3.1.2.A-1, the applicant proposed in ALRA Section 4.3 to use the TLAA for

assessing cumulative fatigue damage of the RPV top head closure studs and nuts. This

proposal is consistent with the GALL Report Revision 1 and is, therefore, acceptable. The

staff's evaluation of the applicant's TLAA on thermal fatigue of ASME Code Class 1

components is in SER Section 4.3.

RPV Valves

The review of the RPV valves is provided in SER Section 3.1A.2.3.4.

Conclusion. The staff has reviewed the applicant's plant-specific AMRs for the RPV

components exposed to the containment air, non-borated water, and treated water (including

steam) environments. For these AMRs, the staff has determined that the applicant has

identified the aging effects applicable for these components exposed to these environments.

The staff has also determined that the applicant has credited either an appropriate

inspection-based AMP, an appropriate mitigation-based AMP, a TLAA, or combination of these

strategies to manage the aging effects applicable to the RPV components exposed to these

environments. On the basis of its review, as discussed above, the staff concludes that there is

reasonable assurance that the applicant has demonstrated that the aging effects associated

with the NMP1 RPV will be adequately managed so that the intended functions will be

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maintained consistent with the CLB for the period of extended operation, as required by

10 CFR 54.21(a)(3).

3.1A.2.3.2 Reactor Vessel, Internals, and Reactor Coolant System - NMP1 Reactor Pressure

Vessel Internals - Summary of Aging Management Evaluation - ALRA Table 3.1.2A-2

The NMP1 RPV internals support the core and other internal components, maintain fuel

configuration (coolable geometry) during normal operation and accident conditions, and

maintain reactor coolant flow through the core. The RPV internals consist of the components

internal to the RPV, mainly the reactor core, core shroud, core shroud stabilizers, core shroud

support structures, top guide, CRD guide tubes, feedwater sparger, core spray spargers, liquid

poison sparger, steam separator assembly, and the steam dryer assembly. All of the RPV

internals except the shroud support assembly and springs in the fuel assemblies are fabricated

from stainless steel. The shroud support plates, spacers, tie rods, head bolts, and associated

welds are fabricated from nickel-based alloys. The shroud support essentially sustains all of the

vertical weight of the core structure and the steam separator assembly. Each guide tube with its

fuel support casing bears the weight of four fuel assemblies and rests on a CRD housing

welded to the stub tube mounted on the vessel bottom head.

The applicant's plant-specific AMRs for the RPV internal components are identified in

ALRA Table 3.1.2.A-2. The staff determined that no RPV internal components for NMP1 have

AMR results not consistent with or addressed in the GALL Report. Therefore, in this review, the

staff did not perform an evaluation of the NMP1 RPV internal components.

3.1A.2.3.3 Reactor Vessel, Internals, and Reactor Coolant System - NMP1 Reactor Vessel

Instrumentation System - Summary of Aging Management Evaluation - ALRA Table 3.1.2.A-3

The NMP1 RPV instrumentation system monitors and transmits information about key RPV

operating parameters during normal and emergency operations. Instrumentation is installed to

monitor reactor parameters and indicate these on meters, chart recorders, and hydraulic

indicator units located in the control room, on remote shutdown panels, and in instrument

rooms. The parameters monitored are RPV temperature, water level and pressure, core

differential pressure, core spray sparger break (differential pressure), and reactor safety valve

position. This system also provides control signals to various systems which in turn initiate

appropriate actions required if a monitored parameter exceeds a desired set point. Systems

receiving control signals from the RPV instrumentation system include the reactor protection,

automatic depressurization, anticipated transient without scram (ATWS), feedwater/high

pressure coolant injection (HPCI), and shutdown cooling systems. The top head leak detection

line is addressed with the RPV (ALRA Section 2.3.1.A.1). The RPV instrumentation system

consists of piping, valves, and excess flow check valves that provide a fluid path from the RPV

to various instrumentation.

The applicant's plant-specific AMRs for the RPV instrumentation system components are

identified in ALRA Table 3.1.2.A-3. The staff determined that no RPV instrumentation system

components for NMP1 have AMR results not consistent with or not addressed in the GALL

Report. Therefore, in this review, the staff did not perform an evaluation of the NMP1 RPV

instrumentation system components.

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3.1A.2.3.4 Reactor Vessel, Internals, and Reactor Coolant System - NMP1 Reactor

Recirculation System - Summary of Aging Management Evaluation - ALRA Table 3.1.2A-4

Summary of Technical Information in the Application. The description of the reactor

recirculation system, recirculation flow control, and the control of the reactor recirculation

pumps can be found in ALRA Section 2.3.1 .A.4. The portion of the reactor recirculation system

containing components subject to AMR includes the entire main reactor recirculation flow path

which begins at the suction nozzle to and ends at the discharge nozzle of each recirculation

loop for NMP1. SR instrument piping and associated components connected to the recirculation

loops are also subject to AMR. The components requiring an AMR for the reactor recirculation

system and their intended functions are shown in ALRA Table 2.3.1 .A.4-1. The AMR results for

these components are provided in ALRA Table 3.1.2.A-4. However, the staff has used in its

evaluation the following information provided in the original LRA pertinent to the reactor

recirculation system.

The materials of construction for NMP1 are carbon or low-alloy steel (yield strength < 100 Ksi

and > 100 Ksi), cast austenitic stainless steel, and wrought austenitic stainless steel.

In the original LRA Section 3.1.2.A.4 the applicant lists the following environments to which the

NMP1 Reactor Recirculation System components are exposed:

* air

* closure bolting for non-borated water systems with operating temperatures > 212 OF

• treated water, temperature < 140 °F, low flow

* treated water or steam, temperature > 482 OF

* treated water or steam, temperature > 482 °F, low flow

The following AMPs manage these aging effects in the NMP1 reactor recirculation system

components:

• ASME Code Section Xl Inservice Inspection (Subsections IWB, IWC, IWD) Program

* Bolting Integrity Program

* BWR Stress Corrosion Cracking Program

* One-Time Inspection Program

* Water Chemistry Control Program

* System Walkdown Program

Staff Evaluation. The applicant described its AMR for the reactor recirculation system in ALRA

Section 3.1. The staff reviewed this section to determine whether the applicant had identified all

aging effects applicable to components in these systems and demonstrated that the effects of

aging on the components will be adequately managed during the period of extended operation

as required by 10 CFR 54.21(a)(3). The staff also reviewed the UFSAR supplements for the

AMPs to ensure that the program descriptions adequately describe them.

The applicant identified the following aging effects for the reactor recirculation system:

* cracking

* cumulative fatigue damage

• loss of fracture toughness

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* loss of material

* loss of preload

In ALRA Table 3.1.2.A-4 the applicant identified cracking and cumulative fatigue damage as

aging effects applicable to the recirculation system closure bolting, piping and fittings,

recirculation pumps, and valves. Cumulative fatigue damage is evaluated in SER Section 4.3,

"Metal Fatigue Analysis." The aging effect of loss of fracture toughness is associated with the

pressure boundary materials in reactor recirculation pumps and in valves made of cast

austenitic stainless steel and operating at or above 480 OF. Loss of material has been detected

as an aging effect in carbon or low-alloy steel and austenitic stainless steel with treated water

environment operating below 140°F for such components as piping and fittings, valves, and

restriction orifices in the reactor recirculation system. The loss of preload is an aging effect

applicable to closure bolting for non-borated water systems operating at or above 212 OF. The

staff notes that this assessment is consistent with the GALL Report.

The applicant identified cracking as an aging effect applicable to the recirculation system

austenitic stainless steel components (piping and fittings, tubing, valve bodies, flow elements,

thermowells, restricting orifices) and to the high-strength low-alloy steel primary pressure

closure bolting exposed to reactor coolant water. The applicant also identified this aging effect

for cast stainless steel components exposed to reactor coolant water. The applicant identified

crack initiation and growth due to thermal and mechanical loading as an aging effect applicable

to small-bore stainless steel piping and fittings and low-alloy steel pressure boundary closure

bolting in the reactor recirculation system. The staff notes that this assessment is consistent

with the GALL Report. The staff requested confirmation that the applicant had no flaws

evaluated according to IWB-3600, "Analytical Evaluation of Flaws," under the ASME Code

Section Xl ISI Program as such an evaluation would require a TLAA under the regulation. The

applicant's response indicated that the NMP1 Reactor Recirculation System contains five welds

that had flaw evaluations performed according to IWB-3600. Re-inspection of each weld found

no growth of the indication. The applicant's evaluation determined that each of the indications

was related to the fabrication of the component and was not caused by IGSCC. The staff

previously had accepted the applicant's evaluation. Therefore, there is no TLAA required for

any of the subject flaw evaluations.

The applicant stated under item number 3.1.1.A-07 in ALRA Table 3.1.1.A, that for small-bore

reactor coolant system and connected systems piping a plant-specific destructive examination

or an NDE of the inside surfaces will be conducted as part of a one-time inspection to verify that

service-induced weld cracking has not occurred. Additionally, for small bore piping and fittings

in the NMP1 CRD system not part of the ISl program NMP1 credits only the Water Chemistry

and One-Time Inspection Programs. The applicant's One-Time Inspection AMP is described in

ALRA Section B.2.1.20 and the applicant states that it is consistent with GALL Report

AMP XI.M32, "One-Time Inspection."

In ALRA Table 3.1.2.A-1, applicable to the vessel drain line, the applicant identified cumulative

fatigue damage and cracking as aging effects requiring management. The applicant uses TLAA

to manage cumulative fatigue damage and the BWR Penetration Program and Water

Chemistry Control Program to manage cracking. Because of the size of the drain line

volumetric examination is not required by ASME Code Section Xl. In response to the staffs

request for information about the adequacy of the AMP applicable to the reactor vessel drain

line not volumetrically examined the applicant stated that the ASME Code Section Xl pressure

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test is performed at every refueling outage. As a function of the pressure test a concurrent VT-2

examination is performed according to acceptance standards stated in Subsection IWB-3522.

The source of any leakage detected during this examination is required to be located and

evaluated according to Subsection IWA-5250 prior to return of the system to service. One

source of leakage could be through-wall pitting or crevice corrosion as the loss of material

mechanism applicable to stainless steel piping and components. Also performed at every

inspection interval under the ISI program according to the acceptance standards stated in

Subsection IWB-3517 is a VT-1 examination of all reactor vessel drain line bolting, studs, and

nuts. The staff considers the AMPs of the reactor vessel drain line effective for the period of

extended operation.

In ALRA Table 3.1.1 .A-1, item number 3.1.1 .A-09, the applicant identified SCC and cyclic

loading as aging effects for isolation condensers and credits the Preventive Maintenance

Program for managing them. The isolation condensers are parts of the reactor coolant pressure

boundary and, therefore, should be inspected according to ASME Code Section XI. The

Preventive Maintenance Program does not require volumetric examination for structural

integrity of pressure boundary material or welds. In response to the staff's request for

information on the management of aging effects of cracking in stainless steel tubes and in shell

welds the applicant stated that ASME Section XI Inservice Inspection (Subsections IWB, IWC,

and IWD) and the Water Chemistry Control Programs are credited in addition to the Preventive

Maintenance Program for managing the aging effect of cracking in stainless steel tubes and in

shell welds. Continuous radiation monitoring of the isolation condenser shell also is credited.

These changes utilize detection methods in addition to visual inspection to ensure detection and

correction of aging degradation prior to a loss of intended function. These revisions to ALRA

Table 3.1.1.A bring the credited programs in line with the guidance of GALL Report Item

IV.C1.4-a for the NMP1 isolation condensers.

In reviewing ALARA Table 3.1.1.A-1, the staff requested that the applicant to submit additional

information about its plant-specific experience with IGSCC of the reactor coolant pressure

boundary piping, mitigative actions taken, and revised inspection schedules following the

BWRVIP-75A guidelines. The staff requested that the applicant provide information on how its

implementation of HWC and NMCA at NMP1 has affected monitoring of water chemistry

parameters. In its response, the applicant stated that recent plant-specific experience at NMP1

had detected indications in four reactor recirculation system welds during the 1999 refueling

outage. The applicant performed its re-inspection evaluations, and determined that the

indications were fabrication-related and not from IGSCC. The scope and schedule of inspection

for IGSCC are according to GL 88-01 as modified by BWRVIP-75A. The current inspection

schedule except for Category A welds subsumed in the alternate Risk-Informed ISI Program is

consistent with the revised inspection frequency allowed by BWRVIP-75A for normal water

chemistry. In implementing HWC and NMCA, NMP1 began treating the reactor vessel internals

with noble metal chemicals in May 2000 and began injecting hydrogen into reactor water in

June 2000. The impact for NMP1 operating under HWC versus normal water chemistry is that

the electrochemical potential is monitored with a goal of < -0.23V SHE (standard hydrogen

reference electrode) to verify the effectiveness of HWC.

The staff's review concludes that the applicant has identified the appropriate aging effects for

the components in the NMP1 reactor recirculation system.

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Conclusion.The staff concludes that there is reasonable assurance that the applicant

adequately identified the aging effects and the AMPs credited for managing them for the

reactor recirculation system and that the components' intended functions will be maintained

consistently with the CLB for the period of extended operation as required by

10 CFR 54.21 (a)(3). The staff also reviewed the applicable UFSAR supplement program

descriptions and concludes that the UFSAR supplement provides an adequate program

description of the AMPs credited for managing aging in the reactor coolant system -

recirculation system as required by 10 CFR 54.21(d).

3.1A.2.3.5 Reactor Vessel, Internals, and Reactor Coolant System - NMP1 Control Rod Drive

System - Summary of Aging Management Evaluation -ALRA Table 3.1.2A-5

The NMP1 CRD system is designed to change core reactivity by changing the position of

control rods within the reactor core in response to manual control signals and to scram the

reactor in response to manual or automatic signals. The system also provides high-pressure

makeup to the RPV for a specified leakage of 25 gpm and provides core cooling in the case of

a small line break (up to 0.003 ft2

). The CRD system also provides water to the RPV level

instrumentation reference leg backfill system and to the keep-fill system for the emergency

cooling system.

Summary of Technical Information in the Application. The applicant's plant-specific AMRs for

the CRD system components are given in ALRA Table 3.1.2.A-5 and in the revised

Table 3.1.2.A-5 of the applicant's letter dated December 20, 2005. The specific CRD system

components for NMP1 that have AMR results that are not consistent with, or not addressed in,

the GALL Report include:

* CRD system valves

* CRD pumps

The applicant identifies that the materials of fabrication for these CRD system components

include copper alloys, aluminum bronze, and wrought austenitic stainless steel. The applicant

identifies that the applicable environments for these CRD system components include treated

water, temperature > 140 OF, but < 212 OF, low flow environments (i.e., the reactor coolant

environment).

The applicant credits the One-Time Inspection Program and the Water Chemistry Control

Program to manage loss of material for the CRD system valves. The applicant also credits the

One-Time Inspection Program and the Water Chemistry Control Program to manage cracking

of the CRD pumps.

Staff Evaluation. The staff reviewed ALRA Table 3.1.2.A-5, and the revised Table 3.1.2.A-5 of

the applicant's letter dated December 20, 2005, which summarizes the results of AMR

evaluations for the CRD system components for NMPI. The staff's assessment of the CRD

system components that are not consistent with, or not addressed in, the GALL Report for

NMP1 is provided below. It should be noted that the assessments for the NMP1 CRD system

valves are addressed in SER Section 3.1A.2.3.4.

Identification of Aging Effects - In Table 3.1.2.A-5 of the applicant's letter dated December 20,

2005, the applicant identified that cracking is an applicable aging effect for the CRD pumps that

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are fabricated from wrought austenitic stainless steel and are exposed to an environment of

treated water, temperature > 140°F, but < 212°F, low flow environments. These components

are made from materials and exposed to environments that are similar to those for the wrought

austenitic stainless steel CRD system valves exposed to reactor coolant, as identified in the

GALL Report

The applicant identified cracking as an aging effect in wrought austenitic stainless steel when

these materials are exposed to the reactor coolant. Based on this analysis, the staff found that

the applicant's determination is acceptable.

Aging Management Programs - In Table 3.1.2.A-5 of the applicant's letter dated December 20,

2005, the applicant credits the One-Time Inspection and Water Chemistry Control Programs

with aging management of cracking for the CRD pumps. The GALL Report does not address

an AMP for these component, material, and environment combinations. However, the GALL

Report does address the AMPs (One-Time Inspection and Water Chemistry Control Programs)

for this material and environment combination that are consistent with the programs that the

applicant has identified to manage cracking. Therefore, the staff found the applicant's proposal

to be acceptable. The applicant's One-Time Inspection Program is a new AMP that is entirely

consistent with GALL AMP XI.M32. The staffs evaluation of the One-Time Inspection Program

is in SER Section 3.0.3.1.4. The applicant's Water Chemistry Control Program is an existing

AMP that is entirely consistent with GALL AMP XI.M2. The staff's evaluation of the Water

Chemistry Program is in SER Section 3.0.3.2.2.

Conclusion. The staff has reviewed the applicant's plant-specific AMRs for the CRD system

components that are exposed to the treated water, temperature > 140 °F, but < 212 OF, low flow

environments. For these AMRs, the staff determined that the applicant identified the aging

effects that are applicable for these components under exposure to these environments. The

staff also determined that the applicant credited either an appropriate inspection-based AMP,

an appropriate mitigation-based AMP, or combination of these management strategies to

manage the aging effects that are applicable to the CRD system components under exposure

to these environments. On the basis of its review, as discussed above, the staff concludes that

there is reasonable assurance that the applicant has demonstrated that the aging effects

associated with the NMP1 CRD system components will be adequately managed so that the

intended functions will be maintained consistent with the CLB for the period of extended

operation, as required by 10 CFR 54.21 (a)(3).

3.1A.3 Conclusion

On the basis of its review, as discussed above, the staff concludes that there is reasonable

assurance that the applicant has demonstrated that the aging effects associated with the NMP1

RPV, RPV internals, and RCS components will be adequately managed so that the intended

functions will be maintained consistent with the CLB for the period of extended operation as

required by 10 CFR 54.21(a)(3).

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3.1 B NMP2 A-ging Management of Reactor Vessel, Internals, and Reactor Coolant

systems

This section of the SER documents the staffs review of the applicant's AMR results for the

reactor vessel, internals, and reactor coolant systems components and component groups

associated with the following NMP2 systems:

• reactor pressure vessel

• reactor pressure vessel internals

" reactor pressure vessel instrumentation system

• reactor recirculation system

• control rod drive system

3.1 B.1 Summary of Technical Information in the Amended Application

In ALRA Section 3.1, the applicant provided AMR results for the reactor vessel, internals, and

reactor coolant systems components and component groups. In ALRA Table 3.1.1.1, "NMP2

Summary of Aging Management Programs for Reactor Vessel, Internals, and Reactor Coolant

Systems Evaluated in Chapter IV of NUREG-1801," the applicant provided a summary

comparison of its AMRs with the AMRs evaluated in the GALL Report for the reactor vessel,

internals, and reactor coolant systems components and component groups.

The applicant's AMRs incorporated applicable operating experience in the determination of

AERMs. These reviews included evaluation of plant-specific and industry operating experience.

The plant-specific evaluation included reviews of condition reports and discussions with

appropriate site personnel to identify AERMs. The applicant's review of industry operating

experience included a review of the GALL Report and operating experience issues identified

since the issuance of the GALL Report.

3.1B.2 Staff Evaluation

The staff reviewed ALRA Section 3.1 to determine if the applicant provided sufficient

information to demonstrate that the effects of aging for the reactor vessel, internals, and reactor

coolant systems components that are within the scope of license renewal and subject to an

AMR will be adequately managed so that the intended functions will be maintained consistent

with the CLB for the period of extended operation, as required by 10 CFR 54.21 (a)(3).

The staff performed an onsite audit of AMRs to confirm the applicant's claim that certain

identified AMRs were consistent with the GALL Report. The staff did not repeat its review of the

matters described in the GALL Report; however, the staff did verify that the material presented

in the ALRA was applicable and that the applicant had identified the appropriate GALL AMRs.

The staff's evaluations of the AMPs are documented in SER Section 3.0.3. Details of the staffs

audit evaluation are documented in the Audit and Review Report and are summarized in SER

Section 3.18.2.1.

In the onsite audit, the staff also selected AMRs that were consistent with the GALL Report and

for which further evaluation is recommended. The staff confirmed that the applicant's further

evaluations were consistent with the acceptance criteria in SRP-LR Section 3.1.2.2. The staff's

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audit evaluations are documented in the Audit and Review Report and are summarized in SER

Section 3.1B.2.2.

In the onsite audit, the staff also conducted a technical review of the remaining AMRs that were

not consistent with, or not addressed in, the GALL Report. The audit and technical review

included evaluating whether all plausible aging effects were identified and evaluating whether

the aging effects listed were appropriate for the combination of materials and environments

specified. The staff's audit evaluations are documented in the Audit and Review Report and are

summarized in SER Section 3.1B.2.3. The staff's evaluation of its technical review is also

documented in SER Section 3.1B.2.3.

Finally, the staff reviewed the AMP summary descriptions in the USAR supplement to ensure

that they provide an adequate description of the programs credited with managing or monitoring

aging for the reactor vessel, internals, and reactor coolant systems components.

Table 3.1B-1 below provides a summary of the staff's evaluation of NMP2 components, aging

effects and aging effects mechanisms , and AMPs listed in ALRA Section 3.1, that are

addressed in the GALL Report.

Table 3.1B-1 Staff Evaluation for NMP2 Reactor Vessel, Internals, and Reactor Coolant

Systems Components In the GALL Report

•Component Group, A gngEffectl AMP in GALL.ýrý- AMP in"ALRA Staff Evaluation" -. Mechanism ' Report.. _______-_. __ _' __. _______. _

Reactor coolant Cumulative fatigue TLAA, evaluated in TLAA This TLAA is

pressure boundary damage accordance with evaluated in Section

components 10 CFR 54.21(c) 4.3. Metal Fatigue

(Item Number Analysis

3.1.1.B-01)

Steam generator Loss of material Inservice Not applicable, PWR

shell assembly due to pitting and inspection; water only

(Item Number crevice corrosion chemistry

3.1.1.8-02)

Isolation condenser Loss of material Inservice Not applicable

(Item Number due to general, inspection; water (isolation condenser

3.1.1.8-03) pitting, and crevice chemistry does not exist - See

corrosion Section 3.1B.2.2.2)

Pressure vessel Loss of fracture TLAA, evaluated in TLAA This TLAA is

ferritic materials toughness due to accordance with evaluated in Section

that have a neutron neutron irradiation Appendix G of 4.2, Reactor Vessel

fluence greater than embrittlement 10 CFR 50 and Neutron

1017 n/cm2 RG 1.99 Embrittlement

(E > 1 MeV) Analysis

(Item Number

3.1.1.B-04)

Reactor vessel Loss of fracture Reactor vessel Reactor Vessel Consistent with

beltline shell and toughness due to surveillance Surveillance GALL, which

welds neutron irradiation Program (B2.1.19) recommends further

(Item Number embrittlement evaluation (See

3.1.1.B-05) Section 3.18.2.2.3)

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Component Group: ';'Aging Effect " AMP in GALL-.• AMP In ALRA Staff Evaluation

'Mechanism Report ______."__ _________:'______

Westinghouse and Loss of fracture Plant-specific Not applicable, PWR

B&W baffle/former toughness due to only

bolts neutron irradiation

(Item Number embrittlement and

3.1.1.1-06) void swelling

Small-bore reactor Crack Initiation and Inservice ASME Section XI Consistent with

coolant system and growth due to SCC, inspection; water Inservice Inspection GALL, which

connected systems intergranular SCC, chemistry; one-time (Subsections IWB, recommends further

piping and thermal and inspection IWC, IWD) Program evaluation (See

(Item Number mechanical loading (B2.1.1); Water Section 3.1B.2.2.4)

3.1.1.B-07) Chemistry Control

Program (B2.12);

One-Time

Inspection Program

(B2.1.20)

Jet pump sensing Crack initiation and Plant-specific ASME Section XI Consistent with

line, and reactor growth due to SCC, Inservice Inspection GALL, which

vessel flange leak intergranular stress (Subsections IWB, recommends further

detection line corrosion cracking IWC, IWD) Program evaluation (see

(Item Number (IGSCC), or cyclic (82.1.1); Water Section 3.1B.2.2.4)

3.1.1.8-08) loading Chemistry Control

Program (B2.1.2);

One-Time

Inspection Program

(B2.1.20)

Isolation condenser Crack initiation and Inservice Not applicable

(Item Number growth due to stress inspection; water (isolation condenser

3.1.1.B-09) corrosion cracking chemistry does not exist - (see

(SCC) or cyclic Section 3.1B.2.2.4))

loading

Vessel shell Crack growth due to TLAA Not applicable, PWR

(Item Number cyclic loading only

3.1.1.1-10)

Reactor internals Changes in Plant-specific Not applicable, PWR

(Item Number dimension due to only

3.1.1.8-11) void swelling

PWR core support Crack initiation and Plant-specific Not applicable, PWR

pads, instrument growth due to SCC only

tubes (bottom head and/or primary

penetrations), water stress

pressurizer spray corrosion cracking

heads, and nozzles (PWSCC)

for the steam

generator

instruments and

drains

(Item Number 3.1.1.8-12) _________ _________ _________ ____ _____

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'Component Group Aging Effect/ AMP In LL - AMP In ALRA ;.-Staff Evaluation

'Mechanism Report __________________

Cast austenitic Crack initiation and Plant-specific Not applicable, PWR

stainless steel growth due to SCC only

(CASS) reactor

coolant system

piping

(Item Number

3.1.1.B-13)

Pressurizer Crack initiation and Inservice Not applicable, PWR

instrumentation growth due to inspection; water only

penetrations and PWSCC chemistry

heater sheaths and

sleeves made of

Ni-alloys

(Item Number

3.1.1.3-14)

Westinghouse and Crack initiation and Plant-specific Not applicable, PWR

B&W baffle former growth due to SCC only

bolts and IASCC

(Item Number

3.1.1..B-15)

Westinghouse and Loss of preload due Plant-specific Not applicable, PWR

B&W baffle former to stress relaxation only

bolts

(Item Number

3.1.1..B-116)

Steam generator Loss of section Plant-specific Not applicable, PWR

feedwater thickness due to only

impingement plate erosion

and support

(Item Number

3.1.1..B-17)

(Alloy 600) Steam Crack initiation and Steam generator Not applicable, PWR

generator tubes, growth due to tubing integrity; only

repair sleeves, and PWSCC, outside water chemistry

plugs diameter stress

(Item Number corrosion cracking

3.1.1.B-18) (ODSCC), and/or

intergranular attack

(IGA) or loss of

material due to

wastage and pitting

corrosion, and

fretting and wear; or

deformation due to

corrosion at tube

support plate

intersections

Tube support lattice Loss of section Plant-specific Not applicable, PWR

bars made of thickness due to only

carbon steel FAC

(Item Number 3,1.1 .B-19) _________ _________ _________

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Component Group Aging Effectf AMP in GALL AMP in ALRA' -Staff Evaluation

M echaniSm R eport ..... .___... ..... ...... __

Carbon steel tube Ligament cracking Plant-specific Not applicable, PWR

support plate due to corrosion only

(Item Number

3.1.1.1-20)

Steam generator Loss of material Combustion Not applicable, PWR

feedwater inlet ring due to engineering (CE) only

and supports flow-corrosion steam generator

(Item Number feedwater ring

3.1.1..B-21) inspection

Reactor vessel Crack initiation and Reactor head Reactor Head Consistent with

closure studs and growth due to SCC closure studs Closure Studs GALL, which

stud assembly and/or IGSCC Program (12.1.3) recommends no

(Item Number further evaluation

3.1.1..B-22) (See Section ____ __ ____ __ ___ ___ ___ ___3.1B.2.1.1)

CASS pump casing Loss of fracture Inservice inspection ASME Section XI Consistent with

and valve body toughness due to Inservice Inspection GALL, which

(Item Number thermal aging (Subsections IWB, recommends no

3.1.1.B-23) embrittlement IWC, IWD) Program further evaluation

(B2.1.1) (See Section

3.11B.2.1)

CASS piping Loss of fracture Thermal aging Not applicable

(Item Number toughness due to embrittlement of (CASS piping does

3.1.1.8-24) thermal aging CASS not exist)

embrittlement

BWR piping and Wall thinning due to Flow-accelerated Flow Accelerated Consistent with

fittings; steam flow-accelerated corrosion Corrosion Program GALL, which

generator corrosion (82.1.9) recommends no

components further evaluation

(Item Number (See Section

3.1.1.B-25) 3.1B.2.1)

Not applicable, PWR

only

Reactor coolant Loss of material Bolting integrity Bolting Integrity Consistent with

pressure boundary due to wear, loss of Program (B2.1.36) GALL, which

(RCPB) valve preload due to recommends no

closure bolting, stress relaxation; further evaluation

manway and crack initiation and (See Section

holding bolting, and growth due to cyclic 3.1B.2.1)

closure bolting in loading and/or SCC

high pressure and Not applicable, PWR

high temperature only

systems

(Item Number

3.1.1.8-26)

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"Component Group Aging Effect/ AMP in GALL 'AMP inALRA - ::Staff Evaluation

"Mechanism Report ______.__________ ______________-__

Feedwater and Crack initiation and Feedwater nozzle; BWR Feedwater Consistent with

control rod drive growth due to cyclic CRD return line Nozzle Program GALL, which

(CRD) return line loading nozzle (B2.1.5), BWR recommends no

nozzles Control Rod Drive further evaluation

(Item Number Return Line (See Section

3.1.1.1-27) (CRDRL) Nozzle 3.1B.2.1.2)

Program (B2.1.37)

Vessel shell Crack initiation and BWR vessel ID Water Chemistry Consistent with

attachment welds growth due to SCC, attachment welds; Control Program GALL, which

(Item Number IGSCC water chemistry (B2.1.2), BWR recommends no

3.1.1.B-28) Vessel ID further evaluation

Attachment Welds (See Section

Program (B2.1A) 3.1B.2.1)

Nozzle safe ends, Crack initiation and BWR stress Water Chemistry Consistent with

recirculation pump growth due to SCC, corrosion cracking; Control Program GALL, which

casing, connected IGSCC water chemistry (B2.1.2), BWR recommends no

systems piping and Stress Corrosion further evaluation

fittings, body and Cracking Program (See Section

bonnet of valves (B2.1.6) 3.1B.2.1)

(Item Number

3.1.1.8-29)

Penetrations Crack initiation and BWR penetrations; Water Chemistry Consistent with

(Item Number growth due to SCC, water chemistry Control Program GALL, which

3.1.1.B-30) IGSCC, cyclic (B2.1.2), BWR recommends no

loading Penetrations further evaluation

Program (82.1.6) (See Section

3.18.2.1)

Core shroud and Crack initiation and BWR vessel Water Chemistry Consistent with

core plate, support growth due to SCC, internals; water Control Program GALL, which

structure, top guide, IGSCC, IASCC chemistry (B2.1.2), BWR recommends no

core spray lines and Vessel Internals further evaluation

spargers, jet pump Program (B2.1.8) (See Section

assemblies, control 3.1B.2.1)

rod drive housing,

nuclear

instrumentation

guide tubes

(Item Number

3.1.1.B-31)

Core shroud and Crack initiation and ASME Section XI BWR Vessel Consistent with

core plate access growth due to SCC, inservice Internals Program GALL with

hole cover (welded IGSCC, IASCC inspection; water (B2.1.8), Water exceptions

and mechanical chemistry Chemistry Control

covers) Program (B2.1.2) Access hole cover is

(Item Number managed through

3.1.1.B-32) BWRVIP

Jet pump assembly Loss of fracture Thermal aging and BWR Vessel Consistent with

castings; orificed toughness due to neutron irradiation Internals Program GALL (see Section

fuel support thermal aging and embrittlement (B2.1.8) 3.1B.2.1.3)

(Item Number neutron irradiation

3.1.1.B-33) embrittlement

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Component Group"' Aging Effectil', AMP In GALL AMP In ALRA'ý Staff Evaluation

Mechanism Report. __" ___________. _ ____________.. _

Unclad top head Loss of material Inservice Water Chemistry Consistent with

and nozzles due to general, inspection; water ControlProgram GALL, which

(Item Number pitting, and crevice chemistry (82.1.2), ASME recommends no

3.1.1.8-34) corrosion Section XI, further evaluation

Inservice Inspection (See Section

(Subsections IWB, 3.11.2.1)

IWC, IWD) Program ____ ___ __ ___ ___ ___ ____ ___ _ _ ___ ___ ___ ___ (B2.1.1)

CRD nozzle Crack initiation and Ni-alloy nozzles and Not applicable, PWR

(Item Number growth due to penetrations; water only

3.1.1.B-35) PWSCC chemistry

Reactor vessel Crack initiation and Inservice Not applicable, PWR

nozzles safe ends growth due to cyclic inspection; water only

and CRD housing; loading, and/or SCC chemistry

reactor coolant and PWSCC

system components

(except CASS and

bolting)

(Item Number

3.1.1.8-36)

Reactor vessel Loss of fracture Thermal aging and Not applicable, PWR

internals CASS toughness due to neutron irradiation only

components thermal aging, embrittlement

(Item Number neutron irradiation

3.1.1.B-37) embrittlement, and

void swelling

External surfaces of Loss of material Boric acid corrosion Not applicable, PWR

carbon steel due to boric acid only

components in corrosion

reactor coolant

system pressure

boundary

(Item Number

3.1.1.B-38)

Steam generator Loss of material Inservice inspection Not applicable, PWR

secondary due to erosion only

manways and

handholds (CS)

(Item Number

3.1.1.8-39)

Reactor internals, Loss of material Inservice inspection Not applicable, PWR

reactor vessel due to wear only

closure studs, and

core support pads

(Item Number

3.1.1.1-40)

Pressurizer, integral Crack initiation and Inservice inspection Not applicable, PWR

support growth due to cyclic only

(Item Number loading

3.1.1.B-41)

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Component Group Aging Effect. '.'..'AMP. A-' In GALL:-' 'AMP In ALRA"•.•!: Staff Evaiuation

Mechanism "Report ________________ __-______________

Upper and lower Loss of preload due Inservice Not applicable, PWR

internals assembly to stress relaxation inspection; loose only

(Westinghouse) part and/or neutron

(Item Number noise monitoring

3.1.1.1-42)

Reactor vessel Loss of fracture PWR vessel Not applicable, PWR

internals in fuel toughness due to internals; water only

zone region [except neutron irradiation chemistry

Westinghouse and embrittlement, and

Babcock & Wilcox void swelling

(B&W) baffle bolts]

(Item Number

3.1.1 .B-43)

Steam generator Crack initiation and Inservice Not applicable, PWR

upper and lower growth due to SCC, inspection; water only

heads; tubesheets; PWSCC, IASCC chemistry

primary nozzles and

safe ends

(Item Number

3.1.1..B-44)

Vessel internals Crack initiation and PWR vessel Not applicable, PWR

(except growth due to SCC internals; water only

Westinghouse and and IASCC chemistry

B&W baffle former

bolts)

(Item Number

3.1.1 .B-45)

Reactor internals Loss of preload due Inservice Not applicable, PWR

(B&W screws and to stress relaxation inspection; loose only

bolts) part monitoring

(Item Number

3.1.1.B-46)

Reactor vessel Loss of material Reactor head Not applicable, PWR

closure studs and due to wear closure studs only

stud assembly

(Item Number

3.1.1.1-47)

Reactor internals Loss of preload due Inservice Not applicable, PWR

(Westinghouse to stress relaxation inspection; loose only

upper and lower part monitoring

internal assemblies;

CE bolts and tie

rods)

(Item Number

3.1.1.1-48)

The staffs review of the NMP2 component groups followed one of several approaches. One

approach, documented in SER Section 3.1B.2.1, discusses the staff's review of the AMR

results for components in the reactor vessel, internals, and reactor coolant systems that the

applicant indicated are consistent with the GALL Report and do not require further evaluation.

Another approach, documented in SER Section 3.1B.2.2, discusses the staffs review of the

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AMR results for components in the reactor vessel, internals, and reactor coolant systems that

the applicant indicated are consistent with the GALL Report and for which further evaluation is

recommended. A third approach, documented in SER Section 3.1 B.2.3, discusses the staff's

review of the AMR results for components in the reactor vessel, internals, and reactor coolant

systems that the applicant indicated are not consistent with, or not addressed in, the GALL

Report. The staff's review of AMPs that are credited to manage or monitor aging effects of the

reactor vessel, internals, and reactor coolant systems components is documented in SER

Section 3.0.3.

3.1B.2.1 AMR Results That Are Consistent with the GALL Report

Summary of Technical Information in the Amended Application' In ALRA Section 3.1.2.B, the

applicant identified the materials, environments, and AERMs. The applicant identified the

following programs that manage the aging effects related to the reactor vessel, internals, and

reactor coolant systems components:

* ASME Section XI Inservice Inspection (Subsections IWB, IWC, IWD) Program

" Water Chemistry Control Program

" Reactor Head Closure Studs Program

* BWR Vessel ID Attachment Welds Program

" BWR Feedwater Nozzle Program

" BWR Stress Corrosion Cracking Program

• BWR Penetrations Program

" BWR Vessel Internals Program

* Flow-Accelerated Corrosion Program

* Reactor Vessel Surveillance Program

" One-Time Inspection Program

" Systems Walkdown Program

" Bolting Integrity Program

" BWR Control Rod Drive Return Line (CRDRL) Nozzle Program

Staff Evaluation. In ALRA Tables 3.1.2.B-1 through 3.1.2.B-5, the applicant provided a

summary of AMRs for the reactor vessel, internals, and reactor coolant systems components,

and identified which AMRs it considered to be consistent with the GALL Report.

For component groups evaluated in the GALL Report for which the applicant has claimed

consistency with the GALL Report, and for which the GALL Report does not recommend further

evaluation, the staff performed an audit and review to determine whether the plant-specific

components contained in these GALL Report component groups were bounded by the GALL

Report evaluation.

The applicant provided a note for each AMR line item. The notes indicate how the information in

the tables aligns with the information in the GALL Report. The staff audited those AMRs with

Notes A through E, which indicate that the AMR is consistent with the GALL Report.

Note A indicates that the AMR line item is consistent with the GALL Report for component,

material, environment, and aging effect. In addition, the AMP is consistent with the AMP

identified in the GALL Report. The staff audited these line items to verify consistency with the

GALL Report and the validity of the AMR for the site-specific conditions.

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Note B indicates that the AMR line item is consistent with the GALL Report for component,

material, environment, and aging effect. In addition, the AMP takes some exceptions to the

AMP identified in the GALL Report. The staff audited these line items to verify consistency with

the GALL Report. The staff verified that the identified exceptions to the GALL AMPs had been

reviewed and accepted by the staff. The staff also determined whether the AMP identified by

the applicant was consistent with the AMP identified in the GALL Report and whether the AMR

was valid for the site-specific conditions.

Note C indicates that the component for the AMR line item, although different from, is

consistent with the GALL Report for material, environment, and aging effect. In addition, the

AMP is consistent with the AMP identified by the GALL Report. This note indicates that the

applicant was unable to find a listing of some system components in the GALL Report.

However, the applicant identified a different component in the GALL Report that had the same

material, environment, aging effect, and AMP as the component that was under review. The

staff audited these line items to verify consistency with the GALL Report. The staff also

determined whether the AMR line item of the different component was applicable to the

component under review and whether the AMR was valid for the site-specific conditions.

Note D indicates that the component for the AMR line item, although different from, is

consistent with the GALL Report for material, environment, and aging effect. In addition, the

AMP takes some exceptions to the AMP identified in the GALL Report. The staff audited these

line items to verify consistency with the GALL Report. The staff verified whether the AMR line

item of the different component was applicable to the component under review. The staff

verified whether the identified exceptions to the GALL AMPs had been reviewed and accepted

by the staff. The staff also determined whether the AMP identified by the applicant was

consistent with the AMP identified in the GALL Report and whether the AMR was valid for the

site-specific conditions.

Note E indicates that the AMR line item is consistent with the GALL Report for material,

environment, and aging effect, but a different aging management program is credited. The staff

audited these line items to verify consistency with the GALL Report. The staff also determined

whether the identified AMP would manage the aging effect consistent with the AMP identified

by the GALL Report and whether the AMR was valid for the site-specific conditions.

The staff conducted an audit and review of the information provided in the ALRA, as

documented in the Audit and Review Report. The staff did not repeat its review of the matters

described in the GALL Report; however, the staff did verify that the material presented in the

ALRA was applicable and that the applicant identified the appropriate GALL Report AMRs. The

staff's evaluation is discussed below.

3.1B.2.1.1 Crack Initiation and Growth Due to SCC and/or IGSCC

In the discussion section of ALRA Table 3.1.1 .B, Item 3.1.1 .B-22 the applicant stated that the

Reactor Head Closure Studs Program is credited for closure head studs and nuts that have an

aging effect and aging effect mechanism of loss of material due to general corrosion. As

documented in the audit and review report, the staff noted that ALRA Table 3.1.1.B,

Item 3.1.1.B-22 applies to the aging effect and aging effect mechanism of cracking and asked

the applicant to provide clarification.

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In its letter dated December 1, 2005, the applicant revised the ALRA Table 3.1.1.B,

Item 3.1.1.8-22 discussion column by deleting the reference to managing loss of material and

crediting the aging effect and aging effect mechanism of crack initiation and growth due to

SCC. The staff found this revision consistent with the GALL Report and, therefore, acceptable.

The staff's review found that the applicant appropriately addressed the aging effect and aging

effect mechanism as recommended by the GALL Report.

3.1B.2.1.2 Crack Initiation and Growth Due to Cyclic Loading

In the discussion section of ALRA Table 3.1.1..B, Item 3.1.1..B-27, the applicant stated that for

feedwater nozzles NMP2 manages aging with the BWR Feedwater Nozzle Program, which is

consistent with GALL AMP XI.M5, "Feedwater Nozzle."

In the ALRA, the applicant stated that GALL AMP XI.M5 is credited also with managing

cracking of feedwater nozzle thermal sleeves due to SCC. Verification of the absence of nozzle

cracking provides proof that the thermal sleeve intended function is not degraded. For CRDRL

nozzles NMP2 manages aging with the BWR CRDRL Nozzle Program, which is consistent with

GALL AMP XI.M6, "BWR Control Rod Drive Return Line Nozzle." GALL AMP XI.M6 is credited

also with managing cracking of CRD return line nozzle thermal sleeves due to SCC. The

applicant stated that verification of the absence of nozzle cracking proves that the thermal

sleeve intended function is not degraded. In its letter dated September 15, 2005, the applicant

stated that its BWR Feedwater Nozzle and BWR CRDRL Nozzle Programs had been removed

as credited programs for the feedwater nozzle and CRDRL nozzle thermal sleeves. As

documented in the audit and review report, the staff asked the applicant to address the aging

management for the feedwater nozzle thermal sleeves. The applicant responded that it will use

inspections performed under the BWR Vessel Internals Program with surrogate components

more readily accessible for examination. For NMP2, the surrogate components are the

feedwater sparger end bracket welds. As documented in the audit and review report, the

applicant also provided its basis for choosing the feedwater sparger end bracket welds as

follows.

The applicant noted that a similar evaluation of the NMP1 feedwater sparger welds and the

selection of surrogate welds accessible for inspection also would be acceptable for NMP2.

These accessible welds would be used as a-leading indicator of potential IGSCC cracking of

the thermal sleeve. If cracking is found in these welds a supplemental evaluation of the thermal

sleeve integrity would be required.

The applicant stated that review of the NMP2 feedwater thermal sleeve and sparger had been

completed and had confirmed that the thermal sleeve material is 316L with several hidden

stainless steel welds. The fabrication method review, not complete, will determine the welding

procedures. If the hidden welds were stress relieved they would not be considered susceptible

to IGSCC and the aging effect of cracking would not be considered applicable to NMP2.

In addition, as documented in the audit and review report, the applicant stated that review of the

NMP2 feedwater sparger installation details found field installation of a 20,000 lbf load creating

a 0.125 inch cold spring to the sparger. The sparger end brackets were pinned, locking in the

cold spring, and then final field-welded with a fillet weld. The applicant stated further that this

installation detail is similar to that of NMP1. The r'esult of the cold spring is a fit-up net tensile

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stress superimposed on the weld residual stress. The combination of the fit-up stress (cold

spring) plus the residual stress of the field weld conditions and the fillet weld crevice geometry

is more susceptible to IGSCC than the thermal sleeve welds. The corrosion potential of reactor

water in the region of the feedwater sparger end bracket welds is equivalent to if not greater

than that of the reactor water in contact with the outside diameter weld of the thermal sleeve.

The applicant also stated that an EVT-1 examination of the NMP1 and NMP2 feedwater

sparger end bracket welds will be added to its BWR Vessel Internals Program as an

enhancement. The inspection extent and frequency of the end bracket weld inspection will be

the same as the ASME Section XI inspection of the feedwater sparger bracket vessel

attachment welds. If the final fabrication review of the NMP2 feedwater thermal sleeve

concludes that the hidden welds are not IGSCC-susceptible the NMP2 inspections will be

discontinued.

Furthermore, the applicant concluded that overall inspection of the NMP2 feedwater sparger

end bracket welds represents conservative inspection of the material condition of the hidden

thermal sleeve welds for potential IGSCC cracking. Therefore, consistent with the discussion

between the staff and the applicant, as documented in the audit and review report, cracking of

the NMP2 feedwater nozzle thermal sleeves will be managed by the applicant's BWR

Feedwater Nozzle, BWR Vessel Internals, and Water Chemistry Control Programs. In its letter

dated December 1, 2005, the applicant stated that it will add an EVT-1 examination of the

NMP2 feedwater sparger brackets as an enhancement to its BWR Vessel Internals Program to

address this issue. The staff reviewed the applicant's response and found it acceptable

because the applicant's surrogate weld inspection manages aging adequately for the feedwater

nozzle thermal sleeves.

The staffs review found that the applicant appropriately addressed the aging effect and aging

effect mechanism as recommended by the GALL Report.

3.1B.2.1.3 Loss of Fracture Toughness Due to Thermal Aging and Neutron Irradiation

Embrittlement

In the discussion section of ALRA Table 3.1.1..B, Item 3.1.1..B-33 the applicant stated that loss

of fracture toughness due to thermal aging and neutron irradiation embrittlement of jet pumps is

managed by BWRVIP-41, "BWR Jet Pump Assembly Inspection and Flaw Evaluation

Guidelines," of GALL AMP XI.M9, "BWR Vessel Internals Program." Aging management of the

orificed fuel supports is conducted according to BWRVIP-47, "BWR Lower Plenum Inspection

and Flaw Evaluation Guidelines," of GALL AMP XI.M9.

GALL AMP XI.M13, "Thermal Aging and Neutron Irradiation Embrittlement of Cast Austenitic

Stainless Steel," is credited for managing the aging effect and aging effect mechanism of loss

of fracture toughness due to thermal aging and neutron embrittlement. In its letter dated

November 17, 2005, the applicant revised its BWR Vessel Internals Program to address the

management of fracture toughness due to neutron fluence and thermal embrittlement for NMP

CASS components. The staffs review and evaluation of the applicant's BWR Vessel Internals

Program are documented in SER Section 3.0.3.2.6. The staff found the applicant's BWR Vessel

Internals Program acceptable for managing the loss of fracture toughness because the

applicant committed to meet the GALL AMP XI.M13 recommendation.

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The staffs review found that the applicant appropriately addressed the aging effect and aging

effect mechanism as recommended by the GALL Report.

Conclusion. The staff evaluated the applicant's claim of consistency with the GALL Report. The

staff also reviewed information pertaining to the applicant's consideration of recent operating

experience and proposals for managing associated aging effects. On the basis of its review, the

staff concludes that the AMR results, which the applicant claimed to be consistent with the

GALL Report, are consistent with the AMRs in the GALL Report. Therefore, the staff concludes

that there is reasonable assurance that the applicant has demonstrated that the effects of aging

for these components will be adequately managed so that their intended functions will be

maintained consistent with the CLB for the period of extended operation, as required by

10 CFR 54.21(a)(3).

3.1B.2.2 AMR Results That are Consistent with the GALL Report, for Which Further

Evaluation is Recommended

Summary of Technical Information in the Amended Application. In Section 3.1.2.C of its letter

dated August 19, 2005, the applicant provided further evaluation of aging management for

NMPNS as recommended by the GALL Report for the reactor vessel, internals, and reactor

coolant systems components. The applicant provided information concerning how it will manage

the following aging effects:

* cumulative fatigue damage

* loss of material due to pitting and crevice corrosion

* loss of fracture toughness due to neutron irradiation embrittlement

* crack initiation and growth due to thermal and mechanical loading or stress corrosion

cracking

* crack growth due to cyclic loading

* changes in dimension due to void swelling

* crack initiation and growth due to stress corrosion cracking or primary water stress

corrosion cracking

crack initiation and growth due to stress corrosion cracking or irradiation-assisted stress

corrosion cracking

* loss of preload due to stress relaxation

• loss of section thickness due to erosion

• crack initiation and growth due to PWSCC, ODSCC, or intergranular attack or loss of

material due to wastage and pitting corrosion or loss of section thickness due to fretting

and wear or denting due to corrosion of carbon steel tube support plate

• loss of section thickness due to flow-accelerated corrosion

" ligament cracking due to corrosion

• loss of material due to flow-accelerated corrosion

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Staff Evaluation. For component groups evaluated in the GALL Report for which the applicant

has claimed consistency with the GALL Report, and for which the GALL Report recommends

further evaluation, the staff audited and reviewed the applicant's evaluation to determine

whether it adequately addressed the issues that were further evaluated. In addition, the staff

reviewed the applicant's further evaluations against the criteria contained in SRP-LR

Section 3.1.2.2. Details of the staff s audit are documented in the staff's Audit and Review

Report. The staffs evaluation of the aging effects is discussed in the following sections.

3.1B.2.2.1 Cumulative Fatigue Damage

In Section 3.1.2.C.1 of its letter dated August 19, 2005, the applicant stated that fatigue is a

TLAA as defined in 10 CFR 54.3. Applicants must evaluate TLAAs according to

10 CFR 54.21(c)(1). SER Section 4.3 documents the staffs review of the applicant's evaluation

of this TLAA.

As documented in the audit and review report, the staff noted that for ALRA Table 3.1.2.A-2 (on

page 3.1-51), the fatigue damage of CRD assemblies (including drive mechanism and housing)

will be managed through the TLAA but that in ALRA Appendix B, Aging management program

and activities (page B2-25), the applicant stated that there are no TLAAs. The staff asked the

applicant to explain how the specified NMP1 components are managed. The applicant

responded that the only NMPI reactor vessel internals (RVI) components with calculations or

analyses meeting TLAA criteria are the core shroud tie rod assemblies, the clamps, and the

CRD assemblies (including drive mechanism and housing). The tie rod assemblies and clamps

are repairs for horizontal and vertical core shroud welds on which ASME Ill-type stress and

fatigue analyses were performed during the design process. The pressure boundary portion of

the CRD assemblies was evaluated for fatigue. A cumulative usage factor was determined for

the CRD penetration including the stub tube, CRD housing, and the stub tube-to-vessel weld

and housing-to-stub tube weld. The AMR for the stub tube is addressed in ALRA Table 3.1.2.A.

The applicant also responded that for RVI components with no analysis meeting TLAA criteria

the "Aging Management Program" column of ALRA Table 3.1.2.A-2 will be modified to replace

"TLAA evaluated according to 10 CFR 54.21(c)" with "None." A plant-specific note referencing

the relevant BWRVIP Inspection and Evaluation guideline or other basis for not managing

fatigue will be added to ALRA Table 3.1.2.A-2 for each component with "None" in the AMP

column for the aging effect and aging effect mechanism of cumulative fatigue damage or where

the TLAA is applicable only to a subset of the component type.

In its letter dated December 1, 2005, the applicant responded by revising ALRA Table 3.1.2.A-2

and Table 3.1.2.B-2 to address this issue. The staff determined that a high cumulative fatigue

usage factor indicates a high potential for crack initiation. Although the applicant's response

removed the aging effect of cumulative fatigue damage for those components identified in the

December 1, 2005, letter, the aging effect of cracking is adequately managed through other

AMPs. Therefore, the staff found the response acceptable.

The staffs review of the applicant's response found its action consistent with the GALL Report

and therefore acceptable.

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3.1B.2.2.2 Loss of Material Due to Pitting and Crevice Corrosion

The staff reviewed Section 3.1.2.C.2 of the applicant's letter dated August 19, 2005, against the

criteria of SRP-LR Section 3.1.2.2.2.

The applicant stated in Section 3.1.2.C.2 of its letter dated August 19, 2005 that the aging

effect and aging effect mechanism of pitting and crevice corrosion are not applicable to the

PWR steam generator shell assembly. The staff determined that the aging effect and aging

effect mechanism of PWR steam generator shell assembly pitting and crevice corrosion are not

applicable to NMP.

Because NMP has no components from this group the staff found this aging effect and aging

effect mechanism not applicable to NMP.

In addition the staff reviewed 10 CFR 3.1.2.C.2 of the applicant's letter dated August 19, 2005,

against the criteria of SRP-LR 10 CFR 3.1.2.2.2.

In Section 3.1.2.C.2 of its letter dated August 19, 2005, the applicant also addressed loss of

material due to isolation condenser components due to general pitting and crevice corrosion.

The applicant stated in the August 19, 2005, letter that NMP2 has no isolation condensers;

therefore this aging effect and aging effect mechanism are not applicable to NMP2.

Because NMP2 has no isolation condensers the staff found this aging effect and aging effect

mechanism not applicable to NMP2.

3.18.2.2.3 Loss of Fracture Toughness Due to Neutron Irradiation Embrittlement

The staff reviewed Section 3.1.2.C.3 of the applicant's letter dated August 19, 2005, against the

criteria of SRP-LR Section 3.1.2.2.3.

In Section 3.1.2.C.3 of its letter dated August 19, 2005, the applicant addressed loss of fracture

toughness due to neutron irradiation embrittlement of the reactor vessel.

SRP-LR Section 3.1.2.2.3 states that certain aspects of neutron irradiation embrittlement are

TLAAs as defined in 10 CFR 54.3 and must be evaluated according to 10 CFR 54.21(c)(1).

SER Section 4.2 documents the staffs review of the applicant's evaluation of this TLAA.

SRP-LR Section 3.1.2.2.3 states that loss of fracture toughness due to neutron irradiation

embrittlement could occur in the reactor vessel.

The Reactor Vessel Surveillance Program monitors neutron irradiation embrittlement of the

reactor vessel. The staff review and evaluation of the applicant's Reactor Vessel Surveillance

Program are documented in SER 10 CFR 3.0.3.2.16.

In ALRA Table 3.1.2.B-1 the applicant stated that loss of fracture toughness of vessel shells

(beltine, lower shell, upper nozzle shell, and upper RPV shell and vessel shell welds (including

attachment welds) will be managed by its Reactor Vessel Surveillance Program. The staff

asked the applicant to clarify which areas have neutron fluence exceeding 1E17 n/cm2

(E> 1 MeV).

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The applicant responded that vessel shells -beltline and vessel shells - lower and the beltline

welds have a neutron fluence exceeding 1 E17 n/cm2. The applicant's Reactor Vessel

Surveillance Program manages aging of these components. The component type attachment

welds needs no management by the applicant's Reactor Vessel Surveillance Program because

even though these welds receive a neutron fluence equal to or greater than El 7 n/cm 2 they are

not ferritic material. The only carbon/low alloy steel attachment welds are the steam dryer

holddown bracket attachment welds in the upper head which are low-fluence welds. The

applicant modified ALRA Table 3.1.2.B-1 to show those components managed by the Reactor

Vessel Surveillance Program. In its letter dated December 1, 2005, the applicant revised ALRA

Table 3.1.2.B-1 to address this issue. The staff reviewed the applicant's letter and found this

revision consistent with the GALL Report and, therefore, acceptable.

In ALRA Table 3.1.2.B-1 the applicant stated that loss of fracture toughness of nozzles will be

managed by its Reactor Vessel Surveillance Program. The staff asked the applicant to clarify

which nozzles will be managed by the Reactor Vessel Surveillance Program.

As documented in the audit and review report, the applicant responded that LPCI/residual heat

removal (RHR) nozzles and water level nozzle will be managed by the Reactor Vessel

Surveillance Program. Activities of the Reactor Vessel Surveillance Program include an

analysis of these nozzles for pressure-temperature (P-T) limits considering the projected

fluence for 54 effective full-power years (EFPYs) for them. In its letter dated December 1, 2005,

the applicant added a plant-specific Note 76 to ALRA Table 3.1.2.B-1 to specify those

components managed by the Reactor Vessel Surveillance Program. The staff found this note

consistent with the GALL Report and therefore acceptable.

SRP-LR Section 3.1.2.2.3 states that loss of fracture toughness due to neutron irradiation

embrittlement and void swelling could occur in Westinghouse and B&W baffle/former bolts.

In Section 3.1.2.C.3 of its letter dated August 19, 2005, the applicant stated that this item

pertains to PWR baffle/former bolts only and is not applicable to NMP.

Because NMP has no components in this group the staff found that this aging effect and aging

effect mechanism not applicable.

The staff concludes that the applicant's programs have met the criteria of SRP-LR

Section 3.1.2.2.3. For those line items addressed in Section 3.1.2.C.3 of the applicant's letter

dated August 19, 2005, the staff determined that the applicant has demonstrated consistent

with the GALL Report that aging effects will be adequately managed so that intended functions

will be maintained consistent with the CLB during the period of extended operation as required

by 10 CFR 54.21(a)(3).

3.1B.2.2.4 Crack Initiation and Growth Due to Thermal and Mechanical Loading or Stress

Corrosion Cracking

The staff reviewed Section 3.1.2.C.4 of the applicant's letter dated August 19, 2005 against the

criteria of SRP-LR Section 3.1.2.2.4.

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In Section 3.1.2.C.4 of its letter dated August 19, 2005, the applicant addressed crack initiation

and growth due to thermal and mechanical loading or SCC (including IGSCC) that could occur

in small-bore reactor coolant systems and connected system piping less than NPS 4.

SRP-LR Section 3.1.2.2.4.1 states that crack initiation and growth due to thermal and

mechanical loading or SCC (including IGSCC) could occur in small-bore reactor coolant

systems and connected system piping less than NPS 4. The program relies on ASME

Section XI ISI and on control of water chemistry to mitigate SCC. The GALL Report

recommends a plant-specific destructive examination or a NDE that permits inspection of the

inside surfaces of the piping to ensure that cracking has not occurred and that component

intended function will be maintained during the extended period. The AMPs should be

augmented by confirming that service-induced weld cracking has not occurred in small-bore

piping less than NPS 4 including pipe, fittings, and branch connections. A one-time inspection

of a sample of locations is an acceptable method to ensure that the aging effect and aging

effect mechanism are not occurring and that the component's intended function will be

maintained during the period of extended operation.

In Section 3.1.2.C.4 of its letter dated August 19, 2005, the applicant also stated that for NMP2

aging of the subject small-bore piping is managed by the ASME Section XI (Subsections IWB,

IWC, and IWD) ISI Program, Water Chemistry Control Program, and One-Time Inspection

Program.

Additionally the applicant stated in Section 3.1.2.C.4 of its letter dated August 19, 2005, that for

NMP2 reactor vessel instrumentation, reactor recirculation, and CRD systems not part of its

ASME Section XI (Subsections IWB, IWC, and IWD) ISI Program NMP credits only its Water

Chemistry Control and One-Time Inspection Programs to manage aging.

The applicant further stated in Section 3.1.2.C.4 of its letter dated August 19, 2005, that for the

small-bore piping included in the ASME Section XI (Subsections IWB, IWC, and IWD) ISI

Program or not the inspections of the One-Time Inspection Program will use either NDE

methods with a demonstrated capability to detect cracks on the inside surfaces of the piping or

destructive examinations. Both nondestructive and destructive examinations will be performed

on a piping sample.

The staff reviewed the applicant's ISI plan and One-Time Inspection Program and found them

adequate to managed this cracking issue and consistent with the GALL Report ,

recommendation. The staff's evaluations of the applicant's ASME Section XI (Subsections IWB,

IWC, and IWD) ISI, Water Chemistry Control, and One-Time Inspection Programs are

documented in SER Sections 3.0.3.2.1, 3.0.3.2.2, and 3.0.3.1.4, respectively.

In addition the staff reviewed Section 3.1.2.C.4 of the applicant's letter dated August 19, 2005,

against the criteria of SRP-LR Section 3.1.2.2.4.

Also in Section 3.1.2.C.4 of its letter dated August 19, 2005, the applicant addressed crack

initiation and growth due to thermal and mechanical loading or SCC (including IGSCC) that

could occur in the BWR reactor vessel flange leak detection line and BWR jet pump sensing

line.

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SRP-LR Section 3.1.2.2.4 also states that crack initiation and growth due to thermal and

mechanical loading or SCC (including IGSCC) could occur in the BWR reactor vessel flange

leak detection line and the BWR jet pump sensing line. The GALL Report recommends that a

plant-specific aging management program be evaluated to mitigate or detect crack initiation and

growth due to SCC of vessel flange leak detection line.

The applicant stated in its letter dated August 19, 2005, that for NMP1 and NMP2 cracking of

the vessel flange leak detection lines is managed by the ASME Section Xl (Subsections IWB,

IWC, and IWD) ISI Program, One-Time Inspection Program, and Water Chemistry Control

Program. The inspections conducted under the applicant's One-Time Inspection Program will

use either NDE methods with a demonstrated capability to detect cracks on the inside surfaces

of the piping or destructive examinations. Both nondestructive and destructive examinations will

be performed on a piping sample. A portion of the NMP2 vessel flange leak detection line is

carbon steel not subject to cracking. The applicant stated that loss of material of the carbon

steel portion is managed by its Water Chemistry Control and One-Time Inspection Programs.

The applicant also stated in its letter dated August 19, 2005, that for NMP2 the jet pump

sensing lines are not within the scope of license renewal; therefore, the aging effect and aging

effect mechanism of cracking for jet pump sensing lines is not applicable at NMP.

The staff reviewed the applicant's piping and instrument drawings (P&ID) and ISI plan to

determine whether the applicant's program is adequate and consistent with the GALL Report

recommendation.

The staff's review and evaluation of the applicant's ASME Section XI (Subsections IWB, IWC,

and IWD) ISI, Water Chemistry Control and One-Time Inspection Programs are documented in

SER Sections 3.0.3.2.1, 3.0.3.2.2, and 3.0.3.1.4, respectively.

Furthermore, the staff reviewed Section 3.1.2.C.4 of the applicant's letter dated August19,

2005, against the criteria of SRP-LR Section 3.1.2.2.4.

Also in Section 3.1.2.C.4 of its letter dated August 19, 2005, the applicant addressed crack

initiation and growth due to thermal and mechanical loading or SCC (including IGSCC) that

could occur in BWR isolation condenser components.

The applicant stated in its August 19, 2005, letter that NMP2 has no isolation condensers;

therefore, this aging effect and aging effect mechanism is not applicable to NMP2.

Because NMP2 has no isolation condensers the staff found this aging effect and aging effect

mechanism not applicable to NMP2.

The staff concludes that there is reasonable assurance that the applicant's programs have met

the criteria of SRP-LR Section 3.1.2.2.4. For those line items addressed in Section 3.1.2.C.4 of

the applicant's letter dated August 19, 2005, the staff determined that the applicant has

demonstrated that the effects of aging will be adequately managed consistent with the GALL

Report and that intended functions will be maintained consistent with the CLB during the period

of extended operation as required by 10 CFR 54.21(a)(3).

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3.1B.2.2.5 Crack Growth due to Cyclic Loading

The staff reviewed Section 3.1.2.C.5 of the applicant's letter dated August 19, 2005, against the

criteria in SRP-LR Section 3.1.2.2.5.

In Section 3.1.2.C.5 of letter dated August 19, 2005, the applicant stated that this aging effect

applies to PWRs only.

SRP-LR Section 3.1.2.2.5 states that crack growth due to cyclic loading could occur in the

reactor vessel shell and the reactor coolant system piping and fittings. SRP-LR Table 3.1-1

states that further evaluation for this aging effect is only applicable to PWR plants.

The staff found that this aging effect is not applicable to NMP2.

3.1B.2.2.6 Changes in Dimension due to Void Swelling

The staff reviewed Section 3.1.2.C.6 of the applicant's letter dated August 19, 2005, against the

criteria in SRP-LR Section 3.1.2.2.6.

In Section 3.1.2.C.6 of letter dated August 19, 2005, the applicant stated that this aging effect

applies to PWRs only.

SRP-LR Section 3.1.2.2.6 states that changes in dimension due to void swelling could occur in

reactor internal components. SRP-LR Table 3.1-1 states that further evaluation for this aging

effect is only applicable to PWR plants.

The staff found that this aging effect is not applicable to NMP2.

3.1B.2.2.7 Crack Initiation and Growth due to Stress Corrosion Cracking or Primary Water

Stress Corrosion Cracking

The staff reviewed Section 3.1.2.C.7 of the applicant's letter dated August 19, 2005, against the

criteria in SRP-LR Section 3.1.2.2.7.

In Section 3.1.2.C.7 of letter dated August 19, 2005, the applicant stated that this aging effect

applies to PWRs only.

SRP-LR Section 3.1.2.2.7 states that crack initiation and growth due to SCC and PWSCC could

occur: (1) in PWR core support pads (or core guide lugs), instrument tubes (bottom head

penetrations), pressurizer spray heads, and nozzles for the steam generator instruments and

drains; (2) in PWR CASS reactor coolant system piping and fittings and pressurizer surge line

nozzles; and (3) in PWR pressurizer instrumentation penetrations and heater sheaths and

sleeves made of Ni alloys. SRP-LR Table 3.1-1 states that further evaluation for this aging

effect is only applicable to PWR plants.

The staff found that this aging effect is not applicable to NMP2.

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3.18.2.2.8 Crack Initiation and Growth due to Stress Corrosion Cracking or Irradiation-Assisted

Stress Corrosion Cracking

The staff reviewed Section 3.1.2.C.8 of the applicant's letter dated August 19, 2005, against the

criteria in SRP-LR Section 3.1.2.2.8.

In Section 3.1.2.C.8 of letter dated August 19, 2005, the applicant stated that this aging effect

applies to PWRs only.

SRP-LR Section 3.1.2.2.8 states that crack initiation and growth due to SCC or IASCC could

occur in baffle/former bolts in Westinghouse and B&W reactors. SRP-LR Table 3.1-1 states

that further evaluation for this aging effect is only applicable to PWR plants.

The staff concurs that this aging effect is not applicable to NMP2.

3.1 B.2.2.9 Loss of Preload due to Stress Relaxation

The staff reviewed Section 3.1.2.C.9 of the applicant's letter dated August 19, 2005, against the

criteria in SRP-LR Section 3.1.2.2.9.

In Section 3.1.2.C.9 of letter dated August 19, 2005, the applicant stated that this aging effect

applies to PWRs only.

SRP-LR Section 3.1.2.2.9 states that loss of preload due to stress relaxation could occur in

baffle/former bolts in Westinghouse and B&W reactors. SRP-LR Table 3.1-1 states that further

evaluation for this aging effect is only applicable to PWR plants.

The staff found that this aging effect is not applicable to NMP2.

3.1B.2.2.10 Loss of Section Thickness due to Erosion

The staff reviewed Section 3.1.2.C.10 of the applicant's letter dated August 19, 2005, against

the criteria in SRP-LR Section 3.1.2.2.10.

In Section 3.1.2.C.10 of letter dated August 19, 2005, the applicant stated that this aging effect

applies to PWRs only.

SRP-LR Section 3.1.2.2.10 states that loss of section thickness due to erosion could occur in

steam generator feedwater impingement plates and supports. SRP-LR Table 3.1-1 states that

further evaluation for this aging effect is only applicable to PWR plants.

The staff found that this aging effect is not applicable to NMP2.

3.1B.2.2.11 Crack Initiation and Growth due to PWSCC, ODSCC, or Intergranular Attack or

Loss of Material due to Wastage and Pitting Corrosion or Loss of Section Thickness due to

Fretting and Wear or Denting due to Corrosion of Carbon Steel Tube Support Plate

The staff reviewed Section 3.1.2.C.1 1 of the applicant's letter dated August 19, 2005, against

the criteria in SRP-LR Section 3.1.2.2.11.

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In Section 3.1.2.C.1 1 of letter dated August 19, 2005, the applicant stated that this aging effect

applies to PWRs only.

SRP-LR Section 3.1.2.2.11 states that crack initiation and growth due to PWSCC, ODSCC, or

IGA or loss of material due to wastage and pitting corrosion or deformation due to corrosion

could occur in alloy 600 components of the steam generator tubes, repair sleeves and plugs.

SRP-LR Table 3.1-1 states that further evaluation for this aging effect is only applicable to PWR

plants.

Based on the above review, the staff found that this aging effect is not applicable to NMP2.

3.1B.2.2.12 Loss of Section Thickness due to Flow-accelerated Corrosion

The staff reviewed Section 3.1.2.C.12 of the applicant's letter dated August 19, 2005, against

the criteria in SRP-LR Section 3.1.2.2.12.

In Section 3.1.2.C.12 of letter dated August 19, 2005, the applicant stated that this aging effect

applies to PWRs only.

SRP-LR Section 3.1.2.2.12 states that loss of section thickness due to flow-accelerated

corrosion could occur in tube support lattice bars made of carbon steel. SRP-LR Table 3.1-1

states that further evaluation for this aging effect is only applicable to PWR plants.

The staff found that this aging effect is not applicable to NMP2.

3.18.2.2.13 Ligament Cracking due to Corrosion

The staff reviewed Section 3.1.2.C.13 of the applicant's letter dated August 19, 2005, against

the criteria in SRP-LR Section 3.1.2.2.13.

In Section 3.1.2.C.13 of letter dated August 19, 2005, the applicant stated that this aging effect

applies to PWRs only.

SRP-LR Section 3.1.2.2.13 states that ligament cracking due to corrosion could occur in carbon

steel components in the steam generator tube support plate. SRP-LR Table 3.1-1 states that

further evaluation for this aging effect is only applicable to PWR plants.

The staff found that this aging effect is not applicable to NMP2.

3.1B.2.2.14 Loss of Material due to Flow-accelerated Corrosion

The staff reviewed Section 3.1.2.C.14 of the applicant's letter dated August 19, 2005 against

the criteria in SRP-LR Section 3.1.2.2.14.

In Section 3.1.2.C.14 of letter dated August 19, 2005, the applicant stated that this aging effect

applies to PWRs only.

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SRP-LR Section 3.1.2.2.14 states that loss of material due to flow-accelerated corrosion could

occur in feedwater inlet ring and supports. SRP-LR Table 3.1-1 states that further evaluation for

this aging effect is only applicable to PWR plants.

The staff found that this aging effect is not applicable to NMP2.

3.1B.2.2.15 Quality Assurance for Aging Management of Nonsafety-Related Components

SER Section 3.0.4 includes the staffs evaluation of the applicant's quality assurance program.

Conclusion. On the basis of its review, for component groups evaluated in the GALL Report for

which the applicant has claimed consistency with the GALL Report, and for which the GALL

Report recommends further evaluation, the staff determined that the applicant adequately

addressed the issues that were further evaluated. The staff found that the applicant had

demonstrated that the effects of aging will be adequately managed so that the intended

functions will be maintained consistent with the CLB for the period of extended operation, as

required by 10 CFR 54.21(a)(3).

3.1B.2.3 AMR Results That Are Not Consistent with or Not Addressed in the GALL

Report

Summary of Technical Information in the Amended Application. In ALRA Tables 3.1.2.B-1

through 3.1.2.B-5, the staff reviewed additional details of the results of the AMRs for material,

environment, AERM, and AMP combinations that are not consistent with the GALL Report, or

that are not addressed in the GALL Report.

In ALRA Tables 3.1.2.B-1 through 3.1.2.8-5, the applicant indicated, via Notes F through J, that

the combination of component type, material, environment, and AERM does not correspond to

a line item in the GALL Report, and provided information concerning how the aging effect will

be managed. Specifically, Note F indicates that the material for the AMR line item component is

not evaluated in the GALL Report. Note G indicates that the environment for the AMR line item

component and material is not evaluated in the GALL Report. Note H indicates that the aging

effect for the AMR line item component, material, and environment combination is not evaluated

in the GALL Report. Note I indicates that the aging effect identified in the GALL Report for the

line item component, material, and environment combination is not applicable. Note J indicates

that neither the component nor the material and environment combination for the line item is

evaluated in the GALL Report.

Staff Evaluation. For component type, material, and environment combinations that are not

evaluated in the GALL Report, the staff reviewed the applicant's evaluation to determine

whether the applicant had demonstrated that the effects of aging will be adequately managed

so that the intended functions will be maintained consistent with the CLB during the period of

extended operation. The staff's evaluation is discussed in the following sections.

3.18.2.3.1 Reactor Vessel, Internals, and Reactor Coolant System - NMP2 Reactor Pressure

Vessel - Summary of Aging Management Evaluation - ALRA Table 3.1.2.8-1

The NMP2 RPV contains and supports the reactor core, reactor internals, and the reactor

coolant/moderator. The RPV forms part of the RCPB and serves as a barrier against leakage of

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radioactive materials to the drywell. The NMP2 RPV is a vertical, cylindrical pressure vessel

with hemispherical bottom and top heads. The cylindrical shell and top and bottom heads of the

RPV are fabricated from low-alloy steel, the interior of which is clad with stainless steel weld

overlay except for the top head and nozzle and nozzle weld zones. The RPV top head is

secured to the RPV by studs and nuts. The RPV flanges are sealed with two concentric metal

seal rings designed to permit no detectable leakage through the inner or outer seal at any

operating condition. The top head leak detection lines tap off of the vessel head between the

seal rings to detect leakage should the inner seal-ring fail.

The RPV is penetrated by various nozzles and the CRD housings and in-core instrumentation

thimbles are welded to the bottom head of the RPV. The concrete and steel vessel support

pedestal is constructed as part of the building foundation. Steel anchor bolts set in the concrete

extend through the bearing plate and secure the flange of the RPV support skirt to the bearing

plate and thus to the support pedestal.

Summary of Technical Information in the Application. The applicant's plant-specific AMRs for

the RPV components are identified in ALRA Table 3.1.2.8-1. By letter dated December 5, 2005,

in ALRA Table 3.1.2.B-1, the applicant identified the following RPV components with AMR

results that are not consistent with or not addressed in the GALL Report: "

" RPV core differential pressure and liquid control, CRD stub tube, drain lines, in-core

instruments, and instrumentation penetrations

* RPV support skirt and attachment welds

* RPV top head closure studs and nuts

* RPV top head leak detection lines

* RPV valves

The applicant identified the materials of fabrication for these RPV components as carbon steel

and low alloy steel. The applicant indicated that applicable environments for these RPV

components include containment air, non-borated water, and treated water (including steam).

The applicant credited the FAC Program with managing loss of material for the RPV core

differential pressure and liquid control, CRD stub tube, drain lines, in-core instruments, and

instrumentation penetrations. The ASME Section Xl (Subsections IWB, IWC, and IWD) ISI

Program is credited with the management of loss of material for the RPV support skirt and

attachment welds. The applicant credited the Reactor Head Closure Studs Program with

managing loss of material of the top head closure studs and nuts. The Water Chemistry Control

Program and the One-Time Inspection Program are credited with managing the loss of material

for the RPV top head leak detection lines and the RPV valves. In addition the applicant credited

TLAA 4.3, "Thermal Fatigue," with managing cumulative fatigue damage of the top head

closure studs and nuts and the top head leak detection lines.

Staff Evaluation. The staff reviewed ALRA Table 3.1.2.B-1 which summarizes the results of

AMR evaluations for the NMP2 RPV component groups. The staffs assessment of the RPV

components not consistent with or addressed in the GALL Report for NMP2 is provided below.

The assessments of the NMP2 RPV top head leak detection lines and the RPV valves are in

SER Section 3.1B.2.3.4.

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RPV Core Differential Pressure and Liquid Control, CRD Stub Tube,. Drain Lines, In-core

Instruments, and Instrumentation Penetrations

Identification of Aging Effects - In ALRA Table 3.1.2.8-1, the applicant identified loss of material

due to FAC as an aging effect applicable to the RPV core differential pressure and liquid

control, CRD stub tube, drain lines, in-core instruments, and instrumentation penetrations

fabricated from carbon or low alloy steel exposed to a treated water or steam in a

high-temperature environment.

FAC is a phenomenon in which repetitive cycles of corrosion and erosion cause wall thinning of

carbon steel or low-alloy steel components exposed to high-temperature, high-velocity water or

water/steam environments. Normally, FAC occurs only with environmental temperatures above

200 OF. The rate of metal loss depends on a complex interplay of such parameters as water

chemistry, material composition, and hydrodynamics.

The staff determined that the applicant adequately identified loss of material due to FAC as an

AERM for the RPV core differential pressure and liquid control, CRD stub tube, drain lines,

in-core instruments, and instrumentation penetrations exposed to these environments. This

aging effect is not addressed in GALL Report Volume 2 for these component, material, and

environment combinations; therefore, the staff concludes that this AERM is acceptable because

it is conservative relative to GALL Report Volume 2 and consistent with the EPRI Report,

"Recommendations for an Effective Flow-Accelerated Corrosion Program."

Aging Management Programs - In ALRA Table 3.1.2.B-1 the applicant credited the FAC

Program with managing loss of material due to FAC for the RPV core differential pressure and

liquid control, CRD stub tube, drain lines, in-core instruments, and instrumentation penetrations.

Even though GALL Report Volume 2 does not address an AMP for such component, material,

and environment combinations, it does recommend crediting the FAC Program with managing

FAC-induced wall thinning of carbon steel piping and fitting components. The staff found the

applicant's proposal conservative relative to GALL Report Volume 2 and, therefore, acceptable.

The applicant's FAC Program (ALRA AMP B2.1.9) is entirely consistent with GALL

AMP XI.M17. The staff's evaluation of the FAC Program is in SER Section 3.0.3.1.3.

RPV Support Skirt and Attachment Welds

Identification of Aging Effects- In ALRA Table 3.1.2.8-1 and by letter dated December 5, 2005,

the applicant identified loss of material due to general corrosion as an applicable aging effect

for the RPV support skirt and attachment welds fabricated from carbon or low alloy steel and

exposed to an environment of "air with thermal fatigue." The applicant's definition of "air with

thermal fatigue" is "this environment is applied to components exposed to air, that are also

subject to thermal cycles of sufficient magnitude for thermal fatigue to be a concern." The air

environment is the containment air surrounding the RPV and the support skirt.

GALL Report Volume 2 does not identify loss of material due to general corrosion as an aging

effect in carbon and low alloy steel when these materials are exposed to an environment of

containment air; however, carbon and low alloy steel may rust or corrode in the presence of air

with an elevated humidity level. The staff found that the applicant has addressed this issue

conservatively; therefore, the staff found the applicant's identification of this AERM acceptable

for the RPV support skirt and attachment welds.

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Aging Management Programs - In ALRA Table 3.1.2.B-1 the applicant credited the ASME

Section Xl (Subsections IWB, IWC, and IWD) ISl Program with managing loss of material due

to general corrosion for the RPV support skirt. By letter dated November 22, 2005, the staff

requested that the applicant address why the ASME Section XI (Subsections IWB, IWC, and

IWD) ISI Program was credited with managing loss of material due to general corrosion in the

RPV support skirt. Instead, the staff recommended that this aging effect in the RPV support

skirt be managed by the ASME Section Xl (Subsection IWF) ISI Program because the RPV

support skirt is an ASME Class MC support. By letter dated December 5, 2005, the applicant

revised Table 3.1.2.B-1 to indicate that the AERM of loss of material of the RPV support skirt

would be managed by the ASME Section Xl (Subsection IWF) ISI Program. The staff found the

applicant's response acceptable because the RPV support skirt is an ASME Class MC

component, and, therefore, is managed appropriately by the ASME Section XI (Subsection

IWF) ISI Program.

By letter dated December 5, 2005, the applicant indicated that it credits the ASME Section Xl

(Subsections IWB, IWC, and IWD) ISI Program with managing the loss of material due to

general corrosion in the RPV attachment welds.

The GALL Report Volume 2 does not identify any AMPs for managing loss of material due to

general corrosion for these component, material, and environment combinations. The staff

found the applicant's proposal conservative relative to the GALL Report Volume 2 and,

therefore, acceptable. The applicant's ASME Section Xl (Subsections IWB, IWC, and IWD) ISI

Program is an AMP consistent with GALL AMP XI.M1 with exceptions. The staff's evaluation of

the ASME Section Xl (Subsections IWB, IWC, and IWD) ISI Program is in SER

Section 3.0.3.2.1. The applicant's ASME Section Xl (Subsection IWF) ISI Program is an AMP

consistent with GALL AMP XI.S3 with exceptions. The staff's evaluation of the ASME

Section Xl (Subsection IWF) ISI Program is in SER Section 3.0.3.2.19.

RPV Top Head Closure Studs and Nuts

Identification of Aging Effects - In ALRA Table 3.1.2.B-1, the applicant identified loss of material

due to general, crevice, and pitting corrosion as an aging effect applicable to the RPV top head

closure studs and nuts fabricated from carbon or low alloy steel and exposed to an environment

of non-borated water systems with operating temperatures > 212 *F.

The GALL Report Volume 2 identifies crack initiation and growth, SCC and IGSCC as aging

effects for RPV top head enclosure closure studs and nuts fabricated from carbon or low alloy

steel exposed to air, leaking reactor coolant water, or steam at 288 °C, but does not identify loss

of material due to general, crevice, and pitting corrosion as aging effects in carbon and low

alloy steel when exposed to leakage of non-borated reactor coolant or steam. However, carbon

and low alloy steel may rust or corrode when exposed to aqueous liquids. The staff found that

the applicant has addressed this issue conservatively; therefore, the staff found the applicant's

identification of this AERM acceptable.

Also in ALRA Table 3.1.2.B-1, the applicant identified cumulative fatigue damage as an aging

effect applicable to the RPV top head closure studs and nuts because of thermal cycling from

heatup and cooldown and other transient operating conditions of these components. The staff

found this identification acceptable because it meets the provisions in of SRP-LR Revision 1

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Chapter 3.1 for assessing cumulative fatigue damage in ASME Code Class I components.

SER Section 4.3 contains the staffs assessment of those plant components requiring thermal

fatigue analyses for license renewal.

Aging Management Programs - In ALRA Table 3.1.2.B-1, the applicant credited the Reactor

Head Closure Studs Program with management of loss of material due to general, pitting, and

crevice corrosion for the RPV top head closure studs and nuts. Even though the GALL Report

Volume 2 does not address an AMP for these component, material, and environment

combinations, the staff found the applicant's proposal conservative relative to GALL Report

Volume 2 and, therefore, acceptable. The applicant's Reactor Head Closure Studs Program

(ALRA AMP B2.1.3) is an AMP consistent with exception to GALL AMP XI.M3. The staffs

evaluation of the Reactor Head Closure Studs Program is in SER Section 3.0.3.2.3.

In ALRA Table 3.1.2.1-1, the applicant proposed managing cumulative fatigue damage of the

RPV top head closure studs and nuts with the TLAA. This proposal is consistent with SRP-LR

Revision 1 and is, therefore, acceptable. The staffs evaluation of the applicant's TLAA on

thermal fatigue of ASME Code Class 1 components is in SER Section 4.3.

RPV Valves

The review of the RPV valves is in SER Section 3.1B.2.3.4.

Conclusion. The staff has reviewed the applicant's plant-specific AMRs for evaluating the RPV

components exposed to the containment air, non-borated water, and treated water (including

steam) environments. For these AMRs the staff has determined that the applicant has identified

aging effects applicable to these components that are exposed to these environments. The

staff also has determined that the applicant has credited either an appropriate inspection-based

AMP, an appropriate mitigation-based AMP, a TLAA, or combination of these strategies with

managing the aging effects applicable to the RPV components exposed to these environments.

The staffs review concludes that the applicant has demonstrated that the aging effects

associated with the NMP2 RPV will be adequately managed so that the intended functions will

be maintained consistent with the CLB for the period of extended operation as required by

10 CFR 54.21(a)(3).

3.1B.2.3.2 Reactor Vessel, Internals, and Reactor Coolant System - NMP2 Reactor Pressure

Vessel Internals - Summary of Aging Management Evaluation - ALRA Table 3.1.2.B-2

The NMP2 RPV internals support the core and other internal components, maintain fuel

configuration (coolable geometry) during normal operation and accident conditions, and provide

reactor coolant flow through the core. The main NMP2 RPV internals components are the

reactor core, core shroud, core shroud stabilizers, core shroud support structures, top guide,

CRD guide tubes, feedwater sparger, core spray spargers, steam dryer, and the jet pumps.

Except for the Zircaloy used in the fuel assemblies reactor internals are stainless steel or other

corrosion-resistant alloys.

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Summary of Technical Information in the Application. The applicant's plant-specific AMRs for

the RPV internals components are in ALRA Table 3.1.2.B-2. The specific RPV components for

NMP2 with AMR results not consistent with or addressed in the GALL Report and within the

scope of ALRA Table 3.1.2.B-2 include:

• core shroud head bolts

* core shroud support structures (bolts, brackets, cap screws, clamps, keepers, restraints,

and supports)

The applicant identified the materials of fabrication for the core shroud head bolts and the core

shroud support structures (including the bolts, brackets, clamps, keepers, restraints, and

supports) as nickel-based alloys. The material of fabrication for the cap screws is carbon or low

alloy steel. The applicant identified applicable environments for these RPV internals

components as treated water (including steam) environments of temperatures > 482 OF, treated

water or steam, high temperature with neutron fluences of < 5 x 1020 n/cm 2 (E > 1.0 MeV), and

treated water or steam high temperature with neutron fluences of_> 1 x 10i n/cm2

(E > 1.0 MeV).

The applicant credited the BWR Vessel Internals and the Water Chemistry Control Programs

with managing cracking of the core shroud head bolts and core shroud support structures. In

addition the applicant credited TLAA 4.3, "Thermal Fatigue," with managing cumulative fatigue

damage of the core shroud support structures.

Staff Evaluation. The staff reviewed ALRA Table 3.1.2.B-2, which summarizes the results of

AMR evaluations for the NMP2 RPV internal components. The staff s assessment of the RPV

internals components not consistent with or addressed in the GALL Report for NMP2 is

provided here.

RPV Internals - Core Shroud Head Bolts

Identification of Aging Effects - In ALRA Table 3.1.2.8-2 the applicant identified SCC or IGSCC

as an aging effect applicable to the core shroud head bolts fabricated from nickel-based alloys

and exposed to a treated water or steam temperature > 482 OF environment.

GALL Report Volume 2 does not identify SCC or IGSCC as an AERM for the core shroud head

bolts. However, as these components are made from materials identical to those of the

nickel-alloy RPV internal components that have AMR Commodity Group line items on

SCC/IGSCC in GALL Report Volume 2 the staff concludes that there is reasonable assurance

that the applicant's determination is consistent with the GALL Report Volume 2 for other RPV

internal components made from nickel-based alloy materials and acceptable.

Also in ALRA Table 3.1.2.B-2 the applicant identified cumulative fatigue damage as an aging

effect applicable to the core shroud head bolts because of thermal cycling from heatup,

cooldown, and other operating transient conditions of these components. The staff found this

identification acceptable because it meets the provisions in the SRP-LR Section 3.1 Revision 1

Report for assessing cumulative fatigue damage in RPV internal components. Refer to SER

Section 4.3 for the staffs assessment of plant components required to have thermal fatigue

analyses for license renewal.

3-229
Aging Management Programs - In ALRA Table 3.1.2.B-2 the applicant credited the BWR

Vessel Internals and the Water Chemistry Control Programs with aging management of

SCC/IGSCC of the core shroud head bolts. Even though GALL Report Volume 2 does not

address an AMP for such component, material, and environment combinations it does

recommend crediting the BWR Vessel Internals and Water Chemistry Programs with managing

SCC and IGSCC for stainless steel and nickel-alloy components (i.e., core shroud, core plate,

core plate bolts, holddown beams, etc). Therefore, the staff found the applicant's proposal

acceptable. The applicant's BWR Vessel Internals Program is an AMP entirely consistent with

GALL AMP XI.M9. The staff's evaluation of the BWR Vessel Internals Program is in SER

Section 3.0.3.2.6. The applicant's Water Chemistry Control Program is an AMP entirely

consistent with GALL AMP XI.M2. The staff's evaluation of the Water Chemistry Program is in

SER Section 3.0.3.2.2.

In ALRA Table 3.1.2.8-2 in ALRA Section 4.3 the applicant proposed using the TLAA for

managing cumulative fatigue damage of the core shroud head bolts. This proposal is consistent

with the NUREG-1800 Revision 1 Report and is, therefore, acceptable. The staffs evaluation of

the applicant's TLAA on thermal fatigue of RPV internal components is in SER Section 4.3.

RPV Internals Core Shroud Support Structures (bolts. cap screws, and supports)

Identification of Aging Effects - In ALRA Table 3.1.2.8-2, the applicant identified SCC or IGSCC

as an aging effect applicable to the core shroud support structures fabricated from carbon or

low alloy steels and nickel-based alloys that are exposed to treated water or steam, high

temperature with neutron fluences of < 5 x 1020 n/cm2 (E > 1.0 MeV).

The GALL Report Volume 2 does not identify SCC or IGSCC as an AERM for the RPV internals

core shroud support structures. Industry experience has not indicated that carbon steel or low

alloy steel materials are susceptible to SCC or IGSCC but that stainless steel and nickel-based

alloy materials are. The applicant has identified conservatively SCC/IGSCC as an aging effect

applicable to the carbon steel/low alloy steel core shroud support structures (i.e., the core

shroud support cap screws). Therefore, the staff concludes that there is reasonable assurance

that the applicant's determination is conservative relative to the AMR Commodity Group line

items in the GALL Report Volume 2 for RPV internal components made from stainless steel.

The staff also concludes that the applicant's identification of SCC/IGSCC for the nickel-based

core shroud support structures (i.e., the bolts and supports) is consistent with the AMR

Commodity Group line items in the GALL Report Volume 2 for RPV internal components made

from nickel-based alloy materials and acceptable.

Also in ALRA Table 3.1.2.B-2, the applicant identified cumulative fatigue damage as an aging

effect applicable to the core shroud support structures because of thermal cycling from heatup,

cooldown, and other operating transient conditions of these components. The staff found this

identification acceptable because it meets the provisions in the SRP-LR Chapter 3.1 Revision 1

Report for assessing cumulative fatigue damage in RPV internal components. Refer to SER

Section 4.3 for the staffs assessment of plant components required to have thermal fatigue

analyses for license renewal.

Aging Management Programs - In ALRA Table 3.1.2.B-2 the applicant credited the BWR

Vessel Internals and Water Chemistry Control Programs with aging management of

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SCC/IGSCC of the core shroud support structures. Even though the GALL Report Volume 2

does not address an AMP for such component, material, and environment combinations it does

recommend crediting the BWR Vessel Internals and WaterChemistry Programs with managing

SCC and IGSCC for RPV internal components (i.e., core shroud, core plate, core plate bolts,

holddown beams, etc). Therefore, the staff found the applicant's proposal acceptable. The

applicant's BWR Vessel Internals Program is an AMP entirely consistent with GALL

AMP XI.M9. The staff's evaluation of the BWR Vessel Internals Program is in SER

Section 3.0.3.2.6. The applicant's Water Chemistry Control Program is an AMP entirely

consistent with GALL AMP XI.M2. The staffs evaluation of the Water Chemistry Control

Program is in SER Section 3.0.3.2.2.

In ALRA Table 3.1.2.B-2 in ALRA Section 4.3 the applicant proposed using the TLAA for

managing cumulative fatigue damage of the RPV internals core shroud support structures. This

proposal is consistent with the SRP-LR Revision 1 and, therefore, acceptable. The staffs

evaluation of the applicant's TLAA on thermal fatigue of RPV internal components is in SER

Section 4.3.

Conclusion. The staff reviewed the applicant's plant-specific AMRs for evaluating the RPV

internals components exposed to the treated water (including steam) environments of

temperatures > 4820 F, treated water or steam high temperature with neutron fluences of

< 5 x 102" n/cm2 (E > 1.0 MeV), and treated water or steam high temperature with neutron

fluences of_> 1 x 1017 n/cm2 (E > 1.0 MeV) environments. For these AMRs the staff determined

that the applicant has identified the aging effects applicable to components that are exposed to

these environments. The staff has also determined that the applicant credited either an

appropriate inspection-based AMP, an appropriate mitigation-based AMP, a TLAA, or

combination of these strategies with managing the aging effects applicable to the RPV internal

components exposed to these environments. The staffs review concludes that the applicant

has demonstrated that the aging effects of NMP2 RPV internals will be adequately managed so

that the intended functions will be maintained consistent with the CLB for the period of extended

operation as required by 10 CFR 54.21 (a)(3).

3.1B.2.3.3 Reactor Vessel, Internals, and Reactor Coolant System - NMP2 Reactor Vessel

Instrumentation System - Summary of Aging Management Evaluation - ALRA Table 3.1.2.8-3

The NMP2 RPV instrumentation system monitors and transmits information about key RPV

operating parameters during normal and emergency operations., Instrumentation is installed to

monitor reactor parameters and indicate them on meters, chart recorders and hydraulic

indicator units located in the control room, on remote shutdown panels, and in instrument

rooms. The parameters monitored are RPV temperature, water level and pressure, and core

flow and core plate differential pressure. This system also provides control signals to various

systems which in turn initiate the appropriate actions required if the monitored parameter

exceeds its desired set point. Systems receiving control signals from the RPV instrumentation

system include the reactor protection, primary containment isolation, automatic

depressurization, feedwater control, reactor recirculation flow control, redundant reactivity

control, and RHR (shutdown cooling mode) systems. The RPV instrumentation system'consists

of piping, valves, and restricting orifices that provide a fluid path from the RPV to various

instrumentation.

3-231
Summary of Technical Information in the Application. The applicant's plant-specific AMRs for

the RPV instrumentation system components are in Table 3.1.2.B-3 of the ALRA. The specific

RPV components for NMP2 with AMR results not consistent with or addressed in the GALL

Report and within the scope of ALRA Table 3.1.2.B-3 include:

RPV instrumentation system closure bolting

RPV instrumentation system piping and fittings

The applicant identified materials of fabrication for these RPV instrumentation components as

martensitic, precipitation-hardenable, and superferritic stainless steels and carbon and low alloy

steels. The applicant identified applicable environments for these RPV instrumentation system

components as non-borated water systems with operating temperatures > 212 OF and treated

water or steam temperature > 482 OF (high temperature) environments.

The applicant credited the Bolting Integrity Program with managing cracking, loss of material,

and loss of preload of the RPV instrumentation system closure bolting. The applicant credited

the One-Time Inspection and the Water Chemistry Control Programs with managing loss of

material for the RPV instrumentation system piping and fittings.

Staff Evaluation. The staff reviewed ALRA Table 3.1.2.8-3, which summarizes the results of

AMR evaluations for the NMP2 RPV instrumentation system components. The staff's

assessment of the RPV instrumentation system components not consistent with or addressed

in the GALL Report for NMP2 is provided here. It should be noted that the assessment for the

NMP2 RPV instrumentation system piping and fittings is in SER Section 3.1B.2.3.4.

RPV Instrumentation System Closure Bolting

Identification of Aging Effects - In ALRA Table 3.1.2.B-3 the applicant identified SCC or IGSCC,

loss of material due to wear, and loss of preload due to thermal effects, gasket creep, and

self-loosening as aging effects applicable to RPV instrumentation system closure bolting

fabricated from martensitic, precipitation-hardenable, and superferritic stainless steels and

exposed to a non-borated water system with operating temperatures _> 212 OF environment (i.e.,

the reactor coolant or its steam environment).

The GALL Report Volume 2 does not identify these aging effects as applicable AERMs for

these components; however, as these components are made from materials similar to those for

the stainless steel RCPB closure bolting in high-pressure and high-temperature environments

identified in the GALL Report Volume 2; therefore, the staff concludes that there is reasonable

assurance that the applicant's determination is consistent with the AERMs identified in GALL

Report Volume 2 for RCPB closure bolting and found the applicant's determination acceptable.

Aging Management Programs - In ALRA Table 3.1.2.B-3 the applicant credited the Bolting

Integrity Program with aging management of SCC or IGSCC, loss of material due to wear, and

loss of preload due to thermal effects. Even though the GALL Report Volume 2 does not

address an AMP for such component, material, and environment combinations it does

recommend crediting the Bolting Integrity Program with managing SCC, loss of material due to

wear, loss of preload due to thermal effects, gasket creep, and self-loosening of stainless steel

RCPB pump and valve closure bolting in high-pressure and high-temperature systems.

Therefore, the staff finds the applicant's proposal acceptable. The applicant's Bolting Integrity

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Program is an AMP consistent with GALL AMP XI.M18 with exceptions. The staff's evaluation

of the Bolting Integrity Program is in SER Section 3.0.3.2.23.

Conclusion. The staff reviewed the applicant's plant-specific AMRs for evaluating the RPV

instrumentation system components exposed to non-borated water with operating temperatures

> 212 OF and treated water or steam temperature > 482 OF (high temperature) environments.

For these AMRs the staff determined that the applicant has identified aging effects applicable to

these components exposed to these environments. The staff also determined that the applicant

has credited either an appropriate inspection-based AMP, an appropriate mitigation-based

AMP, or combination of these strategies with managing aging effects applicable to the RPV

instrumentation system components exposed to these environments. The staff finds that the

applicant has demonstrated that the aging effects associated with the NMP2 RPV

instrumentation system components will be adequately managed so that the intended functions

will be maintained consistent with the CLB for the period of extended operation as required by

10 CFR 54.21(a)(3).

3.1B.2.3.4 Reactor Vessel, Internals, and Reactor Coolant System - NMP2 Reactor

Recirculation System - Summary of Aging Management Evaluation - ALRA Table 3.1.2.8-4

Summary of Technical Information in the Application. The description of the reactor

recirculation system, recirculation flow control, and the control of the reactor recirculation

pumps can be found in ALRA Section 2.3.11.1.4. Reactor recirculation system components

subject to AMR include the entire main reactor recirculation flow path which begins at the

suction nozzle and ends at the discharge manifold nozzles to the jet pump risers of each

recirculation loop for NMP2. SR instrument piping and associated components connected to the

recirculation loops are also subject to AMR. The components requiring an AMR for the reactor

recirculation system and their intended functions are shown in ALRA Table 2.3.1.8.4-1. The

AMR results for these components are shown in ALRA Table 3.1.2.B-4. The following

information pertains to the reactor recirculation system provided in the ALRA which the staff has

used in its evaluation.

The materials of construction are carbon or low alloy steel (yield strength < 100 Ksi and

> 100 Ksi), CASS, and wrought austenitic stainless steel including nickel-based alloys in piping

and fittings.

In ALRA Section 3.1.2.B.4 the applicant listed the following environments to Which NMP2

reactor recirculation system components are exposed:

• air

• closure bolting for non-borated water systems with operating temperatures > 212 OF

* hydraulic fluid

* treated water, temperature < 140°F

* treated water, temperature < 140 OF, low flow

* treated water, temperature > 140 OF, but < 212 OF

" treated water, temperature > 140 OF, but < 212 OF, low flow

* treated water or steam, temperature > 482 OF

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0 treated water or steam, temperature > 482 "F, low flow

The applicant identified the following aging effects associated with the NMP1 and NMP2

Reactor Recirculation System piping requiring management:

* cracking

* cumulative fatigue damage

* loss of fracture toughness

* loss of material

* loss of preload

The following AMPs manage these aging effects in the NMP2 reactor recirculation system

components:

* ASME Code Section Xl (Subsections IWB, IWC, IWD) ISI Program

• Bolting Integrity Program

* BWR Stress Corrosion Cracking Program

• One-Time Inspection Program

* Water Chemistry Control Program

Staff Evaluation. The applicant described its AMR for the reactor recirculation system in ALRA

Section 3.1. The staff reviewed this section to determine whether the applicant had identified all

the applicable aging effects for components in these systems and demonstrated that the aging

effects on the components will be adequately managed during the period of extended operation

as required by 10 CFR 54.21(a)(3). The staff also reviewed the USAR supplements for the

AMPs to ensure that the program descriptions adequately describe the AMPs.

The applicant identified the following aging effects for the reactor recirculation system:

* cracking

• cumulative fatigue damage

• loss of fracture toughness

* loss of material

* loss of preload

In ALRA Table 3.1.2.B-4 the applicant identified cracking and cumulative fatigue damage as

aging effects applicable to the recirculation system closure bolting, piping and fittings,

recirculation pumps, and valves. Cumulative fatigue damage is evaluated in SER Section 4.3,

"Metal Fatigue Analysis." The aging effect of loss of fracture toughness is associated with the

pressure boundary materials in reactor recirculation pumps and in CASS valves operating at or

above 480 0F. The loss of material has been identified as an aging effect in carbon or low alloy

steel or austenitic stainless steel with treated water environment operating below 140 OF for

such components as piping and fittings, valves, and restriction orifices in the reactor

recirculation system. The loss of preload is identified as the applicable aging effect in closure

bolting for non-borated water system operating at or above 212 °F. The staff noted that this

assessment is consistent with the GALL Report.

The applicant identified cracking as an aging effect applicable to the recirculation system

austenitic stainless steel components (piping and fittings, tubing, valve bodies, flow elements,

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thermowells, restricting orifices) and to the high-strength low-alloy steel primary pressure

closure bolting exposed to reactor coolant water. The applicant also identified this aging effect

for CASS components exposed to reactor coolant water. The applicant identified crack initiation

and growth due to thermal and mechanical loading as an aging effect applicable to small-bore

stainless steel piping and fittings and low-alloy steel pressure boundary closure bolting in the

reactor recirculation system. The staff noted that this assessment is consistent with the GALL

Report. The staff requested confirmation that the applicant had no flaws evaluated according to

IWB-3600 "Analytical Evaluation of Flaws" under the ISI program of ASME Code, Section XI as

such an evaluation would require a TLAA under the regulation. The applicant's response

indicated that the NMP2 Reactor Recirculation System has no weld evaluated according to

IWB-3600.

The applicant stated under item number 3.1.1.B-07 in ALRATable 3.1.1.B that for the

small-bore reactor coolant system and connected systems piping a plant-specific destructive

examination or an NDE of the inside surfaces of the piping will be conducted as part of a

one-time inspection to verify that service-induced weld cracking is not occurring in the

small-bore piping. The applicant's One-Time Inspection AMP is described in ALRA

Section B.2.1.20 and the applicant stated that it is consistent with GALL Report Chapter

XI.M32, "One-Time Inspection."

In ALRA Table 3.1.2.B-1 the applicant identified cumulative fatigue damage and cracking as

AERMs applicable to the vessel drain line. The applicant uses TLAA to manage cumulative

fatigue damage and the BWR Penetration Program and Water Chemistry Control Program to

manage cracking. Because of the size of the drain line volumetric examination is not required

by ASME Code Section Xl. In response to the staff s request for information about the

adequacy of the AMP applicable to the reactor vessel drain line which is not volumetrically

examined the applicant stated that the ASME Code Section XI pressure test is performed every

refueling outage. As a function of the pressure test a concurrent VT-2 examination is performed

according to acceptance standards stated in Subsection IWB-3522. Any source of leakage

detected during this examination must be located and evaluated according to Subsection

IWA-5250 prior to return of the system to service. One source of leakage could be from

through-wall pitting or crevice corrosion as the applicable loss of material mechanism for

stainless steel piping and components. Also performed under the ISI program according to the

Subsection IWB-3517 acceptance standards is a VT-1 examination of all reactor vessel drain

line bolting, studs, and nuts at every inspection interval. The staff considers the reactor vessel

drain line AMPs effective for the period of extended operation.

The staff, however, requested, during the audit, that the applicant submit information about its

plant-specific experience related to IGSCC of the reactor coolant pressure boundary piping,

mitigative actions taken, and revised inspection schedules following the BWRVIP-75A

guidelines. The staff requested that the applicant provide information about its implementation

of HWC and NMCA at NMP2 and how implementation has affected monitoring of water

chemistry parameters. In response the applicant stated that there have been two indications of

potential IGSCC at NMP2. A mechanical stress improvement process was applied to one of the

welds to improve the residual stress distribution in the region of the flaw to eliminate the

potential for flaw growth. The weld has been classified as a GL 88-01 Category E weld and will

be inspected once every six years. The second indication was repaired by weld overlay. The

scope and the schedule of inspection for IGSCC are according to GL 88-01 as modified by

BWRVIP-75A. The current inspection schedule except for Category A welds subsumed in the

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alternate Risk-Informed ISI Program is according to the revised inspection frequency allowed by

BWRVIP-75A for normal water chemistry. With respect to implementation of HWC and NMCA

NMP2 treated the reactor vessel internals with noble metal chemicals in September 2000 and

began injecting hydrogen into reactor water in January 2001. Under HWC versus normal water

chemistry the electrochemical potential is monitored with a goal of < -0.23V SHE for the

effectiveness of HWC. For NMP2 the significant change in water chemistry control when HWC

is in operation is the addition of hydrogen-to-oxygen molar ratio monitoring as an indirect

means of determining the electrochemical potential.

The staffs review concludes that the applicant had identified appropriate aging effects for the

components in the NMP2 reactor recirculation system.

Conclusion. The staff concludes that the applicant had identified adequately the aging effects

and the AMPs credited for managing them for the reactor recirculation system and that the

components' intended functions will be maintained consistent with the CLB for the period of

extended operation as required by 10 CFR 54.21(a)(3). The staff also reviewed the applicable

USAR supplement program descriptions and concludes that the USAR supplement adequately

describes the AMPs credited for managing aging in the reactor coolant system - recirculation

system as required by 10 CFR 54.21(d).

3.11.2.3.5 Reactor Vessel, Internals, and Reactor Coolant System - NMP2 Control Rod Drive

System - Summary of Aging Management Evaluation - ALRA Table 3.1.2.B-5

The NMP2 CRD system is designed to change core reactivity by changing the position of

control rods within the reactor core in response to manual control signals and to scram the

reactor in response to manual or automatic signals. The system also provides water to the

nuclear boiler instrumentation system reference leg backfill injection lines and the reactor water

cleanup and reactor recirculation pump seals.

Summary of Technical Information in the Application. The applicant's plant-specific AMRs for

the CRD system components are in ALRA Table 3.1.2.B-5. The specific NMP2 CRD system

components with AMR results not consistent with or addressed in the GALL Report and within

the scope of ALRA Table 3.1.2.B-5 include:

* CRD system accumulators

* CRD hydraulic control units

* CRD system piping and fittings

* CRD system valves

The applicant identified materials of fabrication for these CRD system components as including

carbon and low alloy steels. The applicant identified applicable environments for these CRD

system components as treated water or steam, temperature > 212°F < 482 OF, low flow

environments (i.e., the reactor coolant or its steam environment).

The applicant credited the One-Time Inspection and Water Chemistry Control Programs with

managing loss of material for the CRD system accumulators, hydraulic control units, and

valves. The applicant also credited the One-Time Inspection Program and the Water Chemistry

Control Program with managing cracking of the CRD system piping and fittings.

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Staff Evaluation. The staff reviewed ALRA Table 3.1.2.B-5, which summarizes the results of

AMR evaluations for the NMP2 CRD system components. The staff's assessment of the CRD

system components not consistent with or addressed in the GALL Report for NMP2 is provided

here. It should be noted that the assessments for the NMP2 CRD system piping and fittings and

CRD system valves are in SER Section 3.0.3.

CRD System Accumulators and Hydraulic Control Units

Identification of Aging Effects - In ALRA Table 3.1.2.B-5 the applicant identified loss of material

due to general, pitting, and crevice corrosion as an aging effect applicable to the CRD system

accumulators and the CRD hydraulic control units fabricated from carbon or low alloy steel and

exposed to an environment of treated water or steam, temperature > 212 OF < 482 °F, low flow

environments. These components are made from materials and exposed to environments

similar to those for the steel and stainless steel isolation condenser components exposed to

reactor coolant as identified in the SRP-LR Revision 1.

The applicant identified loss of material due to crevice, general, and pitting corrosion as aging

effects in carbon and low alloy steel when these materials are exposed to the reactor coolant or

* its steam environment. The staff found the applicant's determination acceptable.

Aging Management Programs - In ALRA Table 3.1.2.8-5 the applicant credited the One-Time

Inspection and Water Chemistry Control Programs with aging management of loss of material

due to general, pitting, and crevice corrosion for the CRD system accumulators and the CRD

hydraulic control units. The SRP-LR Revision 1 does not address an AMP for these component,

material, and environment combinations; however, the SRP-LR Revision 1 does address the

AMPs (One-Time Inspection Program and the Water Chemistry Control Program) for this

material and environment combination consistent with programs that the applicant identified

with managing loss of material due to general, pitting, and crevice corrosion. Therefore, the

staff found the applicant's proposal acceptable. The applicant's One-Time Inspection Program

is a new AMP consistent with GALL AMP XI.M32. The staff's evaluation of the One-Time

Inspection Program is in SER Section 3.0.3.1.4. The applicant's Water Chemistry Control

Program is an AMP consistent with GALL AMP XI.M2. The staffs evaluation of the Water

Chemistry Program is in Section 3.0.3.2.2.

Conclusion. The staff reviewed the applicant's plant-specific AMRs for evaluating the CRD

system components exposed to the treated water or steam, temperature > 212 OF < 482 OF, low

flow environments. For these AMRs the staff determined that the applicant had identified the

aging effects applicable for components that are exposed to these environments. The staff also

determined that the applicant had credited either an appropriate inspection-based AMP, an

appropriate mitigation-based AMP, or combination of these strategies with managing the aging

effects applicable to the CRD system components that are exposed to these environments. The

staffs review concludes that the applicant had demonstrated that the aging effects of the NMP2

CRD system components will be adequately managed so that the intended functions will be

maintained consistent with the CLB for the period of extended operation as required by

10 CFR 54.21(a)(3).

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3.1B.3 Conclusion

The staff concludes that there is reasonable assurance that the applicant provided sufficient

information to demonstrate that the effects of aging for the NMP2 reactor vessel, internals, and

reactor coolant systems components within the scope of license renewal and subject to an AMR

will be adequately managed so that the intended functions will be maintained consistent with

the CLB for the period of extended operation, as required by 10 CFR 54.21 (a)(3).

The staff also reviewed the applicable USAR supplement program summaries and concludes

that they adequately describe the AMPs credited for managing aging of the reactor vessel,

internals, and reactor coolant systems, as required by 10 CFR 54.21(d).

3.2 Aging Management of Engineered Safety Features

3.2A NMP1 Aging Management of Engineered Safety Features

This section of the SER documents the staff's review of the applicant's AMR results for the

engineered safety features (ESF) systems components and component groups associated with

the following systems:

* containment spray system

* core spray system

* emergency cooling system

3.2A.1 Summary of Technical Information in the Amended Application

In ALRA Section 3.2, the applicant provided AMR results for the ESF systems components and

component groups. In ALRA Table 3.2.1.A, "NMP1 Summary of Aging Management Programs

for the Engineered Safety Features Systems Evaluated in Chapter V of NUREG-1 801," the

applicant provided a summary comparison of its AMRs with the AMRs evaluated in the GALL

Report for the ESF systems components and component groups.

The applicant's AMRs incorporated applicable operating experience in the determination of

AERMs. These reviews included evaluation of plant-specific and industry operating experience.

The plant-specific evaluation included reviews of condition reports and discussions with

appropriate site personnel to identify AERMs. The applicant's review of industry operating

experience included a review of the GALL Report and operating experience issues identified

since the issuance of the GALL Report.

3.2A.2 Staff Evaluation

The staff reviewed ALRA Section 3.2 to determine if the applicant provided sufficient

information to demonstrate that the effects of aging for the ESF systems components that are

within the scope of license renewal and subject to an AMR will be adequately managed so that

the intended functions will be maintained consistent with the CLB for the period of extended

operation, as required by 10 CFR 54.21 (a)(3).

The staff performed an onsite audit of AMRs to confirm the applicant's claim that certain

identified AMRs were consistent with the GALL Report. The staff did not repeat its review of the

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matters described in the GALL Report; however, the staff did verify that the material presented

in the ALRA was applicable and that the applicant had identified the appropriate GALL AMRs.

The staff's evaluations of the AMPs are documented in SER Section 3.0.3. Details of the staffs

audit evaluation are documented in the Audit and Review Report and are summarized in SER

Section 3.2A.2.1.

In the onsite audit, the staff also selected AMRs that were consistent with the GALL Report and

for which further evaluation is recommended. The staff confirmed that the applicant's further

evaluations were consistent with the acceptance criteria of SRP-LR Section 3.2.2.2. The staffs

audit evaluations are documented in the Audit and Review Report and are summarized in SER

Section 3.2A.2.2.

In the onsite audit, the staff also conducted a technical review of the remaining AMRs that were

not consistent with, or not addressed in, the GALL Report. The audit and technical review

included evaluating whether all plausible aging effects were identified and evaluating whether

the aging effects listed were appropriate for the combination of materials and environments

specified. The staffs audit evaluations are documented in the Audit and Review Report and are

summarized in SER Section 3.2A.2.3. The staffs evaluation of its technical review is also

documented in SER Section 3.2A.2.3.

Finally, the staff reviewed the AMP summary descriptions in the UFSAR supplement to ensure

that they provided an adequate description of the programs credited with managing or

monitoring aging for the ESF systems components.

Table 3.2A-1 below provides a summary of the staffs evaluation of NMP1 components, aging

effects/mechanisms, and AMPs listed in ALRA Section 3.2, that are addressed in the GALL

Report.

Table 3.2A-1 Staff Evaluation for NMPI Engineered Safety Features Systems

Components in the GALL Report

Component Group Aging Effect!: .AMP in GALL " AMP inALRA I Staff Evaluation

Mechanism ':,Report , _ _ _"

Piping, fittings, and Cumulative fatlgue TLAA, evaluated in TLAA This TLAA is

valves in damage accordance with evaluated in.

emergency core 10 CFR 54.21(c) Section 4.3, Metal

cooling system Fatigue Analysis

(Item Number

3.2.1.A-01)

Piping, fittings, Loss of material Water chemistry Water Chemistry Consistent with

pumps, and valves due to general and one-time Control Program GALL, which

in emergency core corrosion inspection (B2.1.2), One-lime recommends further

cooling system Inspection Program evaluation (See

(Item Number (B2.1.20) Section 3.2A.2.2.2)

3.2.1 .A-02)

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Component Group Aging Effect) AMP in GALL - AMP In-ALRA 'Staff Evaluation

Mechanism Report ________,_._-__ ________________

Components in Loss of material Plant-specific Open-Cycle Cooling Consistent with

containment spray due to general Water System GALL, which

(PWR only), corrosion Program (B2.1.10), recommends further

standby gas One-Time evaluation (See

treatment (BWR Inspection Program Section 3.2A.2.2.2)

only), containment (B2.1.20),

isolation, and Preventive

emergency core Maintenance

cooling systems Program (B2.1.32)

(Item Number

3.2.1 .A-03)

Piping, fittings, Loss of material Water chemistry Water Chemistry Consistent with

pumps, and valves due to pitting and and one-time Control Program GALL, which

in emergency core crevice corrosion inspection (B2.1.2), One-Time recommends further

cooling system Inspection Program evaluation (See

(Item Number (B2.1.20) Section 3.2A.2.2.3)

3.2.1.A-04)

Components in Loss of material Plant-specific Open-Cycle Cooling Consistent with

containment spray due to pitting and Water System GALL, which

(PWR only), crevice corrosion Program (B2.1.10), recommends further

standby gas One-Time evaluation (See

treatment (BWR Inspection Program Section 3.2A.2.2.3)

only), containment (B2.1.20),

isolation, and Preventive

emergency core Maintenance

cooling systems Program (B2.1.32)

(item Number

3.2.1.A-05)

Containment Loss of material Plant-specific None Not applicable (See

isolation valves and due to MIC Section 3.2A.2.2.4)

associated piping

(Item Number

3.2.1.A-06)

Seals in standby Changes in Plant-specific Preventive Consistent with

gas treatment properties due to Maintenance GALL, which

system elastomer Program (B2.1.32), recommends further

(Item Number degradation Systems Walkdown evaluation (See

3.2.1 .A-07) Program (B2.1.33) Section 3.2A.2.2.5)

High pressure Loss of material Plant specific None Not applicable,

safety injection due to erosion PWR only

(charging) pump

miniflow orifice

(Item Number

3.2.1.A-08)

Drywell and Plugging of flow Plant specific None Not applicable (See

suppression orifice and spray Section 3.2A.2.2.7)

chamber spray nozzles by general

system nozzles and corrosion products

flow orifices

(Item Number

3.2.1 .A-09)

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Component Group Aging Effect/ AMP In GALL AMP In ALRA Staff Evaluation

Mechanism Report __•_, __,_, _ _ _

External surface of Loss of material Plant specific Systems Walkdown Consistent with

carbon steel due to general Program (B2.1.33) GALL, which

components corrosion recommends further

(Item Number evaluation (See

3.2.1.A-10) Section 3.2A.2.2.2)

Piping and fittings Loss of fracture Thermal aging None Not applicable

of CASS in toughness due to embrittlement of

emergency core thermal aging CASS There are no CASS

cooling system embrittlement piping and fittings

(Item Number with this aging

3.2.1.A-11) effect/mechanism

in NMP1 ESF

system

Components Loss of material Open-cycle cooling None Not applicable

serviced by due to general, water system

open-cycle cooling pitting, and crevice Heat exchangers

system corrosion, MIC, and has own open-cycle

(Item Number biofouling; buildup cooling system

3.2.1.A-12) of deposit due to

biofouling

Components Loss of material Closed-cycle None Not applicable

serviced by due to general, cooling water

closed-cycle cooling pitting, and crevice system No components

system corrosion serviced by

(Item Number closed-cycle cooling

3.2.1.A-13) water system

Emergency core Wall thinning due to Flow-accelerated Flow-Accelerated Consistent with

cooling system flow-accelerated corrosion Corrosion Program GALL, which

valves and lines to corrosion (B2.1.9) recommends no

and from HPCI and further evaluation

RCIC pump (See Section

turbines 3.2A.2.1)

(Item Number

3.2.1.A-14) Not applicable for

HPCI lines and

RCIC pump

turbines

Pumps, valves, Crack initiation and Water chemistry None Not applicable,

piping, and fittings growth due to SCC PWR only

in containment

spray and

emergency core

cooling systems

(Item Number

3.2.1.A-15)

Pumps, valves, Crack initiation and Water chemistry Water Chemistry Consistent with

piping, and fittings growth due to SCC and BWR stress Control Program GALL, which

in emergency core and IGSCC corrosion cracking (B2.1.2), BWR recommends no

cooling systems Stress Corrosion further evaluation

(Item Number Cracking Program (See Section

3.2.1.A-16) (B2.1.6), One-Time 3.2A.2.1.1) Inspection Program

(B2.1.20)

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Component Group .:AgIng Effect/ AMP In GALL AMP in ALRA Staff Evaluation"

Mechanism Report __" ___...... ____... ___- __. _-

Carbon steel Loss of material Boric acid corrosion None Not applicable,

components due to boric acid PWR only

(Item Number corrosion

3.2.1 .A-17)

Closure bolting in Loss of material Bolting integrity Bolting Integrity Consistent with

high pressure or due to general Program (B2.1.36) GALL, which

high temperature corrosion; crack recommends no

systems initiation and growth further evaluation

(Item Number due to cyclic (See Section

3.2.1.A-18) loading and/or SCC I 3.2A.2.1)

The staffs review of the NMP1 component groups followed one of several approaches. One

approach, documented in SER Section 3.2A.2.1, discusses the staff's review of the AMR

results for components in the ESF systems that the applicant indicated are consistent with the

GALL Report and do not require further evaluation. Another approach, documented in SER

Section 3.2A.2.2, discusses the staffs review of the AMR results for components in the ESF

systems that the applicant indicated are consistent with the GALL Report and for which further

evaluation is recommended. A third approach, documented in SER Section 3.2A.2.3, discusses

the staffs review of the AMR results for components in the ESF systems that the applicant

indicated are not consistent with, or not addressed in, the GALL Report. The staffs review of

AMPs that are credited to manage or monitor aging effects of the ESF systems components is

documented in SER Section 3.0.3.

3.2A.2.1 AMR Results That Are Consistent with the GALL Report

Summary of Technical Information in the Amended Application. In ALRA Section 3.2.2.A, the

applicant identified the materials, environments, and AERMs. The applicant identified the

following programs that manage the aging effects related to the ESF systems components:

* ASME Section Xl Inservice Inspection (Subsections IWB, IWC, IWD) Program

* Water Chemistry Control Program

* BWR Stress Corrosion Cracking Program

* Open-Cycle Cooling Water System Program

* One-Time Inspection Program

* Selective Leaching of Materials Program

* Preventive Maintenance Program

* Systems Walkdown Program

* Bolting Integrity Program

Staff Evaluation. In ALRA Tables 3.2.2.A-1 through 3.2.2.A-3, the applicant provided a

summary of AMRs for the ESF systems components, and identified which AMRs it considered

to be consistent with the GALL Report.

For component groups evaluated in the GALL Report for which the applicant has claimed

consistency with the GALL Report, and for which the GALL Report does not recommend further

evaluation, the staff performed an audit and review to determine whether the plant-specific

components contained in these GALL Report component groups were bounded by the GALL

Report evaluation.

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The applicant provided a note for each AMR line item. The notes indicate how the information in

the tables aligns with the information in the GALL Report. The staff audited those AMRs with

Notes A through E, which indicate that the AMR is consistent with the GALL Report.

Note A indicates that the AMR line item is consistent with the GALL Report for component,

material, environment, and aging effect. In addition, the AMP is consistent with the AMP

identified in the GALL Report. The staff audited these line items to verify consistency with the

GALL Report and the validity of the AMR for the site-specific conditions.

Note B indicates that the AMR line item is consistent with the GALL Report for component,

material, environment, and aging effect. In addition, the AMP takes some exceptions to the

AMP identified in the GALL Report. The staff audited these line items to verify consistency with

the GALL Report. The staff verified that the identified exceptions to the GALL AMPs had been

reviewed and accepted by the staff. The staff also determined whether the AMP identified by

the applicant was consistent with the AMP identified in the GALL Report and whether the AMR

was valid for the site-specific conditions.

Note C indicates that the component for the AMR line item, although different from, is

consistent with the GALL Report for material, environment, and aging effect. In addition, the

AMP is consistent with the AMP identified by the GALL Report. This note indicates that the

applicant was unable to find a listing of some system components in the GALL Report.

However, the applicant identified a different component in the GALL Report that had the same

material, environment, aging effect, and AMP as the component that was under review. The

staff audited these line items to verify consistency with the GALL Report. The staff also

determined whether the AMR line item of the different component was applicable to the

component under review and whether the AMR was valid for the site-specific conditions.

Note D indicates that the component for the AMR line item, although different from, is

consistent with the GALL Report for material, environment, and aging effect. In addition, the

AMP takes some exceptions to the AMP identified in the GALL Report. The staff audited these

line items to verify consistency with the GALL Report. The staff verified whether the AMR line

item of the different component was applicable to the component under review. The staff

verified whether the identified exceptions to the GALL AMPs had been reviewed and accepted

by the staff. The staff also determined whether the AMP identified by the applicant was

consistent with the AMP identified in the GALL Report and whether the AMR was valid for the

site-specific conditions.

Note E indicates that the AMR line item is consistent with the GALL Report for material,

environment, and aging effect, but a different AMP is credited. The staff audited these line

items to verify consistency with the GALL Report. The staff also determined whether the

identified AMP would manage the aging effect consistent with the AMP identified by the GALL

Report and whether the AMR was valid for the site-specific conditions.

The staff conducted an audit and review of the information provided in the ALRA, as

documented in the Audit and Review Report. The staff did not repeat its review of the matters

described in the GALL Report; however, the staff did verify that the material presented in the

ALRA was applicable and that the applicant identified the appropriate GALL Report AMRs. The

staffs evaluation is discussed below.

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3.2A.2.1.1 Crack Initiation and Growth Due to SCC and IGSCC

In the discussion section of ALRA Table 3.2.1.A Item 3.2.1.A-16 the applicant stated that for

small-bore valves and piping the One-Time Inspection Program is used to manage this aging

effect and aging effect mechanism. The GALL Report suggests using the BWR Stress

Corrosion Cracking Program and Water Chemistry Control Program for managing SCC and

IGSCC in pumps, valves, piping, and fittings in emergency core cooling systems.

As documented in the Audit and Review Report, the staff noted that for ALRA Table 3.2.2.A-3

line item component type piping and fittings, material type wrought austenitic stainless steel,

aging effect cracking, and the One-Time Inspection Program it was not clear whether these

components also are age-managed by the applicant's Water Chemistry Control and BWR

Stress Corrosion Cracking Programs. It was also not clear to which components the applicants

One-Time Inspection Program applied within this component type grouping. The staff requested

the applicant to clarify this line item.

In its letter dated December 1, 2005, the applicant stated that for the components in the subject

line item the BWR Stress Corrosion Cracking Program was not credited because this line item

is for small bore piping. Piping and fittings in the emergency condenser system age- managed

by the applicant's One-Time Inspection Program, are not included in its BWR Stress Corrosion

Cracking Program either because they are small bore piping (< 4 inches nominal diameter),

they are in a low temperature environment, or they are not made from austenitic stainless steel

material. However, the applicants Water Chemistry Control Program in addition to its One-Time

Inspection Program should have been credited for this line item. The subject line item was

revised to credit the applicant's Water Chemistry Control Program in addition to its One-Time

Inspection Program for managing cracking for this component group. Note 10 was also added

to the "Notes" column.

The staff reviewed the applicant's response and determined that after revision of the applicants

AMR line item as described the use of its Water Chemistry Control Program to manage

cracking is consistent with the GALL Report. Because the line item component is small bore

piping and fittings the applicant's BWR Stress Corrosion Cracking Program is not applicable

and its One-Time Inspection Program is an adequate alternative.

The staffs review found that the applicant appropriately addressed the aging effect and aging

effect mechanism as recommended by the GALL Report.

Conclusion. The staff evaluated the applicant's claim of consistency with the GALL Report. The

staff also reviewed information pertaining to the applicant's consideration of recent operating

experience and proposals for managing associated aging effects. On the basis of its review, the

staff concludes that there is reasonable assurance that the AMR results, which the applicant

claimed to be consistent with the GALL Report, are consistent with the AMRs in the GALL

Report. Therefore, the staff concludes that the applicant has demonstrated that the effects of

aging for these components will be adequately managed so that their intended function(s) will

be maintained consistent with the CLB for the period of extended operation, as required by

10 CFR 54.21(a)(3).

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3.2A.2.2 AMR Results That Are Consistent with the GALL Report, for Which Further

Evaluation is Recommended

Summary of Technical Information in the Amended Application. In Section 3.2.2.C of the letter

dated August 19, 2005, the applicant provided further evaluation of aging management as

recommended by the GALL Report for the ESF systems components. The applicant provided

information concerning how it will manage the following aging effects:

* cumulative fatigue damage

" loss of material due to general corrosion

* local loss of material due to pitting and crevice corrosion

" local loss of material due to MIC

* changes in properties due to elastomer degradation

" local loss of material due to erosion

* buildup of deposits due to corrosion

Staff Evaluation. For component groups evaluated in the GALL Report for which the applicant

has claimed consistency with the GALL Report, and for which the GALL Report recommends

further evaluation, the staff audited and reviewed the applicant's evaluation to determine

whether it adequately addressed the issues that were further evaluated. In addition, the staff

reviewed the applicant's further evaluations against the criteria contained in SRP-LR

Section 3.2.2.2. Details of the staff's audit are documented in the staffs Audit and Review

Report. The staff's evaluation of the aging effects is discussed in the following sections.

3.2A.2.2.1 Cumulative Fatigue Damage

In Section 3.2.2.C.1 of the letter dated August 19, 2005, the applicant stated that fatigue is a

TLAA as defined in 10 CFR 54.3. Applicants must evaluate TLAAs according to

10 CFR 54.21(c)(1). SER Section 4.3 documents the staffs review of the applicant's evaluation

of this TLAA.

3.2A.2.2.2 Loss of Material due to General Corrosion

The staff reviewed Section 3.2.2.C.2 of the applicant's letter dated August 19, 2005, against the

criteria in SRP-LR Section 3.2.2.2.2.1.

In Section 3.2.2.C.2 of its letter dated August 19, 2005, the applicant addressed loss of material

at locations with stagnant flow conditions due to general corrosion of pumps, valves, piping, and

fittings associated with some of the BWR emergency core cooling systems and with lines to the

suppression chamber and to the drywell and suppression chamber spray system.

SRP-LR Section 3.2.2.2.2.1 states that the management of loss of material due to general

corrosion of pumps, valves, piping, and fittings associated with some of the BWR emergency

core cooling systems and with lines to the suppression chamber and to the drywell and

suppression chamber spray system should be evaluated further. The AMP relies on monitoring

and control of primary water chemistry based on EPRI guidelines to mitigate degradation.

However, control of primary water chemistry does not prevent loss of material due to general

corrosion at locations of stagnant flow conditions. Therefore, the effectiveness of the applicant's

Chemistry Control Program should be verified to ensure that corrosion does not occur.

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The GALL Report recommends further evaluation of programs to manage loss of material due

to general corrosion to verify the effectiveness of the applicant's Water Chemistry Control

Program. A one-time inspection of select components at susceptible locations is an acceptable

method to determine whether an aging effect and aging effect mechanism does not occur or

progresses very slowly so the component's intended function will be maintained during the

period of extended operation.

In its letter dated August 19, 2005, the applicant stated that for NMP1 the containment spray,

core spray, emergency cooling, and main steam (for automatic depressurization) systems are

applicable. The aging effect and aging effect mechanism are managed by the combination of

the Water Chemistry Control Program and One-Time Inspection Program.

The staff reviewed the applicant's Water Chemistry Control and One-Time Inspection Programs

and its evaluations are documented in SER Sections 3.0.3.2.2 and 3.0.3.1.4, respectively.

The staff reviewed the applicant's further evaluation and concludes that it meets the criteria of

the SRP-LR.

In addition the staff reviewed Section 3.2.2.C.2 of the applicant's letter dated August 19, 2005,

against the criteria of SRP-LR Section 3.2.2.2.2.2.

In Section 3.2.2.C.2 of its letter dated August 19, 2005, the applicant also addressed loss of

material due to general corrosion of components in the standby gas treatment, containment

isolation, and emergency core cooling systems.

SRP-LR Section 3.2.2.2.2.2 also states that loss of material due to general corrosion could

occur in the drywell and suppression chamber spray systems header and spray nozzle

components, standby gas treatment system components, containment isolation valves and

associated piping, the automatic depressurization system piping and fittings, emergency core

cooling system header piping and fittings and spray nozzles, and the external surfaces of

carbon steel components. The GALL Report recommends further plant-specific evaluation to

ensure adequate aging effect and aging effect mechanism management.

In its letter dated August 19, 2005, the applicant also stated that for NMP1 the applicable

systems are the containment spray, core spray, emergency cooling, reactor building ventilation

(for standby gas treatment), and main steam (for automatic pressurization) systems. The aging

effect and aging effect mechanism for internal surfaces is managed by the One-Time

Inspection, Preventive Maintenance, or Open-Cycle Cooling Water System Programs. The

aging effect and aging effect mechanism for external surfaces of carbon steel components in

the emergency core cooling system is managed by the Systems Walkdown Program.

The staff review and evaluations of the applicant's One-Time Inspection, Preventive

Maintenance, Open-Cycle Cooling Water System, and Systems Walkdown Programs are

documented in SER Sections 3.0.3.1.4, 3.0.3.3.1, 3.0.3.2.7, and 3.0.3.3.2, respectively.

The staff reviewed the applicant's further evaluation and concludes that it meets the criteria of

the SRP-LR.

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Based on the programs identified above, the staff concludes that there is reasonable assurance

that the applicant has met the criteria of SRP-LR Section 3.2.2.2.2. For those line items that

apply to Section 3.2.2.C.2 of the applicant's letter dated August 19, 2005, the staff determined

that the information in the application is consistent with the GALL Report and the applicant had

demonstrated that the effects of aging will be adequately managed so that the intended

function(s) will be maintained consistent with the CLB during the period of extended operation,

as required by 10 CFR 54.21(a)(3).

3.2A.2.2.3 Local Loss of Material Due to Pitting and Crevice Corrosion

The staff reviewed Section 3.2.2.C.3 of the applicant's letter dated August 19, 2005, against the

criteria in SRP-LR Section 3.2.2.2.3.1.

In Section 3.2.2.C.3 of its letter dated August 19, 2005, the applicant addressed loss of material

at locations with stagnant flow conditions due to pitting and crevice corrosion of pumps, valves,

piping, and fittings associated with some of the BWR emergency core cooling systems and with

lines to the suppression chamber and to the drywell and suppression chamber spray system.

SRP-LR Section 3.2.2.2.3.1 states that the management of local loss of material due to pitting

and crevice corrosion of pumps, valves, piping, and fittings associated with some of the BWR

emergency core cooling system piping and fittings and with lines to the suppression chamber

and to the drywell and suppression chamber spray system should be evaluated further. The

AMP relies on monitoring and control of primary water chemistry based on EPRI guidelines to

mitigate degradation. However, control of coolant water chemistry does not prevent loss of

material due to crevice and pitting corrosion at locations of stagnant flow conditions. Therefore,

the effectiveness of the applicant's Water Chemistry Control Program should be verified to

ensure that corrosion does not occur. The GALL Report recommends further evaluation of

programs to manage the loss of material due to pitting and crevice corrosion to verify the

effectiveness of the applicant's Water Chemistry Control Program.

In Section 3.2.2.C.3 of its letter dated August 19, 2005, the applicant stated that the

containment spray, core spray, and emergency cooling systems are applicable for NMPI. The

aging effect and aging effect mechanism are managed by a combination of the Water

Chemistry Control Program and One-Time Inspection Program.

The staffs review and evaluations of the applicant's Water Chemistry Control and One-Time

Inspection Programs are documented in SER Sections 3.0.3.2.2 and 3.0.3.1.4, respectively.

The staff reviewed the applicant's further evaluation and concludes that it meets the criteria of

the SRP-LR.

In addition the staff reviewed Section 3.2.2.C.3 of the applicant's letter dated August 19, 2005,

against the criteria of SRP-LR Section 3.2.2.2.3.2.

In Section 3.2.2.C.3 of its letter dated August 19, 2005, the applicant also addressed loss of

material due to pitting and crevice corrosion of components in the standby gas treatment,

containment isolation, and emergency core cooling systems.

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SRP-LR Section 3.2.2.2.3.2 states that local loss of material due to pitting and crevice corrosion

could occur in the containment isolation valves and associated piping and automatic

depressurization system piping and fittings. The GALL Report recommends further evaluation

to ensure adequate aging effect and aging effect mechanism management.

In Section 3.2.2.C.3 of its letter dated August 19, 2005, the applicant stated that the

containment spray, core spray, emergency cooling, and main steam (for automatic

depressurization) systems are applicable for NMP1. The aging effect and aging effect

mechanism are managed by the One-Time Inspection Program, the Preventive Maintenance

Program, or the Open-Cycle Cooling Water System Program.

The staff's review and evaluations of the applicant's One-Time Inspection, Preventive

Maintenance, and Open-Cycle Cooling Water System Programs are documented in SER

Sections 3.0.3.1.4, 3.0.3.3.1 and 3.0.3.2.7, respectively.

The staff reviewed the applicant's further evaluation and concludes that it meets the criteria in

the SRP-LR.

Based on the programs identified above, the staff concludes that there is reasonable assurance

that the applicant has met the criteria of SRP-LR Section 3.2.2.2.3. For those line items that

apply to Section 3.2.2.C.3 of the applicant's letter dated August 19, 2005, the staff determined

that the information in the application is consistent with the GALL Report and the applicant had

demonstrated that the effects of aging will be adequately managed so that the intended

function(s) will be maintained consistent with the CLB during the period of extended operation,

as required by 10 CFR 54.21 (a)(3).

3.2A.2.2.4 Local Loss of Material Due to Microbiologically Influenced Corrosion

The staff reviewed Section 3.2.2.C.4 of the applicant's letter dated August 19, 2005, against the

criteria in SRP-LR Section 3.2.2.2.4.

The applicant stated in Section 3.2.2.C.4 of its letter dated August 19, 2005, that the aging

effect and aging effect mechanism of local loss of material due to microbiologically influenced

corrosion (MIC) in containment isolation valves and associated piping is not applicable to NMP.

The applicant considers MIC an aging effect.and aging effect mechanism for systems with raw

water as an environment. NMP1 has no raw water environment for containment isolation valves

or the associated piping. Therefore, this issue is not applicable. As documented in the Audit and

Review Report, the staff determined through discussions with the applicant's technical

personnel that the local loss of material due to MIC in containment isolation valves and

associated piping is not applicable to NMP1.

Because NMP1 has no containment isolation valves subject to this aging effect and aging effect

mechanism the staff determined that it is not applicable to NMP1.

3.2A.2.2.5 Changes in Properties Due to Elastomer Degradation

The staff reviewed Section 3.2.2.C.5 of the applicant's letter dated August 19, 2005, against the

criteria in SRP-LR Section 3.2.2.2.5.

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In Section 3.2.2.C.5 of its letter dated August 19, 2005, the applicant addressed change in

material properties of seals in the standby gas treatment system.

SRP-LR Section 3.2.2.2.5 states that changes in properties due to elastomer degradation could

occur in seals associated with the standby gas treatment system ductwork and filters. The

GALL Report recommends further evaluation to ensure adequate aging effect and aging effect

mechanism management.

In the ALRA, the applicant also stated the NMP1 reactor building ventilation system provides

the equivalent function of a standby gas treatment system. For the internal surfaces of the

system's seals (grouped with blowers) aging effects/mechanisms are managed by the

Preventive Maintenance Program. For external surfaces the aging effects/mechanisms are

managed by the Systems Walkdown Program. The staff's review and evaluations of the

applicant's Preventive Maintenance and Systems Walkdown Programs are documented in SER

Sections 3.0.3.3.1 and 3.0.3.3.2.

The staff reviewed the applicant's further evaluation and concludes that it meets the criteria of

the SRP-LR.

Based on the programs identified above, the staff concludes that there is reasonable assurance

that the applicant has met the criteria of SRP-LR Section 3.2.2.2.5. For those line items that

apply to Section 3.2.2.C.5 of the applicant's letter dated August 19, 2005, the staff determined

that the information in the application is consistent with the GALL Report and the applicant had

demonstrated that the effects of aging will be adequately managed so that the intended

function(s) will be maintained consistent with the CLB during the period of extended operation,

as required by 10 CFR 54.21 (a)(3).

3.2A.2.2.6 Local Loss of Material Due to Erosion

The staff reviewed Section 3.2.2.C.6 of the applicant's letter dated August 19, 2005, against the

criteria in SRP-LR Section 3.2.2.2.6.

In Section 3.2.2.C.6 of its letter dated August 19, 2005, the applicant stated that this aging

effect applies to PWRs only.

Because NMP is a BWR the staff found this aging effect and aging effect mechanism not

applicable to NMP.

3.2A.2.2.7 Buildup of Deposits Due to Corrosion

The staff reviewed Section 3.2.2.C.7 of the applicant's letter dated August 19, 2005, against the

criteria in SRP-LR Section 3.2.2.2.7.

In Section 3.2.2.C.7 of its letter dated August 19, 2005, the applicant addressed the plugging of

components due to general corrosion in the spray nozzles and flow orifices of the drywell and

suppression chamber spray system.

SRP-LR Section 3.2.2.2.7 states that the plugging of components due to general corrosion

could occur in the spray nozzles and flow orifices of the drywe!l and suppression chamber spray

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system. This aging effect and aging effect mechanism applies since the spray nozzles and flow

orifices are wetted occasionally even though most of the time this system is on standby. The

wetting and drying of these components can aid in the acceleration of this particular corrosion.

The GALL Report recommends further evaluation to ensure adequate aging effect and aging

effect mechanism management.

In Section 3.2.2.C.7 of its letter dated August 19, 2005, the applicant stated that the NMP1

containment spray system contains the subject spray nozzles and flow orifices. Plugging of

spray nozzles due to general corrosion is not an applicable aging effect and aging effect

mechanism as these components are stainless steel and not susceptible to general corrosion.

The plugging of flow orifices due to general corrosion is not an applicable aging effect and

aging effect mechanism because the lines containing these components are drained completely

following each system operation in which they are wetted. The draining ensures that no

corrosion products accumulate in the flow orifices. The flow orifices are located in the

containment spray heat exchanger drain lines such that plugging would not be impact the

intended safety function adversely.

The staff found that general corrosion of stainless steel spray nozzles is not an effect/

mechanism requiring aging management. As documented in the Audit and Review Report, the

staff determined through discussions with the applicant's technical personnel that plugging of

orifices has no adverse impact upon the intended function of the system.

3.2A.2.2.8 Quality Assurance for Aging Management of Nonsafety-Related Components

SER Section 3.0.4 provides the staffs evaluation of the applicant's quality assurance program.

Conclusion. On the basis of its review, for component groups evaluated in the GALL Report for

which the applicant has claimed consistency with the GALL Report, and for which the GALL

Report recommends further evaluation, the staff determined that the applicant adequately

addressed the issues that were further evaluated. The staff found that the applicant had

demonstrated that the effects of aging will be adequately managed so that the intended

functions will be maintained consistent with the CLB for the period of extended operation, as

required by 10 CFR 54.21(a)(3).

3.2A.2.3 AMR Results That Are Not Consistent with or Not Addressed in the GALL

Report

Summary of Technical Information in the Amended Application. In ALRA Tables 3.2.2.A-1

through 3.2.2.A-3, the staff reviewed additional details of the results of the AMRs for material,

environment, AERM, and AMP combinations that are not consistent with the GALL Report, or

that are not addressed in the GALL Report.

In ALRA Tables 3.2.2.A-1 through 3.2.2.A-3, the applicant indicated, via Notes F through J, that

the combination of component type, material, environment, and AERM does not correspond to

a line item in the GALL Report, and provided information concerning how the aging effect will

be managed. Specifically, Note F indicates that the material for the AMR line item component is

not evaluated in the GALL Report. Note G indicates that the environment for the AMR line item

component and material is not evaluated in the GALL Report. Note H indicates that the aging

effect for the AMR line item component, material, and environment combination is not evaluated

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in the GALL Report. Note I indicates that the aging effect identified in the GALL Report for the

line item component, material, and environment combination is not applicable. Note J indicates

that neither the component nor the material and environment combination for the line item is

evaluated in the GALL Report.

Staff Evaluation. For component type, material, and environment combinations that are not

evaluated in the GALL Report, the staff reviewed the applicant's evaluation to determine

whether the applicant had demonstrated that the effects of aging will be adequately managed

so that the intended function(s) will be maintained consistent with the CLB during the period of

extended operation. The staffs evaluation is discussed in the following sections.

3.2A.2.3.1 Engineered Safety Features Systems NMP1 Containment Spray System -

Summary of Aging Management Evaluation - ALRA Table 3.2.2.A-1

The staff reviewed ALRA Table 3.2.2.A-1, which summarizes the results of AMR evaluations for

the containment spray system component groups.

The staff reviewed the following original LRA Table 3.2.2.A-1 line items for the NMP1

Containment Spray System.

Wrought stainless steel bolting in an air environment where the applicant identified no

aging effect.

" Loss of material of gray cast iron external surfaces in an air environment is managed by

the Systems Walkdown Program. The applicant stated that this line item is for external

surfaces of carbon steel components not in the GALL Report (Note F, 4).

* Loss of material for carbon or low alloy steel (yield strength < 100 ksi) filters/strainers in

a demineralized untreated water low flow environment is managed by the One-Time

Inspection and Water Chemistry Control Programs. The applicant stated that this aging

effect is not in the GALL Report for this component, material, and environment (Note H).

Loss of material as an aging effect for gray cast iron pumps in a treated water,

temperature < 140 OF, low flow environment is managed by the One-Time Inspection,

Water Chemistry Control, and Selective Leaching of Materials Programs. The applicant

stated that this aging effect is not in the GALL Report for this component, material, and

environment (Note H).

As to the evaluation of no aging effects for wrought stainless steel bolting in an air environment,

the staff requested the applicant, in RAI 3.2-1 dated November 17, 2004, to discuss how

cracking and loss of pre-load resulting in loss of mechanical closure integrity are managed for

these bolts. In addition, the staff requested that the applicant address how the aging effects are

managed for inaccessible bolts.

In its response dated December 21, 2004, and as amended (ALRA) by attachment 1 to NMP1 L1960 letter dated July 14, 2005, the applicant stated:

The wrought austenitic stainless steel bolting in an air environment in [the

original] LRA Table 3.2.2.A-1 is in the NMP1 Containment Spray System. Since

the environment was identified in the aging management review (AMR) as air,

cracking and loss of preload were not identified as aging effects for wrought

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austenitic stainless steel bolting. The maximum typical operating temperature

(based on the internal environments assigned to components in this system) is

< 140 OF. Loss of preload would not typically be an aging effect requiring

management for bolting in low temperature systems. NUREG-1801 only

specifies loss of preload as an aging effect requiring management for

components in the reactor vessel and internals and reactor coolant pressure

boundary. The only mechanisms for cracking affecting wrought austenitic

stainless steel bolting are stress corrosion cracking and cyclic loading (fatigue).

Stress corrosion cracking and thermal fatigue are not aging effects requiring

management for wrought austenitic stainless steel at temperatures less than

140 OF. Therefore, loss of mechanical closure integrity is not an aging effect

requiring management for bolting in the NMP1 Containment Spray System.

With respect to inaccessible bolts, there are no bolts in the NMPI Containment

Spray System that are inaccessible for examination. The only aging effect

requiring management for any bolting in the Containment Spray System is loss

of material for carbon or low alloy steel bolting, yield strengths > 100 ksi, in an air

environment. This aging effect is managed by the Systems Walkdown Program

(described in [the original] LRA Section B2.1.33), which performs visual

examinations of accessible surfaces for loss of material. The inspection criteria

of the Systems Walkdown Program require that bolted joints be inspected for

corrosion of external surfaces, and will be enhanced to add inspection for

evidence of leakage, which does not require the bolted joints to be

disassembled. This enhancement is described in [the original] LRA

Section B2.1.33 (page B-65), under the "Parameters Monitored/Inspected"

heading.

The staff found the applicant's response reasonable and acceptable because the applicant

justified the absence of aging effects of wrought austenitic bolting in an air environment in the

NMP1 containment spray system. The applicant also satisfactory explained managing the loss

of material for carbon or low alloy steel bolting in an air environment in the NMP1 containment

spray system, and thus the staff's concern in RAI 3.2-1 is resolved.

The staffs review and evaluation of the applicant's Systems Walkdown Program are

documented in SER Section 3.0.3.3.2

As to the loss of material of gray cast iron external surfaces in an air environment managed by

the Systems Walkdown Program the applicant stated that this line item is for external surfaces

of carbon steel components not in the GALL Report (Note F, 4). The staff found the

management of the aging effect for external surfaces of this material in an air environment

reasonable and acceptable because the Systems Walkdown Program contains adequate

provisions. The staff's review and evaluation of the applicant's Systems Walkdown Program are

documented in SER Section 3.0.3.3.2.

As to the evaluation of loss of material for carbon and low alloy steel (yield strength < 100 ksi),

filters/strainers in a demineralized untreated water (< 140 OF), low flow environment the

applicant proposed to manage this aging effect by the One-Time inspection and the Water

Chemistry Control Programs. The staff found these AMPs appropriate and acceptable for

managing loss of material in this environment.

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The applicant also stated in the NMP letter dated December 21, 2004:

This item applies to the four (4) Containment Spray Pump Discharge Strainers

(STR-80-09, STR-80-1 0, STR-80-29, and STR-80-30). The internals of these

strainers were removed as part of the modification to address NRC Bulletin

96-003, "Potential Plugging of Emergency Core Cooling Suction Strainers by

Debris in Boiling-Water Reactors." Additionally, the strainer bodies are made of

carbon steel. These are ASME Section XI Class 2 components. As such, the

bodies of the strainers are subject only to the VT-2 examination under

examination category C-H, 'All Pressure Retaining Components.' The VT-2

examination is conducted during the system pressure test during each inspection

period. VT-2 examinations are conducted to detect evidence of leakage only.

The water source is torus water, so the environment for these strainers is

demineralized untreated water, low flow. The chemistry action levels and

sampling frequencies for the torus water are specified in NMP1 procedure

S-CTP-V666, 'Auxiliary Systems Chemistry'.

The staff found these tests and inspections reasonable and acceptable because they conform

to ASME Section XI requirements and industry practice.

The staff's review of the One-Time Inspection and Water Chemistry Control Programs is

provided in SER Sections 3.0.3.1.4 and 3.0.3.2.2, respectively.

As to loss of material as an aging effect for gray cast iron pumps in a treated water,

temperature < 140"F, low flow environment the applicant stated that this aging effect is not in

the SRP-LR for this component, material, and environment (Note H). The staff concurred with

this statement. This aging effect is managed by the One-Time Inspection, Water Chemistry

Control, and Selective Leaching of Materials Programs. The staff's initial evaluation of the

management of the aging effects for this component is discussed in RAI 3.4-2.

In RAI 3.4-2, dated November 17, 2004, the staff requested that the applicant discuss the

following:

Bases for visual, VT, or other inspection methods, frequency of inspections, and

acceptance criteria

Bases for sampling of the pumps to detect selective leaching and whether hardness

tests will be performed.

In its response by letter dated December 21, 2004, the applicant stated:

The gray cast iron pumps with an internal environment of treated water

(temperature <140 °F), are the two condensate transfer pumps. The aging effect

requiring management is loss of material. The aging mechanisms to be

managed by the One-Time Inspection Program and the Water Chemistry Control

Program include crevice corrosion, general corrosion, and pitting corrosion. The

One-Time Inspection Program is a new license renewal (LR) AMP commitment

for NMP that is to be implemented prior to the period of extended operation. This

commitment was made in the original LRA submittal, as supplemented by

NMPNS letter NMP1L 1880 dated October 29, 2004. As such, program

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documents or procedures specific to managing the aging mechanisms (i.e.

crevice corrosion, general corrosion and pitting corrosion), specific inspection

methods and acceptance criteria for the two condensate transfer pumps do not

currently exist. The frequency of any future inspections for the aging

mechanisms of crevice corrosion, general corrosion and pitting corrosion will be

based on the findings of the One-Time Inspection Program. However, as stated

in Appendix B2.1.20, the One-Time Inspection Program will be implemented

consistent with NUREG-1801, Section XI.M32.

As presented in ALRA Sections A1.1.33 and B2.1.21, the implementation of the Selective

Leaching of Materials Program is addressed in the program description for the One-Time

Inspection Program (see ALRA Sections Al.1.28 and B2.1.20). The One-Time Inspection

Program is a new LR AMP commitment for NMP to be implemented prior to the period of

extended operation so program documents or procedures for managing the aging mechanism

of selective leaching for the two condensate transfer pumps do not exist; however, as stated in

ALRA Section B2.1.21, the Selective Leaching Program will be implemented consistent with

GALL AMP XI.M33 (NMP1 Commitment 23 and NMP2 Commitment 21).

A determination of whether hardness tests are necessary will be made at the time of the

One-Time Inspection Program implementation. This timing is consistent with ALRA

Section B2.1.20, which states that inspection techniques may include a one-time visual

inspection and hardness measurement. Hardness testing will be considered as a possible

inspection technique if visual examination techniques alone cannot determine whether selective

leaching severe enough to affect the component intended function is occurring. The use of field

hardness testing will also be contingent on the accessibility of the affected component surfaces.

Hardness testing on components susceptible to selective leaching may be appropriate if the

component configuration and geometry allow. Tubing and other components like valves with

complex internal geometry do not pro'vide adequate access to internal surfaces requiring

examination for accurate measurements.

This above information is reflected in its ALRA, and the staff found the applicant's response

reasonable and acceptable because the applicant's tests and inspection methods are

consistent with industry practice and the GALL Report guidelines.

The applicant stated that this aging effect is not in the GALL Report for this component,

material, and environment combination (Note H). The staff concurred with this statement.

Based on the above evaluation, the staff found that the applicant had identified the appropriate

AMPs for the materials and environment of the NMP1 containment spray system components.

On the basis of its review, as discussed above, the staff concludes that there is reasonable

assurance that the applicant had demonstrated that the aging effects associated with the

containment spray system components will be adequately managed so that the intended

functions will be maintained consistent with the CLB for the period of extended operation, as

required by 10 CFR 54.21(a)(3).

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3.2A.2.3.2 Engineered Safety Features Systems NMP1 Core Spray System - Summary of

Aging Management Evaluation - ALRA Table 3.2.2A-2

The staff reviewed ALRA Table 3.2.2.A-2, which summarizes the results of AMR evaluations for

the core spray system component groups.

The staff reviewed the following original LRA Table 3.2.2.A-2 items in the NMP1 Core Spray

System:

* Loss of material of gray cast iron external surfaces in an air environment is managed by

the System Walkdown Program. The applicant stated that this material is not in the

GALL Report for carbon steel components to which this item applies (Note F,4).

" Cracking of wrought austenitic stainless steel filters/strainers in a treated water,

temperature > 140 OF, but < 212 OF, low flow environment is managed by the One-Time

Inspection and Water Chemistry Control Programs. The applicant stated that this aging

effect is not in the GALL Report for this component, material, and environment

combination (Note H).

" Cracking of wrought austenitic stainless steel flow orifices in a treated water,

temperature > 140 OF, but < 212 OF, low flow environment is managed by the ASME

Section Xl (Subsection IWB, IWC, IWD) ISI, Water Chemistry Control, and One-Time

Inspection Programs. The applicant stated that this aging effect is not in the GALL

Report for this component, material, and environment combination (Note H).

Copper Alloy (zinc > 15 percent) and aluminum bronze heat exchangers in a lubricating

oil environment for which the applicant has identified no aging effect. The applicant

stated that this material is not in the GALL Report for this component (Note F).

Loss of material of gray cast iron pumps in a treated water, temperature > 140°F, but

< 212 °F, low flow environment is managed by One-Time Inspection, Selective Leaching

of Materials, and Water Chemistry Control Programs. The applicant stated that this

aging effect is not in the GALL Report for this component, material, and environment

combination (Note H).

The applicant stated that the loss of material of gray cast iron external surfaces in an air

environment managed by the Systems Walkdown Program applies to external surfaces of

carbon steel components not in the GALL Report (Note F, 4). The staff found the management

of the aging effect for external surfaces of this material in an air environment reasonable and

acceptable because the Systems Walkdown Program is adequate to manage this aging effect.

The staff's review and evaluation of the applicant's Systems Walkdown Program are

documented in SER Section 3.0.3.3.2. The staff agreed with the applicant's statement that this

item applies to carbon steel components not in the GALL Report (Note F, 4).

The applicant stated that the cracking aging effect of wrought austenitic stainless steel

filters/strainers in a treated water, temperature > 140 °F, but < 212 OF, low flow environment

managed by the One-Time Inspection and Water Chemistry Control Programs is not in the

GALL Report for this component, material and environment combination (Note H). The staff

concurred with this statement. The staff's review of the aging management of this component is

in RAI 3.2-7.

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In RAI 3.2-7 dated November 17, 2004, the staff requested that the applicant address the

specific tests and inspections, frequency of inspections, and acceptance criteria for the

strainers and filters to ensure performance of their intended function in the identified

environment.

In its response by letter dated December 21, 2004, the applicant stated that:

The components addressed by this AMR line item are the two core spray pump

suction strainers located in the torus. Torus water is managed under the Water

Chemistry Control Program, which is described in original LRA Section B2.1.2,

as supplemented by NMPNS letter NMPIL 1880 dated October 29, 2004. The

chemistry action levels and sampling frequencies for the torus water are

provided in the response to RAI 3.2-2. These limits are identical to those

specified in EPRI TR-103515-R2, 'BWR Water Chemistry Guidelines -2000

Revision.'

The One-Time Inspection Program is described in original LRA Section B2.1.20,

as supplemented by NMPNS letter NMP1 L 1880 dated October 29, 2004. The

One-Time Inspection Program is a new program that will be implemented prior to

the period of extended operation. As such, the procedures needed to answer this

question have not yet been developed. However, the One-Time Inspection

Program will be consistent with NUREG-1801, Section XI.M32 (One-Time

Inspection) when implemented. The One-Time Inspection Program Attribute

Assessment (PAA) addresses program implementation at NMPNS relative to the

requirements of Appendix A of NUREG-1800. The One-Time Inspection PAA is

available on-site at NMPNS for review.

The staff found the applicant's response reasonable and acceptable because the applicant's

AMPs will be consistent with industry practice and GALL Report requirements.

The staff review and evaluations of the One-Time Inspection and Water Chemistry Control

Programs are in SER Sections 3.0.3.1.4 and 3.0.3.2.2, respectively. The staff agreed with the

applicant's statement that this aging effect is not in the GALL Report for this component,

material, and environment combination (Note H).

The staff concern in RAI 3.2-7 applies also to the component, material, and environment

combination of cracking of wrought austenitic stainless steel flow orifices in a treated water,

temperature > 140 °F, but < 212 OF, low flow environment managed by the ASME Section XI

(Subsections IWB, IWC, IWD) ISI and Water Chemistry Control Programs.

The staff found the applicant's response reasonable and acceptable because the applicant's

AMPs will be consistent with industry practice and GALL Report requirements; therefore, the

staff's concern described in RAI 3.2-7 is resolved. This information is reflected in the ALRA.

The staff's reviews of the One-Time Inspection and Water Chemistry Control Programs are in

SER Sections 3.0.3.1.4 and 3.0.3.2.2, respectively. The staff agreed with the applicant's

statement that this aging effect is not in the GALL Report for this component, material, and

environment combination (Note H).

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In RAI 3.2-8 dated November 17, 2004, the staff requested that the applicant discuss its

inspection and test activities for the copper alloy (zinc > 15 percent) and aluminum bronze heat

exchangers in a lubricating oil environment for which the applicant has identified no aging effect

to ensure that the lubricating oil remains free of contaminants and water content.

In its response by letter dated December 21, 2004, the applicant stated that, "Lube oil samples

from the NMP1 core spray pump motor cooler (i.e., heat exchanger) oil subsystems are

obtained on an annual basis according to site procedure N1-CTP-V520, 'Lube Oil Sampling,'

and the oil sample results are evaluated and trended. Any indication of an anomalous condition

or adverse trend will result in an investigation under the site CAP."

The staff found the response acceptable because the applicant's inspection and test activities

ensure that the lubricating oil remains free of contaminants and water content. The staff also

agreed with the applicant's statement that this material is not in the GALL Report for this

component (Note F).

In RAI 3.2-10, dated November 17, 2004, the staff requested that the applicant provide

additional details relating to test and inspection methods for the loss of material of gray cast

iron pumps in a treated water temperature > 140 OF, but < 212 OF, low flow environment

managed by One-Time Inspection, Selective Leaching of Materials, and Water Chemistry

Control Programs. Specifically the staff requested that the applicant provide (a) the basis for

selecting a representative sample for the one-time inspection and (b) inspection methods to

detect selective leaching. Also the applicant was requested to indicate whether hardness tests

would be performed.

In its response by letter dated December 21, 2004, the applicant stated:

The basis for selecting representative samples for the one-time inspection are

stated in original LRA Section B2.1.20, supplemented by NMPNS letter NMP1 L

1880 dated October 29, 2004. The process for identifying the population of

potentially affected components will be based upon common characteristics of

the components, such as material of construction, fabrication process, operating

environment, and aging effects. From the selected population, a sample size will

be determined to provide a 90 percent confidence that 90 percent of the

population does not have the degradation mechanism present. This terminology

and methodology are consistent with EPRI TR107514,'Age Related Degradation

Inspection Method and Determination.'

The inspection methods used to detect selective leaching will be consistent with

original LRA Section B2.1.20, which states that inspection techniques may

include a one-time visual inspection and hardness measurement. Hardness

testing will be considered as a possible inspection technique if visual

examination techniques alone cannot determine that selective leaching is severe

enough to affect the component's intended function. The use of field hardness

testing will also be contingent on the accessibility of the affected component

surfaces to perform the test. Hardness testing on components susceptible to

selective leaching may be appropriate if the component configuration and

geometry allows. Tubing and other components such as valves with complex

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internal geometry do not provide adequate physical access to internal surfaces

requiring examination to -allow accurate measurements to be made.

The One-Time Inspection Program is a new program that will be developed and

implemented prior to the period of extended operation [NMP1 Commitment 23

and NMP2 Commitment 21]. The One-Time Inspection Program Attribute

Assessment (PAA) addresses program implementation at NMPNS relative to the

requirements of Appendix A of NUREG-1 800.

The staff found the applicant's response reasonable and acceptable because the inspection

methods are according to industry practice and NRC requirements. The staff also agreed with

the applicant that this aging effect is not in the GALL Report for this component, material, and

environment combination (Note H). This information has been incorporated into the ALRA.

The staff's reviews of the Selective Leaching of Materials, One-Time Inspection, and Water

Chemistry Control Programs are provided in the SER Sections 3.0.3.1.5, 3.0.3.1.4, and

3.0.3.2.2, respectively.

The staff found that the applicant had identified the appropriate AMPs for the materials and

environment associated with the NMP1 core spray system components.

On the basis of its review, as discussed above, the staff concludes that there is reasonable

assurance that the applicant has demonstrated that the aging effects associated with the core

spray system components will be adequately managed so that the intended functions will be

maintained consistent with the CLB for the period of extended operation, as required by

10 CFR 54.21(a)(3).

3.2A.2.3.3 Engineered Safety Features Systems NMP1 Emergency Cooling System -

Summary of Aging Management Evaluation - ALRA Table 3.2.2.A-3

The staff reviewed ALRA Table 3.2.2.A-3, which summarizes the results of AMR evaluations for

the emergency cooling system component groups.

The staff reviewed the following ALRA Table 3.2.2.A-3 items in the NMP1 emergency cooling

system:

" Cumulative fatigue damage of carbon or low alloy steel (yield strength > 100 ksi) bolting

in non-borated water systems with operating temperatures > 212 *F leaking fluid

environment managed by TLAA evaluated according to 10 CFR 54.21(c). (By

attachment 2 to NMPIL 2005 dated December 1, 2005, the applicant deleted this item

from the table)

" Cracking and loss of material of wrought austenitic stainless steel heat exchangers in a

moist air, wetting, temperature > 140 *F, environment managed by the ASME Section Xl

(Subsections IWB, IWC, IWD) ISI and Preventive Maintenance Programs. The applicant

stated that this environment is not in the GALL Report for this material and component

(Note G).

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Aluminum and aluminum alloyed with manganese, magnesium, and magnesium plus

silicon tanks in a treated water, temperature_> 140 0F, environment for which the

applicant has identified no aging effect.

Cracking of aluminum alloy (containing copper or zinc as the primary alloying element)

valves in a treated water_> 140 °F environment managed by ASME Section Xl

(Subsections IWB, IWC, IWD) ISI, One-Time Inspection, and Water Chemistry Control

Programs. The applicant stated that this material is not in the GALL Report for this

component (Note F).

The staff found the deletion by attachment 2 to NMPIL 2005 dated December 1, 2005, of the

cumulative fatigue damage of carbon or low alloy steel (yield strength > 100 ksi) bolting in

non-borated water systems with operating temperatures > 212 °F leaking fluid environment

managed by TLAA evaluated according to 10 CFR 54.21(c) acceptable because cumulative

fatigue damage is not an applicable AERM for this component.

In RAI 3.2-12 dated November 17, 2004, the staff requested that the applicant provide

information as to cracking and loss of material of wrought austenitic stainless steel heat

exchangers in moist air, temperature > 140°F environment managed by the ASME Section XI

(Subsections IWB, IWC, IWD) ISI and Preventive Maintenance Programs for these heat

exchanger components:

(a) parameters monitored or inspected

(b) methods of detection of aging effects

(c) frequency of inspections including monitoring and trending

(d) acceptance criteria and their bases

In its response by letter dated December 21, 2004, the applicant stated that the subject wrought

austenitic stainless steel heat exchangers in a moist air (temperature > 140°F ) environment

listed in the original LRA Table 3.2.2.A-3 consist of the four NMP1 emergency condensers and

that the aging effects requiring management are cracking and loss of material.

By letter dated December 6, 2004, the applicant submitted supplemental information to the

original LRA Section 3.1 including revisions to the AMPs for the NMP1 emergency condensers.

Specifically the original LRA Table 3.1.1.A item numbers 3.1.1.A-03 and 3.1.1.A-09 were

revised to indicate that the emergency condensers were managed by a combination of the

Water Chemistry Control, ASME Section Xl (Subsections IWB, IWC, and IWD) ISI, and

Preventive Maintenance Programs. The emergency condenser vent is monitored continuously

in the control room for radioactivity, and a justification for not performing eddy current testing of

the condenser tubes was provided. The applicant stated that because the Water Chemistry

Control and ASME Section XA Programs are well established in the industry and credited in the

GALL Report and because the applicant's programs are consistent with the GALL Report

guidelines with justified exceptions the four categories of information requested were provided

for the Preventive Maintenance Program only.

Regarding the Preventive Maintenance Program the applicant stated:

(1) The Preventive Maintenance Program includes temperature monitoring of water in the

emergency cooling steam and return lines adjacent to the emergency condensers and in

the shell of the emergency condensers. The parameters monitored are water

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temperature at the inlet and outlet of the condensers and on the shell side of the

condensers.

(2) The methods of detection of cracking and loss of material aging effects are through the

potential impacts on system temperatures consistent with GALL Report guidelines.

(3) Temperature monitoring of the emergency condensers is conducted continuously

through installed instrumentation with local indications and alarms in the control room.

Twice a year the temperature data are collected and analyzed to determine if any

detrimental effects have occurred.

(4) The temperature monitoring procedure contains separate acceptance criteria for the

steam inlet piping, emergency condenser shell water, and condensate return line piping.

The acceptance criteria are based upon design analyses to prevent damage to the

piping and condensers.

The staff found the applicant's response reasonable and acceptable because the inspection

methods described are according to ASME Section Xl requirements and GALL Report

guidelines.

The staff evaluation of aluminum and aluminum alloyed with manganese, magnesium, and

magnesium plus silicon tanks in a treated water, temperature > 140 OF environment for which

the applicant has identified no aging effect is in RAI 3.2-14.

In RAI 3.2-14 dated November 17, 2004, the staff requested that the applicant provide the

following information about the aging management of the tanks:

(1) ASTM designation or specific alloy content of the material

(2) Bases for the conclusion of no aging effects in this environment (for example, EPRI,

ASTM, or similar reference documents with supporting data)

In its response by letter dated December 21, 2004, the applicant stated:

There are two tanks in the NMP1 emergency cooling system that are made of

aluminum alloy with magnesium in a treated water (temperature <140 0 F)

environment. These tanks (TANK-60-9 and TANK-60-10), provide the

demineralized water make-up to the emergency condensers and are in-scope

and subject to AMR.

(1) The tanks are made of wrought-aluminum alloy 5052-H34, which is

essentially pure aluminum with 2.5 percent magnesium and 0.25 percent

chromium.

(2) Aluminum alloyed with magnesium has good corrosion resistance in a

treated water (temperature <140 OF ) environment and resists stress

corrosion cracking. (Reference, Section 2.1.7 and Section 4 of

Appendix A of EPRI TR-1 14882, Non-Class 1 Mechanical

Implementation Guideline and Mechanical Tools, Revision 3.)

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The staff found the applicant's response reasonable and acceptable because the applicant had

provided the bases for the conclusion of no aging effects in the alloyed aluminum tanks;

therefore, the staff's concern described in RAI 3.2-14 is resolved.

The applicant stated as to cracking of aluminum alloy (containing copper or zinc as the primary

alloying elements) valves in a treated water, temperature > 140 OF, environment managed by

ASME Section XI, (Subsections IWB, IWC, IWD) ISI, One-Time Inspection, and Water

Chemistry Control Programs that this material is not in the GALL Report for this component

(Note F). The staff concurred with this statement.

In RAI 3.2-15 dated November 17, 2004, the staff requested that the applicant provide the

following information:

a) ASTM designation or specific alloy content of the material

b) Bases for the conclusion that cracking is the only aging effect in this environment

and EPRI, ASTM, or similar supporting documentary references

In its' response dated December 21, 2004 the applicant stated:

There are six valves in the NMP1 Emergency Cooling System that are made of

aluminum alloy (containing copper or zinc as the primary alloying elements) in a

treated water (temperature <140 OF ) environment. These valves (BV-60-01,

BV-60-02, VLV-60-07, VLV-60-08, VLV-6011 and VLV-60-12) are in-scope and

subject to AMR.

a) The valves are made of aluminum alloy SB-26 (no grade).

b) Aluminum alloyed with copper or zinc as the primary alloying elements is

resistant to general corrosion in a treated water (temperature <140 OF )

environment, but is susceptible to stress corrosion cracking, as discussed in

EPRI TR-1 14882, "Non-Class 1 Mechanical Implementation Guideline and

Mechanical Tools," Revision 3.

The staff found the applicant's response reasonable and acceptable because the applicant had

provided appropriate bases for the conclusion that stress corrosion cracking is the only AERM

in this material-environment combination; therefore, the staff's concern described in RAI 3.2-15

is resolved.

The staff found further that the applicant had identified the appropriate AMPs for the materials

and environment of the NMP1 emergency cooling system components and, the staff's concern

described in RAI 3.2-15 is resolved. The above information is reflected in the ALRA.

On the basis of its review, as discussed above, the staff concludes that there is reasonable

assurance that the applicant has demonstrated that the aging effects associated with the

emergency cooling system components will be adequately managed so that the intended

functions will be maintained consistent with the CLB for the period of extended operation, as

required by 10 CFR 54.21(a)(3).

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Conclusion. On the basis of its review, the staff found that the applicant appropriately evaluated

AMR results involving material, environment, AERMs, and AMP combinations that are not

evaluated in the GALL Report. The staff found that the applicant had demonstrated that the

effects of aging will be adequately managed so that the intended functions will be maintained

consistent with the CLB for the period of extended operation, as required by

10 CFR 54.21(a)(3).

3.2A.3 Conclusion

the staff concludes that there is reasonable assurance that the applicant has provided sufficient

information to demonstrate that the effects of aging for the NMP1 ESF systems components

that are within the scope of license renewal and subject to an AMR will be adequately managed

so that the intended function(s) will be maintained consistent with the CLB for the period of

extended operation, as required by 10 CFR 54.21(a)(3).

The staff also reviewed the applicable UFSAR supplement program summaries and concludes

that they adequately describe the AMPs credited for managing aging of the ESF systems, as

required by 10 CFR 54.21(d).

3.2B NMP2 Aging Management of Engineered Safety Features

This section of the SER documents the staff's review of the applicant's AMR results for the ESF

systems components and component groups associated with the following NMP2 systems:

* hydrogen recombiner system

* high pressure core spray system

* low pressure core spray system

* reactor core isolation cooling system

* residual heat removal system

* standby gas treatment system

3.2B.1 Summary of Technical Information in the Amended Application

In ALRA Section 3.2, the applicant provided AMR results for the ESF systems components and

component groups. In ALRA Table 3.2.1.B, .NMP2 Summary of Aging Management Programs

for the Engineered Safety Features Systems Evaluated in Chapter V of NUREG-1801," the

applicant provided a summary comparison of its AMRs with the AMRs evaluated in the GALL

Report for the ESF systems components and component groups.

The applicant's AMRs incorporated applicable operating experience in the determination of

AERMs. These reviews included evaluation of plant-specific and industry operating experience.

The plant-specific evaluation included reviews of condition reports and discussions with

appropriate site personnel to identify AERMs. The applicant's review of industry operating

experience included a review of the GALL Report and operating experience issues identified

since the issuance of the GALL Report.

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3.2B.2 Staff Evaluation

The staff reviewed ALRA Section 3.2 to determine if the applicant provided sufficient

information to demonstrate that the effects of aging for the ESF systems components that are

within the scope of license renewal and subject to an AMR will be adequately managed so that

the intended functions will be maintained consistent with the CLB for the period of extended

operation, as required by 10 CFR 54.21 (a)(3).

The staff performed an onsite audit of AMRs to confirm the applicant's claim that certain

identified AMRs were consistent with the GALL Report. The staff did not repeat its review of the

matters described in the GALL Report; however, the staff did verify that the material presented

in the ALRA was applicable and that the applicant had identified the appropriate GALL AMRs.

The staff's evaluations of the AMPs are documented in SER Section 3.0.3. Details of the staff's

audit evaluation are documented in the Audit and Review Report and are summarized in SER

Section 3.2B.2.1.

In the onsite audit, the staff also selected AMRs that were consistent with the GALL Report and

for which further evaluation is recommended. The staff confirmed that the applicant's further

evaluations were consistent with the acceptance criteria in SRP-LR Section 3.2.2.2. The staff's

audit evaluations are documented in the Audit and Review Report and are summarized in SER

Section 3.2B.2.2.

In the onsite audit, the staff also conducted a technical review of the remaining AMRs that were

not consistent with, or not addressed in, the GALL Report. The audit and technical review

included evaluating whether all plausible aging effects were identified and evaluating whether

the aging effects listed were appropriate for.the combination of materials and environments

specified. The staff s audit evaluations are documented in the Audit and Review Report and are

summarized in SER Section 3.2B.2.3. The staffs evaluation of its technical review is also

documented in SER Section 3.2B.2.3.

Finally, the staff reviewed the AMP summary descriptions in the USAR supplement to ensure

that they provided an adequate description of the programs credited with managing or

monitoring aging for the ESF systems components.

Table 3.28-1 below provides a summary of the staffs evaluation of NMP2 components, aging

effects/mechanisms, and AMPs listed in ALRA Section 3.2, that are addressed in the GALL

Report

Table 3.2B-1 Staff Evaluation for NMP2 Engineered Safety Features Systems

Components in the GALL Report

Component Group Aging Effect/ AMP In GALL AMP in ALRA:' Staff Evaluation

Mechanism .' Report .... ___I________: __"_.... ______. _

Piping, fittings, and Cumulative fatgue TLAA, evaluated in TLAA This TLAA is

valves in damage accordance with evaluated in

emergency core 10 CFR 54.21(c) Section 4.3, Metal

cooling system - Fatigue Analysis

(Item Number

3.2.1.B-01)

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Component Group Aging Effecti AMP in GALL: AMP in ALRA' Staff E#alua*tion,

Mechanism Report ________________

Piping, fittings, Loss of material Water chemistry Water Chemistry Consistent with

pumps, and valves due to general and one-time Control Program GALL, which

in emergency core corrosion inspection (B2.1.2), One-Time recommends further

cooling system Inspection Program evaluation (See

(Item Number (B2.1.20) Section 3.2B.2.2.2)

3.2.1.B-02)

Components in Loss of material Plant specific Water Chemistry Consistent with

containment spray due to general Control Program GALL, which

(PWR only), corrosion (B2.1.2), One-Time recommends further

standby gas Inspection Program evaluation (See

treatment (BWR (12.1.20) Section 3.2B.2.2.2)

only), containment

isolation, and

emergency core

cooling systems

(Item Number

3.2.1.1-03)

Piping, fittings, Loss of material Water chemistry Water Chemistry Consistent with

pumps, and valves due to pitting and and one-time Control Program GALL, which

in emergency core crevice corrosion inspection (B2.1.2), One-Time recommends further

cooling system Inspection Program evaluation (See

(Item Number (B2.1.20) Section 3.2B.2.2.3)

3.2.1.B-04)

Components in Loss of material Plant-specific Water Chemistry Consistent with

containment spray due to pitting and Control Program GALL, which

(PWR only), crevice corrosion (82.1.2), One-Time recommends further

standby gas Inspection Program evaluation (See

treatment (BWR (82.1.20) Section 3.2B.2.2.3)

only), containment

isolation, and

emergency core

cooling systems

(Item Number

3.2.11.B-05)

Containment Loss of material Plant-specific None Not applicable (See

isolation valves and due to Section 3.21.2.2.4)

associated piping microbiologically

(Item Number influenced corrosion

3.2.1.B-06)

Seals in standby Changes in Plant-specific None Not applicable (See

gas treatment properties due to Section 3.2B.2.2.5)

system elastomer

(Item Number degradation

3.2.1.B-07)

High pressure Loss of material Plant-specific None Not applicable,

safety injection due to erosion PWR only

(charging) pump

miniflow orifice

(Item Number

3.2.1.8-08)

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Component Group ýging Effect! AMP in GALL AMP In ALRA. *': Staff Evaluati on

Mechanism : ::-Report-, _.___._.. _" __._: - _' __. __.. _. __

Drywell and Plugging of flow Plant-specific None Not applicable (See

suppression orifice and spray Section 3.2B.2.2.7)

chamber spray nozzles due to

system nozzles and general corrosion

flow orifices products

(Item Number

3.2.1.B-09)

External surface of Loss of material Plant-specific Systems Walkdown Consistent with

carbon steel due to general Program (B2.1.33) GALL, which

components corrosion recommends further

(Item Number evaluation (See

3.2.1.3-10) Section 3.2B.2.2.2)

Piping and fittings Loss of fracture Thermal aging None Not applicable

of CASS in toughness due to embrittlement of

emergency core thermal aging CASS There are no CASS

cooling system embrittlement piping and fittings

(Item Number with this aging

3.2.1.B-11) effect/mechanism in

NMP2

Components Loss of material Open-cycle cooling Open-Cycle Cooling Consistent with

serviced by due to general, water system Water System GALL, which

open-cycle cooling pitting, and crevice Program (B2.1.10) recommends no

system corrosion, MIC, and further evaluation

(Item Number biofouling; buildup (See Section

3.2.1.B-12) of deposit due to 3.2B.2.1)

biofouling

Components Loss of material Closed-cycle None Not applicable

serviced by due to general, cooling water

closed-cycle cooling pitting, and crevice system No ESF System

system corrosion components [except

(Item Number RHR HXs) serviced

3.2.1..B-13) by closed-cycle cooling water

system

Emergency core Wall thinning due to Flow-accelerated Flow-Accelerated Consistent with

cooling system flow-accelerated corrosion Corrosion Program GALL, which

valves and lines to corrosion (B2.1.9) recommends no

and from HPCI and further evaluation

RCIC pump (See Section

turbines 3.21.2.1)

(Item Number

3.2.1.B-14) Not applicable for

lines to and from

HPCI pump turbine

Pumps, valves, Crack initiation and Water chemistry None Not applicable,

piping, and fittings growth due to SCC PWR only

in containment

spray and

emergency core

cooling systems

(Item Number

3.2.1.8-15)

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Component Group < Aging Effectl AMP In GALL: AMP In ALRA '•iStaff Evaluation

.:Mechanism -Report -

Pumps, valves, Crack initiation and Water chemistry Water Chemistry Consistent with

piping, and fittings growth due to SCC and BWR stress Control Program GALL, which

in emergency core and IGSCC corrosion cracking (82.1.2), BWR recommends no

cooling systems Stress Corrosion further evaluation

(Item Number Cracking Program (See Section

3.2.1.1-16) (B2.1.6), One-Time 3.21.2.1)

Inspection Program

(B2.1.20) Not applicable for

pumps in

emergency core

cooling systems

Carbon steel Loss of material Boric acid corrosion None Not applicable,

components due to boric acid PWR only

(item Number corrosion

3.2.1.1-17) _

The staff's review of the NMP2 component groups followed one of several approaches. One

approach, documented in SER Section 3.2B.2.1, discusses the staff's review of the AMR

results for components in the ESF systems that the applicant indicated are consistent with the

GALL Report and do not require further evaluation. Another approach, documented in SER

Section 3.2B.2.2, discusses the staff's review of the AMR results for components in the ESF

systems that the applicant indicated are consistent with the GALL Report and for which further

evaluation is recommended. A third approach, documented in SER Section 3.2B.2.3, discusses

the staff s review of the AMR results for components in the ESF systems that the applicant

indicated are not consistent with, or not addressed in, the GALL Report. The staffs review of

AMPs that are credited to manage or monitor aging effects of the ESF systems components is

documented in SER Section 3.0.3.

3.2B.2.1 AMR Results That Are Consistent with the GALL Report

Summary of Technical Information in the Amended Application. In ALRA Section 3.2.2.B, the

applicant identified the materials, environments, and AERMs. The applicant identified the

following programs that manage the aging effects related to the ESF systems components:

* ASME Section X1 Inservice Inspection (Subsections IWB, IWC, IWD) Program

* Water Chemistry Control Program

• Flow-Accelerated Corrosion Program

• Open-Cycle Cooling Water System Program

* One-Time Inspection Program

* Preventive Maintenance Program

* Systems Walkdown Program

* Bolting Integrity Program

Staff Evaluation. In ALRA Tables 3.2.2.B-1 through 3.2.2.B-6, the applicant provided a

summary of AMRs for the ESF systems components, and identified which AMRs it considered

to be consistent with the GALL Report.

For component groups evaluated in the GALL Report for which the applicant has claimed

consistency with the GALL Report, and for which the GALL Report does not recommend further

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evaluation, the staff performed an audit and review to determine whether the plant-specific

components contained in these GALL Report component groups were bounded by the GALL

Report evaluation.

The applicant provided a note for each AMR line item. The notes indicate how the information in

the tables aligns with the information in the GALL Report. The staff audited those AMRs with

Notes A through E, which indicate that the AMR is consistent with the GALL Report.

Note A indicates that the AMR line item is consistent with the GALL Report for component,

material, environment, and aging effect. In addition, the AMP is consistent with the AMP

identified in the GALL Report. The staff audited these line items to verify consistency with the

GALL Report and the validity of the AMR for the site-specific conditions.

Note B indicates that the AMR line item is consistent with the GALL Report for component,

material, environment, and aging effect. In addition, the AMP takes some exceptions to the

AMP identified in the GALL Report. The staff audited these line items to verify consistency with

the GALL Report. The staff verified that the identified exceptions to the GALL AMPs had been

reviewed and accepted by the staff. The staff also determined whether the AMP identified by

the applicant was consistent with the AMP identified in the GALL Report and whether the AMR

was valid for the site-specific conditions.

Note C indicates that the component for the AMR line item, although different from, is

consistent with the GALL Report for material, environment, and aging effect. In addition, the

AMP is consistent with the AMP identified by the GALL Report. This note indicates that the

applicant was unable to find a listing of some system components in the GALL Report.

However, the applicant identified a different component in the GALL Report that had the same

material, environment, aging effect, and AMP as the component that was under review. The

staff audited these line items to verify consistency with the GALL Report. The staff also

determined whether the AMR line item of the different component was applicable to the

component under review and whether the AMR was valid for the site-specific conditions.

Note D indicates that the component for the AMR line item, although different from, is

consistent with the GALL Report for material, environment, and aging effect. In addition, the

AMP takes some exceptions to the AMP identified in the GALL Report. The staff audited these

line items to verify consistency with the GALL Report. The staff verified whether the AMR line

item of the different component was applicable to the component under review. The staff

verified whether the identified exceptions to the GALL AMPs had been reviewed and accepted

by the staff. The staff also determined whether the AMP identified by the applicant was

consistent with the AMP identified in the GALL Report and whether the AMR was valid for the

site-specific conditions.

Note E indicates that the AMR line item is consistent with the GALL Report for material,

environment, and aging effect, but a different AMP is credited. The staff audited these line

items to verify consistency with the GALL Report. The staff also determined whether the

identified AMP would manage the aging effect consistent with the AMP identified by the GALL

Report and whether the AMR was valid for the site-specific conditions.

The staff conducted an audit and review of the information provided in the ALRA, as

documented in the Audit and Review Report. The staff did not repeat its review of the matters

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described in the GALL Report; however, the staff did verify that the material presented in the

ALRA was applicable and that the applicant identified the appropriate GALL Report AMRs. The

staffs evaluation is discussed below.

3.2B.2.1.1 Cumulative Fatigue Damage

In the discussion section of ALRA Table 3.2.1 .B Item 3.2.1 .B-01 the applicant stated that

piping, fittings, and valves in the emergency core cooling systems may be subject to cumulative

fatigue damage and are subject to TLAA. In ALRA Table 3.4.2.B-4 the staff noted that a flexible

hose had been included.

As documented in the Audit and Review Report, the applicant explained that the hose is a

flexible bellows welded to end fittings of rigid pipe. A braided stainless steel sheath protects the

outer diameter of the bellows. The component is designed to absorb movement, and no TLAA

has been performed.

Conclusion. The staff evaluated the applicant's claim of consistency with the GALL Report. The

staff also reviewed information pertaining to the applicant's consideration of recent operating

experience and proposals for managing associated aging effects. On the basis of its review, the

staff concludes that there is reasonable assurance that the AMR results, which the applicant

claimed to be consistent with the GALL Report, are consistent with the AMRs in the GALL

Report. Therefore, the staff concludes that there is reasonable assurance that the applicant had

demonstrated that the effects of aging for these components will be adequately managed so

that their intended function(s) will be maintained consistent with the CLB for the period of

extended operation, as required by 10 CFR 54.21(a)(3).

3.2B.2.2 AMR Results That Are Consistent with the GALL Report, for Which Further

Evaluation is Recommended

Summary of Technical Information in the Amended Application. In Section 3.2.2.C of its letter

dated August 19, 2005, the applicant provided further evaluation of aging management as

recommended by the GALL Report for the ESF systems components. The applicant provided

information concerning how it will manage the following aging effects:

* cumulative fatigue damage

* loss of material due to general corrosion

• local loss of material due to pitting and crevice corrosion

* local loss of material due to microbiologically influenced corrosion

* changes in properties due to elastomer degradation

* local loss of material due to erosion

* buildup of deposits due to corrosion

Staff Evaluation. For component groups evaluated in the GALL Report for which the applicant

has claimed consistency with the GALL Report, and for which the GALL Report recommends

further evaluation, the staff audited and reviewed the applicant's evaluation to determine

whether it adequately addressed the issues that were further evaluated. In addition, the staff

reviewed the applicant's further evaluations against the criteria contained in SRP-LR

Section 3.2.2.2. Details of the staffs audit are documented in the staffs Audit and Review

Report. The staffs evaluation of the aging effects is discussed in the following sections.

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3.28.2.2.1 Cumulative Fatigue Damage

In Section 3.2.2.C.1 of its letter dated August 19, 2005, the applicant stated that fatigue is a

TLAA as defined in 10 CFR 54.3. Applicants must evaluate TLAAs in accordance with

10 CFR 54.21(c)(1). SER Section 4.3 documents the staff's review of the applicant's evaluation

of this TLAA.

3.28.2.2.2 Loss of Material Due to General Corrosion

The staff reviewed Section 3.2.2.C.2 of the applicant's letter dated August 19, 2005, against the

criteria in SRP-LR Section 3.2.2.2.2.1.

In Section 3.2.2.C.2 of its letter dated August 19, 2005, the applicant addressed loss of material

at locations with stagnant flow conditions due to general corrosion of pumps, valves, piping, and

fittings of some of the BWR emergency core cooling systems and lines to the suppression

chamber and to the drywell and suppression chamber spray system.

SRP-LR Section 3.2.2.2.2.1 states that the management of loss of material due to general

corrosion of pumps, valves, piping, and fittings of some of the BWR emergency core cooling

systems and of lines to the suppression chamber and to the drywell and suppression chamber.

spray system should be evaluated further. The AMP relies on monitoring and control of primary

water chemistry based on EPRI guidelines to mitigate degradation; however, control of primary

water chemistry does not prevent loss of material due to general corrosion in stagnant flow

conditions. Therefore, the effectiveness of the applicant's Water Chemistry Control Program

should be verified to ensure that corrosion does not occur.

The GALL Report recommends further evaluation of programs to manage loss of material due

to general corrosion to verify the effectiveness of the applicant's Water Chemistry Control

Program. A one-time inspection of select components at susceptible locations is an acceptable

method to determine whether an aging effect and aging effect mechanism is either not

occurring or progressing very slowly so that the component's intended function will be

maintained during the period of extended operation.

In the letter dated August 19, 2005, the applicant stated that the applicable NMP2 systems are

the high pressure core spray, low pressure core spray, reactor core isolation cooling and

residual heat removal systems. The aging effect and aging effect mechanism are managed by

a combination of the Water Chemistry Control Program and One-Time Inspection Program.

The staffs review and evaluation of the applicant's Water Chemistry Control and One-Time

Inspection Programs are documented in SER Sections 3.0.3.2.2 and 3.0.3.1.4, respectively.

The staff reviewed the applicant's further evaluation and concludes that it meets the criteria of

the SRP-LR.

In addition the staff reviewed Section 3.2.2.C.2 of the applicant's letter dated August 19, 2005,

against the criteria of SRP-LR Section 3.2.2.2.2.2.

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In Section 3.2.2.C.2 of its letter dated August 19, 2005, the applicant also addressed loss of

material due to general corrosion of components in the standby gas treatment, containment

isolation, and emergency core cooling systems.

SRP-LR Section 3.2.2.2.2.2 states that loss of material due to general corrosion could occur in

the drywell and suppression chamber spray systems header and spray nozzle components,

standby gas treatment system components, containment isolation valves and associated piping,

the automatic depressurization system piping and fittings, emergency core cooling system

header piping and fittings and spray nozzles, and the external surfaces of carbon steel

components. The GALL Report recommends further plant-specific evaluation to ensure

adequate management of the aging effect and aging effect mechanism.

In the letter dated August 19, 2005, the applicant also stated that the applicable NMP2 systems

are the hydrogen recombiner, reactor core isolation cooling, standby gas treatment, and main

steam (for automatic depressurization) systems. The aging effect and aging effect mechanism

for internal surfaces is managed by the One-Time Inspection Program. The aging effect and

aging effect mechanism for external surfaces of carbon steel components in ECCS systems is

managed by the Systems Walkdown Program.

The staff review and evaluations of the applicant's One-Time Inspection and Systems

Walkdown Programs are documented in SER Sections 3.0.3.1.4 and 3.0.3.3.2, respectively.

The staff reviewed the applicant's further evaluation and concludes that it meets the criteria of

the SRP-LR.

The staff concludes that the applicant's programs have met the criteria of SRP-LR

Section 3.2.2.2.2. For those line items addressed in Section 3.2.2.C.2 of the applicant's letter

dated August 19, 2005, the staff determined that the information in the application is consistent

with the GALL Report and the applicant had demonstrated that the effects of aging will be

adequately managed so that intended functions will be maintained consistent with the CLB

during the period of extended operation as required by 10 CFR 54.21(a)(3).

3.2B.2.2.3 Local Loss of Material Due to Pitting and Crevice Corrosion

The staff reviewed Section 3.2.2.C.3 of the applicant's letter dated August 19, 2005, against the

criteria of SRP-LR Section 3.2.2.2.3.1.

In Section 3.2.2.C.3 of its letter dated August 19, 2005, the applicant addressed loss of material

in stagnant flow conditions due to pitting and crevice corrosion of pumps, valves, piping, and

fittings of some of the BWR emergency core cooling systems and of lines to the suppression

chamber and to the drywell and suppression chamber spray system.

SRP-LR Section 3.2.2.2.3.1 states that the management of local loss of material due to pitting

and crevice corrosion of pumps, valves, piping, and fittings of some of the BWR emergency

core cooling system piping and fittings and of lines to the suppression chamber and to the

drywell and suppression chamber spray system should be evaluated further. The AMP relies on

monitoring and control of primary water chemistry based on EPRI guidelines to mitigate

degradation; however, control of coolant water chemistry does not prevent loss of material due

to crevice and pitting corrosion in stagnant flow conditions. Therefore, the effectiveness of the

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applicant's Water Chemistry Control Program should be verified to ensure that corrosion does

not occur. The GALL Report recommends further evaluation of programs to manage the loss of

material due to pitting and crevice corrosion to verify the effectiveness of the applicant's Water

Chemistry Control Program.

In Section 3.2.2.C.3 of its letter dated August 19, 2005, the applicant stated that the applicable

NM2 systems are the high pressure core spray, low pressure core spray, reactor core isolation

cooling, and residual heat removal systems. The aging effect and aging effect mechanism are

managed by a combination of the Water Chemistry Control Program and the One-Time

Inspection Program.

The staffs review and evaluation of the applicant's Water Chemistry Control and One-Time

Inspection Programs are documented in SER Sections 3.0.3.2.2 and 3.0.3.1.4, respectively.

The staff reviewed the applicant's further evaluation and concludes that it meets the criteria of

the SRP-LR.

In addition the staff reviewed Section 3.2.2.C.3 of the applicant's letter dated August 19, 2005,

against the criteria of SRP-LR Section 3.2.2.2.3.2.

In Section 3.2.2.C.3 of its letter dated August 19, 2005, the applicant also addressed loss of

material due to piting and crevice corrosion of components in the standby gas treatment,

containment isolation, and emergency core cooling systems.

SRP-LR Section 3.2.2.2.3.2 states that local loss of material due to pitting and crevice corrosion

could occur in the containment isolation valves and associated piping and automatic

depressurization system piping and fittings. The GALL Report recommends further evaluation

to ensure adequate management of the aging effect and aging effect mechanism.

In Section 3.2.2.C.3 of its letter dated August 19, 2005, the applicant stated that the applicable

NM2 system is the hydrogen recombiner system. The aging effect and aging effect mechanism

are managed by the One-Time Inspection Program.

The staff reviewed the applicant's One-Time Inspection Program and its evaluation is

documented in SER Section 3.0.3.1.4.

The staff reviewed the applicant's further evaluation and concludes that it meets the criteria in

the SRP-LR.

Based on the programs identified above, the staff concludes that there is reasonable assurance

that the applicant's programs have met the criteria of SRP-LR Section 3.2.2.2.3. For those line

items addressed in Section 3.2.2.C.3 of the applicant's letter dated August 19, 2005, the staff

determined that the information in the application is consistent with the GALL Report and the

applicant had demonstrated that the effects of aging will be adequately managed so that the

intended functions will be maintained consistent with the CLB during the period of extended

operation as required by 10 CFR 54.21 (a)(3).

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3.28.2.2.4 Local Loss of Material Due to Microbiologically Influenced Corrosion

The staff reviewed Section 3.2.2.C.4 of the applicant's letter dated August 19, 2005, against the

criteria of SRP-LR Section 3.2.2.2.4.

The applicant stated in Section 3.2.2.C.4 of its letter dated August 19, 2005, that for the local

loss of material due to microbiologically induced corrosion (MIC) in containment isolation valves

and associated piping this aging effect and aging effect mechanism are not applicable to NMP.

NMP considers MIC an aging effect and aging effect mechanism for systems with raw water

environments. NMP2 has no raw water environment for containment isolation valves or

associated piping; therefore, this issue is not applicable for NMP2. As documented in the Audit

and Review Report, the staff determined through discussions with the applicant's technical

personnel that the local loss of material due to MIC in containment isolation valves and

associated piping is not applicable to NMP2.

Because NMP2 has no containment isolation valves subject to this aging effect and aging effect

mechanism the staff determined that it is not applicable to NMP2.

3.2B.2.2.5 Changes in Properties Due to Elastomer Degradation

The staff reviewed Section 3.2.2.C.5 of the applicant's letter dated August 19, 2005, against the

criteria of SRP-LR Section 3.2.2.2.5.

In Section 3.2.2.C.5 of its letter dated August 19, 2005, the applicant stated that for the seals in

the standby gas treatment system this aging effect and aging effect mechanism are not

applicable to NMP2. The NMP2 standby gas treatment system contains no seals. As

documented in the Audit and Review Report, the staff determined through discussions with the

applicant's technical personnel that the standby gas treatment system contains no seals;

therefore, this aging effect and aging effect mechanism are not applicable to NMP2.

Because NMP2 has no components subject to this aging effect and aging effect mechanism the

staff determined that it is not applicable to NMP2.

3.2B.2.2.6 Local Loss of Material Due to Erosion

The staff reviewed Section 3.2.2.C.6 of the applicant's letter dated August 19, 2005, against the

criteria of SRP-LR Section 3.2.2.2.6.

In Section 3.2.2.C.6 of its letter dated August 19, 2005, the applicant stated that this aging

effect applies to PWRs only.

Because NMP is a BWR the staff found that this aging effect and aging effect mechanism are

not applicable to NMP2.

3.2B.2.2.7 Buildup of Deposits Due to Corrosion

The staff reviewed Section 3.2.2.C.7 of the applicant's letter dated August 19, 2005, against the

criteria of Section 3.2.2.2.7.

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In Section 3.2.2.C.7 of its letter dated August 19, 2005, the applicant addressed the plugging of

components due to general corrosion in the spray nozzles and flow orifices of the drywell and

suppression chamber spray system.

SRP-LR Section 3.2.2.2.7 states that the plugging of components due to general corrosion

could occur in the spray nozzles and flow orifices of the drywell and suppression chamber spray

system. This aging effect and aging effect mechanism and effect will apply because spray

nozzles and flow orifices are wetted occasionally even though most of the time this system is on

standby. The wetting and drying of these components can accelerate this particular corrosion.

The GALL Report recommends further evaluation to ensure adequate management of the

aging effect and aging effect mechanism.

In Section 3.2.2.C.7 of its letter dated August 19, 2005, the applicant stated that for NMP2 the

containment spray cooling mode of the residual heat removal system contains the subject spray

nozzles and flow orifices. The plugging of spray nozzles due to general corrosion is not an

applicable aging effect and aging effect mechanism as these components are stainless steel

not susceptible to general corrosion. The plugging of flow orifices due to general corrosion is

not an applicable aging effect and aging effect mechanism because the lines containing these

components are flushed during quarterly testing which prevents the buildup of deposits.

NMP2 spray nozzles are made of stainless steel and the orifices are periodically flushed;

therefore; the staff found this aging effect not applicable to NMP2.

3.2B.2.2.8. Quality Assurance for Aging Management of Nonsafety-Related Components

SER Section 3.0.4 includes the staff's evaluation of the applicant's quality assurance program.

Conclusion. On the basis of its review, for component groups evaluated in the GALL Report for

which the applicant has claimed consistency with the GALL Report, and for which the GALL

Report recommends further evaluation, the staff determined that the applicant adequately

addressed the issues that were further evaluated. The staff found that the applicant had

demonstrated that the effects of aging will be adequately managed so that the intended

functions will be maintained consistent with the CLB for the period of extended operation, as

required by 10 CFR 54.21(a)(3).

3.2B.2.3 AMR Results That Are Not Consistent with or Not Addressed in the GALL

Report

Summary of Technical Information in the Amended Application. In ALRA Tables 3.2.2.B-1

through 3.2.2.B-6, the staff reviewed additional details of the results of the AMRs for material,

environment, AERM, and AMP combinations that are not consistent with the GALL Report, or

that are not addressed in the GALL Report.

In ALRA Tables 3.2.2.B-1 through 3.2.2.B-6, the applicant indicated, via Notes F through J, that

the combination of component type, material, environment, and AERM does not correspond to

a line item in the GALL Report, and provided information concerning how the aging effect will

be managed. Specifically, Note F indicates that the material for the AMR line item component is

not evaluated in the GALL Report. Note G indicates that the environment for the AMR line item

component and material is not evaluated in the GALL Report. Note H indicates that the aging

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effect for the AMR line item component, material, and environment combination is not evaluated

in the GALL Report. Note I indicates that the aging effect identified in the GALL Report for the

line item component, material, and environment combination is not applicable. Note J indicates

that neither the component nor the material and environment combination for the line item is

evaluated in the GALL Report.

Staff Evaluation. For component type, material, and environment combinations that are not

evaluated in the GALL Report, the staff reviewed the applicant's evaluation to determine

whether the applicant had demonstrated that the effects of aging will be adequately managed

so that the intended function(s) will be maintained consistent with the CLB during the period of

extended operation, as required by 10 CFR 54.21(a)(3). The staff's evaluation is discussed in

the following sections.

3.2B.2.3.1 Engineered Safety Features Systems NMP2 Hydrogen Recombiner System -

Summary of Aging Management Evaluation - ALRA Table 3.2.2.B-1

The staff reviewed ALRA Table 3.2.2.B-1, which summarizes the results of AMR evaluations for

the hydrogen recombiner system component groups.

The staff reviewed the following ALRA Table 3.2.2.8-1 item for the NMP2 hydrogen recombiner

system.

Martensitic precipitation hardenable and superferritic stainless steel bolting in an air

environment for which the applicant has identified no aging effect.

The staff found the applicant's assessment of no aging effect for this material, environment,

and component combination acceptable as supported by industry data and operating

experience. (Also refer to staff's evaluation in RAI 3.2-16 discussed in SER Section 3.2B.2.3.6,

Standby Gas Treatment Systems, where the aging management in a similar component,

material, environment combination is evaluated).

On the basis of its review, as discussed above, the staff concludes that there is reasonable

assurance that the applicant has demonstrated that the aging effects associated with the

hydrogen recombiner system components will be adequately managed so that the intended

functions will be maintained consistent with the CLB for the period of extended operation, as

required by 10 CFR 54.21(a)(3).

3.28.2.3.2 Engineered Safety Features Systems NMP2 High Pressure Core Spray System -

Summary of Aging Management Evaluation - ALRA Table 3.2.2.3-2

The staff reviewed ALRA Table 3.2.2.B-2, which summarizes the results of AMR evaluations for

the high pressure core spray system component groups.

The staff reviewed the following ALRA Table 3.2.2.B-2 items in the NMP2 high pressure core

spray system.

Cumulative fatigue damage of carbon or low alloy steel (yield strength > 100 ksi) closure

bolting for non-borated water system with operating temperatures _> 212 OF, leaking fluid

environment managed by TLAA evaluated in accordance with 10 CFR 54.21(c). The

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applicant stated that this environment is not in the GALL Report for this

material-component combination (Note G). (By attachment 2 of NMPIL 2005 dated

December 1, 2005, the applicant deleted this item from the table)

Cracking and loss of material of martensitic precipitation hardenable and superferritic

stainless steel closure bolting for non-borated water systems with temperatures

> 212 OF, leaking fluid environment managed by the Bolting Integrity Program. The

applicant stated that this environment is not in the GALL Report for this

material-component combination (Note G).

Cumulative fatigue damage in martensitic, precipitation hardenable and superferritic

stainless steel bolting for non-borated systems with temperatures > 212 OF, leaking fluid

environment managed by TLAA evaluated in accordance with 10 CFR 54.21(c). (By

NMPIL 2005 attachment 2 dated December 1, 2005, the applicant deleted this item from

the table)

* Cumulative fatigue damage of nickel-based alloy piping and fittings in a treated water or

steam environment managed by TLAA evaluated in accordance with 10 CFR 54.21(c).

The applicant stated that this material is not in the GALL Report for this component

(Note F).

" Cracking of nicked based piping and fittings in a treated water or steam, temperatures >

482 OF low flow environment managed by the One-Time Inspection and Water

Chemistry Control Programs The applicant stated that this material is not in the GALL

Report for this component (Note F).

" Cracking of wrought austenitic stainless steel restriction orifices in a treated water or

steam, temperature >482 °F, low flow environment managed by the One-Time

Inspection and Water Chemistry Control Programs. The applicant stated that this aging

effect is not in the GALL Report for this component, material, and environment

combination (Note H).

The applicant deleted cumulative fatigue damage of carbon or low alloy steel (yield strength

> 100 ksi) closure bolting for non-borated water systems with operating temperatures > 212 OF,

leaking fluid environment managed by TLAA evaluated in accordance with 10 CFR 54.21(c)

from the table by NMPIL 2005 attachment 2 dated December 1, 2005. The staff found this

deletion acceptable because cumulative fatigue damage is not an applicable AERM for this

component.

The staff found the management of the aging effects of cracking and loss of material of

martensitic precipitation hardenable and superferritic stainless steel closure bolting for

non-borated water systems with temperatures_> 212 OF, leaking fluid environment managed by

the Bolting Integrity Program acceptable as discussed in the evaluation of the program in SER

Section 3.0.3.2.23. The applicant stated that this environment is not in the GALL Report for this

material-component combination (Note G). The staff concurred with this statement.

The applicant deleted cumulative fatigue damage in martensitic, precipitation hardenable and

superferritic stainless steel bolting for non-borated systems with temperatures > 212 OF, leaking

fluid environment managed by TLAA evaluated in accordance with 10 CFR 54.21(c) from the

table by NMPIL 2005 attachment 2 dated December 1, 2005.

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The staff found the aging management of cumulative fatigue damage of nickel-based alloy

piping and fittings in a treated water or steam environment managed by TLAA evaluated in

accordance with 10 CFR 54.21(c) reasonable and acceptable. The applicant stated that this

material is not in the GALL Report for this component (Note F). The staff concurred with this

statement.

The staff found the aging management of cracking of nickel-based piping and fittings in a

treated water or steam, temperature > 482 °F, low flow environment by One-Time Inspection

and Water Chemistry Control Programs appropriate and acceptable in this environment. The

staff evaluations of the One-Time Inspection and Water Chemistry Control Programs are in

SER Sections 3.0.3.1.4 and 3.0.3.2.2 respectively. The applicant stated that this material is not

in the GALL Report for this component (Note F). The staff concurred with this statement.

The staffs evaluation of the management of cracking of wrought austenitic stainless steel

restriction orifices in a treated water or steam, temperature > 482 OF, low flow environment by

One-Time Inspection and Water Chemistry Control Programs is in RAI 3.2-7 (SER

Section 3.2A.2.3.2). The staff found these AMPs appropriate and acceptable for this

environment. The staffs evaluations of One-Time Inspection and Water Chemistry Control

Programs are in SER Sections 3.0.3.1.4 and 3.0.3.2.2 respectively. The applicant stated that

this aging effect is not in the GALL Report for this component, material, and environment

combination (Note H). The staff concurred with this statement.

The staff's evaluations found that the applicant had identified the appropriate AMPs for the

materials and environment associated with the components in the NMP2 high pressure core

spray system.

On the basis of its review, as discussed above, the staff concludes that there is reasonable

assurance that the applicant has demonstrated that the aging effects associated with the high

pressure core spray system components will be adequately managed so that the intended

functions will be maintained consistent with the CLB for the period of extended operation, as

required by 10 CFR 54.21(a)(3).

3.2B.2.3.3 Engineered Safety Features Systems NMP2 Low Pressure Core Spray System -

Summary of Aging Management Evaluation - ALRA Table 3.2.2.8-3

The staff reviewed ALRA Table 3.2.2.B-3, which summarizes the results of AMR evaluations for

the low pressure core spray system component groups.

The staff reviewed the following ALRA Table 3.2.2.B-3 items in the NMP2 low pressure core

spray system

• Cumulative fatigue damage of carbon or low alloy steel (yield strength > 100 ksi) bolting

for non-borated water systems with operating temperatures > 212 °F, leaking fluid

environment managed by TLAA evaluated in accordance with 10 CFR 54.21 (c).The

applicant stated that this environment is not in the GALL Report for this

material-component combination (Note G). (By NMPIL 2005 attachment 2 dated

December 1, 2005, the applicant deleted this item from the table)

Cracking and loss of material in martensitic precipitation hardenable and superferritic

stainless steel bolting for non-borated water systems with operating temperatures

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> 212 OF, leaking fluid environment managed by the Bolting Integrity Program. The

applicant stated that this environment is not in the GALL Report for this

material-component combination (Note G).

" Cumulative fatigue damage of martensitic precipitation hardenable and superferritic

stainless steel bolting for non-borated water systems with operating temperatures

> 212OF, leaking fluid environment managed by TLAA evaluated in accordance with

10 CFR 54.21(c).The applicant stated that this environment is not in the GALL Report

for this material-component combination (Note G). (By NMPIL 2005 attachment 2 dated

December 1, 2005, the applicant deleted this item from the table)

" Cracking in wrought austenitic stainless steel restriction orifices in a treated water,

temperature _> 140 °F, but < 212 OF, environment managed by the One-Time inspection

and Chemistry Control Programs. The applicant stated that this aging effect is not in the

GALL Report for this component, material, and environment combination (Note H).

" Cracking of wrought austenitic stainless steel restriction orifices in a treated water or

steam, temperature > 482 OF, environment managed by the One-Time Inspection and

Chemistry Control Programs. The applicant stated that this aging effect is not in the

GALL Report for this component, material, and environment combination (Note H).

The applicant by NMPIL 2005 attachment 2 dated December 1, 2005, deleted from the table

cumulative fatigue damage of carbon or low alloy steel (yield strength > 100 ksi) bolting for

non-borated water systems with operating temperatures > 212 °F, leaking fluid environment

managed by TLAA.

The staff found management of cracking and loss of material in martensitic precipitation

hardenable and superferritic stainless steel bolting for non-borated water systems with

operating temperatures > 212 OF, leaking fluid environment by the Bolting Integrity Program

acceptable as discussed in the evaluation of the Bolting Integrity Program in SER

Section 3.0.3.2.23. The applicant stated that this environment is not in the GALL Report for this

material-component combination (Note G). The staff concurred with this statement.

The applicant by NMPIL 2005 attachment 2 dated December 1, 2005, deleted from the table

cumulative fatigue damage of martensitic precipitation hardenable and superferritic stainless

steel bolting for non-borated water systems with operating temperatures > 212 OF, leaking fluid

environment managed by TLAA evaluated in accordance with 10 CFR 54.21(c).

The applicant stated that this environment is not in the GALL Report for this

material-component combination (Note G). The staff concurred with this statement.

The applicant stated that cracking in wrought austenitic stainless steel restriction orifices in a

treated water, temperature > 140 OF, but < 212 OF, environment managed by the One-Time

inspection and Chemistry Control Programs is not in the GALL Report for this component,

material, and environment combination (Note H). The staff concurred with this statement. The

staff found these AMPs appropriate and acceptable for managing the aging effect in this

environment. The staff evaluations of the One-Time Inspection and Water Chemistry Control

Programs are provided in SER Sections 3.0.3.1.4 and 3.0.3.2.2, respectively.

The applicant stated that cracking of wrought austenitic stainless steel restriction orifices in a

treated water or steam, temperature > 482 OF, environment managed by the One-Time

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Inspection and Chemistry Control Programs is not in the GALL Report for this component,

material, and environment combination (Note H). The staff concurred with this statement. The

staff evaluation of the management of the aging effects is in RAI 3.2-7 (SER

Section 3.2A.2.3.2). The staff found these management programs appropriate and acceptable

for the aging effect in this environment. The staff evaluations of the One-Time Inspection and

Water Chemistry Control Programs are in SER Sections 3.0.3.1.4 and 3.0.3.2.2 respectively.

The staff's evaluations found that the applicant had identified the appropriate AMPs for the

materials and environment associated with the above components in the NMP2 low pressure

core spray system

On the basis of its review, as discussed above, the staff concludes that there is reasonable

assurance that the applicant has demonstrated that the aging effects associated with the low

pressure core spray system components will be adequately managed so that the intended

functions will be maintained consistent with the CLB for the period of extended operation, as

required by 10 CFR 54.21(a)(3).

3.2B.2.3.4 Engineered Safety Features Systems NMP2 Reactor Core Isolation Cooling System

- Summary of Aging Management Evaluation - ALRA Table 3.2.2.B-4

The staff evaluated the following items in the NMP2 reactor core isolation cooling system

" Cumulative fatigue damage of carbon or low alloy steel (yield strength > 100 ksi) bolting

for non-borated water systems with operating temperatures > 212 OF, leaking fluid

environment managed by TLAA evaluated in accordance with 10 CFR 54.21 (c).The

applicant stated that this environment is not in the GALL Report for this

material-component combination (Note G). (By NMPIL 2005 attachment 2 dated

December 1, 2005, the applicant deleted this item from the table.

" Cumulative fatigue damage of martensitic precipitation hardenable and superferritic

stainless steel bolting for non-borated water systems with operating temperatures

> 212 OF, leaking fluid environment managed by TLAA evaluated in accordance with

10 CFR 54.21(c). The applicant stated that this environment is not in the GALL Report

for this material-component combination (Note G). (By NMPIL 2005 attachment 2 dated

December 1, 2005, the applicant deleted this item from the table)

" Cracking and loss of material of martensitic precipitation hardenable and superferritic

stainless steel closure bolting for non-borated water systems with temperatures

_>212 OF, leaking fluid environment managed by the Bolting Integrity Program. The

applicant stated that this environment is not in the GALL Report for this

material-component combination. (Note G).

Cracking of wrought austenitic stainless steel condensing chambers in a treated water

or steam, temperature > 482 °F, environment managed by the One-Time Inspection and

Chemistry Control Programs. The applicant stated that this aging effect is not in the

GALL Report for this component, material, and environment combination (Note H).

Cumulative fatigue damage of wrought austenitic stainless steel piping and fittings in a

treated water or steam, temperature > 482 OF, environment managed by TLAA

evaluated in accordance with 10 CFR 54.21(c). The applicant stated that this material is

not in the GALL Report for this component (Note F). (By NMPIL 2005 attachment 2

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dated December 1, 2005, the applicant added note 10 stating that this item applies to.

small bore piping not included in the ISI Testing Program).

" Cracking and loss of strength of polymeric external surfaces in an air environment

managed by the Preventive Maintenance Program. The applicant stated that this aging

effect is not in the GALL Report for this component, material, and environment

combination (Note H).

" Cracking in wrought austenitic stainless steel restriction orifices in a treated water,

temperature > 212'F, but < 482 OF, environment managed by the One-Time inspection

and Chemistry Control Programs. The applicant stated that this aging effect is not in the

GALL Report for this component, material, and environment combination (Note H).

" Cracking of wrought austenitic stainless steel restriction orifices in a treated water or

steam, temperature > 482 °F, environment managed by the One-Time Inspection and

Chemistry Control Programs. The applicant stated that this aging effect is not in the

GALL Report for this component, material, and environment combination (Note H).

The applicant deleted cumulative fatigue damage of carbon or low alloy steel (yield strength

> 100 ksi) bolting for non-borated water systems with operating temperatures > 212 °F, leaking

fluid environment managed by TLAA evaluated in accordance with 10 CFR 54.21(c) by NMPIL

2005 attachment 2 dated December 1, 2005. The staff found the deletion acceptable because

cumulative fatigue damage is not an applicable AERM for this component.

The applicant deleted cumulative fatigue damage of martensitic precipitation hardenable and

superferritic stainless steel bolting for non-borated water systems with operating temperatures

> 212 °F, leaking fluid environment managed by TLAA evaluated in accordance with

10 CFR 54.21(c) by NMPIL 2005 attachment 2 dated December 1, 2005. The staff found the

deletion acceptable because cumulative fatigue damage is not an applicable AERM for this

component.

The applicant stated that cracking and loss of material of martensitic precipitation hardenable

and superferritic stainless steel closure bolting for non-borated water systems with

temperatures > 212 °F, leaking fluid environment managed by the Bolting Integrity Program, is

not in the GALL Report for this material-component combination (Note G). The staff concurred

with this statement. The staff found the management of the aging effects acceptable as stated

in the evaluation of the Bolting Integrity Program in SER Section 3.0.3.2.23.

The applicant stated that cracking of wrought austenitic stainless steel condensing chambers in

a treated water or steam, temperature_> 482 °F, environment managed by the One-Time

Inspection and Chemistry Control Programs is not in the GALL Report for this component,

material, and environment combination (Note H). The staff concurred with this statement. The

staff evaluation of the management of the aging effects is in RAI 3.2-7 (SER

Section 3.2A.2.3.2). The staff found these AMPs appropriate and acceptable for the aging

effect in this environment. The staff evaluations of the One-Time Inspection and Water

Chemistry Control Programs is in SER Sections 3.0.3.1.4 and 3.0.3.2.2 respectively.

The applicant stated that cumulative fatigue damage of wrought austenitic steel piping and

fittings in a treated water or steam, temperature > 482 OF, environment managed by TLAA

evaluated in accordance with 10 CFR 54.21(c) is not in the GALL Report for this component

(Note F). The staff concurred with this statement. By NMPIL 2005 attachment 2 dated

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December 1, 2005, the applicant added note 10 stating that this item applies to small bore

piping not included in the ISI Program. This component also is not evaluated in ALRA

Section 4.3. The staff found the aging management of cumulative fatigue damage of small bore

piping by TLAA in accordance with 10 CFR 54.21(c) reasonable and acceptable.

The applicant stated that cracking and loss of strength of polymeric external surfaces in an air

environment managed by the Preventive Maintenance Program is not in the GALL Report for

this component, material, and environment combination (Note H). The staff concurred with this

statement. The staff requested additional information about the Preventive Maintenance

Program tests and inspections to manage the aging effects for this component. In its response

dated November 15, 2005, the applicant stated:

The polymer components in the NMP2 RCIC System are expansion joints

between RCIC System Piping and the Condensate Storage Tank. They are

fabricated of butyl rubber with polyester fabric and metal reinforcement.

The PM Program methods of inspection associated with these expansion

joints are visual, dimensional, and durometer readings as follows:

* Inspection of the expansion joints is performed every two years.

* Replacement of the components is scheduled for every 20 years.

The PM Program acceptance criteria for the inspections are the following:

Visual Inspection

No excessive and deep cracking or cuts of outer cover exposing reinforcing

wire, body rings or fabric.

* No blistering or local areas of deformation or ply separation.

* No leakage or weeping through bellows or at flange connections.

* No soft or gummy areas.

* No mechanical damage due to maintenance or operating activity.

" If expansion joint has a liner, liner is not damaged.

" Structural members and attachment hardware are not damaged and maintain

structural integrity.

Dimensional Inspection

" Face to face dimensions are within design tolerances.

" Durometer readings between 50 - 80 (Shur scale).

The inspections and acceptance criteria for the expansion joints are based on

approved vendor manuals.

The staff found the applicant's response reasonable and acceptable because the Preventive

Maintenance Program tests and inspections are consistent with industry practice and vendor

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recommendations. The staff found the management of the aging effects in polymeric

components by the Preventive Maintenance Program acceptable.

The applicant stated that cracking in wrought austenitic stainless steel restriction orifices in a

treated water, temperature > 212 OF, but < 482 OF, environment managed by the One-Time

Inspection and Chemistry Control Programs is not in the GALL Report for this component,

material, and environment combination (Note H).The staff concurred with this statement. The

staff review of the management of the aging effects is in RAI 3.2-7 (In SER Section 3.2A.2.3.2).

The staff found these AMPs appropriate and acceptable for the aging effect in this environment.

The staff evaluations of the One-Time Inspection and Water Chemistry Control Programs are in

SER Sections 3.0.3.1.4 and 3.0.3.2.2, respectively.

The applicant stated that cracking of wrought austenitic stainless steel restriction orifices in a

treated water or steam, temperature > 482 OF, environment managed by the One-Time

Inspection and Chemistry Control Programs is not in the GALL Report for this component,

material, and environment combination (Note H). The staff concurred with this statement. The

staff review of the management of the aging effects is in RAI 3.2-7 (In SER Section 3.2A.2.3.2).

The staff found these AMPs appropriate and acceptable for managing the aging effect in this

environment. The staff evaluations of the One-Time Inspection and WaterChemistry Control

Programs are provided in SER Sections 3.0.3.1.4 and 3.0.3.2.2, respectively.

The staffs evaluations found that the applicant had identified the appropriate AMPs for the

materials and environment associated with the NMP2 reactor core isolation cooling system

components.

On the basis of its review, as discussed above, the staff concludes that there is reasonable

assurance that the applicant has demonstrated that the aging effects associated with the

reactor core isolation cooling system components will be adequately managed so that the

intended functions will be maintained consistent with the CLB for the period of extended

operation, as required by 10 CFR 54.21(a)(3).

3.2B.2.3.5 Engineered Safety Features Systems NMP2 Residual Heat Removal System -

Summary of Aging Management Evaluation - ALRA Table 3.2.2.B-5

The staff reviewed the following ALRA items for the NMP2 residual heat removal system:

Cumulative fatigue damage of carbon or low alloy steel (yield strength > 100 ksi) bolting for

non-borated water systems with operating temperatures > 212 °F, leaking fluid environment

managed by TLAA evaluated in accordance with 10 CFR 54.21 (c).The applicant stated that

this environment is not in the GALL Report for this material-component combination (Note

G). (By NMPIL 2005 attachment 2 dated December 1, 2005, the applicant deleted this item

from the table)

Cracking and loss of material of martensitic precipitation hardenable and superferritic

stainless steel closure bolting for non-borated water systems with temperatures > 212 OF,

leaking fluid environment managed by the Bolting Integrity Program. The applicant stated

that this environment is not in the GALL Report for this material-component combination

(Note G)

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Cumulative fatigue damage of martensitic precipitation hardenable and superferritic

stainless steel bolting for non-borated water systems with operating temperatures > 212 OF,

leaking fluid environment managed by TLAA evaluated in accordance with

10 CFR 54.21 (c).The applicant stated that this environment is not in the GALL Report for

this material-component combination (Note G). (By NMPIL 2005 attachment 2 dated

December 1, 2005, the applicant deleted this item from the table)

The applicant deleted cumulative fatigue damage of carbon or low alloy steel (yield strength

> 100 ksi) bolting for non-borated water systems with operating temperatures > 212 *F, leaking

fluid environment managed by TLAA evaluated in accordance with 10 CFR 54.21(c) by NMPIL

2005 attachment 2 dated December 1, 2005. The staff found the deletion acceptable because

cumulative fatigue damage for this component is not an applicable AERM.

The applicant stated that for cracking and loss of material of martensitic precipitation

hardenable and superferritic stainless steel closure bolting for non-borated water systems with

temperatures > 212 OF, leaking fluid environment managed by the Bolting Integrity Program this

environment is not in the GALL Report for this material-component combination (Note G). The

staff concurred with this statement. The staff found the management of the aging effects

acceptable as discussed in the evaluation of the Bolting Integrity Program in SER

Section 3.0.3.2.23.

The applicant deleted cumulative fatigue damage of martensitic precipitation hardenable and

superferritic stainless steel bolting for non-borated water systems with operating

temperatures > 212 *F, leaking fluid environment managed by TLAA evaluated in accordance

with 10 CFR 54.21(c) by NMPIL 2005 attachment 2 dated December 1, 2005. The staff found

the deletion acceptable because cumulative fatigue damage for this component is not an

applicable AERM.

The staff's evaluations found that the applicant had identified the appropriate AMPs for the

materials and environment associated with the above components in the NMP2 residual heat

removal system.

On the basis of its review, as discussed above, the staff concludes that there is reasonable

assurance that the applicant has demonstrated that the aging effects associated with the

residual heat removal system components will be adequately managed so that the intended

functions will be maintained consistent with the CLB for the period of extended operation, as

required by 10 CFR 54.21(a)(3).

3.2B.2.3.6 Engineered Safety Features Systems NMP2 Standby Gas Treatment System -

Summary of Aging Management Evaluation - ALRA Table 3.2.2.B-6 ,

The staff reviewed the following ALRA items for the NMP2 standby gas treatment system

* Martensitic precipitation hardenable and super ferritic stainless steel bolting in an air

environment for which the applicant has assigned no aging effect

" Loss of material for wrought austenitic stainless steel heaters in an air with moisture or

wetting temperature < 140°F environment managed by the One-Time Inspection Program.

The applicant stated that this aging effect is not in the GALL Report for this component,

material, and environment combination (Note H).

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* Loss of material for wrought austenitic stainless steel piping and fittings in an air with

moisture or wetting temperature < 140 °F environment managed by the One-Time

Inspection Program. The applicant stated that this aging effect is not in the GALL Report

for this component, material, and environment combination (Note H).

" Loss of material for aluminum and aluminum alloyed with manganese, magnesium plus

silicon valves in an air with moisture or wetting temperature < 140 °F environment managed

by One-Time Inspection Program. The applicant stated that this aging effect is not in the

GALL Report for this component, material, and environment combination (Note H).

" Loss of material for wrought austenitic stainless steel valves in an air with moisture or

wetting temperature < 140°F environment managed by One-Time Inspection Program.

The applicant stated that this aging effect is not in the GALL Report for this component,

material, and environment combination (Note H).

The staff requested that the applicant justify assigning no aging effect to the martensitic

precipitation hardenable and superferritic stainless steel bolting. As addressed in RAI 3.2.16 the

applicant stated:

The material specification for the bolting corresponding to the ALRA line item for

martensitic precipitation hardened and superferritic stainless steel bolting in air

(temperature < 140 OF) environments is ASTM A193 Grade B6, which has a minimum

specified tempering temperature of 1100 OF. Material with this heat treatment would

have a yield strength of approximately 100 ksi. The material specification for the

bolting corresponding to the ALRA line items for carbon or low allow steel (yield

strength > 100 ksi) bolting in a moist air (temperature < 140 °F) environment is ASTM

Al 93 Grade B7, which has a minimum tempering temperature of 1100 °F. Yield

strengths for Type 4140 steel bar, which is a steel grade that meets A193 chemical

requirements, are below 150 ksi when tempered at 1100 OF. Therefore, for both

material types, the material yield strengths will not exceed 150 ksi.

GALL Report Section XI.M 18, Bolting Integrity, under the "parameters monitored/inspected"

program element states that cracking must be monitored only for bolts with yield strengths

exceeding 150 ksi. Therefore, that cracking is not identified as an aging effect for the subject

bolts is not inconsistent with the GALL Report.

Loss of preload typically would not be an aging effect requiring management for bolting in low

temperature systems. The GALL Report specifies only loss of preload as an aging effect

requiring management for components in the reactor vessel and internals and reactor coolant

pressure boundary. For closure bolting in ESF systems the GALL Report addresses only

carbon and low alloy steel bolting in high-pressure or high temperature systems. The bolting

with the material-environment combinations of carbon or low alloy steel (yield strength > 100

ksi) and martensitic precipitation hardened and superferritic stainless steel bolting in air are not

in high temperature or high pressure systems. Furthermore, the GALL Report does not identify

loss of preload even for ESF bolts in high temperature, high pressure systems. Therefore, the

determination that loss of preload does not apply to the subject bolts is consistent with the

GALL Report.

The staff found the applicant's assessment reasonable, acceptable, and consistent with the

GALL Report.

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In a-RAI 3.2.2.8-1 dated November 22, 2005, the staff requested that the applicant provide

assurance that a one-time inspection alone is adequate to manage the aging effect of loss of

material for wrought austenitic stainless steel heaters in an air with moisture or wetting

temperature < 140=F environment managed by the One-Time Inspection Program. In addition

the staff requested the applicant to discuss the specifics of the tests and inspections for these

components.

In its response, letter dated December 5, 2005, the applicant stated:

As in the response to RAI 3.4.2.B-2, for the identified components fabricated of either

stainless steel (SS) or alloyed aluminum (high aluminum, low alloy content) in a low

temperature, moist air environment, it is considered unlikely that the loss of material

aging effect will occur. SS in this mild air environment (containment environment)

where any moisture would have extremely low concentrations of halides would not

exhibit aging effects. Aluminum forms a protective passive layer in mild environments

that protects the base metal from further corrosion. The One-Time Inspection Program

activities will utilize visual, volumetric, and other inspection techniques consistent with

industry practices to provide a means of verifying that aging management is not

occurring or is progressing at such a slow rate that the intended function of the -

components would not be adversely affected.

The staff found the applicant's response reasonable and acceptable because the applicant

explained that the aging effect is unlikely to occur in this environment for this component. The

staff therefore considered the One-Time Inspection Program adequate for managing the aging

effect in this environment. The staffs evaluation of the One-Time Inspection Program is in SER

Section 3.0.3.1.4. The staff also concurred with the applicant's assessment that this aging

effect is not in the GALL Report for this component, material, and environment combination

(Note H).

The staff found reasonable and acceptable as stated in a-RAI 3.2.2.1-1 management of loss of

material for wrought austenitic stainless steel piping and fittings in an air with moisture or

wetting temperature < 140 OF environment by the One-Time Inspection Program. The staffs

evaluation of the One-Time Inspection Program is in SER Section 3.0.3.1.4. The staff also

concurred with the applicant's assessment that this aging effect is not in the GALL Report for

this component, material, and environment combination (Note H).

The staff found reasonable and acceptable as stated in a-RAI 3.2.2.1-1 management of loss of

material for wrought austenitic stainless steel valves in an air with moisture or wetting

temperature < 140*°F environment by the One-Time Inspection Program. The staffs evaluation

of the One-Time Inspection Program is in SER Section 3.0.3.1.4. The staff also concurred with

the applicant's assessment that this aging effect is not in the GALL Report for this component,

material, and environment combination (Note H).

The staffs evaluation of loss of material for aluminum and aluminum alloyed with manganese,

magnesium plus silicon valves in an air with moisture or wetting temperature < 140 OF,

environment managed by One-Time Inspection Program is in a-RAI 3.2.2.8-1. The staffs

evaluation of the One-Time Inspection Program is in SER Section 3.0.3.1.4. The staff found it

reasonable and acceptable. The staff also concurred with the applicant's assessment that this

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aging effect is not in the GALL Report for this component, material, and environment

combination (Note H).

The staffs evaluations found that the applicant had identified the appropriate AMPs for the

materials and environment of the NMP2 standby gas treatment system components.

On the basis of its review, as discussed above, the staff concludes that there is reasonable

assurance that the applicant demonstrated that the aging effects associated with the standby

gas treatment system components will be adequately managed so that the intended functions

will be maintained consistent with the CLB for the period of extended operation, as required by

10 CFR 54.21(a)(3).

Conclusion. On the basis of its review, the staff found that the applicant appropriately evaluated

AMR results involving material, environment, AERMs, and AMP combinations that are not

evaluated in the GALL Report. The staff found that the applicant had demonstrated that the

effects of aging will be adequately managed so that the intended functions will be maintained

consistent with the CLB for the period of extended operation, as required by

10 CFR 54.21(a)(3).

3.2B.3 Conclusion

the staff concludes that there is reasonable assurance that the applicant had provided sufficient

information to demonstrate that the effects of aging for the NMP2 ESF systems components

that are within the scope of license renewal and subject to an AMR will be adequately managed

so that the intended function(s) will be maintained consistent with the CLB for the period of

extended operation, as required by 10 CFR 54.21(a)(3).

The staff also reviewed the applicable USAR supplement program summaries and concludes

that they adequately describe the AMPs credited for managing aging of the ESF systems, as

required by 10 CFR 54.21(d).

3.3 Aging Management of Auxiliary Systems

3.3A NMPI Aging Management of Auxiliary Systems

This section of the SER documents the staffs review of the applicant's AMR results for the

auxiliary systems components and component groups associated with the following NMP1

systems:

" circulating water system

" city water system

* compressed air systems

• containment systems

• control room HVAC system

" diesel generator building ventilation system

" emergency diesel generator system

• fire detection and protection system

" hydrogen water chemistry system

" liquid poison system

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" miscellaneous non contaminated vents and drains system

* neutron monitoring system

" radioactive waste disposal building HVAC system

• radioactive waste system

• reactor building closed loop cooling water system

* reactor building HVAC system

* reactor water cleanup system

• sampling system

• service water system

* shutdown cooling system

* spent fuel pool filtering and cooling system

" turbine building closed loop cooling water system

• turbine building HVAC system

• electric steam boiler system

• makeup and demineralizer system

3.3A.1 Summary of Technical Information in the Amended Application

In ALRA Section 3.3, the applicant provided AMR results for the auxiiary systems components

and component groups. In ALRA Table 3.3.1.A, "NMP1 Summary of Aging Management

Programs for the Auxiliary Systems Evaluated in Chapter VII of NUREG-1 801," the applicant

provided a summary comparison of its AMRs with the AMRs evaluated in the GALL Report for

the auxiliary systems components and component groups.

The applicant's AMRs incorporated applicable operating experience in the determination of

AERMs. These reviews included evaluation of plant-specific and industry operating experience.

The plant-specific evaluation included reviews of condition reports and discussions with

appropriate site personnel to identify AERMs. The applicant's review of industry operating

experience included a review of the GALL Report and operating experience issues identified

since the issuance of the GALL Report.

3.3A.2 Staff Evaluation

The staff reviewed ALRA Section 3.3 to determine if the applicant provided sufficient

information to demonstrate that the effects of aging for the auxiliary systems components that

are within the scope of license renewal and subject to an AMR will be adequately managed so

that the intended functions will be maintained consistent with the CLB for the period of extended

operation, as required by 10 CFR 54.21 (a)(3).

The staff performed an onsite audit of AMRs to confirm the applicant's claim that certain

identified AMRs were consistent with the GALL Report. The staff did not repeat its review of the

matters described in the GALL Report; however, the staff did verify that the material presented

in the ALRA was applicable and that the applicant had identified the appropriate GALL AMRs.

The staff's evaluations of the AMPs are documented in SER Section 3.0.3. Details of the staffs

audit evaluation are documented in the Audit and Review Report and are summarized in SER

Section 3.3A.2.1.

In the onsite audit, the staff also selected AMRs that were consistent with the GALL Report and

for which further evaluation is recommended. The staff confirmed that the applicant's further

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evaluations were consistent with the acceptance criteria in SRP-LR Section 3.3.2.2. The staff's

audit evaluations are documented in the Audit and Review Report and are summarized in SER

Section 3.3A.2.2.

In the onsite audit, the staff also conducted a technical review of the remaining AMRs that were

not consistent with, or not addressed in, the GALL Report. The audit and technical review

included evaluating whether all plausible aging effects were identified and evaluating whether

the aging effects listed were appropriate for the combination of materials and environments

specified. The staff's audit evaluations are documented in the Audit and Review Report and are

summarized in SER Section 3.3A.2.3. The staff's evaluation of its technical review is also

documented in SER Section 3.3A.2.3.

Finally, the staff reviewed the AMP summary descriptions in the UFSAR supplement to ensure

that they provided an adequate description of the programs credited with managing or

monitoring aging for the auxiliary systems components.

Table 3.3A-1 below provides a summary of the staffs evaluation of NMP1 components, aging

effects and mechanisms, and AMPs listed in ALRA Section 3.3, that are addressed in the GALL

Report

Table 3.3A-1 Staff Evaluation for NMPI Auxiliary Systems Components in the GALL

Report

Component Group - Aging EffectlU.'.' ,•AMP In GALL AMPin ALRA'.: Staff Evaluation

___ __ __ __ !,•.": __ •i Mechanism -ý,' z' ýReport ______... _____. . ________________

Components in Loss of material Water chemistry Water Chemistry Consistent with

spent fuel pool due to general, and one-time Control Program GALL, which

cooling and cleanup pitting, and crevice inspection (B2.1.2), One-Time recommends further

(Item Number corrosion Inspection Program evaluation (See

3.3.1.A-01) (B2.1.20) Section 3.3A.2.2.1)

Linings in spent fuel Hardening, cracking Plant specific Preventive Consistent with

pool cooling and and loss of strength Maintenance GALL, which

cleanup system; due to elastomer Program (82.1.32) recommends further

seals and collars In degradation; loss of evaluation (See

ventilation systems material due to Section 3.3A.2.2.2)

(Item Number wear

3.3.1.A-02)

Components in load Cumulative fatigue TLAA, evaluated in TLAA No TLAA for

handling, chemical damage accordance with components in load

and volume control 10 CFR 54.21(c) handling systemssystem (PWR), and does not meet TLAA

reactor water criteria (See Section

cleanup and 3.3A.2.1.1)

shutdown cooling

systems (older

BWR)

(Item Number

3.3.1.A-03)

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Component GroUp Aging EffeAtMI -AM AMP in GALL. :.uAMP in ALRA 'Staff Evialuation

____L ______ "Mechanism _ -,Report _________- ___ _____________

Heat exchangers in Crack initiation and Plant specific Water Chemistry Consistent with

reactor water growth due to SCC Control Program GALL, which

cleanup system or cracking (B2.1.2), Preventive recommends further

(BWR); high Maintenance evaluation (See

pressure pumps in Program (B2.1.32) Section 3.3A.2.2.4)

chemical and

volume control

system (PWR)

(Item Number

3.3.1.A-04)

Components in Loss of material Plant specific Closed-Cycle Consistent with

ventilation systems, due to general, Cooling Water GALL, which

diesel fuel oil pitting, and crevice System Program recommends further

system, and corrosion, and MIC (B2.1.11), Fire evaluation (See

emergency diesel Water System Section 3.3A.2.2.5)

generator systems; Program (82.1.17),

external surfaces of One-Time

carbon steel Inspection Program

components (B2.1.20),

(Item Number 10 CFR 50

3.3.1.A-05) Appendix J

Program (B2.1.26),

Preventive

Maintenance

Program (12.1.32),

Systems Walkdown

Program (62.1.33)

Components in Loss of material One-time inspection None Not applicable (See

reactor coolant due to galvanic, Section 3.3A.2.2.6)

pump oil collect general, pitting, and

system of fire crevice corrosion

protection

(Item Number

3.3.1 .A-06)

Diesel fuel oil tanks Loss of material Fuel oil chemistry Fuel Oil Chemistry Consistent with

in diesel fuel oil due to general, and one-time Program (12.1.18), GALL, which

system and pitting, and crevice inspection One-Time recommends further

emergency diesel corrosion, MIC, and Inspection Program evaluation (See

generator system biofouling (82.1.20) Section 3.3A.2.2.7)

(Item Number

3.3.1.A-07)

Piping, pump Loss of material Water chemistry Water Chemistry Consistent with

casing, and valve due to pitting and and one-time Control Program GALL, which

body and bonnets in crevice corrosion inspection (82.1.2), One-Time recommends further

shutdown cooling Inspection Program evaluation.

system (older BWR) (82.1.20) One-Time

(Item Number Inspection Program

3.3.1 .A-08) is used for further

evaluation (See Section 3.3A.2.2.1)

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Component Group Aging Effect! AMPIn GALL AMP In ALRA Staff Evaluation'

, Mechanismn Report ____"_.________,

Heat exchangers in Crack initiation and Water chemistry None Not applicable (See

chemical and growth due to SCC and a plant-specific Section 3.3A.2.2.9)

volume control and cyclic loading verification program

system

(Item Number

3.3.1.A-09)

Neutron absorbing Reduction of Plant specific Water Chemistry (See Section

sheets in spent fuel neutron absorbing Control Program 3.3A.2.2.10)

storage racks capacity and loss of (B2.1.2), One-Time

(Item Number material due to Inspection Program

3.3.1.A-10) general corrosion (B2.1.20)

(Boral, boron steel)

New fuel rack Loss of material Structures None Not applicable.

assembly due to general, monitoring

(Item Number pitting, and crevice The new fuel rack

3.3.1.A-11) corrosion assembly is not in

scope.

Neutron absorbing Reduction of Boraflex monitoring Boraflex Monitoring Consistent with

sheets in spent fuel neutron absorbing Program (B2.1.12) GALL, which

storage racks capacity due to recommends no

(Item Number. Boraflex further evaluation

3.3.1.A-12) degradation (See Section

3.3A.2.1)

Spent fuel storage Crack initiation and Water chemistry Water Chemistry Consistent with

racks and valves in growth due to stress Control Program GALL, which

spent fuel pool corrosion cracking (B2.1.2) recommends no

cooling and cleanup further evaluation

(Item Number (See Section

3.3.1.A-13) 3.3A.2. 1)

Closure bolting and Loss of material Boric acid corrosion Systems Walkdown Consistent with

external surfaces of due to boric acid Program (B2.1.33), GALL, which

carbon steel and corrosion Bolting Integrity recommends no

low-alloy steel Program (B2.1.36) further evaluation

components (See Section

(Item Number 3.3A.2.1.7)

3.3.1.A-14)

Components in or Loss of material Closed-cycle Closed-Cycle Consistent with

serviced by due to general, cooling water Cooling Water GALL, which

closed-cycle cooling pitting, and crevice system System .Program recommends no

water system corrosion, and MIC (B2.1.11) further evaluation

(Item Number (See Section

3.3.1.A-15) 3.3A.2.1)

Cranes including Loss of material Overhead heavy Inspection of Consistent with

bridge and trolleys due to general load and light load Overhead Heavy GALL, which

and rail system in corrosion and wear handling systems Load and Light recommends no

load handling Load Handling further evaluation

system Systems Program (See Section

(Item Number (B2.1.13) 3.3A.2.1)

3.3.1.A-16)

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Component Group vAging Effect.! AMP In GALL ",-' -' AMP In ALRA ::.Staff Evaluation

Mechanism Repo'rt ________________ ___.____________

Components in or Loss of material Open-cycle cooling Open-Cycle Consistent with

serviced by due to general, water system Cooling Water GALL, which

open-cycle cooling pitting, crevice, and Program (B2.1.10); recommends no

water systems galvanic corrosion, One-Time further evaluation

(Item Number MIC, and biofouling; Inspection Program (See Section

3.3.1.A-17) buildup of deposit (82.1.20); 3.3A.2.1)

due to biofouling Preventive.

Maintenance

Program (B2.1.32)

Buried piping and Loss of material Buried piping and Buried Piping and Consistent with

fittings due to general, tanks surveillance Tanks Inspection GALL, which

(Item Number pitting, and crevice Program (B2.1.22) recommends further

3.3.1.A-18) corrosion, and MIC or evaluation (See Section 3.3A.2.2.1 1)

Buried piping and

tanks inspection

Components in Loss of material Compressed air Compressed Air Consistent with

compressed air due to general and monitoring Monitoring Program GALL, which

system . pitting corrosion (82.1.14), Bolting recommends no

(Item Number Integrity Program further evaluation

3.3.1.A-19) (82.1.36) (See Section

3.3A.2.1)

Components (doors Loss of material Fire protection Fire Protection Consistent with

and barrier due to wear, Program (82.1.16) GALL, which

penetration seals) hardening and recommends no

and concrete shrinkage due to further evaluation

structures in fire weathering (See Section

protection 3.3A.2. 1)

(Item Number

3.3.1 .A-20)

Components in Loss of material Fire water system Fire Water System Consistent with

water-based fire due to general, Program (82.1.17) GALL, which

protection pitting, crevice, and recommends no

(Item Number galvanic corrosion, further evaluation

3.3.1.A- 21) MIC, and biofouling (See Section

3.3A.2.1)

Components in Loss of material Fire protection and None Not applicable. Fuel

diesel fire system due to galvanic, fuel oil chemistry oil supply lines do

(Item Number general, pitting, and not have this aging

3.3.1.A-22) crevice corrosion effect.

Tanks in diesel fuel Loss of material Aboveground None Not applicable.

oil system due to general, carbon steel tanks Diesel fuel oil tanks

(Item Number pitting, and crevice are not supported

3.3.1.A-23) corrosion on earthen or

concrete

foundations

Closure bolting Loss of material Bolting integrity Bolting Integrity Consistent with

(Item Number due to general Program (B2.1.36) GALL, which

3.3.1.A-24) corrosion; crack recommends no initiation and growth further evaluation

due to cyclic (See Section

loading and SCC 3.3A.2.1)

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N..'

Component Group :.Aging Effect/ AMP In GALL AMP In ALRA: Staff Evaluation'

Mechanism Report _________" ___ _... _' _______

Components in Crack initiation and Water chemistry Water Chemistry Consistent with

contact with sodium growth due to SCC Control Program GALL, which

pentaborate (B2.1.2) recommends no

solution in standby further evaluation

liquid control (See Section

system (BWR) 3.3A.2.1)

(Item Number

3.3.1 .A-25)

Components in Crack initiation and Reactor water Water Chemistry Consistent with

reactor water growth due to SCC cleanup system Control Program GALL, which

cleanup system and IGSCC inspection (B2.1.2), BWR recommends no

(Item Number Reactor Water further evaluation

3.3.1.A-26) Cleanup Systemi (See Section

Program (B2.1.15), 3.3A.2.1)

One-Time

Inspection Program

(B2.1.20)

Components in Crack initiation and BWR stress BWR Stress Consistent with

shutdown cooling growth due to SCC corrosion cracking Corrosion Cracking GALL, which

system (older BWR) and water chemistry Program (B2.1.6), recommends no

(Item Number Water Chemistry further evaluation

3.3.1.A-27) Program (B2.1.2) (See Section

3.3A.2.1)

Components in Loss of material Closed-aycle Closed-Cycle Consistent with

shutdown cooling due to pitting and cooling water Cooling Water GALL, which

system (older BWR) crevice corrosion, system Program (B2.1.11) recommends no

(Item Number and MIC further evaluation

3.3.1.A-28) (See Section

3.3A.2.1)

Components Loss of material Selective leaching Closed-Cycle Consistent with

(aluminum bronze, due to selective of materials Cooling Water GALL, which

brass, cast iron, leaching Program (B2.1.11); recommends no

cast steel) in Open-Cycle further evaluation

open-cycle and Cooling Water (See Section

closed-cycle cooling Program (B2.1.10); 3.3A.2.1)

water systems, and Selective Leaching

ultimate heat sink of Materials

(Item Number Program (B2.1.21)

3.3.1 .A-29)

Fire barriers, walls, Concrete cracking Fire protection and None Not applicable.

ceilings, and floors and spalling due to structures

in fire protection freeze-thaw, monitoring The plant-specific

(Item Number aggressive environment for

3.3.1.A-30) chemical attack, concrete structures

and reaction with in fire protection

aggregates; loss of does not generate

material due to the listed aging

corrosion of effects.

embedded steel

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The staff's review of the NMP1 component groups followed one of several approaches. One

approach, documented in SER Section 3.3A.2.1, discusses the staff's review of the AMR

results for components in the auxiliary systems that the applicant indicated are consistent with

the GALL Report and do not require further evaluation. Another approach, documented in SER

Section 3.3A.2.2, discusses the staff's review of the AMR results for components in the auxiliary

systems that the applicant indicated are consistent with the GALL Report and for which further

evaluation is recommended. A third approach, documented in SER Section 3.3A.2.3, discusses

the staff's review of the AMR results for components in the auxiliary systems that the applicant

indicated are not consistent with, or not addressed in, the GALL Report. The staff's review of

AMPs that are credited to manage or monitor aging effects of the auxiliary systems components

is documented in SER Section 3.0.3.

3.3A.2.1 AMR Results That Are Consistent with the GALL Report

Summary of Technical Information in the Amended Application. In ALRA Section 3.3.2.A, the

applicant identified the materials, environments, and AERMs. The applicant identified the

following programs that manage the aging effects related to the auxiliary systems components:

* ASME Section X1 Inservice Inspection (Subsections IWB, IWC, IWD) Program

0 Water Chemistry Control Program . Flow-Accelerated Corrosion Program . Open-Cycle Cooling Water System Program

0 Closed-Cycle Cooling Water System Program

* Compressed Air Monitoring Program

* BWR Reactor Water Cleanup System Program

* Fire Protection Program

* Fire Water System Program

0 Fuel Oil Chemistry Program

• One-Time Inspection Program

0 Selective Leaching of Materials Program

0 Buried Piping and Tanks Inspection Program

* 10 CFR 50 Appendix J Program

* Preventive Maintenance Program

0 Systems Walkdown Program

* Bolting Integrity Program

Staff Evaluation. In ALRA Tables 3.3.2.A-1 through 3.3.2.A-25, the applicant provided a

summary of AMRs for the auxiliary systems components, and identified which AMRs it

considered to be consistent with the GALL Report.

For component groups evaluated in the GALL Report for which the applicant has claimed

consistency with the GALL Report, and for which the GALL Report does not recommend further

evaluation, the staff performed an audit and review to determine whether the plant-specific

components contained in these GALL Report component groups were bounded by the GALL

Report evaluation.

The applicant provided a note for each AMR line item. The notes indicate how the information in

the tables aligns with the information in the GALL Report. The staff audited those AMRs with

Notes A through E, which indicate that the AMR is consistent with the GALL Report.

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Note A indicates that the AMR line item is consistent with the GALL Report for component,

material, environment, and aging effect. In addition, the AMP is consistent with the AMP

identified in the GALL Report. The staff audited these line items to verify consistency with the

GALL Report and the validity of the AMR for the site-specific conditions.

Note B indicates that the AMR line item is consistent with the GALL Report for component,

material, environment, and aging effect. In addition, the AMP takes some exceptions to the

AMP identified in the GALL Report. The staff audited these line items to verify consistency with

the GALL Report. The staff verified that the identified exceptions to the GALL AMPs had been

reviewed and accepted by the staff. The staff also determined whether the AMP identified by

the applicant was consistent with the AMP identified in the GALL Report and whether the AMR

was valid for the site-specific conditions.

Note C indicates that the component for the AMR line item, although different from, is

consistent with the GALL Report for material, environment, and aging effect. In addition, the

AMP is consistent with the AMP identified by the GALL Report. This note indicates that the

applicant was unable to find a listing of some system components in the GALL Report.

However, the applicant identified a different component in the GALL Report that had the same

material, environment, aging effect, and AMP as the component that was under review. The

staff audited these line items to verify consistency with the GALL Report. The staff also

determined whether the AMR line item of the different component was applicable to the

component under review and whether the AMR was valid for the site-specific conditions.

Note D indicates that the component for the AMR line item, although different from, is

consistent with the GALL Report for material, environment, and aging effect. In addition, the

AMP takes some exceptions to the AMP identified in the GALL Report. The staff audited these

line items to verify consistency with the GALL Report. The staff verified whether the AMR line

item of the different component was applicable to the component under review. The staff

verified whether the identified exceptions to the GALL AMPs had been reviewed and accepted

by the staff. The staff also determined whether the AMP identified by the applicant was

consistent with the AMP identified in the GALL Report and whether the AMR was valid for the

site-specific conditions.

Note E indicates that the AMR line item is consistent with the GALL Report for material,

environment, and aging effect, but a different aging management program is credited. The staff

audited these line items to verify consistency with the GALL Report. The staff also determined

whether the identified AMP would manage the aging effect consistent with the AMP identified

by the GALL Report and whether the AMR was valid for the site-specific conditions.

The staff conducted an audit and review of the information provided in the ALRA, as

documented in the Audit and Review Report. The staff did not repeat its review of the matters

described in the GALL Report; however, the staff did verify that the material presented in the

ALRA was applicable and that the applicant identified the appropriate GALL Report AMRs. The

staffs evaluation is discussed below.

3.3A.2.1.1 Cumulative Fatigue Damage

In ALRA Table 3.3.1.A Item 3.3.1.A-03 the applicant stated that cumulative fatigue damage is

managed using a TLAA.

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As documented in the Audit and Review Report, the staff asked the applicant to clarify the

statement on Table 3.3.1.A (page 3.3-86) of the ALRA that NMP has no TLAA for components

in load handling systems. The staff requested the applicant to justify technically why this aging

effect and aging effect mechanism was not applied to NMP. In its letter dated December 1,

2005, the applicant stated that this issue has been screened against the six criteria for a TLAA.

Furthermore in this letter the applicant stated that the operating cycles for the cranes did not

meet the criteria for a TLAA because (1) there were no actual calculations or analyses in the

CLB projecting the number of operating cycles and (2) for cranes designed to CMAA-70 an

estimate of the number of possible operating cycles in 60 years, a substantial fraction (40-95

percent) of the crane maximum rated load, was a very small percentage of the allowable

number of cycles (for the NMP2 reactor building polar crane 1500 cycles versus a minimum

allowable number of cycles of 100,000). Therefore, generating a formal calculation of operating

cycles for 60 years would not result in any meaningful limitations on the use of the crane (i.e.,

the calculation would not meet criteria #4 fora TLAA from 10 CFR 54.3 which is, "Were

determined to be relevant by the licensee in making a safety determination.")

The staff reviewed the applicant's response and found that it adequately justified having no

TLAA for components in load handling systems.

The staffs review found that the applicant appropriately addressed the aging effect and aging

effect mechanism, as recommended by the GALL Report.

3.3A.2.1.2 Crack Initiation and Growth Due to SCC or Cracking

In the discussion section of ALRA Table 3.3.1.A, Item 3.3.1 .A-04, the applicant stated that for

stainless steel heat exchangers aging management is by the Water Chemistry Control Program

and Preventive Maintenance Program; however, as documented in the Audit and Review

Report, the staff noted that the applicant has applied ALRA Table 3.3.1, Item 3.3.1.A-04 to

manage cracking in wrought austenitic stainless steel in a treated water or steam environment

with temperatures > 140 OF < 212 OF using its Water Chemistry Control Program and One-Time

Inspection Program. The staff asked the applicant to identify the AMPs to be applied. In a letter

dated December 1, 2005, the applicant stated that ALRA Table 3.3.1.A, Item 3.3.1.A-04 would

be revised to state that further evaluation is documented in Appendices B2.1.2 (Water

Chemistry Control Program) and B2.1.20 (One-Time Inspection Program).

The staff reviewed the applicant's response and found it consistent with the GALL Report and

therefore acceptable.

The staffs review found that the applicant appropriately addressed the aging effect and aging

effect mechanism, as recommended by the GALL Report.

3.3A.2.1.3 Loss of Material Due to General, Pitting, and Crevice Corrosion, and MIC

As documented in the Audit and Review Report, the staff noted that the applicant had cited

ALRA Table 3.3.1.A, Item 3.3.1.A-15 a number of times and had assigned Notes A, B, C, or D

even though no exception to GALL AMP XI.M21, "Closed-Cycle Cooling Water System," had

been taken in NMP AMP B2.1.11, "Closed-Cycle Cooling Water System Program." The staff

requested the applicant to clarify the basis for the assignment of Notes B and D. In a letter

dated December 1, 2005, the applicant stated that the notes are all A unless a GALL Report

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Item does not address a specific component type, in which case the Note is C. Also the

applicant stated that the notes for pumps, tanks, and valves line items referencing ALRA

Table 3.3.1.A-15 (three on pages 3.3-137, 3.3-138, and 3.3-139) had been revised from Note B

to Note A. The applicant removed the GALL Report item and Table 1 item, and replaced Note E

with Note H for gray cast iron pumps in ALRA Tables 3.2.2.A-1 (page 3.2-38) and 3.3.2.A-21

(page 3.3-197). Finally, the applicant stated in this letter that there is also reference to this

Table 1 Item for GCI HXs in ALRA Table 3.3.2.A-7 and that Note D should have been Note C

because the component is a heat exchanger (HX) instead of a pump. The staff reviewed the

applicant's response and found it acceptable because the applicant had assigned the

appropriate notes to the AMR line items.

The staffs review found that the applicant appropriately addressed the aging effect and aging

effect mechanism as recommended by the GALL Report.

3.3A.2.1.4 Loss of Material Due to General Corrosion and Wear

As documented in the Audit and Review Report, the staff noted that in ALRA Table 3.5.2.A-4

(page 3.5-74) for component type refueling platform and aging effect and aging effect

mechanism loss of material the Tablel line item shown is 3.3.1.B-16. Thestaff asked the

applicant to explain why a NMP2 line item is shown with an NMP1 component type.

In its letter dated December 1, 2005, the applicant stated that the reference is an error. For

ALRA Table 3.5.2.A-4 with line item component type refueling platform and aging effect and

aging effect mechanism loss of material the Table 1 reference was changed from Item

3.3.1.B-16 to Item 3.3.1.A-16.

The staff reviewed the applicant's response and found the correction of the reference to ALRA

Table 3.3.1.A, Item 3.3.1.A-16 acceptable.

The staff's review found that the applicant appropriately addressed the aging effect and aging

effect mechanism as recommended by the GALL Report.

3.3A.2.1.5 Loss of Material Due to Wear; Hardening and Shrinkage Due to Weathering

In ALRA Table 3.5.2.A-1 the applicant referenced ALRA Table 3.3.1 .A, Item 3.3.1 .A-20.

As documented in the Audit and Review Report, the staff noted that for component type doors

and aging effect and aging effect mechanism loss of material the Note shown is C, indicating

that the NMP AMP is consistent with the GALL Report AMP; however, the AMP shown is NMP

AMP B2.1.16, "Fire Protection Program," for which the applicant takes some exceptions to the

GALL AMP XI.M26, "Fire Protection." The staff asked the applicant to explain why a Note C

was shown instead of a Note D. This request also applied to ALRA Table 3.5.2.A-6

(page 3.5-76), ALRA Table 3.5.2A-7 and ALRA Table 3.5.2.A-1 1 for component type doors

and aging effect/ mechanism loss of material managed by the applicant's Fire Protection

Program.

In its letter dated December 1, 2005, the applicant stated that the note entry should be Note D

instead of C. Note C was changed to Note D for ALRA Tables 3.5.2.A-1 1, 3.5.2.A-6, and

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3.5.2.A-7 with AMR line item component doors and aging effect and aging effect mechanism

loss of material managed by the applicant's Fire Protection Program.

The staff reviewed the applicant's response and found it acceptable because the correction of

Note C to Note D assigned the proper note to these AMR line items.

The staffs review found that the applicant appropriately addressed the aging effect and aging

effect mechanism, as recommended by the GALL Report.

3.3A.2.1.6 Loss of Material Due to General Corrosion; Crack Initiation and Growth Due to

Cyclic Loading and SCC

As documented in the Audit and Review Report, the staff noted that in ALRA Table 3.3.2.A-1 0

(page 3.3-147) for component type bolting and aging effect and aging effect mechanism of loss

of material or cracking, the Note shown is B, which indicates that, for the NMP AMP shown, the

applicant has taken an exception to the GALL Report AMP; however, the AMP shown is NMP

AMP B2.1.36, "Bolting Integrity Program," for which the applicant claimed consistency with

GALL AMP XI.M18, "Bolting Integrity." The staff asked the applicant to explain why a Note B

was shown instead of a Note A. In its letter dated December 1, 2005, the applicant stated that

Note B is appropriate because its letter dated September 15, 2005, had declared an exception

for the applicant's Bolting Integrity Program. The staff reviewed the applicant's response and

found the applicant correct and the appropriate note assigned to the AMR line items.

The staffs review found that the applicant appropriately addressed the aging effect and aging

effect mechanism as recommended by the GALL Report.

3.3A.2.1.7 Loss of Material Due to Boric Acid Corrosion

In reviewing ALRA Table 3.3.1 .A, Item 3.3.1-14, the staff noted that the applicant had credited

the Bolting Integrity Program and Systems Walkdown Program. These AMPs are different from

the AMP recommended by the GALL Report, GALL AMP XI.M10, "Boric Acid Corrosion."

The staff review and evaluations of the applicant's Bolting Integrity and Systems Walkdown

Programs are documented in Sections 3.0.3.2.23 and 3.0.3.3.2 of this SER, respectively. The

staff found that the applicant's System Walkdown Program detects leakage and manages

material degradation through visual inspection and that the applicant's Bolting Integrity Program

monitors the potential leakage of sodium pentaborate solution on the liquid poison system

component bolting. The staff concludes that these AMPs will ensure detection of leakage

before a loss of intended function and manage adequately the loss of material due to boric acid

corrosion.

The staffs review found that the applicant appropriately addressed the loss of material due to

boric acid corrosion for closure bolting and external surfaces of carbon steel components.

Conclusion. The staff evaluated the applicant's claim of consistency with the GALL Report. The

staff also reviewed information pertaining to the applicant's consideration of recent operating

experience and proposals for managing associated aging effects. On the basis of its review, the

staff concludes that there is reasonable assurance that the AMR results, which the applicant

claimed to be consistent with the GALL Report, are consistent with the AMRs in the GALL

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Report. Therefore, the staff concludes that the applicant had demonstrated that the effects of

aging for these components will be adequately managed so that their intended function(s) will

be maintained consistent with the CLB for the period of extended operation, as required by

10 CFR 54.21(a)(3).

3.3A.2.2 AMR Results That are Consistent with the GALL Report, for Which Further

Evaluation is Recommended

Summary of Technical Information in the Amended Application. In Section 3.3.2.C of its

supplemental letter to the ALRA, dated August 19, 2005, the applicant provided further

evaluation of aging management as recommended by the GALL Report for the auxiliary

systems components. The applicant provided information concerning how it will manage the

following aging effects:

" loss of material due to general, pitting, and crevice corrosion

" hardening and cracking or loss of strength due to elastomer degradation or loss of material

due to wear

• cumulative fatigue damage

" crack initiation and growth due to cracking or stress corrosion cracking

" loss of material due to general, microbiologically influenced, pitting, and crevice corrosion

" loss of material due to general, galvanic, pitting, and crevice corrosion

" loss of material due to general, pitting, crevice, and MIC and biofouling

" crack initiation and growth due to stress corrosion cracking and cyclic loading

" reduction of neutron-absorbing capacity and loss of material due to general corrosion

• loss of material due to general, pitting, crevice, and MIC

Staff Evaluation. For component groups evaluated in the GALL Report for which the applicant

has claimed consistency with the GALL Report, and for which the GALL Report recommends

further evaluation, the staff audited and reviewed the applicant's evaluation to determine

whether it adequately addressed the issues that were further evaluated. In addition, the staff

reviewed the applicant's further evaluations against the criteria contained in SRP-LR

Section 3.3.2.2. Details of the staff s audit are documented in the staff s Audit and Review

Report. The staffs evaluation of the aging effects is discussed in the following sections.

3.3A.2.2.1 Loss of Material Due to General, Pitting, and Crevice Corrosion

The staff reviewed Section 3.3.2.C.1 of the applicant's letter dated August 19, 2005 against the

criteria in SRP-LR Section 3.3.2.2.1.1.

In Section 3.3.2.C.1 of a letter dated August 19, 2005, the applicant addressed loss of material

due to general, pitting, and crevice corrosion for components in the spent fuel pool cooling and

cleanup system. For NMP1 components in the spent fuel pool cooling systems are managed by

the combination of the Water Chemistry Control Program and One-Time Inspection Program.

SRP-LR Section 3.3.2.2.1.1 states that loss of material due to general, pitting, and crevice

corrosion could occur in the channel head and access cover, tubes, and tubesheets of the heat

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exchanger in the spent fuel pool cooling and cleanup system. The Water Chemistry Program

relies on monitoring and control of reactor water chemistry based on the EPRI guidelines of

BWRVIP-29, (TR-1 03515), "BWR Water Chemistry Guidelines - Normal and Hydrogen Water

Chemistry," to manage the effects of loss of material from general, pitting, or crevice corrosion;

however, high concentrations of impurities at crevices and locations of stagnant flow conditions

could cause general, pitting, or crevice corrosion. Therefore, the effectiveness of the Water

Chemistry Control Program should be verified to ensure no corrosion. The GALL Report

recommends further evaluation of programs to manage loss of material from general, pitting,

and crevice corrosion to verify the effectiveness of the applicant's Water Chemistry Control

Program. A one-time inspection of select components at susceptible locations is an acceptable

method to ensure no corrosion and that the component's intended function will be maintained

during the period of extended operation.

The staffs review and evaluation of the applicant's Water Chemistry Control Program and

One-Time Inspection Program are documented in SER Sections 3.0.3.2.2 and 3.0.3.1.4,

respectively.

The staff reviewed the applicant's further evaluation and concludes that it meets the criteria of

the SRP-LR.

In addition the staff reviewed Section 3.3.2.C.1 of the applicant's letter dated August 19, 2005,

against the criteria of SRP-LR Section 3.3.2.2.1.2.

In Section 3.3.2.C.1 of its letter dated August 19, 2005, the applicant addressed loss of material

due to pitting and crevice corrosion of components in the spent fuel cooling and cleanup system

and the shutdown cooling system of older BWRs.

SRP-LR Section 3.3.2.2.1.2 states that loss of material due to pitting and crevice corrosion

could occur in the piping, filter housing, valve bodies, and shell and nozzles of the ion

exchanger in the spent fuel pool cooling and cleanup system and in the piping and pump casing

in the shutdown cooling system (older BWR). The Water Chemistry Control Program relies on

monitoring and control of reactor water chemistry based on EPRI guidelines of BWRVIP-29

(TR-1 03515), -BWR Water Chemistry Guidelines - Normal and Hydrogen Water Chemistry," to

manage the effects of loss of material from pitting or crevice corrosion; however, high

concentrations of impurities at crevices and locations of stagnant flow conditions could cause

pitting or crevice corrosion. Therefore, the effectiveness of the chemistry control program

should be verified to ensure no corrosion. The GALL Report recommends further evaluation of

programs to manage loss of material from pitting and crevice corrosion to verify the

effectiveness of The Water Chemistry Control Program. A one-time inspection of select

components at susceptible locations is an acceptable method to ensure no corrosion and that

the component's intended function will be maintained during the period of extended operation.

In Section 3.3.2.C.1 of its letter dated August 19, 2005, the applicant also stated that for NMP1

the reactor water cleanup and shutdown cooling systems are applicable. The aging effect/

mechanism is managed by the combination of the Water Chemistry Control Program and

One-Time Inspection Program.

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The staff review and evaluation of the applicant's Water Chemistry Control Program and

One-Time Inspection Program are documented in SER Sections 3.0.3.2.2 and 3.0.3.1.4,

respectively.

The staff reviewed the applicant's further evaluation and concludes that it meets the criteria of

the SRP-LR.

Based on the programs identified above, the staff concludes that there is reasonable assurance

that the applicant has met the criteria of SRP-LR Section 3.3.2.2.1. For those line items that

apply to Section 3.3.2.C.1 of the applicant's letter dated August 19, 2005, the staff determined

that the information in the application is consistent with the GALL Report and the applicant had

demonstrated that the effects of aging will be adequately managed so that intended functions

will be maintained consistent with the CLB during the period of extended operation as required

by 10 CFR 54.21(a)(3).

3.3A.2.2.2 Hardening and Cracking or Loss of Strength Due to Elastomer Degradation or Loss

of Material due to Wear

The staff reviewed Section 3.3.2.C.2 of the applicant's letter dated August 19, 2005 against the

criteria in SRP-LR Section 3.3.2.2.2.

In Section 3.3.2.C.2 of its letter dated August 19, 2005, the applicant addressed aging effects

and aging effect mechanisms that could occur for the elastomer lining of some components

exposed to the treated water environment of the spent fuel pool cooling system and elastomer

seals and collars in the ductwork of certain ventilation systems exposed to a range of

atmospheric conditions.

SRP-LR Section 3.3.2.2.2 states that hardening and cracking due to elastomer degradation

could occur in elastomer linings of the filter, valve, and ion exchangers in spent fuel pool cooling

and cleanup systems. Hardening and loss of strength due to elastomer degradation could occur

in the collars and seals of the duct and in the elastomer seals of the filters in the control room

area, auxiliary and radwaste area, and primary containment heating ventilation systems and in

the collars and seals of the duct in the diesel generator building ventilation system. Loss of

material due to wear could occur in the collars and seals of the duct in the ventilation systems.

The GALL Report recommends further evaluation to ensure that these aging effects and aging

effects mechanisms are adequately managed.

In Section 3.3.2.C.2 of its letter dated August 19, 2005, the applicant also stated that

elastomers are not used in the lining of spent fuel pool system components within the scope of

license renewal at NMP.

In addition the applicant stated in its letter dated August 19, 2005, that for NMP1 ventilation

systems the aging effects and aging effects mechanisms for seals and collars are managed by

the Preventive Maintenance Program. The staff reviewed the applicant's Preventive

Maintenance Program and its evaluation is documented in SER Section 3.0.3.3.1.

The staff reviewed the applicant's further evaluation and concludes that it meets the criteria of

the SRP-LR.

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Based on the programs identified above, the staff concludes that there is reasonable assurance

that the applicant has met the criteria of SRP-LR Section 3.3.2.2.2. For those line items that

apply to Section 3.3.2.C.2 of the applicant's letter dated August 19, 2005, the staff determined

that the information in the application is consistent with the GALL Report and the applicant had

demonstrated that the effects of aging will be adequately managed so that the intended

function(s) will be maintained consistent with the CLB during the period of extended operation,

as required by 10 CFR 54.21(a)(3).

3.3A.2.2.3 Cumulative Fatigue Damage

In Section 3.3.2.C.3 of its letter dated August 19, 2005, the applicant stated that fatigue is a

TLAA, as defined in 10 CFR 54.3. Applicants must evaluate TLAAs in accordance with

10 CFR 54.21(c)(1). SER Section 4.3 documents the staff's review of the applicant's evaluation

of this TLAA.

3.3A.2.2.4 Crack Initiation and Growth Due to Cracking or Stress Corrosion Cracking

The staff reviewed Section 3.3.2.C.4 of the applicant's letter dated August 19, 2005 against the

criteria in SRP-LR Section 3.3.2.2.4.

In Section 3.3.2.C.4 of its letter dated August 19, 2005, the applicant addressed cracking due to

SCC for the stainless steel reactor water cleanup system regenerative and non-regenerative

heat exchangers.

SRP-LR Section 3.3.2.2.4 states that crack initiation and growth due to SCC could occur in the

regenerative and non-regenerative heat exchanger components in the reactor water cleanup

system. The GALL Report recommends further evaluation to ensure that these aging effects

and aging effects mechanisms are adequately managed.

In its August 19, 2005, letter the applicant also stated that for NMP1 this aging effect and aging

effects mechanism for the reactor water cleanup system regenerative and non-regenerative

heat exchangers is managed by a combination of the Water Chemistry Control Program and

One-Time Inspection Program.

The staffs review and evaluation of the applicant's Water Chemistry Control Program and

One-Time Inspection Program are documented in SER Sections 3.0.3.2.2 and 3.0.3.1.4,

respectively.

The staff reviewed the applicant's further evaluation and concludes that it meets the criteria in

the SRP-LR.

Based on the programs identified above, the staff concludes that there is reasonable assurance

that the applicant has met the criteria of SRP-LR Section 3.3.2.2.4. For those line items that

apply to Section 3.3.2.C.4 of the applicant's letter dated August 19, 2005, the staff determined

that the information in the application is consistent with the GALL Report and the applicant had

demonstrated that the effects of aging will be adequately managed so that the intended

function(s) will be maintained consistent with the CLB during the period of extended operation,

as required by 10 CFR 54.21 (a)(3).

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3.3A.2.2.5 Loss of Material Due to General, Microbiologically Influenced, Pitting, and Crevice

Corrosion

The staff reviewed Section 3.3.2.C.5 of the applicant's letter dated August 19, 2005 against the

criteria in SRP-LR Section 3.3.2.2.5.

In Section 3.3.2.C.5 of its letter dated August 19, 2005, the applicant addressed loss of material

from corrosion that could occur on internal and external surfaces of components exposed to a

range of atmospheric conditions. Specifically included in the subsection are the ventilation

systems, the diesel generator systems' fuel oil, starting air, and combustion air intake and

exhaust subsystems, and auxiliary systems' external carbon steel surfaces within the scope of

license renewal.

SRP-LR Section 3.3.2.2.5 states that loss of material due to general, pitting, and crevice

corrosion could occur in the piping and filter housing and supports in the control room area, the

auxiliary and radwaste area, the primary containment heating and ventilation systems, in the

piping of the diesel generator building ventilation system, in the above-ground piping and

fittings, valves, and pumps in the diesel fuel oil system, and in the diesel engine starting air,

combustion air intake, and combustion air exhaust subsystems in the emergency diesel

generator system. Loss of material due to general, pitting, crevice, and MIC could occur in the

duct fittings, access doors and closure bolts, equipment frames, and housing of the duct; due to

pitting and crevice corrosion could occur in the heating/cooling coils of the air handler; and due

to general corrosion could occur on the external surfaces of all carbon steel structures and

components, including bolting exposed to operating temperatures < 212 OF in the ventilation

systems. The GALL Report recommends further evaluation to ensure that these aging effects

and aging effects mechanisms are adequately managed. Acceptance criteria are stated in

Branch Technical Position RLSB-1.

In Section 3.3.2.C.5 of its letter dated August 19, 2005, the applicant also stated that for NMP1

this aging effect and aging effect mechanism for the applicable systems and components is

managed by the Closed-Cycle Cooling Water, Fire Water System, One-Time Inspection,

10 CFR 50 Appendix J, Preventive Maintenance, and Systems Walkdown Programs.

The staff's review and evaluation of the applicant's Closed-Cycle Cooling Water System, Fire

Water System, One-Time Inspection, 10 CFR 50 Appendix J, Preventive Maintenance and

Systems Walkdown Programs are documented in SER Sections 3.0.3.2.8, 3.0.3.2.14, 3.0.3.1.4,

3.0.3.1.7, 3.0.3.3.1 and 3.0.3.3.2, respectively.

The staff reviewed the applicant's further evaluation and concludes that it meets the criteria in

the SRP-LR.

Based on the programs identified above, the staff concludes that there is reasonable assurance

that the applicant has met the criteria of SRP-LR Section 3.3.2.2.5. For those line items that

apply to Section 3.3.2.C.5 of the applicant's letter dated August 19, 2005, the staff determined

that the information in the application is consistent with the GALL Report and the applicant had

demonstrated that the effects of aging will be adequately managed so that the intended

function(s) will be maintained consistent with the CLB during the period of extended operation,

as required by 10 CFR 54.21 (a)(3).

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3.3A.2.2.6 Loss of Material Due to General, Galvanic, Pitting, and Crevice Corrosion

The staff reviewed Section 3.3.2.C.6 of the applicant's letter dated August 19, 2005 against the

criteria in SRP-LR Section 3.3.2.2.6.

In Section 3.3.2.C.6 of its letter dated August 19, 2005, the applicant addressed loss of material

due to general, galvanic, pitting, and crevice corrosion in the reactor recirculation pumps' oil

collection system in fire protection.

The applicant stated in Section 3.3.2.C.6 of its letter dated August 19, 2005, that this item is not

applicable because NMP has no oil collection systems for its reactor recirculation pumps. As

documented in the Audit and Review Report, the staff determined through discussions with the

applicant's technical personnel that loss of material due to general, galvanic, pitting, and crevice

corrosion in the reactor recirculation pumps' oil collection system in fire protection is not

applicable because NMP has no oil collection systems for its reactor recirculation pumps.

Because NMP has no components from this group the staff found this aging effect and aging

effect mechanism not applicable to NMP.

3.3A.2.2.7 Loss of Material Due to General, Pitting, Crevice, and Microbiologically Influenced

Corrosion and Biofouling

The staff reviewed Section 3.3.2.C.7 of the applicant's letter dated August 19, 2005, against the

criteria in SRP-LR Section 3.3.2.2.7.

In Section 3.3.2.C.7 of its letter dated August 19, 2005, the applicant addressed loss of material

due to general, pitting, crevice, and MIC and biofouling for the internal surfaces of components

in the diesel fuel oil system.

SRP-LR Section 3.3.2.2.7 states that loss of material due to general, pitting, crevice, and MIC

and biofouling could occur in the internal surfaces of tanks in the diesel fuel oil system and due

to general, pitting, crevice, and MIC in the tanks of the diesel fuel oil system in the emergency

diesel generator system. The existing AMP relies on the Fuel Oil Chemistry Program for

monitoring and control of fuel oil contamination according to the guidelines of ASTM Standards

D4057, D1796, D2709 and D2276 to manage loss of material due to corrosion or biofouling that

may occur where contaminants accumulate. The effectiveness of the chemistry control program

should be verified to ensure no corrosion. The GALL Report recommends further evaluation of

programs to manage corrosion/biofouling to verify program effectiveness. A one-time inspection

of selected components at susceptible locations is an acceptable method to ensure no

corrosion and maintenance of the component's intended function during the period of extended

operation.

The applicant also stated in the ALRA that for NMP1 this aging effect and aging effect

mechanism are managed by the combination of the Fuel Oil Chemistry Program and One-Time

Inspection Program.

The staffs review and evaluation of the applicant's Fuel Oil Chemistry Program and One-Time

Inspection Program are documented in SER Sections 3.0.3.2.15 and 3.0.3.1.4, respectively.

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The staff reviewed the applicant's further evaluation and concludes that it meets the criteria in

the SRP-LR.

Based on the programs identified above, the staff concludes that there is reasonable assurance

that the applicant has met the criteria of SRP-LR Section 3.3.2.2.7. For those line items that

apply to Section 3.3.2.C.7 of the applicant's letter dated August 19, 2005, the staff determined

that the information in the application is consistent with the GALL Report and the applicant had

demonstrated that the effects of aging will be adequately managed so that the intended

function(s) will be maintained consistent with the CLB during the period of extended operation,

as required by 10 CFR 54.21 (a)(3).

3.3A.2.2.8 Quality Assurance for Aging Management of Non-Safety-Related Components

SER Section 3.0.4 provides the staffs evaluation of the applicant's quality assurance program.

3.3A.2.2.9 Crack Initiation and Growth Due to Stress Corrosion Cracking and Cyclic Loading

The staff reviewed Section 3.3.2.C.9 of the applicant's letter dated August 19, 2005, against the

criteria in SRP-LR Section 3.3.2.2.9.

In Section 3.3.2.C.9 of its letter dated August 19, 2005, the applicant stated that crack initiation

and growth due to SCC and cyclic loading apply to PWRs only and that this aging effect/

mechanism is not applicable to NMP. The staff determined through discussions with the

applicant's technical personnel that because this aging effect and aging effect mechanism

applies to PWRs only it is not applicable to NMP.

Because NMP has no components from this group the staff determined that this aging effect

and aging effect mechanism are not applicable to NMP.

3.3A.2.2.10 Reduction of Neutron-Absorbing Capacity and Loss of Material Due to General

Corrosion

The staff reviewed Section 3.3.2.C.10 of the applicant's letter dated August 19, 2005, against

the criteria in SRP-LR Section 3.3.2.2.10.

SRP-LR Section 3.3.2.2.10 states that reduction of neutron-absorbing capacity and loss of

material due to general corrosion could occur in the neutron-absorbing sheets of the spent fuel

storage rack in the spent fuel storage. The GALL Report recommends further evaluation to

ensure that these aging effects are adequately managed.

In Section 3.3.2.C.10 of its letter dated August 19, 2005, the applicant stated that reduction of

neutron-absorbing capacity and loss of material due to general corrosion in the

neutron-absorbing (Boral or boron steel) sheets of the spent fuel storage racks are not

applicable as it had identified no aging effects and aging effects mechanisms for these

components.

In its letter dated November 17, 2005, the applicant revised ALRA to address discussion held

during the license renewal audit. In this letter, the applicant credits the Water Chemistry Control

and One-Time Inspection Programs for aging management. The Water Chemistry Control and

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One Time Inspection Programs manage general corrosion. The Boraflex Monitoring Program

manages the effects of reduction of neutron-absorbing capability.

The staff reviewed the applicant's Water Chemistry Control, One-Time Inspection, and Boraflex

Monitoring Programs. The staff found this acceptable since its change meets the GALL

Report's recommendation. On this basis, the staff found this acceptable.

3.3A.2.2.11 Loss of Material Due to General, Pitting, Crevice, and Microbiologically Influenced

Corrosion

The staff reviewed Section 3.3.2.C.11 of the applicant's letter dated August 19, 2005, against

the criteria in SRP-LR Section 3.3.2.2.11.

In Section 3.3.2.C.1 I of its letter dated August 19, 2005, the applicant addressed loss of

material due to general, pitting, crevice, and MIC for buried piping and fittings.

SRP-LR Section 3.3.2.2.11 states that loss of material due to general, pitting, and crevice

corrosion and MIC could occur in the underground piping and fittings in the open-cycle cooling

water system (service water system) and in the diesel fuel oil system. The Buried Piping and

Tanks Inspection Program relies on industry practice,'frequency of pipe excavation, and

operating experience to manage the effects of loss of material from general, pitting, crevice,

and MIC. The effectiveness of the applicant's Buried Piping and Tanks Inspection Program

should be verified to evaluate an applicant's inspection frequency and operating experience

with buried components and ensure no loss of material.

In Section 3.3.2.C.1 1 of its letter dated August 19, 2005, the applicant also stated that this

aging effect and aging effect mechanism are managed by the Buried Piping and Tanks

Inspection Program for NMP1 diesel generator systems.

The staffs review and evaluation of the applicant's Buried Piping and Tanks Inspection

Program are documented in SER Section 3.0.3.1.6.

As documented in the Audit and Review Report, the staff asked the applicant to clarify its

position on opportunistic inspections prior to the period of extended operation. In its letter dated

December 1, 2005, the applicant stated that the ALRA had been revised to include the following

in its Buried Piping and Tanks Inspection Program:

Program activities will include visual inspections of external coatings and wrappings to

detect damage and degradation. Prior to entering the period of extended operation,

NMP will verify that there has been at least one opportunistic or focused inspection

within the past ten years. Upon entering the period of extended operation, NMP will

perform a focused inspection within ten years, unless an opportunistic inspection

occurred within this ten year period. All credited inspections will be performed in areas

with the highest likelihood of corrosion problems, and in areas with a history of

corrosion problems.

After a review of the applicant's clarification of its visual inspection position and its further

evaluation the staff concludes that the program meets the criteria of the SRP-LR.

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Based on the programs identified above, the staff concludes that there is reasonable assurance

that the applicant has met the criteria of SRP-LR Section 3.3.2.2.11. For those line items that

apply to Section 3.3.2.C.1 1 of the applicant's letter dated August 19, 2005, the staff determined

that the information in the application is consistent with the GALL Report and the applicant had

demonstrated that the effects of aging will be adequately managed so that the intended

function(s) will be maintained consistent with the CLB during the period of extended operation,

as required by 10 CFR 54.21 (a)(3).

Conclusion. On the basis of its review, for component groups evaluated in the GALL Report for

which the applicant has claimed consistency with the GALL Report, and for which the GALL

Report recommends further evaluation, the staff determined that the applicant adequately

addressed the issues that were further evaluated. The staff found that the applicant had

demonstrated that the effects of aging will be adequately managed so that the intended

functions will be maintained consistent with the CLB for the period of extended operation, as

required by 10 CFR 54.21(a)(3).

3.3A.2.3 AMR Results That Are Not Consistent with or Not Addressed in the GALL

Report

Summary of Technical Information in the Application. In the original LRA Tables 3.3.2.A-1

through 3.3.2.A-25, the staff reviewed additional details of the results of the NMP1 AMRs for

material, environment, aging effect requiring management, and AMP combinations that are not

consistent with the GALL Report, or not addressed in the GALL Report.

In the original LRA Tables 3.3.2.A-1 through 3.3.2.A-25, the applicant indicated, via Notes F

through J, that the combination of component type, material, environment, and aging effect

requiring management does not correspond to a line item in the GALL Report, and provided

information concerning how the aging effect will be managed. Specifically, Note F indicated that

the material for the AMR line item component is not evaluated in the GALL Report. Note G

indicated that the environment for the AMR line item component and material is not evaluated in

the GALL Report. Note H indicated that the aging effect for the AMR line item component,

material, and environment combination is not evaluated in the GALL Report. Note I indicated

that the aging effect identified in the GALL Report for the line item component, material, and

environment combination is not applicable. Note J indicated that neither the component nor the

material and environment combination for the line item is evaluated in the GALL Report.

Staff Evaluation. For component type, material, and environment combinations that are not

evaluated in the GALL Report, the staff reviewed the applicant's evaluation to determine

whether it had demonstrated that the effects of aging will be adequately managed so that the

intended functions will be maintained consistent with the CLB during the period of extended

operation. The staffs evaluation is discussed in the following sections.

3.3A.2.3.0 General RAls on AMR Issues

By letter dated November 2, 2005, the staff requested that the applicant provide additional

information on issues described in the general RAI (a-RAI 3.3.2-1) for the ALRA applicable to

more than one system in both NMP1 and NMP2. By letter dated November 30, 2005, the

applicant responded. The following describes a-RAI 3.3.2-1, the applicant's response, and the

staffs evaluation of the applicant's response.

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Adequacy of the Use of One-Time Inspection (a-RAI 3.3.2-1). One-time inspection is

appropriate where either an aging effect is not expected to occur but there is insufficient data to

rule it out completely or the aging effect is expected to occur very slowly and not affect the

component intended function. The applicant proposed to use the One-Time Inspection Program

to manage aging effects for various materials exposed to various environments for a majority of

the components in two systems: (a) ALRA Table 3.3.2.A-1 4, NMP1 radioactive waste system

and (b) ALRA Table 3.3.2.B-14, NMP2 floor and equipment drains system.

In a-RAI 3.3.2-1 dated November 2, 2005, the staff requested that the applicant:

(1) Explain from system characteristics why the One-Time Inspection Program rather than

periodic inspections is proposed as the sole AMP for these two systems to manage

aging effects of material-environment combinations

(2) Justify the use of the One-Time Inspection Program for the following cases:

(a) In Table 3.3.2.A-14 AERM of cracking for wrought austenitic stainless steel

(WASS) Heat Exchangers exposed to air, moisture, or wetting, temperature

> 140°F and for WASS valves exposed to treated water temperature

> 140°F < 212°F.

(b) In Table 3.3.2.A-14 AERM of loss of material (LOM) for carbon or low alloy steel

(yield strength < 100 ksi) or WASS valves, piping, and fittings exposed to

demineralized untreated water (DUW).

(c) In Table 3.3.2.A-14 AERM of LOM for carbon or low alloy steel (yield strength

< 100 ksi) valves exposed to either DUW, low flow, or treated water, temperature

> 140°F < 212°F.

(d) In Table 3.3.2.B-14 AERM of cracking for WASS drainers exposed to treated

water, temperature > 140 OF < 212 OF.

(e) In Table 3.3.2.8-14 AERM of LOM for aluminum pump or carbon or low alloy

steel (yield strength < 100 ksi) strainers exposed to raw water.

In its letter dated November 30, 2005, the applicant responded:

(1) The NMPI radwaste and NMP2 floor and equipment drains systems include

the following subsystems:

• equipment drains in various building

* floor drains in various buildings

* the piping, pumps, tanks, and valves in these subsystems

The components in these systems are fabricated predominantly of carbon steel and the

environment is generally water; however, exposure to water is not continuous. When tanks or

sumps reach pre-set levels the pumps automatically start to empty them and expose the

downstream components to water.

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The applicant stated that for this non-continuous exposure the One Time Inspection Program

was chosen to manage aging because the identified aging effects were judged to occur at such

a slow rate that the component intended functions would not be impacted during the period of

extended operation. After further evaluation, including review of the guidance from the most

recent industry aging management documentation, the applicant concluded that the

Preventative Maintenance Program manages the aging of the carbon steel and gray cast iron

components in these systems more effectively than the One Time Inspection Program. The

Preventive Maintenance Program was, therefore, substituted for the One Time Inspection

Program to manage the aging of the carbon steel and gray cast iron components in these

systems with the exception of the carbon steel piping and fittings and valves subjected to an

internal fuel oil environment. As these components are exposed to fuel oil drainage loss of

material from water contamination is possible. This possibility is considered unlikely because

there would be an oil film on the inside of these components; however, the One Time Inspection

Program will ascertain whether loss of material occurs. Through its CAP, the applicant will

document and correct the anomaly. The cast and wrought austenitic stainless steel,

nickel-based alloy, and copper alloy (zinc < 15 percent) components will continue to be

managed by the One Time Inspection Program.

The applicant further stated that an extent of condition review had been performed for the other

NMP1 and NMP2 mechanical systems to determine if similar changes were needed in the

application of the One Time Inspection Program for aging management. As a result of this

review, there were two other changes identified: (1) for the NMP1 miscellaneous

non-contaminated vents and drains system the AMP for managing the internals of the system

components (carbon steel piping and fittings in a demineralized untreated water or raw water

environment) was changed to the Preventive Maintenance Program and (2) for the NMP2

standby liquid control system the line item on Table 3.3.2.8-30 (page 3.3-288) of the ALRA for

WASS valves in the air, moisture or wetting, temperature < 140°F environment was deleted

(line with Note H). The valves identified as in that environment are actually wetted and covered

by the other wetted WASS valve environments already included in the ALRA.

For the specific instances questioned the applicant provided the following response:

(2)(a) The heat exchangers that are addressed by the line item in the ALRA are

associated with the Radwaste System Concentrator 12. This Concentrator, and hence

its associated components, are infrequently (less than once per operating cycle) used

since other preferable methods for liquid waste processing are normally utilized (see

USAR Section XII.2.2. 1). As shown on Drawing LR- 18045-C, Sheet 5, the heat

exchangers associated with Concentrator 12 are the Concentrator Heat Exchanger,

the Concentrator Distillate Sub-Cooler, the Concentrator Vent Condenser, and the

Concentrator Vapor Condenser. The One- Time Inspection Program is considered to

be the appropriate aging management program for these components since they are

normally exposed to air and the rate of aging is judged to be so slow that their

intended functions would not be impacted during the period of extended operation.

The valves in this system that are WASS in Treated Water_> 140 OF, but < 212OF are

all 3/4" valves (mostly ball valves) in either instrument lines or drain lines. As such, the

applicable AERM of cracking was considered to be unlikely since there is normally no

flow through these lines and it is very improbable that the water temperature is

sustained at the high end of the indicated range. For this reason, the One Time

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Inspection Program was considered to be adequate for aging management of these

valves, so it was credited.

(2)(b-d) As discussed in the response to the first part of this RAI, the aging

management of the carbon steel and gray cast iron components within the NMPI

Radioactive Waste System is changed from the One Time Inspection Program to the

PM Program. For the stainless steel components within the system, it is considered to

be unlikely that they will experience the AERMs that have been identified for them. For

this reason, the One Time Inspection Program is retained as the AMP.

(2)(e) These pumps are the sump pumps in the Control Building floor drain sump (see

Drawing LR-66C-0). These pumps are non-safety-related pumps that are in scope for

10 CFR 54.4(a)(2) because they are located in the Control Building and there is

safety-related equipment in the vicinity. Even though the Environment for these pumps has

been identified as Raw Water, the water that enters the sump is treated or demineralized

water that has leaked onto the floor and drained to the sump. Since there is no chemistry

control of this water, it has been identified as Raw Water. The One Time Inspection

Program has been credited for aging management since it is considered unlikely that the

AERM of LOM would ever occur to the extent such that the loss of the intended function of

the pumps would be lost.

For the carbon steel strainers, as discussed in the response to the first part of this

RAI, the AMP is to be changed to the PM Program.

The staff reviewed the applicant's response and found it reasonable and acceptable because

the applicant has revised the aging management strategy for carbon steel components in the

radioactive waste system, the auxiliary NMP2 floor and equipment drains system, and the other

systems to ensure detection of aging effects prior to loss of intended function.

The staff's system-specific evaluations are discussed below.

3.3A.2.3.1 Auxiliary Systems NMP1 Circulating Water System - Summary of Aging

Management Evaluation - ALRA Table 3.3.2.A-1

The staff reviewed ALRA Table 3.3.2.A-1, which summarizes the results of AMR evaluations for

the circulating water system component-material-environment AERM combinations not

addressed in the GALL Report. These combinations use Note F through J in ALRA

Table 3.3.2.A-1 as revised in the applicant's letter NMP1L 1996 dated November 17, 2005. The

staff verified that the applicant had identified all AERMs and credited appropriate AMPs for

managing them. The staff also reviewed the applicable UFSAR supplements for the AMPs to

ensure that the program descriptions adequately describe them.

Aging Effects. ALRA Table 2.3.3.A.2-1 lists individual system components within the scope of

license renewal and subject to an AMR. The component types that do not rely on the GALL

Report for an AMR include external surfaces, valves, and traveling screens and rakes.

For these component types the applicant identified the following materials, environments, and

AERMs:

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" gray cast iron exposed to air subject to loss of material

* gray cast iron exposed to raw water subject to loss of material

* fiberglass exposed to raw water subject to cracking and loss of strength

The staff reviewed the information in ALRA Section 2.3.3.A.2, Table 2.3.3.A.2-1,

Section 3.3.2.A.1, and Table 3.3.2.A-1.

The staff's review of the information provided in the ALRA found the aging effects of the

circulating water system component types not addressed by the GALL Report consistent with

industry experience for these combinations of materials and environments. The staff did not

identify any omitted aging effects. Therefore, the staff found that the applicant had identified the

appropriate aging effects for the materials and environments associated with the above

components in the circulating water system.

Aginq Management Programs. After evaluating the applicant's identification of aging effects for

each of the above components the staff evaluated the AMPs to determine whether they are

appropriate for managing the identified aging effects. The staff also verified that the UFSAR

supplement contains an adequate description of the program.

ALRA Table 3.3.2.A-1 identifies the following AMPs for managing the-aging effects for the

circulating water system components not addressed by the GALL Report:

• System Walkdown Program

• Open-Cycle Cooling Water System Program

* Selective Leaching of Materials Program

The staffs detailed review of these AMPs is in SER Sections 3.0.3.3.2, 3.0.3.2.7, and 3.0.3.1.5.

On the basis of its review, as discussed above, the staff concludes that there is reasonable

assurance that the applicant has demonstrated that the aging effects associated with the

circulating water system components will be adequately managed so that the intended

functions will be maintained consistent with the CLB for the period of extended operation, as

required by 10 CFR 54.21(a)(3).

The staff also reviewed the applicable UFSAR supplement program descriptions and concludes

that the UFSAR supplement provides an adequate description of the AMPs credited for

managing aging of these components, as required by 10 CFR 54.21(d).

3.3A.2.3.2 Auxiliary Systems NMPI City Water System - Summary of Aging Management

Evaluation - ALRA Table 3.3.2.A-2

The staff reviewed ALRA Table 3.3.2.A-2, which summarizes the results of AMR evaluations for

the city water system component-material-environment AERM combinations not addressed in

the GALL Report. These combinations use note F through J in ALRA Table 3.3.2.A-2 as revised

by the applicant's letters NMP1L 1996 dated November 17, 2005, and NMP1L 2007 dated

December 5, 2005. The staff reviewed these supplemental letters and verified that the applicant

had identified all AERMs and credited appropriate AMPs for managing them. The staff also

reviewed the applicable UFSAR supplements for the AMPs to ensure that the program

descriptions adequately describe them.

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Aging Effects. ALRA Table 2.3.3.A.3-1 lists individual system components within the scope of

license renewal subject to an AMR. The component types that do not rely on the GALL Report

for an AMR include external surfaces, valves, and traveling screens and rakes.

For these component types the applicant identified the following materials, environments, and

AERMs:

" gray cast iron exposed to air subject to loss of materia.

• carbon or low alloy steel (yield strength < 100 Ksi) exposed to demineralized untreated

water subject to loss of material

* copper alloys (zinc < 15 percent) exposed to demineralized untreated water subject to loss

of material

* gray cast iron exposed to demineralized untreated water subject to loss of material

The staff reviewed the information in ALRA Section 2.3.3.A.3, Table 2.3.3.A.3-1,

Section 3.3.2.A.2, and Table 3.3.2.A-2. During its review the staff determined that additional

information was needed.

The RAIs are organized in two groups, general and system-specific. The general RAI applicable

to this system is a-RAI 3.3.2-1.

In a-RAI 3.3.2-1 dated November 2, 2005, the staff requested that the applicant provide

additional information and by letter dated November 30, 2005, the applicant responded. The

RAI, the applicant's response, and the staffs evaluation of the response are described in SER

Section 3.3A.2.3.0. There are no relevant system-specific RAIs associated with this system.

The staffs review of the information provided in the ALRA and the additional information in the

applicant's response to the RAI the staff found the aging effects of the city water system

component types not addressed by the GALL Report consistent with industry experience for

these combinations of materials and environments. The staff did not identify any omitted aging

effects. Therefore, the staff found that the applicant had identified the appropriate aging effects

for the materials and environments of the city water system components.

Aging Management Programs. After evaluating the applicant's identification of aging effects for

each of the components the staff evaluated the AMPs to determine whether they are

appropriate for managing the identified aging effects. The staff also verified that the UFSAR

supplement adequately describes the program.

ALRA Table 3.3.2.A-2 identifies the following AMPs for managing aging effects for the city

water system components not addressed by the GALL Report:

" System Walkdown Program

" One-Time Inspection Program

" Selective Leaching of Materials Program

In the applicant's response to general RAI a-RAI 3.3.2-1, as described in SER

Section 3.3A.2.3.0, the applicant revised its management strategy for the aging effects of some

components in this system by replacing the One-Time Inspection Program with the Preventive

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Maintenance Program. The staff's detailed review of the Preventive Maintenance Program is in

SER Section 3.0.3.3.1. ...

The staff's detailed review of System Walkdown Program and Selective Leaching of Materials

Program is in SER Sections 3.0.3.3.2 and 3.0.3.1.5.

Conclusion: On the basis of its review, as discussed above, the staff concludes that there is

reasonable assurance that the applicant has demonstrated that the aging effects associated

with the city water system components will be adequately managed so that the intended

functions will be maintained consistent with the CLB for the period of extended operation, as

required by 10 CFR 54.21(a)(3).

The staff also reviewed the applicable UFSAR supplement program descriptions and concludes

that the UFSAR supplement provides an adequate description of the AMPs credited for

managing aging of these components, as required by 10 CFR 54.21(d)

3.3A.2.3.3 Auxiliary Systems NMP1 Compressed Air Systems - Summary of Aging

Management Evaluation - ALRA Table 3.3.2.A-3

The staff reviewed ALRA Table 3.3.2.A-3, which summarizes the results of AMR evaluations for

the compressed air systems component-material-environment AERM combinations not

addressed in the GALL Report. These combinations use Notes F through J in ALRA

Table 3.3.2.A-3 as revised by the applicant's letter NMP1L 1996 dated November 17, 2005. The

staff reviewed this supplemental letter and verified that the applicant had identified all AERMs

and had credited appropriate AMPs with managing them. The staff also reviewed the applicable

UFSAR supplements for the AMPs to ensure that the program descriptions describe them

adequately.

Aping Effects. ALRA Table 2.3.3.A.4-1 lists individual system components within the scope of

license renewal and subject to an AMR. The component types that do not rely on the GALL

Report for an AMR include drain traps, external surfaces, filters/strainers, heat exchangers,

piping and fittings, separators, and valves.

For these component types the applicant identified the following materials, environments, and

AERMs:

" copper alloys (zinc_< 15 percent) exposed to demineralized untreated water, low flow,

subject to loss of material

" gray cast iron exposed to air subject to loss of material

" gray cast iron exposed to demineralized untreated water, or demineralized untreated water,

low flow, subject to loss of material

• polymers exposed to air subject to cracking, hardening and shrinkage, and loss of strength

" red brass cold worked exposed to air subject to cracking

* wrought austenitic stainless steel exposed to demineralized untreated water, low flow,

subject to loss of material

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" copper alloys (zinc > 15 percent) and aluminum bronze exposed to air subject to loss of

heat transfer

" copper alloys (zinc > 15 percent) and aluminum bronze exposed to demineralized

untreated water or demineralized untreated water, low flow, subject to loss of heat transfer

and loss of material

* carbon or low alloy steel (Yield strength < 100 Ksi) exposed to demineralized untreated

water or demineralized untreated water, low flow, subject to loss of material

The staff reviewed the information in ALRA Section 2.3.3.A.4, Table 2.3.3.A.4-1,

Section 3.3.2.A.3, and Table 3.3.2.A-3.

The staffs review of the information provided in the ALRA found the aging effects of the

compressed air systems component types not addressed by the GALL Report consistent with

industry experience for these combinations of materials and environments. The staff did not

identify any omitted aging effects. Therefore, the staff found that the applicant had identified the

appropriate aging effects for the materials and environments of the components in the

compressed air systems.

Aping Management Programs. After evaluating the applicant's identification of aging effects for

each of the components the staff evaluated the AMPs to determine whether they are

appropriate for managing the identified aging effects. The staff also verified that the UFSAR

supplement describes the program adequately.

ALRA Table 3.3.2.A-3 identifies the following AMPs for managing the aging effects for the

compressed air systems components not addressed by the GALL Report:

" System Walkdown Program

" Compressed Air Monitoring Program

* Selective Leaching of Materials Program

The staffs detailed review of these AMPs is in SER Sections 3.0.3.3.2, 3.0.3.2.11, and

3.0.3.1.5.

Conclusion: On the basis of its review, as discussed above, the staff concludes that there is

reasonable assurance that the applicant has demonstrated that the aging effects associated

with the compressed air systems components will be adequately managed so that the intended

functions will be maintained consistent with the CLB for the period of extended operation, as

required by 10 CFR 54.21(a)(3).

The staff also reviewed the applicable UFSAR supplement program descriptions and concludes

that the UFSAR supplement provides an adequate description of the AMPs credited for

managing aging of these components, as required by 10 CFR 54.21(d)

3.3A.2.3.4 Auxiliary Systems NMP1 Containment Systems - Summary of Aging Management

Evaluation - ALRA Table 3.3.2.A-4

The staff reviewed ALRA Table 3.3.2.A-4, which summarizes the results of AMR evaluations for

the containment systems component-material-environment AERM combinations not addressed

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in the GALL Report. These combinations use Notes F through J in ALRA Table 3.3.2.A-4. The

staff verified that the applicant had identified all AERMs and had credited appropriate AMPs

with managing them. The staff also reviewed the applicable UFSAR supplements for the AMPs

to ensure that the program descriptions describe them adequately.

Aging Effects. ALRA Table 2.3.3.A.5-1 lists individual system components within the scope of

license renewal and subject to an AMR. The component types that do not rely on the GALL

Report for an AMR include heat exchanger, piping and fittings, valves, and vaporizers..

For these component types the applicant identified the following materials, environments, and

AERMs.

" copper alloys (zinc < 15 percent) exposed to air subject to loss of heat transfer

" copper alloys (zinc < 15 percent) exposed to air, moisture or wetting, temperature > 140 0F,

subject to loss of heat transfer

" copper alloys (zinc < 15 percent) exposed to demineralized untreated water subject to loss

of material

" wrought austenitic stainless steel exposed to air, moisture or wetting, temperature

> 140 OF, subject to cracking

" carbon or low alloy steel (Yield strength < 100 Ksi) exposed to demineralized untreated

water, low flow, subject to loss of material

" wrought austenitic stainless steel exposed to demineralized untreated water, low flow,

subject to loss of material

The staff reviewed the information in ALRA Section 2.3.3.A.5, Table 2.3.3.A.5-1,

Section 3.3.2.A.4 and Table 3.3.2.A-4.

The staffs review of the information provided in the ALRA found the aging effects of the

containment systems component types not addressed by the GALL Report consistent with

industry experience for these combinations of materials and environments. The staff did not

identify any omitted aging effects. Therefore, the staff found that the applicant had identified the

appropriate aging effects for the materials and environments of the components in the

containment systems.

Aging Management Programs. After evaluating the applicant's identification of aging effects for

each of the components the staff evaluated the AMPs to determine whether they are

appropriate for managing the identified aging effects. The staff also verified that the UFSAR

supplement describes the programs adequately.

ALRA Table 3.3.2.A-4 identifies the following AMPs for managing the aging effects for the

containment systems components not addressed by the GALL Report:

" One-Time Inspection Program

* Preventive Maintenance Program

• Closed-Cycle Cooling Water System Program

The staffs detailed review of these AMPs is in SER Sections 3.0.3.1.4, 3.0.3.3.1, and 3.0.3.2.8.

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Conclusion: On the basis of its review, as discussed above, the staff concludes that there is

reasonable assurance that the applicant has demonstrated that the aging effects associated

with the containment systems components will be adequately managed so that the intended

functions will be maintained consistent with the CLB for the period of extended operation, as

required by 10 CFR 54.21(a)(3).

The staff also reviewed the applicable UFSAR supplement program descriptions and concludes

that the UFSAR supplement provides an adequate description of the AMPs credited for

managing aging of these components, as required by 10 CFR 54.21(d).

3.3A.2.3.5 Auxiliary Systems NMP1 Control Room HVAC System - Summary of Aging

Management Evaluation - ALRA Table 3.3.2.A-5

The staff reviewed ALRA Table 3.3.2.A-5, which summarizes the results of AMR evaluations for

the control room HVAC system component-material-environment AERM combinations not

addressed in the GALL Report. These combinations use Notes F through J in ALRA

Table 3.3.2.A-5. The staff verified that the applicant had identified all AERMs and had credited

appropriate AMPs with managing them. The staff also reviewed the applicable UFSAR

supplements for the AMPs to ensure that the program descriptions describe them adequately.

Aping Effects. ALRA Table 2.3.3.A.6-1 lists individual system components within the scope of

license renewal and subject to an AMR. The component types that do not rely on the GALL

Report for an AMR include expansion tank, external surfaces, filters/strainers, flow elements,

heat exchanger, piping and fittings, pumps, seals and gaskets, and valves and dampers.

For these component types the applicant identified the following materials, environments, and

AERMs:

" carbon or low alloy steel (Yield strength < 100 Ksi) exposed to demineralized untreated

water, low flow, subject to loss of material

" gray cast iron exposed to air subject to loss of material

" carbon or low alloy steel (Yield strength < 100 Ksi) exposed to demineralized untreated

water subject to loss of material

" copper alloys (zinc < 15 percent) exposed to air subject to loss of heat transfer

" copper alloys (zinc < 15 percent) exposed to demineralized untreated water subject to loss

of heat transfer

" wrought austenitic stainless steel exposed to demineralized untreated water subject to loss

of heat transfer and loss of material

" copper alloys (zinc < 15 percent) exposed to demineralized untreated water subject to loss

of material

• polymers exposed to air subject to loss of sealing

" gray cast iron exposed to demineralized untreated water subject to loss of material

The staff reviewed the information in ALRA Section 2.3.3.A.6, Table 2.3.3.A.6-1,

Section 3.3.2.A.5, and Table 3.3.2.A-5.

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In a-RAI 3.3.2.A-5-1 dated November 2, 2005, the staff requested that the applicant clarify the

Note "K" for heat exchangers and valves and dampers in Table 3.3.2.A-5 and explain why the

LOM was not identified as an AERM for wrought austenitic stainless (WASS) steel heat

exchangers exposed to demineralized untreated water (DUW) similar to the WASS heat

exchangers in Table 3.3.2.A-14.

In its response by letter dated November 30, 2005, the applicant stated that as part of the

recovery effort which led to the submittal of the ALRA it chose to convert the lettered

plant-specific notes to the standard industry-lettered notes. As discussed with the staff, the

applicant agreed that Note H should be substituted for Note K. For those two cited locations in

Table 3.3.2.A-5 each Note K is, therefore, changed to Note H.

The applicant further stated that there is a similar Notes anomaly in ALRA Table 3.3.2.B-6

(page 3.3-217). For the component type piping and fittings the indicated Notes column entry of

'J' should be 'None' consistent with the other Notes column entries in this table and is changed

accordingly.

As to the second question in the RAI the applicant agreed that the AERM of LOM should be

applied to the WASS heat exchangers in DUW environments. Therefore, the applicant made

the following changes:

(a) Consistent with Table 3.3.2.A-14, the HT and PB function for the WASS heat

exchangers in Table 3.3.2.A-5 should have a line item for the AERM of LOM which is

added. For this line item, the AMP is the Closed Cycle Cooling Water System Program

with the Note of H. Additionally, the Note 9 for the LOHT AERM line item is removed.

(b) In Table 3.3.2.A-15, for the WASS heat exchangers with HT and PB intended

functions in a DUW environment, a line item for the AERM of LOM is added. For this

line item, the AMP is the Closed Cycle Cooling Water System Program with the Note

of H. The Note 9 for the LOHT intended function line item is removed (additionally, for

the LOHT line item, the One Time Inspection Program was removed in NMP letter

NMP1L 1996, dated November 17, 2005).

(c) In Table 3.3.2.A-17, for the WASS heat exchangers in a DUW environment, the

AERM is changed from None to LOM, the AMP is changed from None to the Closed

Cycle Cooling Water System Program, and the Note is changed from None to H.

(d) In Table 3.3.2.A-21, for WASS heat exchangers in a DUW environment, a line item

for the AERM of LOM is added with the AMP of the Closed Cycle Cooling Water

System Program, and Note H. Additionally, the Note 9 in the LOHT AERM line item is

removed.

(e) In Table 3.3.2.B-27, for the WASS heat exchangers with the HT and PB intended

functions in a DUW environment, a line item for the AERM of LOM is added with the

AMP of the Closed Cycle Cooling Water System Program, and Note H. Additionally,

the Note 9 in the LOHT AERM line item is removed.

The staff s review of the information provided in the ALRA and the additional information

included in the applicant's response to the RAI found the aging effects of the control room

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HVAC system component types not addressed by the GALL Report consistent with industry

experience for these combinations of materials and environments. The staff did not identify any

omitted aging effects. Therefore, the staff found that the applicant had identified the appropriate

aging effects for the materials and environments of the components in the control room HVAC

system.

Aping Management Programs. After evaluating the applicant's identification of aging effects for

each of the components the staff evaluated the AMPs to determine whether they are

appropriate for managing the identified aging effects. The staff also verified that the UFSAR

supplement describes the programs adequately.

ALRA Table 3.3.2.A-5 identifies the following AMPs for managing the aging effects for the

control room HVAC system components not addressed by the GALL Report:

" Closed-Cycle Cooling Water System Program

" System Walkdown Program

" Preventive Maintenance Program

" One-Time Inspection Program

* Selective Leaching of Materials Program

The staff's detailed review of these AMPs is in SER Sections 3.0.3.2.8, 3.0.3.3.2, 3.0.3.3.1,

3.0.3.1.4, and 3.0.3.1.5.

Conclusion: On the basis of its review, as discussed above, the staff concludes that there is

reasonable assurance that the applicant has demonstrated that the aging effects associated

with the control room HVAC system components will be adequately managed so that the

intended functions will be maintained consistent with the CLB for the period of extended

operation, as required by 10 CFR 54.21 (a)(3).

The staff also reviewed the applicable UFSAR supplement program descriptions and concludes

that the UFSAR supplement provides an adequate description of the AMPs credited for

managing aging of these components, as required by 10 CFR 54.21(d)

3.3A.2.3.6 Auxiliary Systems NMP1 Diesel Generator Building Ventilation System - Summary

of Aging Management Evaluation - ALRA Table 3.3.2.A-6

The staff reviewed ALRA Table 3.3.2.A-6, which summarizes the results of AMR evaluations for

the diesel generator building ventilation system component groups.

This auxiliary system is listed here for information and completeness. The AMR results for the

NMP1 diesel generator building ventilation system are consistent with the GALL Report. The

staffs evaluation of these results is presented in SER Section 3.3A.2.2.5

3.3A.2.3.7 Auxiliary Systems NMPI Emergency Diesel Generator System - Summary of Aging

Management Evaluation - ALRA Table 3.3.2.A-7

The staff reviewed ALRA Table 3.3.2.A-7, which summarizes the results of AMR evaluations for

the emergency diesel generator system component-material-environment AERM combinations

not addressed in the GALL Report. These combinations use Notes F through J in ALRA

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Table 3.3.2.A-7. The staff verified that the applicant had identified all AERMs and had credited

appropriate AMPs with managing them. The staff also reviewed the applicable UFSAR

supplements for the AMPs to ensure that the program descripiions describe them adequately.

Apinq Effects. ALRA Table 2.3.3.A.8-1 lists individual system components within the scope of

license renewal and subject to an AMR. The component types that do not rely on the GALL

Report for an AMR include external surfaces, filters/strainers, heat exchangers, and pumps.

For these component types the applicant identified the following materials, environments, and

AERMs:

* gray cast iron exposed to air subject to loss of material

* carbon or low alloy steel (Yield strength < 100 Ksi) exposed to treated water, temperature

< 140 OF, subject to loss of heat transfer

" gray cast iron exposed to treated water, temperature < 140 0

F, subject to loss of heat

transfer

" wrought austenitic stainless steel exposed to raw water subject to loss of heat transfer

" gray cast iron exposed to raw water subject to loss of material

The staff reviewed the information in ALRA Section 2.3.3.A.8, Table 2.3.3.A.8-1,

Section 3.3.2.A.7, and Table 3.3.2.A-7.

The staffs review of the information provided in the ALRA found the aging effects of the

emergency diesel generator system component types not addressed by the GALL Report

consistent with industry experience for these combinations of materials and environments. The

staff did not identify any omitted aging effects. Therefore, the staff found that the applicant had

identified the appropriate aging effects for the materials and environments of the components in

the emergency diesel generator system.

Aqing Management Programs. After evaluating the applicant's identification of aging effects for

each of the components the staff evaluated the AMPs to determine whether they are

appropriate for managing the identified aging effects. The staff also verified that the UFSAR

supplement describes the programs adequately.

ALRA Table 3.3.2.A-7 identifies the following AMPs for managing the aging effects for the

emergency diesel generator system components not addressed by the GALL Report:

• System Walkdown Program

° One-Time Inspection Program

• Closed-Cycle Cooling Water System Program

" Open-Cycle Cooling Water System Program

" Selective Leaching of Materials Program

The staffs detailed review of these AMPs is in SER Sections 3.0.3.3.2, 3.0.3.1.4, 3.0.3.2.8,

3.0.3.2.7, and 3.0.3.1.5.

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Conclusion: On the basis of its review, as discussed above, the staff concludes that there is

reasonable assurance that the applicant has demonstrated that the aging effects associated

with the emergency diesel generator system components will be adequately managed so that

the intended functions will be maintained consistent with the CLB for the period of extended

operation, as required by 10 CFR 54.21 (a)(3).

The staff also reviewed the applicable UFSAR supplement program descriptions and concludes

that the UFSAR supplement provides an adequate description of the AMPs credited for

managing aging of these components, as required by 10 CFR 54.21(d).

3.3A.2.3.8 Auxiliary Systems NMP1 Fire Detection and Protection System - Summary of Aging

Management Evaluation - ALRA Table 3.3.2.A-8

The staff reviewed the ALRA Table 3.3.2.A-8, which summarizes the results of AMR

evaluations for the fire detection and protection system component groups.

The staff initially reviewed ALRA Table 3.3.2.A-8 (only those line items that are not consistent

with the GALL Report or component aging effects for material/environment was not listed in the

GALL Report), which summarizes the results of AMR evaluations for the NMP1 fire detection

and protection system component groups.

In ALRA Section 3.3.2.A.8 and Table 3.3.2.A-8, the applicant identified the materials,

environments, and AERMs. The materials identified include carbon steel or low alloy steel,

concrete, copper alloy (zinc < 15%), copper alloy (zinc > 15%) and aluminum bronze, gray cast

iron, and wrought austenitic stainless steel.

The applicant identified the environments to which these materials could be exposed as air,

dried air or gas, exhaust, fuel oil without water contamination, lubricating oil, raw water low flow,

soil above the water table, and soil below the water table as the environments associated with

the fire detection and protection system. The applicant identified AERMs from cracking and loss

of material associated with the fire detection and protection system.

The applicant proposed to manage the fire protection system aging effects by using the Fire

Protection Program, Fire Water System Program, Preventive Maintenance Program, Systems

Walkdown Program, Bolting Integrity Program, One-Time Inspection Program, and Selective

Leaching of Materials Program. The staffs evaluations of these programs are documented in

SER Sections 3.0.3.2.13, 3.0.3.2.14, 3.0.3.3.1, 3.0.3.3.2, 3.0.3.3.23, 3.0.3.1.4, and 3.0.3.1.5

respectively.

The staff reviewed ALRA Section 3.3.2.A.8 and Table 3.3.2.A-8, to determine whether the

applicant demonstrated that it will adequately manage the effects of aging for the fire protection

system during the period of extended operation, as required by 10 CFR 54.21 (a)(3). The staff

conducted its review, described below, in accordance with SRP-LR Section 3.3 and the GALL

Report

In RAI 2.3.3.A.9-8 dated November 17, 2004, the staff stated that the GALL Report describes

recommendations for aging management of the fire protection water system based on the

combination of component type, material, and environment. ALRA Table 3.3.2.A-8 for the

auxiliary systems for the NMP1 fire detection and protection system summarizes the AMP for

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each of the combinations mentioned above. When the combinations do not exactly match the

requirements of the GALL Report, the ALRA table includes a note indicating that the prescribed

AMP has been modified for use or that the applicant will use another aging management

program.

For the combination of fire hydrants, gray cast iron, raw water, low flow, a table note indicates

that the Selective Leaching Program is being used in addition to the Fire Water System

Program to manage loss of material.

To complete its review, the staff required further information regarding the use of the Selective

Leaching Program to manage loss of material. Therefore, in the RAI 2.3.3.A.9-8, the staff

requested that the applicant supply the portions of the Selective Leaching Program that are

applicable to the combination of fire hydrants, gray cast iron, raw water, low flow. The staff also

requested that the applicant include program documents and procedures credited for managing

the loss of material for this combination.

In its response by letter dated December 17, 2004, the applicant stated that as presented in

ALRA Sections A1.1.33 and B2.1.21, the implementation of the selective leaching of materials

program is discussed in the program description for the One-Time Inspection Program (see

ALRA Section B2.1.20). The One-Time Inspection Program is a new license renewal aging

management program commitment for NMPNS (NMP1 Commitment 23 and NMP2

Commitment 21) that is to be implemented prior to the period of extended operation. This

commitment was made in the original LRA submittal, as supplemented by the NMP letter

NMPIL 1880 dated October 29, 2004. As such, NMP does not currently have any program

documents or procedures specific to managing selective leaching for fire hydrants

Based on its review, the staff found the applicant's response to RAI 2.3.3.A.9-8 acceptable

because it adequately describes how the Selective Leaching Program would be used to

manage loss of material components in question. Therefore, the staff's concern described in

RAI 2.3.3.A.9-8 is resolved.

In RAI 2.3.3.A.9-9 dated November 17, 2004, the staff stated that the GALL Report describes

requirements for aging management of the fire protection water system based on the

combination of component type, material, and environment.

The original LRA Table 3.3.2.A-8 for the auxiliary systems for the NMP1 fire detection and

protection system summarizes the AMP for each of the combinations mentioned above. When

the combinations do not exactly match the requirements of the GALL Report, the original LRA

table includes a note indicating that the prescribed AMP has been modified for use or that

another AMP is being used.

For the combination of flow elements, wrought austenitic stainless steel, raw water, low flow, a

table note indicates that the Fire Water System Program has been modified to manage

cracking in addition to loss of material.

Additionally, another note of the original LRA table indicates that flow elements are not

specifically identified in GALL Report Chapter VII for the fire protection system.

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Therefore, to complete its review, the staff required further information regarding the use of the

Fire Water System Program to manage cracking and loss of material. In the RAI, the staff

requested that the applicant supply the Fire Water System Program documents and procedures

that are applicable to the combination of flow elements, wrought austenitic stainless steel, raw

water, low flow that are credited with managing cracking and loss of material.

In its response by letter dated December 17, 2004, the applicant stated that the AERM of

material cracking resulting from SCC for wrought austenitic stainless steel components

(including the flow elements) in low flow, raw water will be reassigned to the One-Time

Inspection Program for aging management. As presented in the original LRA Sections A1.1.28

and B2.1.20, the One-Time Inspection Program is a new AMP, documented as commitments

(NMP1 Commitment 23 and NMP2 Commitment 21) to be implemented prior to the period of

extended operation. These commitments were made in the original LIRA submittal, as

supplemented by the NMP correspondence NMPIL 1880 dated October 29, 2004. As such,

NMP does not currently have any program documents or procedures specific to manage

cracking of flow elements.

The above flow elements are also susceptible to loss of material from galvanic, general, pitting,

and MIC mechanisms. The applicant credits fire system flow test and a site chemistry

procedure with managing the aging along with a new inspection activity yet to be generated.

These credited activities are discussed below:

" The new site activity is identified as an enhancement in "parameters monitored/inspected"

in original LIRA Sections A1.1.18 and B2.1.17. The enhancement adds procedural

guidance for performing visual inspections to monitor internal corrosion and detect

biofouling. This enhancement will include inspections for loss of material in the flow

elements above and will be implemented prior to the period of extended operation. As

such, there are no existing program documents or procedures implementing these

inspections.

" Site procedure S-CTP-V632, "Sampling and Analysis of Water Systems for Bacteria," is

credited with managing loss of material as a result of microbiological activity. The

procedure provides guidance for sampling and analysis of raw water systems for the

presence of bacteria. Acceptance criteria are defined and the site corrective action

process is utilized when the criteria are not met. Additionally, as presented in the original

LIRA Sections A1.1.18 and B2.1.17, the fire water system program will be enhanced prior

to the period of extended operation to add specific requirements for periodic sampling of

water-based fire protection systems.

" Site procedure N1-FST-FPW-3A001, "FPW System Flow Test," is credited with managing

corrosion, biofouling, and MIC of the fire protection water distribution system. The testing

actiivity provides full flow testing of the system in accordance with the NFPA Fire Protection

Handbook. Acceptance criteria are defined and the site corrective action process is utilized

when the criteria are not met. The procedure verifies the system is capable of retaining

pressure and is not obstructed or degraded by corrosion or fouling.

The applicant revised AMR original LIRA Table 3.3.2.A-8 to replace Fire Water System Program

with One-Time Inspection Program for the management of material cracking for wrought

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austenitic stainless steel components (flow elements and orifices) in a raw water, low flow

environment.

Based on its review, the staff found the applicant's response to RAI 2.3.3.A.9-9 acceptable

because it adequately describes how the aging effects requiring management of material

cracking resulting from SCC for wrought austenitic stainless steel components, galvanic,

general, pitting, MIC, and selective leaching would be managed for the components in question.

The applicant also revised the AMR original LRA table for the component types in question to

show the One-Time Inspection Program for the management of cracking. Therefore, the staff's

concern described in RAI 2.3.3.A.9-9 is resolved.

In RAI 2.3.3.A.9-10 dated November 17, 2004, the staff stated that the GALL Report describes

recommendations for aging management of the fire protection water system based on the

combination of component type, material, and environment.

The original LRA Table 3.3.2.A-8 for the auxiliary systems for the NMP1 fire detection and

protection system summarizes the aging management program for each of the combinations

mentioned above. When the combinations do not exactly match the requirements of the GALL

Report, the original LRA table includes a note indicating that the prescribed AMP has been

modified for use or that another AMP is being used.

For the combination of heat exchangers, carbon or low alloy steel (yield strength < 100 Ksi),

raw water, and low flow, a table note indicates that the Fire Water System Program has been

modified to manage loss of material in heat exchangers which are not specifically identified in

GALL Report Chapter VII for the fire protection system.

To complete its review, the staff required further information regarding the use of the Fire Water

System Program to manage loss of material for heat exchangers. The staff asked the applicant

to supply the Fire Water System Program documents and procedures that are applicable to the

combination of heat exchangers, carbon or low alloy steel (yield strength < 100 Ksi), raw water,

and low flow that are credited with managing loss of material in heat exchangers.

In its response by letter dated December 17, 2004, the applicant stated that the heat

exchangers in question are susceptible to loss of material from galvanic, general, pitting, and

MIC mechanisms. A new inspection activity (see NMP1 Commitment 20 and NMP2

Commitment 18), for which a procedure must be generated, a site chemistry procedure, and a

fire system flow test are credited with managing aging. These activities are discussed below:

" The new site activity is identified as an enhancement in "parameters monitored/inspected"

in original LRA Sections A1.1.18 and B2.1.17. The enhancement adds procedural

guidance for performing visual inspections to monitor internal corrosion and to detect

biofouling. This new activity will include inspections for loss of material in the heat

exchangers in question and will be implemented prior to the period of extended operation.

As such, there are no existing procedures implementing these inspections at this time. The

Fire Water System Program attribute assessment addresses program implementation at

NMP relative to the requirements of SRP-LR Appendix A.

" Site procedure S-CTP-V632, "Sampling and Analysis of Water Systems for Bacteria," is

credited with managing loss of material as a result of microbiological activity. The

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procedure provides guidance for sampling and analysis of raw water systems for the

presence of bacteria. Additionally, as presented in original LRA Sections Al.1.18 and

B2.1.17, the Fire Water System Program will be enhanced prior to the period of extended

operation to add specific requirements for periodic sampling of water-based fire protection

systems.

Site procedure NI-FST-FPW-3A001, "FPW System Flow Test," is credited with the

possible discovery of corrosion, biofouling, and MIC of the fire protection water distribution

system. The procedure provides for full flow testing of the system in accordance with the

NFPA Fire Protection Handbook. Acceptance criteria are defined and the site corrective

action process is utilized when the criteria are not met. The procedure verifies that the

system is capable .of retairning pressure and is not obstructed or adversely affected by

degradation such as corrosion or fouling.

Based on its review, the staff found the applicant's response to RAI 2.3.3.A.9-10 acceptable

because it adequately describes how the aging effects requiring management of loss of

material resulting from galvanic, general, pitting, and MIC mechanisms for carbon or low alloy

steel combinations would be managed for the components in question. Therefore, the staff's

concern described in RAI 2.3.3.A.9-1 0 is resolved. The above information is reflected in the

ALRA.

In RAI 2.3.3.A.9-11 dated November 17, 2004, the staff stated that the GALL Report describes

recommendations for aging management of the fire protection water system based on the

combination of component type, material, and environment.

The original LRA Table 3.3.2.A-8 for the auxiliary systems for the NMP1 fire detection and

protection system summarizes the aging management program for each of the combinations

mentioned above. When the combinations do not exactly match the requirements of the GALL

Report, the original LRA table includes a note indicating that the prescribed AMP has been

modified for use or that another AMP is being used.

For the combination of orifices, carbon or low alloy steel (yield strength < 100 Ksi), cast iron,

raw water, and low flow, a table note indicates that the Fire Water System Program has been

modified to manage loss of material in orifices which are not specifically identified in GALL

Report Chapter VII for the fire protection system.

Therefore, to complete its review, the staff required further information regarding the use of the

Fire Water System Program to manage loss of material for orifices. The staff requested that the

applicant supply the Fire Water System Program documents and procedures that are

applicable to the combination of orifices, carbon or low alloy steel (yield strength < 100 Ksi), raw

water, and low flow that are credited with managing loss of material in orifices.

In its response by letter dated December 17, 2004, the applicant stated that the population of

orifices satisfying the criteria above is limited to flow orifice FOR-100-509 (diesel fire pump to

EDG cooling). This orifice is susceptible to loss of material from galvanic, general, pitting, and

microbiologically influenced corrosion mechanisms. A fire system flow test and a site chemistry

procedure are credited with managing the aging along with a new inspection activity yet to be

generated. As stated in the response by the applicant, these credited activities are as follows:

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The new site activity (see NMP1 Commitment 20 and NMP2 Commitment 18) is identified as an

enhancement in "parameters monitored/inspected" in original LRA Sections A1.1.18 and

B2.1.17. The enhancement adds procedural guidance for performing visual inspections to

monitor internal corrosion and detect biofouling. This new activity will include inspections for

loss of material in the above orifice and will be implemented prior to the period of extended

operation.

Site procedure S-CTP-V632, "Sampling and Analysis of Water Systems for Bacteria," is

credited with managing loss of material as a result of microbiological activity. This procedure

provides guidance for sampling and analysis of raw water systems for the presence of bacteria.

Additionally, as presented in original LRA Sections A1.1.18 and B2.1.17, the Fire Water System

Program will be enhanced prior to the period of extended operation to include periodic sampling

of water-based fire protection systems.

Site procedure N1 -FST-FPW-3A001, "FPW System Flow Test," is credited with managing

corrosion, biofouling, and microbiologically influenced corrosion of the fire protection water

distribution system. The testing actiivity provides full flow testing of the system in accordance

with the NFPA Fire Protection Handbook. Acceptance criteria are defined and the site

corrective action process is utilized when the criteria are not met. The procedure verifies the

system is capable of retaining pressure and is not obstructed or degraded by corrosion or

fouling.

Based on its review, the staff found the applicant's response to RAI 2.3,3.A.9-11 acceptable

because it adequately describes how the aging effects requiring management for orifices would

be managed for the combination in question. Therefore, the staff's concern described in

RAI 2.3.3.A.9-11 is resolved. The above information is reflected in the ALRA.

In RAI 2.3.3.A.9-12 dated November 17, 2004, the staff stated that the GALL Report describes

recommendations for aging management of the fire protection water system based on the

combination of component type, material, and environment.

The original LRA Table 3.3.2.A-8 for the auxiliary systems for the NMP1 fire detection and

protection system summarizes the AMP for each of the combinations mentioned above. When

the combinations do not exactly match the requirements of the GALL Report, the original LRA

table includes a note indicating that the prescribed AMP has been modified for use or that

another AMP is being used.

For the combination of orifices, wrought austenitic stainless steel, raw water, low flow, a table

note indicates that the Fire Water System Program has been modified to manage cracking in

addition to loss of material.

Another table note indicates that orifices are not specifically identified in GALL Report

Chapter VII for the fire protection system.

Therefore, to complete its review, the staff required further information regarding the use of the

Fire Water System Program to manage cracking and loss of material. The staff requested that

the applicant supply the Fire Water System Program documents and procedures that are

applicable to the combination of orifices, wrought austenitic stainless steel, raw water, and low

flow that are credited with managing cracking and loss of material.

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In its response by letter dated December 17, 2004, the applicant stated that identification of the

Fire Water System Program as the aging management program for cracking of wrought

austenitic stainless steel orifices in raw water with low flow (original LRA Table 3.3.2.A-8) was

an error. The Fire Water System Program is focused on managing loss of material rather than

cracking. The One-Time Inspection Program should have been designated as the aging

management program for the subject flow orifices. Use of the One-Time Inspection Program to

manage cracking is appropriate because the aging mechanism that can cause cracking of

wrought austenitic stainless steel in raw water with low flow is SCC. While SCC is possible in

non-brackish fresh water, it is unlikely. Therefore, a one-time inspection is sufficient to verify

that SCC is not occurring. As presented in original LRA Sections A1.1.28 and B2.1.20, the

One-Time Inspection Program is a new AMP for NMP that is to be implemented prior to the

period of extended operation. Development of the new program is a commitment made with the

original LRA submittal (see NMP1 Commitment 23 and NMP2 Commitment 21), as

supplemented by NMP Nuclear Station letter (NMP1L 1880) dated October 29, 2004. As such,

NMP does not currently have any program documents or procedures specific to managing

cracking of flow orifices in the fire water system. The One-Time Inspection Program attribute

assessment addresses program implementation at NMP relative to the requirements of SRP-LR

Appendix A.

The subject orifices are also susceptible to loss of material from galvanic, general, pitting, and

microbiologically influenced corrosion mechanisms. A new inspection activity, for which a

procedure must be generated, a site chemistry procedure, and a fire system flow test are

credited with managing aging. These credited activities are discussed below:

The new site activity is identified as an enhancement in "parameters monitored/inspected"

in original LRA Sections A1.1.18 and B2.1.17. The enhancement adds procedural

guidance for performing visual inspections to monitor internal corrosion and to detect

biofouling. This new activity will include inspections for loss of material in the subject

orifices and will be implemented prior to the period of extended operation. As such, there

are no existing procedures implementing these inspections at this time. The Fire Water

System Program attribute assessment addresses program implementation at NMP relative

to the requirements of SRP-LR Appendix A

Site pProcedure S-CTP-V632, "Sampling and Analysis of Water Systems for Bacteria," is

credited with managing loss of material as a result of microbiological activity. The

procedure provides guidance for sampling and analysis of raw water systems for the

presence of bacteria. Acceptance criteria are defined and the site corrective action process

is utilized when the criteria are not met. Additionally, as presented in original LRA

Sections A1.1.18 and B2.1.17, the Fire Water System Program will be enhanced prior to

the period of extended operation to add specific requirements for periodic sampling of

water-based fire protection systems.

Site procedure N1-FST-FPW-3A001, "FPW System Flow Test," is credited with the

possible discovery of corrosion, biofouling, and MICof the fire protection water distribution

system. The testing activity provides full flow testing of the system in accordance with the

NFPA fire protection handbook. Acceptance criteria are defined and the site corrective

action process is utilized when the criteria are not met. The procedure, therefore, verifies

the system is capable of retaining pressure and is not obstructed or degraded by corrosion

or fouling.

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Based on its review, the staff found the applicant's response to RAI 2.3.3.A.9-12 acceptable

because it adequately describes how the aging effects requiring management for orifices would

be managed for the combination in question. The applicant also revised the original LRA AMR

table for the component type in question to show the One-Time Inspection Program for the

management of cracking. Therefore, the staffs concern described in RAI 2.3.3.A.9-12 is

resolved.

In RAI 2.3.3.A.9-13 dated November 17, 2004, the staff stated that the GALL Report describes

recommendations for aging management of the fire protection water system based on the

combination of component type, material, and environment.

Original LRA Section 3.3.2.A-8 for the auxiliary systems for the NMP1 fire detection and

protection system summarizes the AMP for each of the combinations mentioned above. When

the combinations do not exactly match the requirements of the GALL Report, the original LRA

table includes a note indicating that the prescribed AMP has been modified for use or that

another AMP is being used.

For the combination of sluice gate for motor driven fire pump, carbon or low alloy steel (yield

strength < 100 Ksi), raw water, and low flow, a table note indicates that the Fire Water System

Program has been modified to manage loss of material in the sluice gate for motor driven fire

pump which is not specifically identified in GALL Report Chapter VII for the fire protection

system.

Therefore, to complete its review, the staff required further information regarding the use of the

Fire Water System Program to manage loss of material for the sluice gate for the motor driven

fire pump. The staff requested that the applicant supply the Fire Water System Program

documents and procedures that are applicable to the combination of sluice gate for motor

driven fire pump, carbon or low alloy steel (yield strength < 100 Ksi), raw water, and low flow

that are credited with managing loss of material in the sluice gate for motor driven fire pump.

In its response by letter dated December 17, 2004, the applicant stated that the sluice gate for

the motor-driven fire pump is susceptible to loss of material from galvanic, general, pitting, and

MIC mechanisms. A new inspection activity (see NMP Commitment 20 and NMP2 Commitment

21), for which a procedure must be generated, a site chemistry procedure, and a fire system

flow test are credited with managing aging. These activities are discussed below:

The new site activity is identified as an enhancement in "parameters monitored/inspected"

in original LRA Sections A1.1.18 and B2.1.17. The enhancement includes performing

visual inspections to monitor component corrosion and to detect biofouling. This new

activity will include inspections for loss of material in the sluice gates identified above and

will be implemented prior to the period of extended operation. As such, there are no

existing procedures implementing these inspections at this time. The Fire Water System

Program attribute assessment addresses program implementation at NMP relative to the

requirements of SRP-LR Appendix A.

Site procedure S-CTP-V632, "Sampling and Analysis of Water Systems for Bacteria," is

credited with managing loss of material as a result of microbiological activity. The

procedure includes sampling and analysis of raw water systems for the presence of

bacteria. Acceptance criteria are defined and the site corrective action process is utilized

when the criteria are not met. Additionally, as presented in original LRA Sections A1.1.18

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and B2.1.17, the Fire Water System Program will be enhanced prior to the period of

extended operation to add specific requirements for periodic sampling of water-based fire

protection systems.

Site procedure N1-FST-FPW-3A001, "FPW System Flow Test," is credited with the

possible discovery of corrosion, biofouling, and microbiologically influenced corrosion of the

fire protection water distribution system. The procedure provides for full flow testing of the

system in accordance with the NFPA fire protection handbook. Acceptance criteria are

defined and the site corrective action process is utilized when the criteria are not met. The

procedure verifies that the system is capable of retaining pressure and is not obstructed or

adversely affected by degradation such as corrosion or fouling.

Based on its review, the staff found the applicant's response to RAI 2.3.3.A.9-13 acceptable

because it adequately describes how the aging effects requiring management for sluice gates

would be managed for the combination in question. Therefore, the staff's concern described in

RAI 2.3.3.A.9-13 is resolved. The above information is reflected in the ALRA.

In RAI 2.3.3.A.9-14 dated November 17, 2004, the staff stated that the GALL Report describes

recommendations for aging management of the fire protection water system based on the

combination of component type, material, and environment.

The original LRA Table 3.3.2.A-8 for the auxiliary systems for the NMP1 fire detection and

protection system summarizes the AMP for each of the combinations mentioned above. When

the combinations do not exactly match the requirements of the GALL Report, the original LRA

table includes a note indicating that the prescribed AMP has been modified for use or that

another AMP is being used.

For the combination of spray nozzles, copper alloys (zinc < 15%), raw water, and low flow, a

table note indicates that the Fire Water System Program has been modified to manage loss of

material in the spray nozzles which are not specifically identified in GALL Report Chapter VII for

the fire protection system.

To complete its review, the staff required further information regarding the use of the Fire Water

System Program to manage loss of material for spray nozzles. The staff asked the applicant to

supply the Fire Water System Program documents and procedures that are applicable to the

combination of spray nozzles, copper alloys (zinc - 15%), raw water, low flow, that are credited

with managing loss of material in spray nozzles.

In its response by letter dated December 17, 2004, the applicant stated that the spray nozzles

fabricated from copper alloys (zinc < 15%), in an environment of raw water and low flow, are

susceptible to loss of material. A new inspection activity (NMP1 Commitment 20 and NMP2

Commitment 18), for which a procedure must be generated, a site chemistry procedure, and a

fire system functional test are credited with managing aging. These activities are discussed

below:

The new site activity is identified as an enhancement in "parameters monitored/inspected" in

original LRA Sections A1.1.18 and B2.1.17. The enhancement includes performing visual

inspections to monitor component corrosion and to detect biofouling. This new activity will

include inspections for loss of material in the sluice gates identified above and will be

implemented prior to the period of extended operation. As such, there are no existing

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procedures implementing these inspections at this time. The Fire Water System Program

attribute assessment addresses program implementation at NMP relative to the requirements of

SRP-LR Appendix A.

Site procedure S-CTP-V632, "Sampling and Analysis of Water Systems for Bacteria," is

credited with managing loss of material as a result of microbiological activity. The procedure

includes sampling and analysis of raw water systems for the presence of bacteria. Acceptance

criteria are defined and the site corrective action process is utilized when the criteria are not

met. Additionally, as presented in original LRA Sections A1.1.18 and B2.1.17, the Fire Water

System Program will be enhanced prior to the period of extended operation to add specific

requirements for periodic sampling of water-based fire protection systems.

Site procedure N1-FST-FPW-C003, "Fire Protection Preaction, Deluge and Automatic Sprinkler

Test," verifies the operability of the fire protection preaction, deluge, and automatic systems by

performing a system functional test which includes simulated automatic actuation of the system

and a visual inspection of the sprinkler heads and system piping to verify their integrity and

verify no blockage. Acceptance criteria are defined and the site corrective action process is

utilized when the criteria are not met.

Based on its review, the staff found the applicant's response to RAI 2.3.3.A.9-14 acceptable

because it adequately describes how the aging effects requiring management for spray nozzles

would be managed for the combination in question. Therefore, the staff's concern described in

RAI 2.3.3.A.9-14 is resolved.

By supplemental letter dated November 17, 2005, the applicant stated that an additional item

will be added to Table 3.3.2.A-8. This being an external surfaces item for "gray cast iron in soil,

above the water table" environment with the AERM of LOM, the AMP of Buried Piping and

Tanks Inspection Program, the GALL Report Item of VII.C2.1-b, the Type 1 Table Item of

3.3.1.A-18, and Note F. This item is added based on the determination that the barrel of the

gray cast iron fire hydrants is partially buried. The staff reviewed this change and found it

acceptable.

As documented in the Audit and Review Report, the staff requested that the applicant describe

the aging management of the fire hose reel supports to capture the stated changes to the

Assessment Summary of the Fire Water Program Basis Document. The applicant subsequently

described the procedures used to test hose stations and standpipe. The applicant also stated

that when reviewing the AMR Reports and the ALRA, it was found that NMP2 credits the Fire

Protection Program for hose reels, while this "hose reels" was not included as a component

type for the NMP1 fire detection and protection system.

By supplemental letter dated December 1, 2005, the applicant stated an additional item will be

added to ALRA Table 3.3.2.A-8. This component being "hose reels" with the intended function

of pressure boundary. The aging management information for this item will be the same shown

for hose reels in ALRA Table 3.3.2.B-13. The staff reviewed this change made to the ALRA and

found that it is acceptable for the aging management of hose reels.

By letter dated December 20, 2005, the applicant submitted a summary of the CLB changes

that have occurred during the staff review of the application that materially affects the contents

of the application. The summary included an additional item added to ALRA Table 3.3.2.A-8.

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This being a valve item for "gray cast iron in raw water, low flow table" environment with the

AERM of LOM, the AMP of Fire Water System and Selective Leaching of Materials Programs,

the GALL Report Items of VII.G.6-b, VII.C1.5-a, the Type 1 Table Items of 3.3.1.A-21 3.3.1.A29, and Note A, C respectively. The applicant stated that the changes were made as a result of

replacing the carbon steel pressure safety valve that serves as the air release valve for the

NMP1 diesel-driven fire pump with a cast iron model. The staff reviewed these changes and

found that it is acceptable for the aging management of cast iron pressure safety valve.

An addition to the letters mentioned above, the staff also reviewed the applicant's letter, dated

July 14, 2005. This letter detailed changes that were made to the LRA, and found in the ALRA.

The staff reviewed the changes to ALRA Table 3.3.2.A-8, and found that they are acceptable.

In its letter dated December 1, 2005, the applicant stated that the note for bolting will be

modified from A to B in Table 3.3.2.A-8. This change is due to an exception found in the Bolting

Integrity Program, which is the AMP for bolting. The staff evaluation for this exception is

documented in Section 3.0.3.2.23. This staff reviewed the change in note, and found that it is

acceptable.

3.3A.2.3.9 Auxiliary Systems NMP1 Hydrogen Water Chemistry System - Summary of Aging

Management Evaluation - ALRA Table 3.3.2.A-9

The staff reviewed ALRA Table 3.3.2.A-9, which summarizes the results of AMR evaluations for

the hydgrogen water chemistry system component-material-environment AERM combinations

not addressed in the GALL Report. These combinations use Notes F through J in ALRA

Table 3.3.2.A-9. The staff verified that the applicant had identified all AERMs and had credited

appropriate AMPs with managing them. The staff also reviewed the applicable UFSAR

supplements for the AMPs to ensure that the program descriptions describe them adequately.

Agqing Effects. ALRA Table 2.3.3.A.10-1 lists individual system components within the scope of

license renewal and subject to an AMR. The component types that do not rely on the GALL

Report for an AMR include flow element, piping and fittings, and valves.

For these component types the applicant identified the following materials, environments, and

AERMs:

wrought austenhtic stainless steel exposed to treated water or steam, temperature > 212 *F,

but < 482 OF, subject to cracking

The staff reviewed the information In ALRA Section 2.3.3.A.10, Table 2.3.3.A.10-1,

Section 3.3.2.A.9, and Table 3.3.2.A-9.

The staffs review of the information provided in the ALRA found the aging effects of the

hydrogen water chemistry system component types not addressed by the GALL Report

consistent with industry experience for these combinations of materials and environments. The

staff did not identify any omitted aging effects. Therefore, the staff found that the applicant had

identified the appropriate aging effects for the materials and environments of the components in

the hydrogen water chemistry system.

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Aging Management Pro-rams. After evaluating the applicant's identification of aging effects for

each of the components the staff evaluated the AMPs to determine whether they are

appropriate for managing the identified aging effects. The staff also verified that the UFSAR

supplement describes the programs adequately.

ALRA Table 3.3.2.A-9 identifies the following AMPs for managing the aging effects for the

hydrogen water chemistry system components not addressed by the GALL Report:

* One-Time Inspection Program

" Water Chemistry Control Program

The staff's detailed review of these AMPs is found in Sections 3.0.3.1.4 and 3.0.3.2.2 of this

SER.

Conclusion: On the basis of its review, as discussed above, the staff concludes that there is

reasonable assurance that the applicant has demonstrated that the aging effects associated

with the hydgrogen water chemistry system components will be adequately managed so that

the intended functions will be maintained consistent with the CLB for the period of extended

operation, as required by 10 CFR 54.21 (a)(3).

The staff also reviewed the applicable UFSAR supplement program descriptions and concludes

that the UFSAR supplement provides an adequate description of the AMPs credited for

managing aging of these components, as required by 10 CFR 54.21(d).

3.3A.2.3.10 Auxiliary Systems NMP1 Liquid Poison System - Summary of Aging Management

Evaluation - ALRA Table 3.3.2.A-1 0

The staff reviewed ALRA Table 3.3.2.A-10, which summarizes the results of AMR evaluations

for the liquid poison system component groups.

This auxiliary system is listed here for information and completeness. The AMR results for the

NMPI liquid poison system are consistent with the GALL Report. The staff's evaluation of these

results is presented in SER Section 3.3A.2.2.5

3.3A.2.3.11 Auxiliary Systems NMP1 Miscellaneous Non Contaminated Vents and Drains

System - Summary of Aging Management Evaluation - ALRA Table 3.3.2.A-1 1

The staff reviewed ALRA Table 3.3.2.A-1 1, which summarizes the results of AMR evaluations

for the miscellaneous non contaminated vents and drains system of those AERM combinations

not addressed in the GALL Report. These combinations use Notes F through J in ALRA

Table 3.3.2.A-1 1. The staff verified that the applicant had identified all AERMs and had credited

appropriate AMPs with managing them. The staff also reviewed the applicable UFSAR

supplements for the AMPs to ensure that the program descriptions describe them adequately.

Aging Effects. ALRA Table 2.3.3.A.12-1 lists individual system components within the scope of

license renewal and subject to an AMR. The component types that do not rely on the GALL

Report for an AMR include piping and fittings.

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For these component types, the applicant identified the following materials, environments, and

AERMs: - .. "

carbon or low alloy steel (Yield strength < 100 Ksi) exposed to demineralized untreated

water subject to loss of material

The staff reviewed the information in ALRA Section 2.3.3.A.12, Table 2.3.3.A.12-1,

Section 3.3.2.A.1 1, and Table 3.3.2.A-1. During its review the staff determined that additional

information was needed.

The RAls are organized in two groups, general and system-specific. The general RAI applicable

to this system is a-RAI 3.3.2-1

In a-RAI 3.3.2-1 dated November 2, 2005, the staff requested that the applicant provide

additional information on the system aging effects. By letter dated November 30, 2005, the

applicant responded. The RAI, the applicant's response, and the staff's evaluation of the

response are described in SER Section 3.3A.2.3.0.

There are no relevant system-specific RAls associated with this system.

The staff's review of the information provided in the ALRA and the additional information in the

applicant's response to the RAI found the aging effects of the miscellaneous noncontaminated

vents and drains system component types not addressed by the GALL Report consistent with

industry experience for these combinations of materials and environments. The staff did not

identify any omitted aging effects. Therefore, the staff found that the applicant had identified the

appropriate aging effects for the materials and environments of the components in the

miscellaneous noncontaminated vents and drains system.

Aging Management Programs. After evaluating the applicant's identification of aging effects for

each of the components the staff evaluated the AMPs to determine whether they are

appropriate for managing the identified aging effects. The staff also verified that the UFSAR

supplement describes the programs adequately.

ALRA Table 3.3.2.A-1 1 identifies the following AMPs for managing the aging effects for the

miscellaneous noncontaminated vents and drains system components not addressed by the

GALL Report:

* One-Time Inspection Program

In the applicant's response to general RAt a-RAI 3.3.2-1, dated November 30, 2005, as

described in SER Section 3.3A.2.3.0 the applicant revised its management strategy for the

aging effects of some components in this system by replacing the One-Time Inspection

Program with the Preventive Maintenance Program. The staffs detailed review of the

Preventive Maintenance Program is in SER Section 3.0.3.3.1.

Conclusion: On the basis of its review, as discussed above, the staff concludes that there is

reasonable assurance that the applicant has demonstrated that the aging effects associated

with the miscellaneous non contaminated vents and drains system components will be

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adequately managed so that the intended functions will be maintained consistent with the CLB

for the period of extended operation, as required by 10 CFR 54.21 (a)(3).

The staff also reviewed the applicable UFSAR supplement program descriptions and concludes

that the UFSAR supplement provides an adequate description of the AMPs credited for

managing aging of these components, as required by 10 CFR 54.21(d).

3.3A.2.3.12 Auxiliary Systems NMPI Neutron Monitoring System - Summary of Aging

Management Evaluation - ALRA Table 3.3.2.A-12

This auxiliary system is listed here for information and completeness. The AMR results for the

NMPI neutron monitoring system are consistent with the GALL Report. The staff's evaluation of

these results is presented in SER Section 3.3A.2.2.5

3.3A.2.3.13 Auxiliary Systems NMP1 Radioactive Waste Solidification and Storage Building

HVAC System - Summary of Aging Management Evaluation - ALRA Table 3.3.2.A-1 3

This auxiliary system is listed here for information and completeness. The AMR results for the

NMP1 radioactive waste solidification and storage building HVAC system are consistent with

the GALL Report. The staff's evaluation of these results is presented in SER Section 3.3A.2.2.5

3.3A.2.3.14 Auxiliary Systems NMP1 Radioactive Waste System - Summary of Aging

Management Evaluation -ALRA Table 3.3.2.A-14

The staff reviewed ALRA Table 3.3.2.A-14, which summarizes the results of AMR evaluations

for the radioactive waste system component-material-environment AERM combinations not

addressed in the GALL Report. These combinations use Notes F through J in ALRA

Table 3.3.2.A-14 as revised in the applicant's letter NMPIL 2005 dated December 1, 2005. The

staff verified that the applicant had identified all AERMs and had credited appropriate AMPs

with managing them. The staff also reviewed the applicable UFSAR supplements for the AMPs

to ensure that the program descriptions describe them adequately.

Aginq Effects. ALRA Table 2.3.3.A.16-1 lists individual system components within the scope of

license renewal and subject to AMR. The component types that do not rely on the GALL Report

for an AMR include external surfaces, filters/strainers, flow element, heat exchangers, piping

and fittings, pumps, separator, tanks, and valves.

For these component types the applicant identified the following materials, environments, and

AERMs:

" carbon or low alloy steel (Yield strength < 100 Ksi) exposed to demineralized untreated

water subject to loss of material

* gray cast iron exposed to air subject to loss of material

• wrought austenitic stainless steel exposed to demineralized untreated water subject to loss

of material

" wrought austenitic stainless steel exposed to air, moisture or wetting, temperature

> 140 OF, subject to loss of material

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" nickel based alloys exposed to demineralized untreated water subject to loss of material

* carbon or low alloy steel (Yield strength < 100 Ksi) exposed to treated water, temperature

> 140 OF, but < 212 0F, subject to loss of material

" gray cast iron exposed to demineralized untreated water subject to loss of material

• carbon or low alloy steel (Yield strength < 100 Ksi) exposed to treated water, temperature

< 140 OF, subject to loss of material

" cast austenitic stainless steel exposed to demineralized untreated water subject to loss of

material

" wrought austenitic stainless steel exposed to treated water, temperature < 140 OF, subject

to loss of material

" carbon or low alloy steel (yield strength < 100 Ksi) exposed to demineralized untreated

water, low flow, subject to loss of material

" copper alloys (zinc < 15 percent) exposed to demineralized untreated water subject to loss

of material

" wrought austenitic stainless steel exposed to treated water, temperature > 140 OF, but

< 212 OF, subject to cracking

The staff reviewed the information in ALRA Section 2.3.3.A.16, Table 2.3.3.A.16-1,

Section 3.3.2.A.14, and Table 3.3.2.A-14. During its review, the staff determined that additional

information was needed.

The RAls are organized in two groups, general and system-specific. The general RAI applicable

to this system is a-RAI 3.3.2-1 as discussed below:

By letter dated November 2, 2005, the staff requested that the applicant provide additional

information on the issue addressed in a-RAI 3.3.2-1. By letter dated November 30, 2005, the

applicant responded. The RAI, the applicant's response, and the staff's evaluation of the

response are described in SER Section 3.3A.2.3.0.

There are no relevant system-specific RAIs for this system.

The staffs review of the information provided in the ALRA and the additional information

included in the applicant's response to the RAI found the aging effects of the radioactive waste

system component types not addressed by the GALL Report consistent with industry

experience for these combinations of materials and environments. The staff did not identify any

omitted aging effects. Therefore, the staff found that the applicant had identified the appropriate

aging effects for the materials and environments of the components in the radioactive waste

system.

Aging Management Programs. After evaluating the applicant's identification of aging effects for

each of the components the staff evaluated the AMPs to determine whether they are

appropriate for managing the identified aging effects. The staff also verified that the UFSAR

supplement describes the programs adequately.

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ALRA Table 3.3.2.A-14 identifies the following AMPs for managing the aging effects for the

radioactive waste system components not addressed by the GALL Report:

" One-Time Inspection Program

" Selective Leaching of Materials Program

* System Walkdown Program

In the applicant's response to general RAI a-RAI 3.3.2-1 as described in SER

Section 3.3A.2.3.0, the applicant revised its strategy for managing the aging effects of some

components in this system by replacing the One-Time Inspection Program with the Preventive

Maintenance Program. The staffs detailed review of the Preventive Maintenance Program is in

SER Section 3.0.3.3.1.

The staffs detailed review of Selective Leaching of Materials Program and System Walkdown

Program is in SER Sections 3.0.3.1.5 and 3.0.3.3.2.

Conclusion: On the basis of its review, as discussed above, the staff concludes that there is

reasonable assurance that the applicant has demonstrated that the aging effects associated

with the radioactive waste system components will be adequately managed so that the intended

functions will be maintained consistent with the CLB for the period of extended operation, as

required by 10 CFR 54.21(a)(3).

The staff also reviewed the applicable UFSAR supplement program descriptions and concludes

that the UFSAR supplement provides an adequate description of the AMPs credited for

managing aging of these components, as required by 10 CFR 54.21(d).

3.3A.2.3.15 Auxiliary Systems NMP1 Reactor Building Closed Loop Cooling Water System -

Summary of Aging Management Evaluation - ALRA Table 3.3.2.A-1 5

The staff reviewed ALRA Table 3.3.2.A-15, which summarizes the results of AMR evaluations

for the reactor building closed loop cooling water system component-material-environment

AERM combinations not addressed in the GALL Report. These combinations use Notes F

through J in ALRA Table 3.3.2.A-15 as revised by the applicant's letter NMPIL 1996 dated

November 17, 2005, the applicant's response to a-RAI 3.3.2.A-5-1 dated November 30, 2005,

and the applicant's letter NMPIL 2005 dated December 1, 2005. The staff verified that the

applicant had identified all AERMs and had credited appropriate AMPs with managing them.

The staff also reviewed the applicable UFSAR supplements for the AMPs to ensure that the

program descriptions describe them adequately.

Aping Effects. ALRA Table 2.3.3.A.17-1 lists individual system components within the scope of

license renewal and subject to an AMR. The component types that do not rely on the GALL

Report for an AMR include external surfaces, filters/strainers, flow elements, heat exchangers,

orifices, piping and fittings, pumps, temperature elements, and valves.

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For these component types, the applicant identified the following materials, environments, and

AERMs:

0 gray cast iron exposed to air subject to loss of material

0 carbon or low alloy steel (yield strength < 100 Ksi) exposed to demineralized untreated

water subject to loss of material

* copper alloys (zinc < 15 percent) exposed to demineralized untreated water subject to loss

of material

0 gray cast iron exposed to demineralized untreated water, or demineralized untreated water,

low flow, subject to loss of material

& wrought austenitic stainless steel exposed to demineralized untreated water subject to loss

of material

0 carbon or low alloy steel (yield strength < 100 ksi) exposed to demineralized untreated

water subject to loss of heat transfer

* copper alloys (zinc > 15 percent) and aluminum bronze exposed to demineralized

untreated water subject to loss of heat transfer and loss of material

- copper alloys (zinc > 15 percent) and aluminum bronze exposed to raw water, low flow,

subject to loss of heat transfer and loss of material

• copper alloys (zinc > 15 percent) and aluminum bronze exposed to treated water,

temperature < 140 OF, subject to loss of heat transfer

0 wrought austenitic stainless steel exposed to demineralized untreated water subject to loss

of heat transfer

0 wrought austenitic stainless steel exposed to raw water subject to loss of heat transfer

* wrought austenitic stainless steel exposed to treated water, temperature > 482 OF, subject

to cracking

. carbon or low alloy steel (yield strength < 100 Ksi) exposed to raw water, low flow, subject

to loss of material

0 wrought austenitic stainless steel exposed to demineralized untreated water, low flow,

subject to loss of material

• carbon or low alloy steel (Yield strength < 100 Ksi) exposed to air, Moisture or wetting,

temperature < 140°F, subject to loss of material

• carbon or low alloy steel (Yield strength < 100 Ksi) exposed to demineralized untreated

water, low flow, subject to loss of material

& copper alloys (zinc_< 15 percent) exposed to demineralized untreated water, low flow,

subject to loss of material

The staff reviewed the information in ALRA Section 2.3.3.A.17, Table 2.3.3.A.17-1,

Section 3.3.2.A.15, and Table 3.3.2.A-15. During its review the staff determined that additional

information was needed.

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The RAIs are organized in two groups, general and system-specific. There are no general RAls

associated with this system. Systemi-specific a-RAI 3.3.2.A-5-1 is applicable to this system. The

staff's detailed review of the applicant's response to a-RAI 3.3.2.A-5-1 is in SER

Section 3.3A.2.3.5.

The staff's review of the information provided in the ALRA and the additional information

included in the applicant's response to the RAI found the aging effects of the reactor building

closed loop cooling water system component types not addressed by the GALL Report

consistent with industry experience for these combinations of materials and environments. The

staff did not identify any omitted aging effects. Therefore, the staff found that the applicant had

identified the appropriate aging effects for the materials and environments of the components in

the reactor building closed loop cooling water system.

Aging Management Programs. After evaluating the applicant's identification of aging effects for

each of the components the staff evaluated the AMPs to determine whether they are

appropriate for managing the identified aging effects. The staff also verified that the UFSAR

supplement describes the program adequately.

ALRA Table 3.3.2.A-15 identifies the following AMPs for managing the aging effects for the

reactor building closed loop cooling water system components not addressed by the GALL

Report

" System Walkdown Program

* Closed-Cycle Cooling Water System Program

" Selective Leaching of Materials Program

* One-Time Inspection Program

" Water Chemistry Control Program

The staff's detailed review of the AMPs is in SER Sections 3.0.3.3.2, 3.0.3.2.8, 3.0.3.1.5,

3.0.3.1.4, and 3.0.3.2.2.

Conclusion: On the basis of its review, as discussed above, the staff concludes that there is

reasonable assurance that the applicant has demonstrated that the aging effects associated

with the reactor building closed loop cooling water system components will be adequately

managed so that the intended functions will be maintained consistent with the CLB for the

period of extended operation, as required by 10 CFR 54.21(a)(3).

The staff also reviewed the applicable UFSAR supplement program descriptions and concludes

that the UFSAR supplement provides an adequate description of the AMPs credited for

managing aging of these components, as required by 10 CFR 54.21(d).

3.3A.2.3.16 Auxiliary Systems NMP1 Reactor Building HVAC System - Summary of Aging

Management Evaluation - ALRA Table 3.3.2.A-16

The staff reviewed ALRA Table 3.3.2.A-16, which summarizes the results of AMR evaluations

for the reactor building HVAC system component-material-environment AERM combinations not

addressed in the GALL Report. These combinations use Notes F through J in ALRA

Table 3.3.2.A-16. The staff verified that the applicant had identified all AERMs and had credited

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appropriate AMPs with managing them. The staff also reviewed the applicable UFSAR

supplements for the AMPs to ensure that the program descriptions describe them adequately.

Ap.ing Effects. ALRA Table 2.3.3.A.18-1 lists individual system components within the scope of

license renewal and subject to an AMR. The component types that do not rely on the GALL

Report for an AMR include external surfaces and flow elements.

For these component types the applicant identified the following materials, environments, and

AERMs:

• gray cast iron exposed to air subject to loss of material

* gray cast iron expbsed to air, moisture or wetting, temperature < 140°F, subject to loss of

material

" polymers exposed to air subject to cracking, hardening and shrinkage, and loss of strength

The staff reviewed the information in ALRA Section 2.3.3.A.18, Table 2.3.3.A.18-1,

Section 3.3.2.A.16, and Table 3.3.2.A-16.

The staffs review of the information provided in the ALRA found the aging effects of the reactor

building HVAC system component types not addressed by the GALL Report consistent with

industry experience for these combinations of materials and environments. The staff did not

identify any omitted aging effects. Therefore, the staff found that the applicant had identified the

appropriate aging effects for the materials and environments of the components in the reactor

building HVAC system.

Aging Management Programs. After evaluating the applicant's identification of aging effects for

each of the components the staff evaluated the AMPs to determine whether they are

appropriate for managing the identified aging effects. The staff also verified that the UFSAR

supplement describes the programs adequately.

ALRA Table 3.3.2.A-1 6 identifies the following AMPs for managing the aging effects for the

reactor building HVAC system components not addressed by the GALL Report:

* System Walkdown Program

" One-Time Inspection Program

The staffs detailed review of these AMPs is in SER Sections 3.0.3.3.2 and 3.0.3.1.4.

Conclusion: On the basis of its review, as discussed above, the staff concludes that there is

reasonable assurance that the applicant has demonstrated that the aging effects associated

with the reactor building HVAC system components will be adequately managed so that the

intended functions will be maintained consistent with the CLB for the period of extended

operation, as required by 10 CFR 54.21 (a)(3).

The staff also reviewed the applicable UFSAR supplement program descriptions and concludes

that the UFSAR supplement provides an adequate description of the AMPs credited for

managing aging of these components, as required by 10 CFR 54.21(d).

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3.3A.2.3.17 Auxiliary Systems NMP1 Reactor Water Cleanup System - Summary of Aging

Management Evaluation - ALRA Table 3.3.2.A-17

The staff reviewed ALRA Table 3.3.2.A-17, which summarizes the results of AMR evaluations

for the reactor water cleanup system component-material-environment AERM combinations not

addressed in the GALL Report. These combinations use Notes F through J in ALRA

Table 3.3.2.A-17 as revised by the applicant's letter NMPIL 1996 dated November 17, 2005, the

applicant's response to a-RAI 3.3.2.A-5-1 dated November 30, 2005, and the applicant's letter

NMPIL 2005 dated December 1, 2005. The staff verified that the applicant had identified all

AERMs and had credited appropriate AMPs with managing them. The staff also reviewed the

applicable UFSAR supplements for the AMPs to ensure that the program descriptions describe

them adequately.

Aging Effects. ALRA Table 2.3.3.A.19-1 lists individual system components within the scope of

license renewal and subject to an AMR. The component types that do not rely on the GALL

Report for an AMR include bolting, heat exchangers, piping and fittings, and pumps.

For these component types the applicant identified the following materials, environments, and

AERMs:

" carbon or low alloy steel (yield strength !c 100 Ksi) exposed to demineralized untreated

water, low flow, subject to loss of material

* carbon or low alloy steel (yield strength < 100 Ksi) exposed to treated water or steam,

temperature > 212 °F, but < 482°F, subject to cumulative fatigue damage and loss of

material

* copper alloys (zinc < 15 percent) exposed to demineralized untreated water subject to loss

of material

* wrought austenitic stainless steel exposed to demineralized untreated water subject to loss

of material

" gray cast iron exposed to treated water, temperature < 140 OF, subject to loss of material

The staff reviewed the information in Section 2.3.3.A.19, Table 2.3.3.A.19-1,

Section 3.3.2.A.17, and Table 3.3.2.A-17 of the ALRA. During its review the staff determined

that additional information was needed.

The RAls are organized in two groups, general and system-specific. There are no general RAIs

associated with this system. System-specific a-RAI 3.3.2.A-5-1 is applicable to this system. The

staff's detailed review of the applicant's response to a-RAI 3.3.2.A-5-1 is in SER

Section 3.3A.2.3.5.

The staffs review of the information provided in the ALRA and the additional information

included in the applicant's response to the RAI found the aging effects of the reactor water

cleanup system component types not addressed by the GALL Report consistent with industry

experience for these combinations of materials and environments. The staff did not identify any

omitted aging effects. Therefore, the staff found that the applicant had identified the appropriate

aging effects for the materials and environments of the components in the reactor water

cleanup system.

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Aging Management Programs. After evaluating the applicant's identification of aging effects for

each of the components the staff evaluated the AMPs to determine whether they are

appropriate for managing the identified aging effects. The staff also verified that the UFSAR

supplement describes the program adequately.

ALRA Table 3.3.2.A-17 identifies TLAA and the following AMPs for managing the aging effects

for the reactor water cleanup system components not addressed by the GALL Report:

• Closed-Cycle Cooling Water System Program

* Flow-Accelerated Corrosion Program

" One-Time Inspection Program

" Water Chemistry Control Program

" Selective Leaching of Materials Program

The staff's evaluation of the TLAA is in SER Section 4.3. The staff's detailed review of the

AMPs is in SER Sections 3.0.3.2.8, 3.0.3.13, 3.0.3.1.4, 3.0.3.2.2, and 3.0.3.1.5.

Conclusion: On the basis of its review, as discussed above, the staff concludes that there is

reasonable assurance that the applicant has demonstrated that the aging effects associated

with the reactor water cleanup system components will be adequately managed so that the

intended functions will be maintained consistent with the CLB for the period of extended

operation, as required by 10 CFR 54.21(a)(3).

The staff also reviewed the applicable UFSAR supplement program descriptions and concludes

that the UFSAR supplement provides an adequate description of the AMPs credited for

managing aging of these components, as required by 10 CFR 54.21(d).

3.3A.2.3.18 Auxiliary Systems NMP1 Sampling System - Summary of Aging Management

Evaluation - ALRA Table 3.3.2.A-18

The staff reviewed ALRA Table 3.3.2.A-18, which summarizes the results of AMR evaluations

for the sampling system component-material-environment AERM combinations not addressed

in the GALL Report. These combinations use Notes F through J in ALRA Table 3.3.2.A-18 as

revised by the applicant's letter NMPIL 2005 dated December 1, 2005. The staff verified that

the applicant had identified all AERMs and had credited appropriate AMPs with managing them.

The staff also reviewed the applicable UFSAR supplements for the AMPs to ensure that the

program descriptions describe them adequately.

Aging Effects. ALRA Table 2.3.3.A.20-1 lists individual system components within the scope of

license renewal and subject to an AMR. The component types that do not rely on the GALL

Report for an AMR include heat exchangers, piping and fittings, and rupture disc.

For these component types the applicant identified the following materials, environments, and

AERMs:

" elastomer exposed to raw water subject to hardening and shrinkage

" wrought austenitic stainless steel exposed to treated water or steam, temperature > 482 OF,

low flow, subject to cracking

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The staff reviewed the information in ALRA Section 2.3.3.A.20, Table 2.3.3.A.20-1,

Section 3.3.2.A.18, and Table 3.3.2.A-18.

The staff s review of the information provided in the ALRA and the additional information

included in the applicant's response to the RAI found the aging effects of the sampling system

component types not addressed by the GALL Report consistent with industry experience for

these combinations of materials and environments. The staff did not identify any omitted aging

effects. Therefore, the staff found that the applicant had identified the appropriate aging effects

for the materials and environments of the components in the sampling system.

Aging Management Programs. After evaluating the applicant's identification of aging effects for

each of the components the staff evaluated the AMPs to determine whether they are

appropriate for managing the identified aging effects. The staff also verified that the UFSAR

supplement describes the program adequately.

ALRA Table 3.3.2.A-18 identifies the following AMPs for managing the aging effects for the

sampling system components not addressed by the GALL Report:

" One-Time Inspection Program

" Water Chemistry Control Program

" Preventive Maintenance Program

The staffs detailed review of the above AMPs is in SER Sections 3.0.3.1.4, 3.0.3.2.2, and

3.0.3.3.1.

Conclusion: On the basis of its review, as discussed above, the staff concludes that there is

reasonable assurance that the applicant has demonstrated that the aging effects associated

with the sampling system component components will be adequately managed so that the

intended functions will be maintained consistent with the CLB for the period of extended

operation, as required by 10 CFR 54.21 (a)(3).

The staff also reviewed the applicable UFSAR supplement program descriptions and concludes

that the UFSAR supplement provides an adequate description of the AMPs credited for

managing aging of these components, as required by 10 CFR 54.21(d).

3.3A.2.3.19 Auxiliary Systems NMP1 Service Water System - Summary of Aging Management

Evaluation - ALRA Table 3.3.2.A-19

The staff reviewed ALRA Table 3.3.2.A-19, which.summarizes the results of AMR evaluations

for the service water system component-material-environment AERM combinations not

addressed in the GALL Report. These combinations use Notes F through J in ALRA

Table 3.3.2.A-19. The staff verified that the applicant had identified all AERMs and had credited

appropriate AMPs with managing them. The staff also reviewed the applicable UFSAR

supplements for the AMPs to ensure that the program descriptions describe them adequately.

Aging Effects. ALRA Table 2.3.3.A.21-1 lists individual system components within the scope of

license renewal and subject to an AMR. The component types that do not rely on the GALL

Report for an AMR include external surfaces and filters/strainers.

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For these component types, the applicant identified the following materials, environments, and

AERMs:

" copper alloys (zinc > 15 percent) and aluminum bronze exposed to air subject to loss of

material

* gray cast iron exposed to air subject to loss of material

" gray cast iron exposed to raw water subject to loss of material

The staff reviewed the information in ALRA Section 2.3.3.A.21, Table 2.3.3.A.21-1,

Section 3.3.2.A.19, and Table 3.3.2.A-19.

The staffs review of the information provided in the ALRA found the aging effects of the service

water system component types not addressed by the GALL Report consistent with industry

experience for these combinations of materials and environments. The staff did not identify any

omitted aging effects. Therefore, the staff found that the applicant had identified the appropriate

aging effects for the materials and environments of the components in the service water

system.

Aping -Management Programs. After evaluating the applicant's identification of aging effects for

each of the components the staff evaluated the AMPs to determine whether they are

appropriate for managing the identified aging effects. The staff also verified that the UFSAR

supplement describes the programs adequately.

ALRA Table 3.3.2.A-19 identifies the following AMPs for managing the aging effects for the

service water system components not addressed by the GALL Report:

• System Walkdown Program

• Open-Cycle Cooling Water System Program

" Selective Leaching of Materials Program

The staffs detailed review of these AMPs is in SER Sections 3.0.3.3.2, 3.0.3.2.7, and 3.0.3.1.5.

Conclusion: On the basis of its review, as discussed above, the staff concludes that there is

reasonable assurance that the applicant has demonstrated that the aging effects associated

with the service water system components will be adequately managed so that the intended

functions will be maintained consistent with the CLB for the period of extended operation, as

required by 10 CFR 54.21(a)(3).

The staff also reviewed the applicable UFSAR supplement program descriptions and concludes

that the UFSAR supplement provides an adequate description of the AMPs credited for

managing aging of these components, as required by 10 CFR 54.21(d).

3.3A.2.3.20 Auxiliary Systems NMP1 Shutdown Cooling System - Summary of Aging

Management Evaluation - ALRA Table 3.3.2.A-20

The staff reviewed ALRA Table 3.3.2.A-20, which summarizes the results of AMR evaluations

for the shutdown cooling system component-material-environment AERM combinations not

addressed in the GALL Report. These combinations use Notes F through J in ALRA

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Table 3.3.2.A-20. The staff verified that the applicant had identified all AERMs and had credited

appropriate AMPs with managing them. The staff also reviewed the applicable UFSAR

supplements for the AMPs to ensure that the program descriptions describe them adequately.

A-qinq Effects. ALRA Table 2.3.3.A.22-1 lists individual system components within the scope of

license renewal and subject to an AMR. The component types that do not rely on the GALL

Report for an AMR include heat exchangers.

For these component types the applicant identified the following materials, environments, and

AERMs:

carbon or low alloy steel (yield strength < 100 Ksi) exposed to treated water, temperature

< 140 degree F, subject to loss of heat transfer

The staff reviewed the information in ALRA Section 2.3.3.A.22, Table 2.3.3.A.22-1,

Section 3.3.2.A.20, and Table 3.3.2.A-20.

The staff's review of the information provided in the ALRA found the aging effects of the

shutdown cooling system component types not addressed by the GALL Report consistent with

industry experience for these combinations of materials and environments. The staff did not

identify any omitted aging effects. Therefore, the staff found thatthe applicant had identified the

appropriate aging effects for the materials and environments of the components in the

shutdown cooling system.

Aging Management Programs. After evaluating the applicant's identification of aging effects for

each of the components the staff evaluated the AMPs to determine whether they are

appropriate for managing them. The staff also verified that the UFSAR supplement describes

the programs adequately.

ALRA Table 3.3.2.A-20 identifies the following AMP for managing the aging effects for the

shutdown cooling system components not addressed by the GALL Report:

0 Open-Cycle Cooling Water System Program

The staffs detailed review of this AMP is in SER Sections 3.0.3.2.7.

Conclusion: On the basis of its review, as discussed above, the staff concludes that there is

reasonable assurance that the applicant has demonstrated that the aging effects associated

with the shutdown cooling system components will be adequately managed so that the intended

functions will be maintained consistent with the CLB for the period of extended operation, as

required by 10 CFR 54.21(a)(3).

The staff also reviewed the applicable UFSAR supplement program descriptions and concludes

that the UFSAR supplement provides an adequate description of the AMPs credited for

managing aging of these components, as required by 10 CFR 54.21(d).

3.3A.2.3.21 Auxiliary Systems NMPI Spent Fuel Pool Filtering and Cooling System - Summary

of Aging Management Evaluation - ALRA Table 3.3.2.A-21

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The staff reviewed ALRA Table 3.3.2.A-21, which summarizes the results of AMR evaluations

for the spent fuel pool filtering and cooling system component-material-environment AERM

combinations not addressed in the GALL Report. These combinations use Notes F through J in

ALRA Table 3.3.2.A-21 as revised by the applicant's response to a-RAI 3.3.2.A-5-1 dated

November 30, 2005 and the applicant's letter NMPIL 2005 dated December 1, 2005. The staff

verified that the applicant had identified all AERMs and had credited appropriate AMPs with

managing them. The staff also reviewed the applicable UFSAR supplements for the AMPs to

ensure that the program descriptions describe them adequately.

Aging Effects. ALRA Table 2.3.3.A.23-1 lists individual system components within the scope of

license renewal and subject to an AMR. The component types that do not rely on the GALL

Report for an AMR include external surfaces, filterststrainers, heat exchangers, pump, and

valves.

For these component types the applicant identified the following materials, environments, and

AERMs:

" gray cast iron exposed to air subject to loss of material

" carbon or low alloy steel (yield strength < 100 Ksi) exposed to treated water, temperature

< 140 OF, oxygenated, subject to loss of material

" wrought Austenitic stainless steel exposed to demineralized untreated water subject to loss

of heat transfer and loss of material

" copper alloys (zinc < 15 percent) exposed to demineralized untreated water subject to loss

of material

" copper alloys (zinc < 15 percent) exposed to treated water, temperature < OF, oxygenated,

subject to loss of material

" gray cast iron exposed to treated water, temperature < 140 OF, oxygenated, subject to loss

of material

• aluminum alloys containing copper or zinc as the primary alloying elements exposed to

treated water, temperature < 140 OF, oxygenated, subject to cracking

" aluminum alloys containing copper or zinc as the primary alloying elements exposed to

treated water, temperature < 140 OF, low flow, oxygenated, subject to cracking

• carbon or low alloy steel (yield strength < 100 Ksi) exposed to treated water, temperature

< 140 °F, low flow, oxygenated, subject to loss of material

• copper alloys (zinc < 15 percent) exposed to treated water, temperature < 140 °F, low flow,

oxygenated, subject to loss of material

" aluminum, and aluminum alloyed with manganese, magnesium, and magnesium plus

silicon exposed to treated water, temperature < 140°F, oxygenated, subject to loss of

material

The staff reviewed the information in ALRA Section 2.3.3.A.23, Table 2.3.3.A.23-1,

Section 3.3.2.A.21, and Table 3.3.2.A-21. During its review the staff determined that additional

information was needed.

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The RAIs are organized in two groups, general and system-specific. There are no general RAIs

associated with this system. System-specific a-RAI 3.3.2.A-5-1 is applicable to this system. The

staff's detailed review of the applicant's response to a-RAl 3.3.2.A-5-1 is in SER

Section 3.3A.2.3.5.

The staff's review of the information provided in the ALRA and the additional information in the

applicant's response to the RAI found the aging effects of the spent fuel pool filtering and

cooling system component types not addressed by the GALL Report consistent with industry

experience for these combinations of materials and environments. The staff did not identify any

omitted aging effects. Therefore, the staff found that the applicant had identified the appropriate

aging effects for the materials and environments of the components in the spent fuel pool

filtering and cooling system.

Apinq Manaaement Programs. After evaluating the applicant's identification of aging effects for

each of the components the staff evaluated the AMPs to determine whether they are

appropriate for managing the identified aging effects. The staff also verified that the UFSAR

supplement describes the programs adequately.

ALRA Table 3.3.2.A-21 identifies the following AMPs for managing the aging effects for the

spent fuel pool filtering and cooling system components not addressed by the GALL Report:

System Walkdown Program

* One-Time Inspection Program

* Water Chemistry Control Program

* Closed-Cycle Cooling Water System Program

The staff's detailed review of the AMPs is in SER Sections 3.0.3.3.2, 3.0.3.1.4, 3.0.3.2.2, and

3.0.3.2.8.

Conclusion: On the basis of its review, as discussed above, the staff concludes that there is

reasonable assurance that the applicant has demonstrated that the aging effects associated

with the spent fuel pool filtering and cooling system components will be adequately managed so

that the intended functions will be maintained consistent with the CLB for the period of extended

operation, as required by 10 CFR 54.21 (a)(3).

The staff also reviewed the applicable UFSAR supplement program descriptions and concludes

that the UFSAR supplement provides an adequate description of the AMPs credited for

managing aging of these components, as required by 10 CFR 54.21(d).

3.3A.2.3.22 Auxiliary Systems NMP1 Turbine Building Closed Loop Cooling Water System -

Summary of Aging Management Evaluation - ALRA Table 3.3.2.A-22

The staff reviewed ALRA Table 3.3.2.A-22, which summarizes the results of AMR evaluations

for the turbine building closed loop cooling water system component-material-environment

AERM combinations not addressed in the GALL Report. These combinations use Notes F

through J in ALRA Table 3.3.2.A-22 as revised by the applicant's letter NMPIL 1996, dated

November 17, 2005. The staff verified that the applicant had identified all AERMs and had

credited appropriate AMPs with managing them. The staff also reviewed the applicable UFSAR

supplements for the AMPs to ensure that the program descriptions describe them adequately.

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Aging Effects. ALRA Table 2.3.3.A.25-1 lists individual system components within the scope of

license renewal and subject to an AMR. The component types that do not rely on the GALL

Report for an AMR include heat exchangers, piping and fittings, pumps, strainers, tanks, and

valves.

For this component type the applicant identified the following materials, environments, and

AERMs:

• carbon or low alloy steel (yield strength < 100 Ksi) exposed to demineralized untreated

water subject to loss of material

" copper alloys (zinc < 15 percent) exposed to demineralized untreated water subject to loss

of material

The staff reviewed the information in ALRA Section 2.3.3.A.25, Table 2.3.3.A.25-1,

Section 3.3.2.A.22, and Table 3.3.2.A-22.

The staff's review of the information provided in the ALRA found the aging effects of the turbine

building closed loop cooling water system component types not addressed by the GALL Report

consistent with industry experience for these combinations of materials and environments. The

staff did not identify any omitted aging effects. Therefore, the staff found that the applicant had

identified the appropriate aging effects for the materials and environments of the components in

the turbine building closed loop cooling water system.

Aging Management Programs. After evaluating the applicant's identification of aging effects for

the components the staff evaluated the AMPs to determine whether they are appropriate for

managing the identified aging effects. The staff also verified that the UFSAR supplement

describes the programs adequately.

ALRA Table 3.3.2.A-22 identifies the following AMPs for managing the aging effects for the

turbine building closed loop cooling water system components not addressed by the GALL

Report

" One-Time Inspection Program

" Preventive Maintenance Program

• Water Chemistry Control Program

The staff's detailed review of this AMP is found in SER Sections 3.0.3.1.4, 3.0.3.3.1, and

3.0.3.2.2.

Conclusion: On the basis of its review, as discussed above, the staff concludes that there is

reasonable assurance that the applicant has demonstrated that the aging effects associated

with the turbine building closed loop cooling water system components will be adequately

managed so that the intended functions will be maintained consistent with the CLB for the

period of extended operation, as required by 10 CFR 54.21 (a)(3).

The staff also reviewed the applicable UFSAR supplement program descriptions and concludes

that the UFSAR supplement provides an adequate description of the AMPs credited for

managing aging of these components, as required by 10 CFR 54.21(d).

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3.3A.2.3.23 Auxiliary Systems NMP1 Turbine Building HVAC System - Summary of Aging

Management Evaluation - ALRA Table 3.3.2.A-23

The staff reviewed ALRA Table 3.3.2.A-23, which summarizes the results of AMR evaluations

for the turbine building HVAC system component-material-environment AERM combinations not

addressed in the GALL Report. These combinations use Notes F through J in ALRA

Table 3.3.2.A-23 as revised by the applicant's letter NMPIL 1996 dated November 17, 2005.

The staff verified that the applicant had identified all AERMs and had credited appropriate

AMPs with managing them. The staff also reviewed the applicable UFSAR supplements for the

AMPs to ensure that the program descriptions describe them adequately.

Aging Effects. ALRA Table 2.3.3.A.26-1 lists individual system components within the scope of

license renewal and subject to an AMR. The component types that do not rely on the GALL

Report for an AMR include ducting, external surfaces, and valves and dampers.

For these component types the applicant identified the following materials, environments, and

AERMs:

• fiberglass exposed to air with vibratory motion subject to cracking, loss of material, and

loss of strength

* fiberglass exposed to air subject to cracking and loss of strength

" gray cast iron exposed to air subject to loss of material

The staff reviewed the information in ALRA Section 2.3.3.A.26, Table 2.3.3.A.26-1,

Section 3.3.2.A.23, and Table 3.3.2.A-23.

On the basis of its review, the staff found the aging effects of the turbine building HVAC system

component types not addressed by the GALL Report consistent with industry experience for

these combinations of materials and environments. The staff did not identify any omitted aging

effects. Therefore, the staff found that the applicant had identified the appropriate aging effects

for the materials and environments of the components in the turbine building HVAC system.

Aqing Mana qement Proqrams. After evaluating the applicant's identification of aging effects for

each of the components the staff evaluated the AMPs to determine whether they are

appropriate for managing the identified aging effects. The staff also verified that the UFSAR

supplement describes the programs adequately.

ALRA Table 3.3.2.A-23 identifies the following AMPs for managing the aging effects for the

turbine building HVAC system components not addressed by the GALL Report:

" Preventive Maintenance Program

• System Walkdown Program

* One-Time Inspection Program

The staffs detailed review of these AMPs is in SER Sections 3.0.3.3.1,3.0.3.3.2, and 3.0.3.1.4.

Conclusion: On the basis of its review, as discussed above, the staff concludes that there is

reasonable assurance that the applicant has demonstrated that the aging effects associated

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with the turbine building HVAC system components will be adequately managed so that the

intended functions will be maintained consistent with the CLB for the period of extended

operation, as required by 10 CFR 54.21 (a)(3).

The staff also reviewed the applicable UFSAR supplement program descriptions and concludes

that the UFSAR supplement provides an adequate description of the AMPs credited for

managing aging of these components, as required by 10 CFR 54.21(d).

3.3A.2.3.24 Auxiliary Systems NMP1 Electric Steam Boiler System - Summary of Aging

Management Evaluation - ALRA Table 3.3.2.A-24

This auxiliary system is listed here for information and completeness. The AMR results for the

NMP1 electric steam boiler system are consistent with the GALL Report. The staff's evaluation

of these results is presented in SER Section 3.3A.2.2.2

3.3A.2.3.25 Auxiliary Systems NMP1 Makeup and Demineralizer System - Summary of Aging

Management Evaluation - ALRA Table 3.3.2.A-25

This auxiliary system is listed here for information and completeness. The AMR results for the

NMP1 makeup and demineralizer system are consistent with the GALL Report. The staffs

evaluation of these results is presented in SER Section 3.3A.2.2.5.

3.3A.3 Conclusion

The staff concludes that there is reasonable assurance that the applicant provided sufficient

information to demonstrate that the effects of aging for the NMPI auxiliary systems

components that are within the scope of license renewal and subject to an AMR will be

adequately managed so that the intended function(s) will be maintained consistent with the CLB

for the period of extended operation, as required by 10 CFR 54.21 (a)(3).

The staff also reviewed the applicable UFSAR supplement program descriptions and concludes

that the UFSAR supplement provides an adequate description of the AMPs credited for

managing aging these auxiliary systems, as required by 10 CFR 54.21(d).

3.3B NMP2 Aging Management of Auxiliary Systems

This section of the SER documents the staffs review of the applicant's AMR results for the

auxiliary systems components and component groups associated with the following NMP2

systems:

" air startup standby diesel generator system

" alternate decay heat removal system

" auxiliary service building HVAC system

" compressed air systems

" containment atmosphere monitoring system

" containment leakage monitoring system

" control building chilled water system

" control building HVAC system

" diesel generator building ventilation system

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• domestic water system

" engine-driven fire pump fuel oil system

" fire detection and protection system

" floor and equipment drains system

" generator standby lube oil system

* hot water heating system

* makeup water system

" neutron monitoring system

" primary containment purge system

* process sampling system

* reactor building closed loop cooling water system

" reactor building HVAC system

" reactor water cleanup system

" service water system

" spent fuel pool cooling and cleanup system

" standby diesel generator fuel oil system

" standby diesel generator protection (generator) system

* standby liquid control system

• yard structures ventilation system

" radiation monitoring system

" auxiliary boiler system

" circulating water system

* makeup water treatment system

" radioactive liquid waste management system

" roof drainage system

" sanitary drains and disposal system

* service water chemical treatment system

* turbine building closed loop cooling water system

3.3B.1 Summary of Technical Information in the Amended Application

In ALRA Section 3.3, the applicant provided AMR results for the auxiliary systems components

and component groups. In ALRA Table 3.3.1.B, "NMP2 Summary of Aging Management

Programs for the Auxiliary Systems Evaluated in Chapter VII of NUREG-1801," the applicant

provided a summary comparison of its AMRs with the AMRs evaluated in the GALL Report for

the auxiliary systems components and component groups.

The applicant's AMRs incorporated applicable operating experience in the determination of

AERMs. These reviews included evaluation of plant-specific and industry operating experience.

The plant-specific evaluation included reviews of condition reports and discussions with

appropriate site personnel to identify AERMs. The applicant's review of industry operating

experience included a review of the GALL Report and operating experience issues identified

since the issuance of the GALL Report.

3.3B.2 Staff Evaluation

The staff reviewed ALRA Section 3.3 to determine if the applicant provided sufficient

information to demonstrate that the effects of aging for the auxiliary systems components that

are within the scope of license renewal and subject to an AMR will be adequately managed so

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that the intended functions will be maintained consistent with the CLB for the period of extended

operation, as required by 10 CFR 54.21 (a)(3).

The staff performed an onsite audit of AMRs to confirm the applicant's claim that certain

identified AMRs were consistent with the GALL Report. The staff did not repeat its review of the

matters described in the GALL Report; however, the staff did verify that the material presented

in the ALRA was applicable and that the applicant had identified the appropriate GALL AMRs.

The staff's evaluations of the AMPs are documented in SER Section 3.0.3. Details of the staff's

audit evaluation are documented in the Audit and Review Report and are summarized in SER

Section 3.3B.2.1.

In the onsite audit, the staff also selected AMRs that were consistent with the GALL Report and

for which further evaluation is recommended. The staff confirmed that the applicant's further

evaluations were consistent with the acceptance criteria in SRP-LR Section 3.3.2.2. The staff's

audit evaluations are documented in the Audit and Review Report and are summarized in SER

Section 3.38.2.2

In the onsite audit, the staff also conducted a technical review of the remaining AMRs that were

not consistent with, or not addressed in, the GALL Report. The audit and technical review

included evaluating whether all plausible aging effects were identified and evaluating whether

the aging effects listed were appropriate for the combination of materials and environments

specified. The staff's audit evaluations are documented in the Audit and Review Report and are

summarized in SER Section 3.3B.2.3. The staff's evaluation of its technical review is also

documented in SER Section 3.3B.2.3.

Finally, the staff reviewed the AMP summary descriptions in the USAR supplement to ensure

that they provided an adequate description of the programs credited with managing or

monitoring aging for the auxiliary systems components.

Table 3.3B-1 below provides a summary of the staffs evaluation of NMP2 components, aging

effects and aging effects mechanisms, and AMPs listed in ALRA Section 3.3, that are

addressed in the GALL Report.

Table 3.3B-1 Staff Evaluation for NMP2 Auxiliary Systems Components in the GALL

Report

Component Group Aging: Effecti:;,_,: AMP in GALL. AMP in ALRA Staff Evaluation

____________ • : Mechanism Report "r.______1 ._.. __

Components in Loss of material Water chemistry Water Chemistry Consistent with

spent fuel pool due to general, and one-time Control Program GALL, which

cooling and cleanup pifting, and crevice inspection (B2.1.2), One-Time recommends further

(Item Number corrosion Inspection Program evaluation (See

3.3.1.1B-01) (B2.1.20), Section 3.3B.2.2.1)

Closed-Cycle

Cooling Water

System Program

(12.1.11)

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Component Group Aging EffecUtl ý'AMP In GALL AMP In ALRA Staff Evaluation,,

• - _ ,-!• Me~~Mechanism Report ________________ _, ______,_, _____

Linings in spent fuel Hardening, cracking Plant-specific Preventive Consistent with

pool cooling and and loss of strength Maintenance GALL, which

cleanup system; due to elastomer Program (B2.1.32) recommends further

seals and collars in degradation; loss of evaluation (See

ventilation systems material due to Section 3.3B.2.2.2)

(item Number wear

3.3.1.B-02)

Components in load Cumulative fatigue TLAA, evaluated in TLAA This TLAA is

handling, chemical damage accordance with evaluated in

and volume control 10 CFR 54.21(c) Section 4.3, Metal

system (PWR), and Fatigue Analysis

reactor water

cleanup and

shutdown cooling

systems (older

BWR)

(Item Number

3.3.1.8-03)

Heat exchangers in Crack initiation and Plant-specific None Not applicable (See

reactor water growth due to SCC Section 3.3B.2.2.4)

cleanup system or cracking

(BWR); high

pressure pumps in

chemical and

volume control

system (PWR)

(Item Number

3.3.1.B-04)

Components in Loss of material Plant-specific Water Chemistry Consistent with

ventilation systems, due to general, Control Program GALL, which

diesel fuel oil pitting, and crevice (82.1.2), Fire recommends further

system, and corrosion, and MIC Protection Program evaluation (See

emergency diesel (82.1.16), Section 3.3B.2.2.5)

generator systems; One-Time

external surfaces of inspection Program

carbon steel (B2.1.20),

components Preventive

(Item Number Maintenance

3.3.1.B-05) Program (82.1.32),

Systems Walkdown

Program (12.1.33),

Bolting Integrity

Program (B2.1.36)

Components in Loss of material One-time inspection None Not applicable (See

reactor coolant due to galvanic, Section 3.3B.2.2.6)

pump oil collect general, pitting, and

system of fire crevice corrosion

protection

(Item Number

3.3.1.8-06)

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SComponent Group Aging Effectn AMP In GALL AMPinALRA Staff Evaluation"

Mechanism -.. Report' ' _ _ _ .____.______.___.

Diesel fuel oil tanks Loss of material Fuel oil chemistry Fuel Oil Chemistry Consistent with

in diesel fuel oil due to general, and one-time Program (B2.1.18), GALL, which

system and pitting, and crevice inspection One-Time recommends further

emergency diesel corrosion, MIC, and Inspection Program evaluation (See

generator system biofouling (B2.1.20) Section 3.3B.2.2.7)

(Item Number

3.3.1.8-07)

Piping, pump Loss of material Water chemistry None Not applicable

casing, and valve due to pitting and and one-time (no shutdown

body and bonnets in crevice corrosion inspection cooling system)

shutdown cooling

system (older BWR)

(Item Number

3.3.1 .B-08)

Heat exchangers in Crack initiation and Water chemistry None Not applicable (See

chemical and growth due to SCC and a plant-specific Section 3.3B.2.2.9)

volume control and cyclic loading verification program

system

(Item Number

3.3.1.1-09)

Neutron absorbing Reduction of Water chemistry Water Chemistry (See Section

sheets in spent fuel neutron absorbing and one-time Control Program 3.31.2.2.10)

storage racks capacity and loss of inspection (B2.1.2)

(Item Number material due to One-Time

3.3.1.1-10) general corrosion Inspection Program

(Boral, boron steel) (82.1.20),

New fuel rack Loss of material Structures None Not applicable

assembly due to general, monitoring The new fuel

(Item Number pitting, and crevice storage racks are

3.3.1.8-11) corrosion addressed in ALRA

Table 3.5.2.B-7.

Neutron absorbing Reduction of Boraflex monitoring None Not applicable

sheets in spent fuel neutron absorbing

storage racks capacity due to Borafiex panels to

(Item Number Boraflex be replaced with

3.3.1.8-12) degradation Boral

Spent fuel storage Crack initiation and Water chemistry Water Chemistry Consistent with

racks and valves in growth due to stress Control Program GALL, which

spent fuel pool corrosion cracking (B2.1.2) recommends no

cooling and cleanup further evaluation

(Item Number (See Section

3.3.1.83-13) 3.31.2.1.9)

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,Component Group, ':Aging Effectv AMP In GALLs: :AMP. In ALRA"'.ý .'.'Staff Evaluation,-

Mechanism Report ___.___- __- ___. __ __, _____- ___...-

Closure bolting and Loss of material Boric acid corrosion None Not applicable

external surfaces of due to boric acid

carbon steel and corrosion This aging effect/

low-alloy steel mechanism does

components not exist at NMP2

(Item Number because NMP2 has

3.3.1..B-14) no liquid poison

system

Components in or Loss of material Closed-cycle Closed-Cycle Consistent with

serviced by due to general, cooling water Cooling Water GALL, which

closed-cycle cooling pitting, and crevice system System Program recommends no

water system corrosion, and MIC (12.1.11), Selective further evaluation

(Item Number Leaching of (See Section

3.3.1.B-15) Materials Program 3.3B.2.1) (B2.1.21)

Cranes including Loss of material Overhead heavy Inspection of Consistent with

bridge and trolleys due to general load and light load Overhead Heavy GALL, which

and rail system in corrosion and wear handling systems Load and Light recommends no

load handling Load Handling further evaluation

system Systems Program (See Section

(Item Number (B.2.1.13) 3.3B.2.1.8)

3.3.1.B-16)

Components in or Loss of material Open-cycle cooling Open-Cycle Cooling Consistent with

serviced by due to general, water system Water System GALL, which

open-cycle cooling pitting, crevice, and Program (B2.1.10), recommends no

water systems galvanic corrosion, One-Time further evaluation

(Item Number MIC, and biofoufing; Inspection Program (See Section

3.3.1.B-17) buildup of deposit (12.1.20), 3.3B.2.1)

due to biofouling Preventive

Maintenance

Program (82.1.32)

Buried piping and Loss of material Buried piping and Buried Piping and Consistent with

fittings due to general, tanks surveillance Tanks Inspection GALL, which

(Item Number pitting, and crevice Program (B2.1.22) recommends further

3.3.1.1-18) corrosion, and MIC or evaluation (See

Section

Buried piping and 3.3B.2.2.11)

tanks inspection.

Components in Loss of material Compressed air Fire Protection Consistent with

compressed air due to general and monitoring Program (82.1.16), GALL, which

system pitting corrosion Fire Water System recommends no

(Item Number - Program (B2.1.17), further evaluation

3.3.1.B-19) One-Time (See Section

Inspection Program 3.3B.2.1.5)

(B2.1.20),

10 CFR 50

Appendix J

Program (B2.1.26)

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Compon'en Group Aging Effecti AMP. |n GALL ::,AMP in ALRA Staff Evaluation"

.-• . . Mechanism , Report -,________. .. __.- . . .._____... ... _

Components (doors Loss of material Fire protection Fire Protection Consistent with

and barrier due to wear. Program (82.1.16) GALL, which

penetration seals) hardening and recommends no

and concrete shrinkage due to further evaluation

structures in fire weathering (See Section

protection 3.3B.2.1.7)

(Item Number

3.3.1 .B-20)

Components in Loss of material Fire water system Fire Water System Consistent with

water-based fire due to general, Program (B2.1.17), GALL, which

protection pitting, crevice, and Selective Leaching recommends no

(Item Number galvanic corrosion, of Materials further evaluation

3.3.1.3-21) MIC, and biofouling Program (82.121) (See Section

3.3B.2.1)

Components in Loss of material Fire protection and None Not applicable

diesel fire system due to galvanic, fuel oil chemistry

(Item Number general, pitting, and Fuel oil supply lines

3.3.1.B-22) crevice corrosion do not have this

aging effect

Tanks in diesel fuel Loss of material Aboveground None Not applicable

oil system due to general, carbon steel tanks

(Item Number pitting, and crevice

3.3.1.B-23) corrosion

Closure bolting Loss of material Bolting integrity Bolting Integrity Consistent with

(Item Number due to general Program (B2.1.36) GALL, which

3.3.1.B-24) corrosion; crack recommends no

initiation and growth further evaluation

due to cyclic (See Section

loading and SCC 3.3B.2.1)

Components in Crack initiation and Water chemistry Water Chemistry Consistent with

contact with sodium growth due to SCC Control Program GALL, which

pentaborate (B2.1.2) recommends no

solution in standby further evaluation

liquid control (See Section

system (BWR) 3.3B.2.1)

(Item Number

3.3.1.B-25)

Components in Crack initiation and Reactor water None Not applicable

reactor water growth due to SCC cleanup system

cleanup system and IGSCC inspection RWCU system

(Item Number components with

3.3.1.8-26) this aging effect/

mechanism are

evaluated in row

3.1.1.1-07

(See Section

3.1B.2.2.4)

Components in Crack initiation and BWR stress None Not applicable

shutdown cooling growth due to SCC corrosion cracking

system (older BWR) and water chemistry NMP Unit 2 has no

(Item Number shutdown cooling

3.3.1.8-27) system

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Component Group Aging Effect/ AMP In GALL AMP in ALRA ' ,: I i,'Staff Evaluation:

* ehnsm * .:: Report -

Components in Loss of material Closed-cycle None Not applicable

shutdown cooling due to pitting and cooling water

system (older BWR) crevice corrosion, system NMP Unit 2 has no

(Item Number and MIC shutdown cooling

3.3.1..B-28) system

Components Loss of material Selective leaching Selective Leaching Consistent with

(aluminum bronze, due to selective of materials of Materials GALL, which

brass, cast Iron, leaching Program (B2.1.21) recommends no

cast steel) in further evaluation

open-cycle and (See Section

closed-cycle cooling 3.3B.2.1)

water systems, and

ultimate heat sink

(Item Number

3.3.1.B-29)

Fire barriers, walls, Concrete cracking Fire protection and None Not applicable

ceilings, and floors and spalling due to structures

in fire protection freeze-thaw, monitoring The plant-specific

(Item Number aggressive environment for

3.3.1.1-30) chemical attack, concrete structures

and reaction with in fire protection

aggregates; loss of does not generate

material due to the listed aging

corrosion of effects

embedded steel

The staff's review of the NMP2 component groups followed one of several approaches. One

approach, documented in SER Section 3.3B.2.1, discusses the staff's review of the AMR

results for components in the auxiliary systems that the applicant indicated are consistent with

the GALL Report and do not require further evaluation. Another approach, documented in SER

Section 3.3B.2.2, discusses the staffs review of the AMR results for components in the auxiliary

systems that the app!icant indicated are consistent with the GALL Report and for which further

evaluation is recommended. A third approach, documented in SER Section 3.38.2.3, discusses

the staffs review of the AMR results for components in the auxiliary systems that the applicant

indicated are not consistent with, or not addressed in, the GALL Report. The staffs review of

AMPs that are credited to manage or monitor aging effects of the auxiliary systems components

is documented in SER Section 3.0.3.

3.3B.2.1 AMR Results That Are Consistent with the GALL Report

Summary of Technical Information in the Amended Application. In ALRA Section 3.3.2.B, the

applicant identified the materials, environments, and AERMs. The applicant identified the

following programs that manage the aging effects related to the auxiliary systems components:

ASME Section XI Inservice Inspection (Subsections IWB, IWC, IWD) Program

Water Chemistry Control Program

Flow-Accelerated Corrosion Program

Open-Cycle Cooling Water System Program

Closed-Cycle Cooling Water System Program

Fire Protection Program

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* Fire Water System Program .

* Fuel Oil Chemistry Program

* One-Time Inspection Program

* Selective Leaching of Materials Program

* Buried Piping and Tanks Inspection Program

* 10 CFR 50 Appendix J Program

• Preventive Maintenance Program

" Systems Walkdown Program

• Bolting Integrity Program

Staff Evaluation. In ALRA Tables 3.3.2.B-1 through 3.3.2.B-40, the applicant provided a

summary of AMRs for the auxiliary systems components, and identified which AMRs it

considered to be consistent with the GALL Report.

For component groups evaluated in the GALL Report for which the applicant has claimed

consistency with the GALL Report, and for which the GALL Report does not recommend further

evaluation, the staff performed an audit and review to determine whether the plant-specific

components contained in these GALL Report component groups were bounded by the GALL

Report evaluation.

The applicant provided a note for each AMR line item. The notes indicate how the information in

the tables aligns with the information in the GALL Report. The staff audited those AMRs with

Notes A through E, which indicate that the AMR is consistent with the GALL Report.

Note A indicates that the AMR line item is consistent with the GALL Report for component,

material, environment, and aging effect. In addition, the AMP is consistent with the AMP

identified in the GALL Report. The staff audited these line items to verify consistency with the

GALL Report and the validity of the AMR for the site-specific conditions.

Note B indicates that the AMR line item is consistent with the GALL Report for component,

material, environment, and aging effect. In addition, the AMP takes some exceptions to the

AMP identified in the GALL Report. The staff audited these line items to verify consistency with

the GALL Report. The staff verified that the identified exceptions to the GALL AMPs had been

reviewed and accepted by the staff. The staff also determined whether the AMP identified by

the applicant was consistent with the AMP identified in the GALL Report and whether the AMR

was valid for the site-specific conditions.

Note C indicates that the component for the AMR line item, although different from, is

consistent with the GALL Report for material, environment, and aging effect. In addition, the

AMP is consistent with the AMP identified by the GALL Report. This note indicates that the

applicant was unable to find a listing of some system components in the GALL Report.

However, the applicant identified a different component in the GALL Report that had the same

material, environment, aging effect, and AMP as the component that was under review. The

staff audited these line items to verify consistency with the GALL Report. The staff also

determined whether the AMR line item of the different component was applicable to the

component under review and whether the AMR was valid for the site-specific conditions.

Note D indicates that the component for the AMR line item, although different from, is

consistent with the GALL Report for material, environment, and aging effect. In addition, the

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AMP takes some exceptions to the AMP identified in the GALL Report. The staff audited these

line items to verify consistency with the GALL Report. The staff verified whether the AMR line

item of the different component was applicable to the component under review. The staff

verified whether the identified exceptions to the GALL AMPs had been reviewed and accepted

by the staff. The staff also determined whether the AMP identified by the applicant was

consistent with the AMP identified in the GALL Report and whether the AMR was valid for the

site-specific conditions.

Note E indicates that the AMR line item is consistent with the GALL Report for material,

environment, and aging effect, but a different aging management program is credited. The staff

audited these line items to verify consistency with the GALL Report. The staff also determined

whether the identified AMP would manage the aging effect consistent with the AMP identified

by the GALL Report and whether the AMR was valid for the site-specific conditions.

The staff conducted an audit and review of the information provided in the ALRA, as

documented in the Audit and Review Report. The staff did not repeat its review of the matters

described in the GALL Report; however, the staff did verify that the material presented in the

ALRA was applicable and that the applicant identified the appropriate GALL Report AMRs. The

staffs evaluation is discussed below.

3.3B.2.1.1 Loss of Material Due to General, Pitting, and Crevice Corrosion, and MIC

As documented in the Audit and Review Report, the staff noted that in ALRA Table 3.3.2.3-5

for component type bolting the applicant manages the aging effect and aging effect mechanism

loss of material with the Bolting Integrity Program. In its letter dated September 15, 2005, the

applicant identified an exception to this program based upon the ASME code edition in use. The

staff asked the applicant to clarify why a Note A was assigned to this line item.

In its letter dated December 1, 2005, the applicant stated that the assignment was an error. The

ALRA will be revised for each AMR line item crediting the applicant's Bolting Integrity Program

to change the note from Note A to Note B.

The staff reviewed the applicant's response and found it acceptable because with the correction

of Note A to Note B the proper note is assigned to these AMR line items.

The staff's review found that the applicant appropriately addressed the aging effect and aging

effect mechanism as recommended by the GALL Report.

3.3B.2.1.2 Loss of Material Due to General, Pitting, and Crevice Corrosion, MIC, and Fouling

As documented in the Audit and Review Report, the staff noted that in ALRA Table 3.3.2.8-28

for component type tanks the applicant manages the aging effect and aging effect mechanism

of loss of material with the Fuel Oil Chemistry Program. The staff asked the applicant to clarify

why a Note A was assigned to this line item as its Fuel Oil Chemistry Program takes an

exception to GALL AMP XI.M30, "Fuel Oil Chemistry."

In its letter dated December 1, 2005, the applicant stated that the assignment was an error. The

ALRA will be revised so that for this AMR line item the note will be changed from Note A to

Note B.

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The staff reviewed the applicant's response and found it acceptable because, with the

correction of Note A to Note B, the proper note is assigned to the AMR line item.

The staff's review found that the applicant appropriately addressed the aging effect and aging

effect mechanism, as recommended by the GALL Report.

3.3B.2.1.3 Loss of Material Due to General, Pitting, and Crevice Corrosion, and MIC

As documented in the Audit and Review Report, the staff noted that in ALRA Table 3.3.2.B-29

for component type heat exchangers and aging effect and aging effect mechanism of loss of

material, the applicant manages this aging effect and aging effect mechanism with Open-Cycle

Cooling Water System Program. The staff asked the applicant to clarify why ALRA

Table 3.3.1.3, Item 3.3.13.-15 was applied which is for closed-cycle cooling water

environments.

In its letter dated December 1, 2005, the applicant stated that the occurrence is an error. The

ALRA will be revised so that the Table I reference will be changed from ALRA Table 3.3. 1.B,

Item 3.3.1.1-15 to ALRA Table 3.3.1.6, Item 3.3.1.6-17.

The staffs review of the applicant's response found the correction of the Table 1 reference

acceptable because it is for an open-cycle cooling water environment.

The staffs review found that the applicant appropriately addressed the aging effect and aging

effect mechanism, as recommended by the GALL Report.

3.3B.2.1.4 Loss of Material Due to General, Pitting, and Crevice Corrosion

As documented in the Audit and Review Report, the staff noted that in ALRA Table 3.3.2.6-28

(page 3.3-279) for component type tanks the applicant manages the aging effect and aging

effect mechanism of loss of material with the Preventive Maintenance Program. The staff asked

the applicant to confirm that all surfaces of the tank are accessible for visual inspection. The

applicant provided documentation confirming that all external surfaces of the tank are

accessible for visual inspection. Furthermore, in response to this question the applicant noted

that the tank line item for the air environment should have been removed from the ALRA.

In its letter dated December 1, 2005, the applicant stated that the ALRA had been revised to

delete the line item for loss of material addressed by its Preventive Maintenance Program. The

applicant further stated in this letter that ALRA Table 3.3.2.B-28 has a carbon steel component

type of external surfaces aging management line item managed by the Systems Walkdown

Program and the references to its Preventive Maintenance Program should have been

removed. The staff reviewed the applicant's Systems Walkdown Program and its evaluation is

documented in SER Section 3.0.3.3.2.

On the basis of the staffs review of the applicant's response, the staff found it consistent with

the GALL Report and, therefore, acceptable.

On the basis of the staffs review, the staff found that the applicant appropriately addressed the

aging effect and aging effect mechanism as recommended by the GALL Report.

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3.3B.2.1.5 Loss of Material Due to General and Pitting Corrosion

In reviewing ALRA Table 3.3.1.8, Item 3.3.1.6-19 the staff hoted that the applicant credited the

Fire Protection, Fire Water System, One-Time Inspection, and Appendix J Programs. These

AMPs are different from the AMP recommended by the GALL Report GALL AMP XI.M24,

"Compressed Air Monitoring."

The staff reviewed the applicant's Fire Protection, Fire Water System, One-Time Inspection,

and Appendix J Programs and its evaluations are documented in SER Sections 3.0.3.2.13,

3.0.3.2.14, 3.0.3.1.4, and 3.0.3.1.7, respectively. The staff found that the applicant's Fire

Protection and Fire Water System Programs manage loss of material degradation by visual

inspection of piping and valves in the fire detection and protection system. Also the staff found

that the applicant's One-Time Inspection and Appendix J Programs manage loss of material

degradation through visual inspection of carbon steel piping and valves in the compressed air

system. The staff concludes that these AMPs will assure detection of material degradation

before the loss of intended function and that these AMPs will manage the loss of material due

to general and pitting corrosion adequately.

The staffs review found that the applicant appropriately addressed the loss of material due to

general and pitting corrosion for carbon steel piping and fitting and valves exposed to an air

environment.

3.3B.2.1.6 Loss of Material Due to General, Pitting, and Crevice Corrosion

In reviewing ALRA Table 3.3.1.8, Item 3.3.1-23 the staff noted that the applicant credited the

Preventive Maintenance Program. This AMP is different from the AMP recommended by the

GALL Report GALL AMP XI.M29, "Aboveground Carbon Steel Tanks."

The staff reviewed the applicant's Preventive Maintenance Program and its evaluation is

documented in SER Section 3.0.3.3.1. The staff found that the applicant's Preventive

Maintenance Program manages material degradation by visual inspection and examination of

component surfaces for evidence of defects and age-related degradation. The staff concludes

that there is reasonable assurance that this AMP will assure detection of material degradation

before the loss of intended function and that this AMP will manage the loss of material due to

general, pitting, and crevice corrosion adequately.

The staffs review found that the applicant appropriately addressed the loss of material due to

general, pitting, and crevice corrosion for the external surfaces of carbon steel tanks in the

diesel fuel oil system.

3.3B.2.1.7 Loss of Material Due to Wear; Hardening and Shrinkage Due to Weathering

The staff reviewed ALRA Table 3.5.2.B-1 as referenced in SER Table 3.3B-1, Item 3.3.1.8-20.

In ALRA Table 3.3.1.8, Item 3.3.1.8-20, the applicant states that fire rated doors for the NMP2

reactor building, auxiliary building, control room building, diesel generator building, essential

yard structures, radwaste building, screenwell building, standby gas treatment building and

turbine building are consistent with the GALL Report. Additionally, in the ALRA, the applicant

included some doors in the reactor building, control room building, essential yard structures,

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radwaste building, and standby gas treatment building that are not addressed in the GALL

Report.

The applicant also states, in the Item 3.3.1.B-20 that loss of material is not applicable for

concrete structures in fire protection because the plant-specific environment is not conducive to

the listed aging effects. Nonetheless, the specified AMP is implemented for these components.

The staff reviewed Table 3.3.2.8 related to this item, and finds that the applicant will credit the

Fire Protection Program to mange the doors type components and credits the Structures

Monitoring Program to mange concrete structures. The staff reviewed the applicant's Fire

Protection Program and its evaluation is documented in SER Section 3.0.3.2.13. The staff

accepted that the applicant's Fire Protection Program does adequately manage material

degradation. The staff concludes that there is reasonable assurance that this AMP will assure

detection of material degradation before the loss of intended function. The staff also determined

that concrete structures will be adequately managed by the structure monitoring program.

On the basis of its review, the staff found that the applicant appropriately addressed the aging

effect/mechanism, as recommended by the GALL Report.

3.3B.2.1.8 Loss of Material Due to General Corrosion and Wear

The staff reviewed ALRA Table 3.5.2.B-1 as referenced in SER Table 3.3B-1, Item 3.3.1.8-16.

In ALRA Tables 3.5.2.8-7 & 3.5.2.B-9, the applicant credits the Inspection of Overhead Heavy

Load and Light Load Handling Systems Program to manage the aging effect of loss of material

due to general corrosion and wear for refueling crane and platform equipment of fuel handling

systems, polar crane, handling crane, and hoists of material handling systems

The staff reviewed and accepted the applicant's Inspection of Overhead Heavy Load and Light

Load Handling Systems Program and its evaluation is documented in SER Section 3.0.3.2.10.

On the basis of its review, the staff concluded that the applicant appropriately addressed the

aging effect/mechanism, as recommended by the GALL Report.

3.38.2.1.9 Crack Initiation and Growth Due to Stress Corrosion Cracking

The staff reviewed ALRA Table 3.5.2.8-1 as referenced in SER Table 3.38-1, Item 3.3.1.8-13.

In ALRA Table 3.5.2.B-7, the applicant credits Water Chemistry Control Program to manage

the aging effect of the crack initiation and growth due to stress corrosion cracking for the

storage racks and frame under treated water environment.

The staff reviewed and accepted the applicant's Water Chemistry Control Program and its

evaluation is documented in SER Section 3.0.3.2.2. The staff reviewed its related AMR item in

ALRA Table 3.5.2.8-7 and found this acceptable since this is consistent with GALL Report's

recommendation. On this basis, the staff concludes this is acceptable.

Conclusion. The staff evaluated the applicant's claim of consistency with the GALL Report. The

staff also reviewed information pertaining to the applicant's consideration of recent operating

experience and proposals for managing associated aging effects. On the basis of its review, the

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staff concludes that there is reasonable assurance that the AMR results, which the applicant

claimed to be consistent with the GALL Report, are consistent with the AMRs in the GALL

Report. Therefore, the staff concludes that the applicant had demonstrated that the effects of

aging for these components will be adequately managed so that their intended function(s) will

be maintained consistent with the CLB for the period of extended operation, as required by

10 CFR 54.21(a)(3).

3.3B.2.2 AMR Results That are Consistent with the GALL Report, for Which Further

Evaluation is Recommended

Summary of Technical Information in the Amended Application. In Section 3.3.2.C of its letter

dated August 19, 2005, the applicant provided further evaluation of aging management as

recommended by the GALL Report for the auxiliary systems components. The applicant

provided information concerning how it will manage the following aging effects:

* loss of material due to general, pitting, and crevice corrosion

• hardening and cracking or loss of strength due to elastomer degradation or loss of material

due to wear

" cumulative fatigue damage

" crack initiation and growth due to cracking or stress corrosion cracking

• loss of material due to general, microbiologically influenced, pitting, and crevice corrosion

° loss of material due to general, galvanic, pitting, and crevice corrosion

" loss of material due to general, pitting, crevice, and MIC and biofouling

" crack initiation and growth due to stress corrosion cracking and cyclic loading

• reduction of neutron-absorbing capacity and loss of material due to general corrosion

* loss of material due to general, pitting, crevice, and MIC

Staff Evaluation. For component groups evaluated in the GALL Report for which the applicant

has claimed consistency with the GALL Report, and for which the GALL Report recommends

further evaluation, the staff audited and reviewed the applicant's evaluation to determine

whether it adequately addressed the issues that were further evaluated. In addition, the staff

reviewed the applicant's further evaluations against the criteria contained in SRP-LR

Section 3.3.2.2. Details of the staffs audit are documented in the staffs Audit and Review

Report. The staffs evaluation of the aging effects is discussed in the following sections.

3.3B.2.2.1 Loss of Material Due to General, Pitting, and Crevice Corrosion

The staff reviewed Section 3.3.2.C.1 of the applicant's letter dated August 19, 2005 against the

criteria in SRP-LR Section 3.3.2.2.1.1.

In Section 3.3.2.C.1 of its letter dated August 19, 2005, the applicant addressed loss of material

due to general, pitting, and crevice corrosion for spent fuel pool cooling and cleanup system

components.

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SRP-LR Section 3.3.2.2.1.1 states that loss of material due to general, pitting, and crevice

corrosion could occur in the channel head and access cover, tubes, and tubesheets of the heat

exchanger in the spent fuel pool cooling and cleanup. The Water Chemistry Control Program

relies on monitoring and control of reactor water chemistry based on EPRI guidelines of

BWRVIP-29 (TR-103515), "BWR Water Chemistry Guidelines - Normal and Hydrogen Water

Chemistry," to manage the effects of loss of material from general, pitting, or crevice corrosion.

However, high concentrations of impurities at crevices and stagnant flow locations could cause

general, pitting, or crevice corrosion. Therefore, the effectiveness of the chemistry control

program should be verified to ensure no corrosion. The GALL Report recommends further

evaluation of programs to manage loss of material from general, pitting, and crevice corrosion

to verify-the effectiveness of the applicant's Water Chemistry Control Program. A one-time

inspection of select components at susceptible locations is an acceptable method to ensure no

corrosion and maintenance of the component's intended function during the period of extended

operation.

In Section 3.3.2.C.1 of its letter dated August 19, 2005, the applicant stated that NMP2 spent

fuel pool cooling system components are managed by the combination of the Water Chemistry

Control and One-Time Inspection Programs.

The staff reviewed the applicant's Water Chemistry Control and One-Time Inspection Programs

and its evaluations are documented in SER Sections 3.0.3.2.2 and 3.0.3.1.4, respectively.

The staff reviewed the applicant's further evaluation and concludes that it meets the criteria of

the SRP-LR.

In addition the staff reviewed Section 3.3.2.C.1 of the applicant's letter dated August 19, 2005,

against the criteria of SRP-LR Section 3.3.2.2.1.2.

In Section 3.3.2.C.1 of its letter dated August 19, 2005, the applicant stated that the aging

effect and aging effect mechanism of loss of material due to general, pitting, and crevice

corrosion of spent fuel pool cooling and cleanup system components is not applicable to NMP2

because it has no shutdown cooling system. Therefore, the staff agreed that this aging effect

and aging effect mechanism is not applicable to NMP2.

Because NMP has no components from this .group the staff found this aging effect and aging

effect mechanism not applicable to NMP.

The staff concludes that there is reasonable assurance that the applicant's programs met the

criteria of SRP-LR Section 3.3.2.2.1. For those line items addressed by Section 3.3.2.C.1 of the

applicant's letter dated August 19, 2005, the staff determined that the information in the

application was consistent with the GALL Report and that the applicant had demonstrated that

the effects of aging will be adequately managed so that the intended functions will be

maintained consistent with the CLB during the period of extended operation, as required by

10 CFR 54.21(a)(3).

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3.3B.2.2.2 Hardening and Cracking or Loss of Strength Due to Elastomer Degradation or Loss

of Material due to Wear

The staff reviewed Section 3.3.2.C.2 of the applicant's letter dated August 19, 2005 against the

criteria of SRP-LR Section 3.3.2.2.2.

In Section 3.3.2.C.2 of its letter dated August 19, 2005, the applicant addressed aging effects

and aging effects mechanisms that could occur for the elastomer lining of some components

exposed to the treated water environment of the spent fuel pool cooling system and elastomer

seals and collars in the ductwork of certain ventilation systems exposed to a range of

atmospheric conditions.

SRP-LR Section 3.3.2.2.2 states that hardening and cracking due to elastomer degradation

could occur in elastomer linings of the filter, valve, and ion exchangers in spent fuel pool cooling

and cleanup systems. Hardening and loss of strength due to elastomer degradation could occur

in the collars and seals of the duct and in the elastomer seals of the filters in the control room

area, auxiliary and radwaste area, and primary containment heating ventilation systems and in

the collars and seals of the duct in the diesel generator building ventilation system. Loss of

material due to wear could occur in the collars and seals of the duct in the ventilation systems.

The GALL Report recommends further evaluation to ensure that these aging effects and aging

effects mechanisms are adequately managed.

In Section 3.3.2.C.2 of its letter dated August 19, 2005, the applicant also stated that

elastomers are not used in the lining of spent fuel pool system components within the scope of

license renewal.

In addition the applicant stated that for NMP2 ventilation systems the aging effects and aging

effects mechanisms for seals and collars are managed by the NMP AMP B2.1.32, "Preventive

Maintenance Program." The staff reviewed the applicant's Preventive Maintenance Program

and its evaluation is documented in SER Section 3.0.3.3.1.

The staff reviewed the applicant's further evaluation and concludes that it meets the criteria of

the SRP-LR.

The staff concludes that the applicant's programs met the criteria of SRP-LR Section 3.3.2.2.2.

For those line items that apply to Section 3.3.2.C.2 of the applicant's letter dated August 19,

2005, the staff determined that the information in the application was consistent with the GALL

Report and the applicant had demonstrated that the effects of aging will be adequately

managed so that intended functions will be maintained consistent with the CLB during the

period of extended operation as required by 10 CFR 54.21 (a)(3).

3.3B.2.2.3 Cumulative Fatigue Damage

In Section 3.3.2.C.3 of its letter dated August 19, 2005, the applicant stated that fatigue is a

TLAA as defined in 10 CFR 54.3. Applicants must evaluate TLAAs in accordance with

10 CFR 54.21(c)(1). SER Section 4.3 documents the staff's review of the applicant's evaluation

of this TLAA.

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3.3B.2.2.4 Crack Initiation and Growth Due to Cracking or Stress Corrosion Cracking

The staff reviewed Section 3.3.2.C.4 of the applicant's letter dated August 19, 2005, against the

criteria in SRP-LR Section 3.3.2.2.4.

In Section 3.3.2.C.4 of its letter dated August 19, 2005, the applicant addressed cracking due to

SCC for the stainless steel reactor water cleanup system regenerative and nonregenerative

heat exchangers.

In the ALRA, the applicant states that for NMP2 this aging effect and aging effect mechanism

are not applicable to the reactor water cleanup system regenerative and nonregenerative heat

exchangers because only the carbon steel shells are within the scope of license renewal and

subject to an AMR cracking is not an applicable aging effect and aging effect mechanism for

this material in the system environment. The staff determined through discussions with the

applicant's technical personnel that this aging effect or aging effect mechanism is (1) not

applicable to NMP2 based on the use of carbon steel in the heat exchanger shells and (2) not

susceptible to SCC.

Because NMP2 has no regenerative or nonregenerative heat exchanger reactor water cleanup

system components susceptible to SCC within the scope of license renewal the staff found

these aging effect and aging effect mechanism not applicable to NMP2.

3.38.2.2.5 Loss of Material Due to General, Microbiologically Influenced, Pitting, and Crevice

Corrosion

The staff reviewed Section 3.3.2.C.5 of the applicant's letter dated August 19, 2005, against the

criteria of SRP-LR Section 3.3.2.2.5.

In Section 3.3.2.C.5 of its letter dated August 19, 2005, the applicant addressed loss of material

from corrosion that could occur on internal and external surfaces of components exposed to a

range of atmospheric conditions. Specifically included were the ventilation systems, the diesel

generator systems' fuel oil, starting air, and combustion air intake and exhaust subsystems, and

auxiliary systems' external carbon steel surfaces within the scope of license renewal.

SRP-LR Section 3.3.2.2.5 states that loss of material due to general, pitting, and crevice

corrosion could occur in the piping and filter housing and supports in the control room area, the

auxiliary and radwaste area, the primary containment heating and ventilation systems, in the

piping of the diesel generator building ventilation system, in the aboveground piping and fittings,

valves, and pumps in the diesel fuel oil system, and in the diesel engine starting air, combustion

air intake, and combustion air exhaust subsystems in the emergency diesel generator system.

Loss of material due to general, pitting, crevice, and MIC could occur in the duct fittings, access

doors, and closure bolts, equipment frames, and housing of the duct; loss due to pitting and

crevice corrosion could occur in the heating/cooling coils of the air handler heating/cooling; and

los due to general corrosion could occur on the external surfaces of all carbon steel structures

and components, including bolting exposed to operating temperatures < 212°F in the ventilation

systems. The GALL Report recommends further evaluation to ensure that these aging effects

and aging effects mechanisms are adequately managed.

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In Section 3.3.2.C.5 of its letter dated August 19, 2005, the applicant stated that for NMP2 this

aging effect and aging effect mechanism are managed by the Fire Water System Program,

One-Time Inspection Program, Preventive Maintenance Program, Systems Walkdown

Program, and Bolting Integrity Program for the applicable systems and components.

The staff reviewed the applicant's Fire Water System, One-Time Inspection, Preventive

Maintenance, Systems Walkdown, and Bolting Integrity Programs and its evaluations are

documented in SER Sections 3.0.3.2.14, 3.0.3.1.4, 3.0.3.3.1, 3.0.3.3.2, and 3.0.3.2.23,

respectively.

The staff reviewed the applicant's further evaluation and concludes that it meets the criteria in

the SRP-LR.

The staff concludes that there is reasonable assurance that the applicant's programs met the

criteria of SRP-LR Section 3.3.2.2.5. For those line items addressed by Section 3.3.2.C.5 of the

applicant's letter dated August 19, 2005, the staff determined that the information in the

application was consistent with the GALL Report and the applicant had demonstrated that the

effects of aging will be adequately managed so that the intended functions will be maintained

consistent with the CLB during the period of extended operation, as required by

10 CFR 54.21(a)(3).

3.3B.2.2.6 Loss of Material Due to General, Galvanic, Pitting, and Crevice Corrosion

The staff reviewed Section 3.3.2.C.6 of the applicant's letter dated August 19, 2005, against the

criteria of SRP-LR Section 3.3.2.2.6.

The applicant stated in the ALRA that loss of material due to general, galvanic, pitting, and

crevice corrosion in the reactor recirculation pumps' oil collection system in fire protection is not

applicable because NMP has no oil collection systems for its reactor recirculation pumps. The

staff determined through discussions with the applicant's technical personnel that loss of

material due to general, galvanic, pitting, and crevice corrosion in the reactor recirculation

pumps' oil collection system in fire protection is not applicable because NMP has no oil

collection systems for its reactor recirculation pumps.

Because NMP has no components from this group the staff found this aging effect and aging

effect mechanism not applicable.

3.3B.2.2.7 Loss of Material Due to General, Pitting, Crevice, and Microbiologically Influenced

Corrosion and Biofouling

The staff reviewedSection 3.3.2.C.7 of the applicant's letter dated August 19, 2005, against the

criteria of SRP-LR Section 3.3.2.2.7.

In Section 3.3.2.C.7 of its letter dated August 19, 2005, the applicant addressed loss of material

due to general, pitting, crevice, and MIC and biofouling for the internal surfaces of diesel fuel oil

system components.

SRP-LR Section 3.3.2.2.7 states that loss of material due to general, pitting, and crevice

corrosion, MIC, and biofouling could occur in the internal surface of tanks in the diesel fuel oil

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system and due to general, pitting, crevice, and MIC in the tanks of the diesel fuel oil system in

the emergency diesel generatorsystem. The existing AMP relies on the Fuel Oil Chemistry

Program for monitoring and control of fuel oil contamination according to the guidelines of

ASTM Standards 04057, D1796, D2709 and D2276 to manage lo ss of material due to

corrosion or biofouling that may occur where contaminants accumulate. The effectiveness of

the chemistry control program should be verified to ensure no corrosion. The GALL Report

recommends further evaluation of programs to manage corrosion/biofouling to verify

effectiveness. A one-time inspection of selected components at susceptible locations is an

acceptable method to ensure no corrosion and maintenance of the component's intended

function during the period of extended operation.

The applicant stated in.Section 3.3.2.C.7 of its letter dated August 19, 2005, that for NMP2 this

aging effect and aging effect mechanism are managed by the combination of the Fuel Oil

Chemistry Program and the One-Time Inspection Program.

The staff reviewed the applicant's Fuel Oil Chemistry Program and One-Time Inspection

Program and its evaluations are documented in Sections 3.0.3.2.15 and 3.0.3.1.4, respectively.

The staff reviewed the applicant's further evaluation and concludes that it meets the criteria of

the SRP-LR.

The staff concludes that there is reasonable assurance that the applicant has met the criteria of

SRP-LR Section 3.3.2.2.7. For those line items that apply to Section 3.3.2.C.7 of the applicant's

letter dated August 19, 2005, the staff determined that the information in the application was

consistent with the GALL Report and the applicant had demonstrated that the effects of aging

will be adequately managed so that the intended functions will be maintained consistent with

the CLB during the period of extended operation as required by 10 CFR 54.21 (a)(3).

3.3B.2.2.8 Quality Assurance for Aging Management of Non-Safety-Related Components

SER Section 3.0.4 includes the staff's evaluation of the applicant's quality assurance program.

3.3B.2.2.9 Crack Initiation and Growth Due to Stress Corrosion Cracking and Cyclic Loading

The staff reviewed Section 3.3.2.C.9 of the applicant's letter dated August 19, 2005, against the

criteria of SRP-LR Section 3.3.2.2.9.

In Section 3.3.2.C.9 of its letter dated August 19, 2005, the applicant stated that because crack

initiation and growth due to SCC and cyclic loading apply to PWRs only this aging effect and

aging effect mechanism are not applicable to NMP. The staff determined through discussions

with the applicant's technical personnel that this aging effect and aging effect mechanism

applies to PWRs only and not to NMP.

Because NMP has no components from this group the staff found this aging effect and aging

effect mechanism not applicable.

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3.3B.2.2.10 Reduction of Neutron-Absorbing Capacity and Loss of Material Due to General

Corrosion

The staff reviewed Section 3.3.2.C.10 of the applicant's letter dated August 19, 2005, against

the criteria of SRP-LR Section 3.3.2.2.10.

SRP-LR Section 3.3.2.2.10 states that reduction of neutron-absorbing capacity and loss of

material due to general corrosion could occur in the neutron-absorbing sheets of the spent fuel

storage rack in the spent fuel storage. The GALL Report recommends further evaluation to

ensure that these aging effects are adequately managed.

In Section 3.3.2.C.10 of its letter dated August 19, 2005, the applicant stated that reduction of

neutron-absorbing capacity and loss of material due to general corrosion in the

neutron-absorbing (Boral or boron steel) sheets of the spent fuel storage racks are not

applicable as NMP identified no aging effects and aging effects mechanisms for these

components.

In its letter dated November 17, 2005, the applicant revised ALRA to address NMP

management decisions to have all Boraflex removed from the NMP2 spent fuel pool prior to

entry into the NMP2 period of extended operation. In this letter, the applicant credits the Water

Chemistry Control and One-Time Inspection Programs for aging management. The Water

Chemistry Control and One Time Inspection Programs manage general corrosion. The

applicant's Commitment 36 of NMP2 states that prior to the period of extended operation for

NMP2, the spent fuel rack design that currently utilizes Boraflex for reactivity control in the

spent fuel pool will be replaced by a design that utilizes Boral for this function. Therefore, the

new design will utilizes Boral for neutron absoption. The reduction of neutron-absorbing

capacity will be adequately managed with this new design.

The staff reviewed the Applicant's Water Chemistry Control and One Time Inspection Programs

and Commitment 36. The staff found this acceptable since its change provides adequate aging

management for the aging effects. On this basis, the staff found this acceptable.

3.3B.2.2.11 Loss of Material Due to General, Pitting, Crevice, and Microbiologically Influenced

Corrosion

The staff reviewed Section 3.3.2.C.11 of the applicant's letter dated August 19, 2005, against

the criteria of SRP-LR Section 3.3.2.2.11.

In Section 3.3.2.C.11 of its letter dated August 19, 2005, the applicant addressed loss of

material due to general, pitting, crevice, and MIC for buried piping and fittings.

SRP-LR Section 3.3.2.2.11 states that loss of material due to general, pitting, and crevice

corrosion and MIC could occur in the underground piping and fittings in the open-cycle cooling

water system (service water system) and in the diesel fuel oil system. The Buried Piping and

Tanks Inspection Program relies on industry practice, frequency of pipe excavation, and

operating experience to manage the effects of loss of material from general, pitting, crevice and

MIC. The effectiveness of the applicant's Buried Piping and Tanks Inspection Program should

be verified to evaluate inspection frequency and operating experience with buried components

to ensure no loss of material.

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In the ALRA, the applicant stated that this aging effect and aging effect mechanism are

managed by the Buried Piping and Tanks Inspection Program for NMP2 fire detection and

protection systems. The staff reviewed the applicant's Buried Piping and Tanks Inspection

Program and its evaluation is documented in SER Section 3.0.3.1.6.

As documented in the Audit and Review Report, the staff asked the applicant to clarify its

position on opportunistic inspections prior to the period of extended operation. In its letter dated

December 1, 2005, the applicant stated that the ALRA will be revised to include the following in

its Buried Piping and Tanks Inspection Program:

Program activities will include visual inspections of external coatings and wrappings to

detect damage and degradation. Prior to entering the period of extended operation,

NMPNS will verify that there has been at least one opportunistic or focused inspection

within the past ten years. Upon entering the period of extended operation, NMPNS will

perform a focused inspection within ten years, unless an opportunistic inspection

occurred within this ten year period. All credited inspections will be performed in areas

with the highest likelihood of corrosion problems, and in areas with a history of

corrosion problems.

The staff reviewed the applicant's clarification of its visual inspection position and the

applicant's further evaluation and staff concludes that they met the criteria of the SRP-LR.

The staff concludes that there is reasonable assurance that the applicant's programs met the

criteria of SRP-LR Section 3.3.2.2.11. For those line items addressed in Section 3.3.2.C.11 of

the applicant's letter dated August 19, 2005, the staff determined that the information in the

application was consistent with the GALL Report and the applicant had demonstrated that the

effects of aging will be adequately managed so that the intended functions will be maintained

consistent with the CLB during the period of extended operation as required by

10 CFR 54.21(a)(3).

Conclusion. On the basis of its review, for component groups evaluated in the GALL Report for

which the applicant has claimed consistency with the GALL Report, and for which the GALL

Report recommends further evaluation, the staff determined that the applicant adequately

addressed the issues that were further evaluated. The staff found that the applicant had

demonstrated that the effects of aging will be adequately managed so that the intended

functions will be maintained consistent with the CLB for the period of extended operation, as

required by 10 CFR 54.21(a)(3).

3.3B.2.3 AMR Results That Are Not Consistent with or Not Addressed in the GALL

Report

Summary of Technical Information in the Amended Application. In ALRA Tables 3.3.2.B-1

through 3.3.2.B-40, the staff reviewed additional details of the results of the NMP2 AMRs for

material, environment, AERM, and AMP combinations that are not consistent with the GALL

Report, or that are not addressed in the GALL Report.

In ALRA Tables 3.3.2.B-1 through 3.3.2.B-40, the applicant indicated, via Notes F through J,

that the combination of component type, material, environment, and aging effect requiring

management does not correspond to a line item in the GALL Report, and provided information

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concerning how the aging effect will be managed. Specifically, Note F indicated that the

material for the AMR'line item component is not evaluated in the GALL Report. Note G

indicated that the environment for the AMR line item component and material is not evaluated in

the GALL Report. Note H indicated that the aging effect for the AMR line item component,

material, and environment combination is not evaluated in the GALL Report. Note I indicated

that the aging effect identified in the GALL Report for the line item component, material, and

environment combination is not applicable. Note J indicated that neither the component nor the

material and environment combination for the line item is evaluated in the GALL Report.

Staff Evaluation. For component type, material, and environment combinations that are not

evaluated in the GALL Report, the staff reviewed the applicant's evaluation to determine

whether the applicant had demonstrated that the effects of aging will be adequately managed

so that the intended function(s) will be maintained consistent with the CLB during the period of

extended operation. The staff's evaluation is discussed in the following sections.

3.31.2.3.1 Auxiliary Systems NMP2 Air Startup Standby Diesel Generator System - Summary

of Aging Management Evaluation - ALRA Table 3.3.2.1-1

The staff reviewed ALRA Table 3.3.2.B-1, which summarizes the results of AMR evaluations for

the air startup standby diesel generator system component-material-environment-AERM

combinations not addressed in the GALL Report. These combinations use Notes F through J.

The staff verified that the applicant had identified all applicable AERMs and had credited

appropriate AMPs for managing them. The staff also reviewed the applicable UFSAR

supplements for the AMPs to ensure that the program descriptions describe them adequately.

Aging Effects. ALRA Table 2.3.3.B.1-1 lists individual system components within the scope of

license renewal and subject to an AMR. The component types that do not rely on the GALL

Report for an AMR include piping and fittings and valves.

For these component types the applicant identified the following materials, environments, and

AERMS:

wrought austenitic stainless steel exposed to exhaust environment subject to loss of

material

The staff reviewed the information in ALRA Section 2.3.3.8.1, Table 2.3.3.B.1-1,

Section 3.3.2.8.1, and Table 3.3.2.8-1.

The staff's review of the information provided in the ALRA found the aging effects of the air

startup standby diesel generator system component types not addressed by the GALL Report

consistent with industry experience for these combinations of materials and environments. The

staff did not identify any omitted aging effects. Therefore, the staff found that the applicant had

identified the appropriate aging effects for the materials and environments associated with the

.air startup standby diesel generator system components.

Aging Management Programs. After evaluating the applicant's identification of aging effects for

each of the components the staff evaluated the AMPs to determine whether they are

appropriate for managing the identified aging effects. The staff also verified that the UFSAR

supplement describes the programs adequately.*

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ALRA Table 3.3.2.B-1 identifies the following AMP for managing the aging effects for the air

startup standby diesel generator system components that are not addressed by the GALL

Report

0 Preventive Maintenance Program

The staffs detailed review of this AMP is found in SER Sections 3.0.3.3.1.

Conclusion: On the basis of its review, as discussed above, the staff concludes that there is

reasonable assurance that the applicant had demonstrated that the aging effects associated

with the air startup standby diesel generator system components will be adequately managed

so that the intended functions will be maintained consistent with the CLB for the period of

extended operation, as required by 10 CFR 54.21(a)(3).

The staff found that the applicant had demonstrated that the effects of aging will be adequately

managed so that the intended functions will be maintained consistent with the CLB for the

period of extended operation, as required by 10 CFR 54.21 (a)(3).

3.3B.2.3.2 Auxiliary Systems NMP2 Alternate Decay Heat Removal System - Summary of

Aging Management Evaluation - ALRA Table 3.3.2.B-2

This auxiliary system is listed here for information and completeness. The AMR results for the

NMP2 alternate decay heat removal system are consistent with the GALL Report. The staffs

evaluation of these results is presented in SER Section 3.3B.2.1

3.38.2.3.3 Auxiliary Systems NMP2 Auxiliary Service Building HVAC System - Summary of

Aging Management Evaluation - ALRA Table 3.3.2.B-3

This auxiliary system is listed here for information and completeness. The AMR results for the

NMP2 auxiliary service building HVAC system are consistent with the GALL Report. The staffs

evaluation of these results is presented in SER Section 3.3B.2.2.5

3.38.2.3.4 Auxiliary Systems NMP2 Chilled Water Ventilation System - Summary of Aging

Management Evaluation - ALRA Table 3.3.2.1-4

This auxiliary system is listed here for information and completeness. This system has been

removed from the scope of license renewal by the applicant in its ALRA dated July 14, 2005.

3.38.2.3.5 Auxiliary Systems NMP2 Compressed Air Systems - Summary of Aging

Management Evaluation - ALRA Table 3.3.2.8-5

This auxiliary system Is listed here for information and completeness. The AMR results for the

NMP2 compressed air systems are consistent with the GALL Report. The staffs evaluation of

these results is presented in SER Section 3.38.2.2.5

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3.3B.2.3.6 Auxiliary Systems NMP2 Containment Atmosphere Monitoring System - Summary

of Aging Management Evaluation - ALRA Table 3.3.2.B-6

This auxiliary system is listed here for information and completeness. The AMR results for the

NMP2 containment atmosphere monitoring system are consistent with the GALL Report. The

environment is air and therefore there is no AMP that requires staff evaluation.

3.3B.2.3.7 Auxiliary Systems NMP2 Containment Leakage Monitoring System - Summary of

Aging Management Evaluation - ALRA Table 3.3.2.B-7

This auxiliary system is listed here for information and completeness. The AMR results for the

NMP2 containment leakage monitoring system are consistent with the GALL Report. The staff's

evaluation of these results is presented in SER Section 3.3B.2.2.5

3.3B.2.3.8 Auxiliary Systems NMP2 Control Building Chilled Water System - Summary of

Aging Management Evaluation -ALRA Table 3.3.2.B-8

The staff reviewed ALRA Table 3.3.2.B-8, which summarizes the results of AMR evaluations for

the control building chilled water system component-material-environment-AERM combinations

not addressed in the GALL Report. These combinations use Notes F through J. The staff

verified that the applicant had identified all applicable AERMs and had credited appropriate

AMPs for managing them. The staff also reviewed the applicable USAR supplements for the

AMPs to ensure that the program descriptions describe them adequately.

A-aina Effects. ALRA Table 2.3.3.B.8-1 lists individual system components within the scope of

license renewal and subject to an AMR. The component types that do not rely on the GALL

Report for an AMR include chillers and external surfaces.

For these component types the applicant identified the following materials, environments, and

AERMS:

copper alloys (zinc < 15 percent) exposed to raw water subject to loss of heat transfer

and loss of material

copper alloys (zinc < 15 percent) exposed to treated water, temperature < 140 OF,

subject to loss of heat transfer

gray cast iron exposed to air subject to loss of material

The staff reviewed the information in ALRA Section 2.3.3.B.8, Table 2.3.3.B.8-1,

Section 3.3.2.B.8, and Table 3.3.2.B-8.

The staffs review of the information provided in the ALRA found the aging effects of the control

building chilled water system component types not addressed by the GALL Report consistent

with industry experience for these combinations of materials and environments. The staff did

not identify any omitted aging effects: Therefore, the staff found that the applicant had identified

the appropriate aging effects for the materials and environments of the control building chilled

water system components.

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Aging Management Programs. After evaluating the applicant's identification of aging effects for

each of the components the staff evaluated the AMPs to determine whether they are

appropriate for managing the identified aging effects. The staff also verified that the USAR

supplement describes the programs adequately.

ALRA Table 3.3.2.B-8 identifies the following AMPs for managing the aging effects for the

control building chilled water system components not addressed by the GALL Report:

• Open-Cycle Cooling Water System Program

* Closed-Cycle Cooling Water System Program

* System Walkdown Program

The staffs detailed review of the AMPs is found in SER Sections 3.0.3.2.7, 3.0.3.2.8 and

3.0.3.3.2.

Conclusion: On the basis of its review, as discussed above, the staff concludes that there is

reasonable assurance that the applicant has demonstrated that the aging effects associated

with the control building chilled water system components will be adequately managed so that

the intended functions will be maintained consistent with the CLB for the period of extended

operation, as required by 10 CFR 54.21 (a)(3).

The staff also reviewed the applicable UFSAR supplement program descriptions and concludes

that the UFSAR supplement provides an adequate description of the AMPs credited for

managing aging of these components, as required by 10 CFR 54.21(d).

3.3B.2.3.9 Auxiliary Systems NMP2 Control Building HVAC system - Summary of Aging

Management Evaluation - ALRA Table 3.3.2.B-9

The staff reviewed ALRA Table 3.3.2.B-9, which summarizes the results of AMR evaluations for

the control building HVAC system component-material-environment-AERM combinations not

addressed in the GALL Report. These combinations use Notes F through J. The staff verified

that the applicant had identified all applicable AERMs and had credited appropriate AMPs for

managing them. The staff also reviewed the applicable USAR supplements for the AMPs to

ensure that the program descriptions describe them adequately.

Aging Effects. ALRA Table 2.3.3.B.9-1 lists individual system components within the scope of

license renewal and subject to an AMR. The component types that do not rely on the GALL

Report for an AMR include external surfaces, heat exchangers, and valves and dampers

(including fire dampers).

For these component types the applicant identified the following materials, environments, and

AERMS:

* gray cast iron exposed to air subject to loss of material

* copper alloys (zinc < 15 percent) exposed to air, moisture or wetting, temperature

< 140 OF, subject to loss of heat transfer

copper alloys (zinc < 15 percent) exposed to demineralized untreated water subject to

loss of heat transfer

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The staff reviewed the information in ALRA Section 2.3.3.B.9, Table 2.3.3.B.9-1,

Section 3.3.2.8.9, and Table 3.3.2.B-9.

The staff's review of the information provided in the ALRA found the aging effects of the control

building HVAC system component types not addressed by the GALL Report consistent with

industry experience for these combinations of materials and environments. The staff did not

identify any omitted aging effects. Therefore, the staff found that the applicant had identified the

appropriate aging effects for the materials and environments of the control building HVAC

system components.

Aging Management Programs. After evaluating the applicant's identification of aging effects for

each of the components the staff evaluated the AMPs to determine whether they are

appropriate for managing the identified aging effects. The staff also verified that the USAR

supplement describes the programs adequately.

ALRA Table 3.3.2.B-9 identifies the following AMPs for managing the aging effects for the

control building HVAC system components not addressed by the GALL Report:

* System Walkdown Program

* Preventive Maintenance Program

* Closed-Cycle Cooling Water System Program

* One-Time Inspection Program

The staffs detailed review of the AMPs is found in SER Sections 3.0.3.3.2, 3.0.3.3.1, 3.0.3.2.8,

and 3.0.3.1.4.

Conclusion: On the basis of its review, as discussed above, the staff concludes that there is

reasonable assurance that the applicant has demonstrated that the aging effects associated

with the control building HVAC system components will be adequately managed so that the

intended functions will be maintained consistent with the CLB for the period of extended

operation, as required by 10 CFR 54.21 (a)(3).

The staff also reviewed the applicable UFSAR supplement program descriptions and concludes

that the UFSAR supplement provides an adequate description of the AMPs credited for

managing aging of these components, as required by 10 CFR 54.21(d).

3.38.2.3.10 Auxiliary Systems NMP2 Diesel Generator Building Ventilation System - Summary

of Aging Management Evaluation - ALRA Table 3.3.2.B-10

The staff reviewed ALRA Table 3.3.2.B-10, which summarizes the results of AMR evaluations

for the diesel generator building ventilation system component-matedal-environment-AERM

combinations not addressed in the GALL Report. These combinations use Notes F through J.

The staff verified that the applicant had identified all applicable AERMs and had credited

appropriate AMPs for managing them. The staff also reviewed the applicable USAR

supplements for the AMPs to ensure that the program descriptions describe them adequately.

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Aging Effects. Table 2.3.3.B.10-1 lists individual system components within the scope of license

renewal and subject to an AMR. The component types that do not rely on the GALL Report for

an AMR include unit coolers.

For this component type the applicant identified the following materials, environments, and

AERMS:

0 copper alloys (zinc < 15 percent) exposed to raw water subject to loss of material

The staff reviewed the information in ALRA Section 2.3.3.B.10, Table 2.3.3.B.10-1,

Section 3.3.2.B.10, and Table 3.3.2.B-10.

The staff's review of the information provided in the ALRA found the aging effects of the control

building HVAC system component types not addressed by the GALL Report consistent with

industry experience for these combinations of materials and environments. The staff did not

identify any omitted aging effects. Therefore, the staff found that the applicant had identified the

appropriate aging effects for the materials and environments of the control building HVAC

system components.

Aging Management Programs. After evaluating the applicant's identification of aging effects for

the component the staff evaluated the AMPs to determine whether they are appropriate for

managing the identified aging effects. The staff also verified that the USAR supplement

describes the programs adequately.

ALRA Table 3.3.2.B-10 identifies the following AMP for managing the aging effects for the

control building HVAC system components not addressed by the GALL Report:

0 Open-Cycle Cooling Water System Program

The staff's detailed review of this AMP is found in SER Section 3.0.3.2.7.

Conclusion: On the basis of its review, as discussed above, the staff concludes that there is

reasonable assurance that the applicant has demonstrated that the aging effects associated

with the diesel generator building ventilation system components will be adequately managed

so that the intended functions will be maintained consistent with the CLB for the period of

extended operation, as required by 10 CFR 54.21(a)(3).

The staff also reviewed the applicable UFSAR supplement program descriptions and concludes

that the UFSAR supplement provides an adequate description of the AMPs credited for

managing aging of these components, as required by 10 CFR 54.21(d).

3.3B.2.3.11 Auxiliary Systems NMP2 Domestic Water System - Summary of Aging

Management Evaluation - ALRA Table 3.3.2.B-11

The staff reviewed ALRA Table 3.3.2.B-11, which summarizes the results of AMR evaluations

for the domestic water system component-material-environment-AERM combinations not

addressed in the GALL Report. These combinations use Notes F through J as revised by the

applicant's letter NMPIL 1996 dated November 17, 2005. The staff verified that the applicant

had identified all applicable AERMs and had credited appropriate AMPs for managing them.

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The staff also reviewed the applicable USAR supplements for the AMPs to ensure that the

program descriptions describe them adequately.

Aping Effects. ALRA Table 2.3.3.8.11-1 lists individual system components within the scope of

license renewal and subject to an AMR. The component types that do not rely on the GALL

Report for an AMR include piping and fittings, tanks, and valves.

For these component types the applicant identified the following materials, environments, and

AERMS:

copper alloys (zinc < 15 percent) exposed to demineralized untreated water subject to

loss of material

carbon or low alloy steel (yield strength < 100 Ksi) exposed to demineralized untreated

water subject to loss of material

The staff reviewed the information in ALRA Section 2.3.3.B.11, Table 2.3.3.B.11-1,

Section 3.3.2.B.11, and Table 3.3.2.8-11.

The staff's review of the information provided in the ALRA found the aging effects of the

domestic water system component types not addressed by the GALL Report consistent with

industry experience for these combinations of materials and environments. The staff did not

identify any omitted aging effects. Therefore, the staff found that the applicant had identified the

appropriate aging effects for the materials and environments of the domestic water system

components.

Aging Managqement Programs. After evaluating the applicant's identification of aging effects for

each of the components the staff evaluated the AMPs to determine whether they are

appropriate for managing the identified aging effects. The staff also verified that the USAR

supplement describes the programs adequately.

ALRA Table 3.3.2.8-11 identifies the following AMP for managing the aging effects for the

domestic water system components not addressed by the GALL Report:

* One-Time Inspection Program

The staff's detailed review of the AMP is found in SER Section 3.0.3.1.4.

Conclusion: On the basis of its review, as discussed above, the staff concludes that there is

reasonable assurance that the applicant has demonstrated that the aging effects associated

with the domestic water system components will be adequately managed so that the intended

functions will be maintained consistent with the CLB for the period of extended operation, as

required by 10 CFR 54.21(a)(3).

The staff also reviewed the applicable UFSAR supplement program descriptions and concludes

that the UFSAR supplement provides an adequate description of the AMPs credited for

managing aging of these components, as required by 10 CFR 54.21(d).

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3.3B.2.3.12 Auxiliary Systems NMP2 Engine-Driven Fire Pump Fuel Oil System- Summary of

Aging Management Evaluation - ALRA Table 3.3.2.B-12

This auxiliary system is listed here for information and completeness. The AMR results for the

NMP2 engine-driven fire pump fuel oil system are consistent with the GALL Report. The staffs.

evaluation of these results is presented in SER Section 3.3B.2.2.5.

3.3B.2.3.13 Auxiliary Systems NMP2 Fire Detection and Protection System - Summary of

Aging Management Evaluation - ALRA Table 3.3.2.B-13

This auxiliary system is listed here for information and completeness. The AMR results for the

NMP2 fire detection and protection system are consistent with the GALL Report. The staffs

evaluation of these results is presented in SER Section 3.3B.2.2.5.

The staff reviewed original LRA Table 3.3.2.8-13 (only those line items that are not consistent

with GALL or component aging effects for material/environment was not listed in GALL), which

summarizes the results of AMR evaluations for the NMP2 fire detection and protection system

component groups.

In original LRA Section 3.3.2.B.13 and Table 3.3.2.B-13, the applicant identified the materials,

environments, and AERMs. The materials identified include brass, carbon steel or low alloy

steel (yield strength < 100 Ksi), carbon steel or low alloy steel (yield strength > 100 Ksi)

polymers, copper alloy (zinc < 15%), copper alloy (zinc > 15%) and aluminum bronze, gray cast

iron, and wrought austenitic stainless steel.

The applicant identified the environments to which these materials could be exposed as air, air

moisture or wetting temperature < 140 OF, dried air or gas, exhaust, liquid foam concentrate,

liquid foam concentrate/raw water/low flow, raw water low flow, soil above the water table and

soil below the water table as the environments associated with the fire detection and protection

system. The applicant identified aging effects requiring management from cracking, harding

and shrinkage, loss of material, and loss strength associated with the fire water system.

The applicant proposed to manage the fire protection system aging effects by using the Fire

Protection Program, Fire Water System Program, Preventive Maintenance Program, Systems

Walkdown Program, Bolting Integrity Program, One-Time Inspection Program, Selective

Leaching of Materials Program, and Buried Piping and Tank Inspection Program. The staff's

evaluations of these programs are documented in SER Sections 3.0.3.2.13, 3.0.3.2.14,

3.0.3.3.1, 3.0.3.3.2, 3.0.3.3.23, 3.0.3.1.4, 3.0.3.1.5, and 3.0.3.1.6, respectively.

The staff reviewed original LRA Section 3.3.2.B-13 and Table 3.3.2.2-13, to determine whether

the applicant demonstrated that it will adequately manage the effects of aging for the fire

protection system during the period of extended operation, as required by 10 CFR 54.21(a)(3).

The staff conducted its review, described below, in accordance with SRP-LR Section 3.3 and

the GALL Report.

In RAI 2.3.3.B.13-28 dated November 17, 2004, the staff stated that the GALL Report describes

recommendations for aging management of the fire protection water system based on the

combination of component type, material, and environment.

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The original LRA Table 3.3.2.B-13 for the NMP2 fire detection and protection system

summarizes the AMP for each of the combinations mentioned above. When the combinations

do not exactly match the requirements of the GALL Report, the original LRA table includes a

note indicating that the prescribed AMP has been modified for use or that another AMP is being

used.

For the combination of flow elements, gray cast iron, raw water, and low flow, Note Q indicates

that the Selective Leaching Program is being used in addition to the Fire Water System

Program to manage loss of material.

Additionally, Note 11 indicates that flow elements are not specifically identified in GALL Report

Chapter VII for the fire protection system. Therefore, the staff requested that the applicant

describe how the Selective Leaching Program would be used to manage loss of material.

In its response by letter dated December 17, 2004, the applicant stated that for the combination

of flow elements, gray cast iron, raw water, and low flow, the applicable portion of the Selective

Leaching Program is a new activity for inspection for selective leaching of fire protection water

system components. The Selective Leaching Program for NMP is implemented under the

One-Time Inspection Program. The details of the inspections to be performed for particular

components have not been determined. As presented in original LRA Sections A2.1.28 and

B2.1.20, the One-Time Inspection Program is a new AMP for NMP, which are commitments

(NMP1 Commitment 23 and NMP2 Commitment 21) made with the original LRA submittal, as

supplemented by the NMP letter NMP1L 1880 dated October 29, 2004. As such, NMP does not

currently have any program documents or procedures specific to managing selective leaching

of fire protection water system components.

Based on its review, the staff found the applicant's response to RAI 2.3.3.B.13-28 acceptable

because it adequately describes how the Selective Leaching Program would be used to

manage loss of material components in question. Therefore, the staffs concern described in

RAI 2.3.3.B.13-28 is resolved.

In RAI 2.3.3.B.13-29 dated November 17, 2004, the staff stated that the GALL Report describes

recommendations for aging management of the fire protection water system based on the

combination of component type, material, and environment.

The original LRA Table 3.3.2.B-13 for the NMP2 fire detection and protection system

summarizes the AMP for each of the combinations mentioned above. When the combinations

do not exactly match the requirements of the GALL Report, the original LRA table includes a

note indicating that the prescribed AMP has been modified for use or that another AMP is being

used.

For the combination of heat exchangers, carbon or low alloy steel (yield strength < 100 Ksi),

raw water, and low flow, Note 6 indicates that the Fire Water System Program has been

modified to manage loss of material in heat exchangers which are not specifically identified in

GALL Report Chapter VII for the fire protection system. Therefore, the staff requested that the

applicant describe how the Fire Water System Program would be used to manage loss of

material for heat exchangers.

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In its response by letter dated December 17, 2004, the applicant stated that heat exchangers

fabricated from carbon or low alloy steel (yield strength < 100 Ksi) in an environment of raw

water and low flow, are susceptible to loss of material from galvanic, general, pitting, and MIC

mechanisms. A new inspection activity, for which a procedure must be generated, a site

chemistry procedure, and a fire system flow test are credited with managing aging. These

credited activities are discussed below:

The new site activity is identified as an enhancement in "parameters monitored/

inspected" in original LRA Sections A1.1.18 and B2.1.17. The enhancement includes

performing visual inspections to monitor internal corrosion and to detect biofouling. This

new activity will include inspections for loss of material in the subject heat exchangers

and will be implemented prior to the period of extended operation. As such, there are no

existing procedures implementing these inspections at this time. The Fire Water System

Program attribute assessment addresses program implementation at NMP relative to

the requirements of SRP-LR Appendix A.

Site procedure S-CTP-V632, "Sampling and Analysis of Water Systems for Bacteria," is

credited with managing loss of material as a result of microbiological activity. The

procedure provides for sampling and analysis of raw water systems for the presence of

bacteria. Additionally, as presented in original LRA Sections A1.1.18 and B2.1.17, the

Fire Water System Program will be enhanced prior to the period of extended operation

to add specific requirements for periodic sampling of water-based fire protection

systems.

Site procedure N2-FSP-FPW-5Y001, "FPW System Flow Test," is credited with the

possible discovery of corrosion, biofouling, and microbiologically influenced corrosion of

the fire protection water distribution system. The procedure provides for full flow testing

of the system in accordance with the NFPA fire protection handbook. Acceptance

criteria are defined and the site corrective action process is utilized when the criteria are

not met. The procedure verifies that the system is capable of retaining pressure and is

not obstructed or adversely affected by degradation such as corrosion or fouling.

Based on its review, the staff found the applicant's response to RAI 2.3.3.B.13-29 acceptable

because it adequately describes how the Fire Water System Program would be used to

manage loss of material for the heat exchangers in question. Therefore, the staff's concern

described in RAI 2.3.3.B.13-29 is resolved.

In RAI 2.3.3.B.13-30 dated November 17, 2004, the staff stated that the GALL Report describes

recommendations for aging management of the fire protection water system based on the

combination of component type, material, and environment.

Original LRA Table 3.3.1.B-13 for the NMP2 fire detection and protection system summarizes

the AMP for each of the combinations mentioned above. When the combinations do not exactly

match the requirements of the GALL Report, the original LRA table includes a note indicating

that the prescribed AMP has been modified for use or that another aging management program

is being used.

For the combination of manifold, carbon or low alloy steel (yield strength < 100 Ksi), cast iron,

raw water, and low flow, Note 26 indicates that the Fire Water System Program has been

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modified to manage loss of material in manifolds which are not specifically identified in GALL

Report Chapter VII for the fire protection system.

The staff requested the applicant to describe how the Fire Water System Program would be

used to manage loss of material for manifolds.

In its response by letter dated December 17, 2004, the applicant stated that manifolds

fabricated from carbon or low alloy steel (yield strength < 100 Ksi) in an environment of raw

water and low flow, are susceptible to loss of material from galvanic, general, pitting, and

microbiologically influenced corrosion mechanisms. A new inspection activity, for which a

procedure must be generated, a site chemistry procedure, and a fire system flow test are

credited with managing aging. These credited activities are discussed below:

The new site activity is identified as an enhancement in "parameters monitored/

inspected" in original LRA Sections A1.1.18 and B2.1.17. The enhancement includes

performing visual inspections to monitor internal corrosion and to detect biofouling. This

new activity will include inspections for loss of material in the manifolds identified above

and will be implemented prior to the period of extended operation (Commitments No. 20

for NMP 1 and No. 18 for NMP2). As such, there are no existing procedures

implementing these inspections at this time. The Fire Water System Program attribute

assessment addresses program implementation at NMP relative to the requirements of

SRP-LR Appendix A.

" Site procedure S-CTP-V632, "Sampling and Analysis of Water Systems for Bacteria," is

credited with managing loss of material as a result of microbiological activity. The

procedure provides for sampling and analysis of raw water systems for the presence of

bacteria. Additionally, as presented in original LRA Sections A1.1.18 and B2.1.17, the

Fire Water System Program will be enhanced prior to the period of extended operation

to add specific requirements for periodic sampling of water-based fire protection

systems.

" Site procedure N2-FSP-FPW-5Y001, "FPW System Flow Test," is credited with the

possible discovery of corrosion, biofouling, and MIC of the fire protection water

distribution system. The procedure provides for full flow testing of the system in

accordance with the NFPA fire protection handbook. Acceptance criteria are defined

and the site corrective action process is utilized when the criteria are not met. The

procedure verifies that the system is capable of retaining pressure and is not obstructed

or adversely affected by degradation such as corrosion or fouling.

Based on its review, the staff found the applicant's response to RAI 2.3.3.B.13-30 acceptable

because it adequately describes how the Fire Water System Program would be used to

manage loss of material for the manifolds in question. Therefore, the staffs concern described

in RAI 2.3.3.B.13-30 is resolved. The above information is reflected in the ALRA.

In RAI 2.3.3.B.13-31 dated November 17, 2004, the staff stated that the GALL Report describes

recommendations for aging management of the fire protection water system based on the

combination of component type, material, and environment.

The original LRA Table 3.2.3.2.6-13 for the NMP2 fire detection and protection system

summarizes the AMP for each of the combinations mentioned above. When the combinations

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do not exactly match the requirements of the GALL Report, the original LRA table includes a

note indicating that the prescribed AMP has been modified for use or that another aging

management program is being used.

For the combination of orifices, copper alloys (zinc -• 15%), raw water, low flow, Note "7"

indicates that the Fire Water System Program has been modified to manage loss of material in

manifolds which are not specifically identified in GALL Report Chapter VII for the fire protection

system.

Therefore, the staff requested that the applicant describe how the Fire Water System Program

would be used to manage loss of material for manifolds.

In its response by letter dated December 17, 2004, the applicant stated that orifices fabricated

from copper alloys (zinc < 15%), in an environment of raw water and low flow, are susceptible

to loss of material. A new inspection activity, for which a procedure must be generated, a site

chemistry procedure, and a fire system flow test are credited with managing aging. These

credited activities are discussed below:

The new site activity is identified as an enhancement in "parameters monitored/

inspected" in original LRA Sections A1.1.18 and B2.1.17. The enhancement includes

performing visual inspections to monitor internal corrosion and to detect biofouling. This

new activity will include inspections for loss of material in the subject orifices and will be

implemented prior to the period of extended operation. As such, there are no existing

procedures implementing these inspections at this time. The Fire Water System

Program attribute assessment addresses program implementation at NMP relative to

the requirements of SRP-LR Appendix A.

* Site procedure S-CTP-V632, "Sampling and Analysis of Water Systems for Bacteria," is

credited with managing loss of material as a result of microbiological activity. The

procedure provides guidance for sampling and analysis of raw water systems for the

presence of bacteria. Additionally, as presented in original LRA Sections A1.1.18 and

B2.1.17, the Fire Water System Program will be enhanced prior to the period of

extended operation to add specific requirements for periodic sampling of water-based

fire protection systems.

" Site procedure N2-FSP-FPW-5Y001, "FPW System Flow Test," is credited with the

possible discovery of corrosion, biofouling, and MIC of the fire protection water

distribution system. The procedure provides for full flow testing of the system in

accordance with the NFPA fire protection handbook. Acceptance criteria are defined

and the site corrective action process is utilized when the criteria are not met. The

procedure verifies that the system is capable of retaining pressure and is not obstructed

or adversely affected by degradation such as corrosion or fouling.

Based on its review, the staff found the applicant's response to RAI 2.3.3.B.13-31 acceptable

because it adequately describes how the Fire Water System Program would be used to

manage loss of material for the orifices in question. Therefore, the staff's concern described in

RAI 2.3.3.B.13-31 is resolved. The above information is reflected in the ALRA.

In RAI 2.3.3.B.13-32 dated November 17, 2004, the staff stated that the GALL Report describes

recommendations for aging management of the fire protection water system based on the

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combination of component type, material, and environment.

The original LRA Table 3.3.2.B-13 for the NMP2 fire detection and protection system

summarizes the AMP for each of the combinations mentioned above. When the combinations

do not exactly match the requirements of the GALL Report, the original LRA table includes a

note indicating that the prescribed AMP has been modified for use or that another AMP is being

used.

For the combination of orifices, wrought austenitic stainless steel, raw water, low flow, Note H

indicates that the Fire Water System Program has been modified to manage cracking in

addition to loss of material.

Additionally, Note 7 indicates that orifices are not specifically identified in GALL Report

Chapter VII for the fire protection system.

The staff requested the applicant to describe how the Fire Water System Program would be

used to manage cracking and loss of material.

In its response by letter dated December 17, 2004, the applicant stated that the aging effect

requiring management of material cracking resulting from SCC for wrought austenitic stainless

steel components (including the orifices) in low flow, raw water is reassigned to the One-Time

Inspection Program for aging management. As presented in original LRA Sections A1.1.28 and

B2.1.20, the One-Time Inspection Program is a new AMP for NMPNS that is to be implemented

prior to the period of extended operation. This commitment (NMP1 Commitment 23 and NMP2

Commitment 21) was made in the original LRA submittal, as supplemented by NMPNS letter

NMP1L 1880 dated October 29, 2004. As such, there are no existing program procedures

specific to the One-Time Inspection Program. The One-Time Inspection Program attribute

assessment addresses program implementation at NMP relative to the requirements of SRP-LR

Appendix A. The subject orifices are also susceptible to loss of material from galvanic, general,

pitting, and MIC mechanisms. A new inspection activity, for which a procedure must be

generated, a site chemistry procedure, and a fire system flow test are credited with managing

aging. These credited activities are discussed below:

The new site activity is identified as an enhancement in "parameters monitored/

inspected" in original LRA Sections A1.1.18 and B2.1.17. The enhancement includes

performing visual inspections to monitor internal corrosion and to detect biofouling. This

new activity will include inspections for loss of material in the orifices identified above

and will be implemented prior to the period of extended operation. As such, there are no

existing procedures implementing these inspections at this time. The Fire Water System

Program attribute assessment addresses program implementation at NMP relative to

the requirements of SRP-LR Appendix A.

Site procedure S-CTP-V632, "Sampling and Analysis of Water Systems for Bacteria," is

credited with managing loss of material as a result of microbiological activity. The

procedure provides for sampling and analysis of raw water systems for the presence of

bacteria. Additionally, as presented in original LRA Sections A1.1.18 and B2.1.17, the

Fire Water System Program will be enhanced prior to the period of extended operation

to add specific requirements for periodic sampling of water-based fire protection

systems.

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Site procedure N2-FSP-FPW-5Y001, "FPW System Flow Test," is credited with the

possible discovery of corrosion, biofouling, and MIC of the fire protection water

distribution system. The procedure provides for full flow testing of the system in

accordance with the NFPA fire protection handbook. Acceptance criteria are defined

and the site corrective action process is utilized when the criteria are not met. The

procedure verifies that the system is capable of retaining pressure and is not obstructed

or adversely affected by degradation such as corrosion or fouling.

The applicant revised original LRA Table 3.3.2.B-13 (pages 3.3-218 and 3.3-222) to replace

Fire Water System Program with One-Time Inspection Program for the management of

material cracking for wrought austenitic stainless steel components (valves and orifices) in a

raw water, low flow environment.

Based on its review, the staff found the applicant's response to RAI 2.3.3.B.13-32 acceptable

because it adequately describes how the one-time inspection and Fire Water System Programs

would be used to manage cracking and loss of material, respectively, for the components in

question. The applicant also revised the original LRA AMR table for the component types in

question to show the One-Time Inspection Program for the management of cracking.

Therefore, the staff's concern described in RAI 2.3.3.B. 13-32 is resolved. The above

information is reflected in the ALRA.

By supplemental letter dated November 17, 2005, the applicant stated that two changes will be

made to Table 3.3.2.1-13. The first being an external surfaces item for =gray cast iron in soil,

above the water table" environment with the AERM of LOM, the AMP of Buried Piping and

Tanks Inspection Program, the GALL Item of VII.C1.1-b, the Type 1 Table Item of 3.3.1.B-18,

and Note F. This item is added based on the determination that the barrel of the gray cast iron

fire hydrants is partially buried. The staff reviewed this change and found it acceptable. The

second change will be modifying the AMP for carbon steel sprinklers in an internal air

environment from Fire Protection Program to the Fire Water System Program. This change was

made for GALL Report consistency. The applicant further stated that the Fire Protection

Program was inadvertently credited for aging management of the sprinklers instead of the Fire

Water System Program. Based on the above staff review of this change, the staff found it

acceptable.

An addition to the letters mentioned above, the staff also reviewed the applicant's letter, dated

July 14, 2005. This letter detailed changes that were made to the LRA, and are found in the

ALRA. The staff reviewed the changes to Table 3.3.2.8-13 (page 3-321 to 3-336), the staff

found these changes had addressed appropriately programs for management of loss of

material aging effect, and that they are acceptable.

In its letter dated December 1, 2005, the applicant stated that the note for bolting will be

modified from A to B in Table 3.3.2.B-13. This change is due to an exception found in the

Bolting Integrity Program, which is the AMP for bolting. The staff evaluation for this exception is

documented in Section 3.0.3.2.23. This staff reviewed the change in note, and found that it is

acceptable.

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3.3B.2.3.14 Auxiliary Systems NMP2 Floor and Equipment Drains System - Summary of Aging

Management Evaluation -ALRA Table 3.3.2.8-14

The staff reviewed ALRA Table 3.3.2.8-14, which summarizes the results of AMR evaluations

for the floor and equipment drains system component-material-environment-AERM

combinations not addressed in the GALL Report. These combinations use Notes F through J as

revised by the applicant's letter NMPIL 2005 dated December 1, 2005. The staff verified that

the applicant identified all applicable AERMs and credited appropriate AMPs for managing

them. The staff also reviewed the applicable USAR supplements for the AMPs to ensure that

the program descriptions describe them adequately.

Aping Effects. ALRA Table 2.3.3.B.14-1 lists individual system components within the scope of

license renewal and subject to an AMR. The component types that do not rely on the GALL

Report for an AMR include drain tanks, external surfaces, flow elements, heat exchanger,

piping and fittings, pumps, orifices, spray nozzle, stainers, and valves.

For these component types the applicant identified the following materials, environments, and

AERMS:

* wrought austenitic stainless steel exposed to treated water, temperature < 140 OF,

subject to loss of material

" wrought austenitic stainless steel exposed to treated water, temperature > 140 °F, but

< 212 OF, subject to cracking

" gray cast iron exposed to air subject to loss of material

" carbon or low alloy steel (yield strength < 100 Ksi) exposed to raw water subject to loss

of material

" carbon or low alloy steel (yield strength < 100 Ksi) exposed to treated water,

temperature > 140°F, but < 2127F, subject to loss of material

" gray cast iron exposed to air, moisture or wetting, temperature < 140 0F, subject to loss

of material

" carbon or low alloy steel (yield strength < 100 Ksi) exposed to treated water,

temperature < 140 OF, subject to loss .of material

" carbon or low alloy steel (yield strength < 100 Ksi) exposed to air, moisture or wetting,

temperature > 140 OF, subject to loss of material

* carbon or low alloy steel (yield strength < 100 Ksi) exposed to fuel oil subject to loss of

material

" carbon or low alloy steel (yield strength < 100 Ksi) exposed to treated water,

temperature > 140 OF, but < 212 OF, low flow, subject to loss of material

" wrought austenitic stainless steel exposed to air, moisture or wetting, temperature

< 140 OF, subject to loss of material

" wrought austenitic stainless steel exposed to air, moisture or wetting, temperature

> 140 OF, subject to loss of material

aluminum exposed to raw water subject to loss of material

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* cast austenitic stainless steel exposed to treated water, temperature > 140 °F, but

< 212 OF, subject to cracking

* carbon or low alloy steel (yield strength < 100 Ksi) exposed to treated water,

temperature < 140 °F, low flow, subject to loss of material

" carbon or low alloy steel (yield strength < 100 Ksi) exposed to air, moisture or wetting,

temperature < 140 OF, subject to loss of material

* cast austenitic stainless steel exposed to air, moisture or wetting, temperature > 140 OF,

subject to loss of material

" gray cast iron exposed to raw water is subject to loss of material

The staff reviewed the information in ALRA Section 2.3.3.B.14, Table 2.3.3.B.14-1,

Section 3.3.2.B.14, and Table 3.3.2.B-14. During its review the staff determined that additional

information was needed.

The RAls are organized in two groups, general and system-specific. The general RAI that is

applicable to this system is a-RAI 3.3.2-1.

By letter dated November 2, 2005, the staff requested that the applicant provide additional

information on the issue addressed in a-RAI 3.3.2-1. By letter dated November 30, 2005, the

applicant responded to this RAI. The RAI, the applicant's response, and the staff's evaluation of

the response are described in Section 3.3.2.3.0.

There are no other relevant system-specific RAls associated with this system.

On the basis of its review of the information provided in the ALRA and the additional information

included in the applicant's response to the above RAI, the staff found the aging effects of the

floor and equipment drains system component types not addressed by the GALL Report

consistent with industry experience for these combinations of materials and environments. The

staff did not identify any omitted aging effects. Therefore, the staff found that the applicant had

identified the appropriate aging effects for the materials and environments of the floor and

equipment drains system components.

AMing Management Programs. After evaluating the applicant's identification of aging effects for

each of the components the staff evaluated the AMPs to determine whether they are

appropriate for managing the identified aging effects. The staff also verified that the USAR

supplement describes the programs adequately.

ALRA Table 3.3.2.B-14 identifies the following AMPs for managing the aging effects for the

floor and equipment drains system components not addressed by the GALL Report:

• One-Time Inspection Program

• System Walkdown Program

* 10 CFR 50 Appendix J Program

In the applicant's response to General a-RAI 3.3.2-1, as described in SER Section 3.3.2.3.0,

the applicant revised its strategy for managing the aging effects of some components in this

system by replacing the One-Time Inspection Program with the Preventive Maintenance

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Program. The staffs detailed review of the Preventive Maintenance Program is found in SER

Section 3.0.3.3.1. In addition, the applicant credits the Selective Leaching of Material Program

to manage the loss of cast iron pump exposed to mineral water.

The staffs detailed reviews of the One-Time Inspection, System Walkdown Program and

10 CFR Part 50 Appendix J Program are found in SER Sections 3.0.3.1.4, 3.0.3.3.2, and

3.0.3.1.7, respectively.

Conclusion: On the basis of its review, as discussed above, there is reasonable assurance that

the applicant has demonstrated that the aging effects associated with the floor and equipment

drains system components will be adequately managed so that the intended functions will be

maintained consistent with the CLB for the period of extended operation, as required by

10 CFR 54.21(a)(3).

The staff also reviewed the applicable UFSAR supplement program descriptions and concludes

that the UFSAR supplement provides an adequate description of the AMPs credited for

managing aging of these components, as required by 10 CFR 54.21(d).

3.3B.2.3.15 Auxiliary Systems NMP2 Generator Standby Lube Oil System - Summary of Aging

Management Evaluation -ALRA Table 3.3.2.8-15

The staff reviewed ALRA Table 3.3.2.B-15, which summarizes the results of AMR evaluations

for the generator standby lube oil system component-material-environment-AERM combinations

not addressed in the GALL Report. These combinations use Notes F through J. The staff

verified that the applicant had identified all applicable AERMs and had credited appropriate

AMPs for managing them. The staff also reviewed the applicable USAR supplements for the

AMPs to ensure that the program descriptions describe them adequately.

Aging Effects. ALRA Table 2.3.3.B.15-1 lists individual system components within the scope of

license renewal and subject to an AMR. The component types that do not rely on the GALL

Report for an AMR include external surfaces and heat exchangers.

For these component types the applicant identified the following materials, environments, and

AERMS:

* gray cast iron exposed to air subject to loss of material

• wrought austenitic stainless steel exposed to treated water, temperature > 140 *F, but

< 212 *F, subject to cracking

The staff reviewed the information in ALRA Section 2.3.3.8.15, Table 2.3.3.B.15-1,

Section 3.3.2.B.15, and Table 3.3.2.1-15.

The staffs review of the information provided in the ALRA found the aging effects of the

generator standby lube oil system component types not addressed by the GALL Report

consistent with industry experience for these combinations of materials and environments. The

staff did not identify any omitted aging effects. Therefore, the staff found that the applicant had

identified the appropriate aging effects for the materials and environments of the generator

standby lube oil system components.

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Aging Management Programs. After evaluating the applicant's identification of aging effects for

each of the components the staff evaluated the AMPs to determine whether they are

appropriate for managing the identified aging effects. The staff also verified that the USAR

supplement describes the programs adequately.

ALRA Table 3.3.2.B-15 identifies the following AMPs for managing the aging effects for the

generator standby lube oil system components not addressed by the GALL Report:

• System Walkdown Program

• Closed-Cycle Cooling Water System Program

The staffs detailed review of the AMPs is found in SER Sections 3.0.3.3.2 and 3.0.3.2.8,

respectively.

Conclusion: On the basis of its review, as discussed above, there is reasonable assurance that

the applicant has demonstrated that the aging effects associated with the generator standby

lube oil system components will be adequately managed so that the intended functions will be

maintained consistent with the CLB for the period of extended operation, as required by

10 CFR 54.2 1(a)(3).

The staff also reviewed the applicable UFSAR supplement program descriptions and concludes

that the UFSAR supplement provides an adequate description of the AMPs credited for

managing aging of these components, as required by 10 CFR 54.21(d).

3.3B.2.3.16 Auxiliary Systems NMP2 Glycol Heating System - Summary of Aging

Management Evaluation -ALRA Table 3.3.2.B-16

This auxiliary system-is listed here for information and completeness. The applicant removed

the NMP2 glycol heating system has been removed from the scope of license renewal in the

ALRA dated July 14, 2005.

3.3B.2.3.17 Auxiliary Systems NMP2 Hot Water Heating System - Summary of Aging

Management Evaluation - ALRA Table 3.3.2.B-17

This auxiliary system is listed here for information and completeness. The AMR results for the

NMP2 hot water heating system are consistent with the GALL Report. The staffs evaluation of

these results is presented in SER Section 3.38.2.2.5

3.3B.2.3.18 Auxiliary Systems NMP2 Makeup Water System - Summary of Aging

Management Evaluation - ALRA Table 3.3.2.1-18

This auxiliary system is listed here for information and completeness. The AMR results for the

NMP2 makeup water system are consistent with the GALL Report. The staffs evaluation of

these results is presented in SER Section 3.3B.2.2.5

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3.3B.2.3.19 Auxiliary Systems NMP2 Neutron Monitoring System - Summary of Aging

Management Evaluation -ALRA Table 3.3.2.B-19

This auxiliary system is listed here for information and completeness. The AMR results for the

NMP2 neutron monitoring system are consistent with the GALL Report. The staff's evaluation of

these results is presented in SER Section 3.3B.2.2.5.

3.3B.2.3.20 Auxiliary Systems NMP2 Primary Containment Purge System - Summary of Aging

Management Evaluation -ALRA Table 3.3.2.B-20

This auxiliary system is listed here for information and completeness. The AMR results for the

NMP2 primary containment purge system are consistent with the GALL Report. The staff's

evaluation of these results is presented in SER Section 3.3B.2.2.5

3.3B.2.3.21 Auxiliary Systems NMP2 Process Sampling System - Summary of Aging

Management Evaluation -ALRA Table 3.3.2.B-21

This auxiliary system is listed here for information and completeness. The AMR results for the

NMP2 process sampling system are consistent with the GALL Report. The staff's evaluation of

these results is presented in SER Section 3.38.2.2.5.

3.3B.2.3.22 Auxiliary Systems NMP2 Reactor Building Closed Loop Cooling Water System -

Summary of Aging Management Evaluation - ALRA Table 3.3.2.B-22

The staff reviewed ALRA Table 3.3.2.B-22, which summarizes the results of AMR evaluations

for the reactor building closed loop cooling water system

component-material-environment-AERM combinations not addressed in the GALL Report.

These combinations use Notes F through J. The staff verified that the applicant had identified

all applicable AERMs and had credited appropriate AMPs for managing them. The staff also

reviewed the applicable USAR supplements for the AMPs to ensure that the program

descriptions describe them adequately.

Aging Effects. ALRA Table 2.3.3.B.23-1 lists individual system components within the scope of

license renewal and subject to an AMR. The component types that do not rely on the GALL

Report for an AMR include flow elements, heat exchangers, piping and fittings, unit coolers, and

valves.

For these component types the applicant identified the following materials, environments, and

AERMS:

" carbon or low alloy steel (yield strength < 100 Ksi) exposed to demineralized untreated

water subject to loss of material

* carbon or low alloy steel (yield strength < to 100 Ksi) exposed to demineralized

untreated water, low flow, subject to loss of material

" carbon or low alloy steel (yield strength > to 100 Ksi) exposed to air subject to loss of

material

* wrought austenitic stainless steel exposed to demineralized untreated water, low flow,

subject to loss of material

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The staff reviewed the information in ALRA Section 2.3.3.B.23, Table 2.3.3.B.23-1,

Section 3.3.2.B.22, and Table 3.3.2.B-22.

The staffs review of the information provided in the ALRA found the aging effects of the reactor

building closed loop cooling water system component types not addressed by the GALL Report

consistent with industry experience for these combinations of materials and environments. The

staff did not identify any omitted aging effects. Therefore, the staff found that the applicant had

identified the appropriate aging effects for the materials and environments of the reactor

building closed loop cooling water system components.

Aging Management Programs. After evaluating the applicant's identification of aging effects for

each of the components the staff evaluated the AMPs to determine whether they are

appropriate for managing the identified aging effects. The staff also verified that the USAR

supplement describes the programs adequately.

ALRA Table 3.3.2.B-22 identifies the following AMPs for managing the aging effects for the

reactor building closed loop cooling water system components not addressed by the GALL

Report:

• Closed-Cycle Cooling Water System Program

* One-Time Inspection Program

The staffs detailed review of the AMPs is found in SER Sections 3.0.3.2.8 and 3.0.3.1.4,

respectively.

Conclusion: On the basis of its review, as discussed above, the staff concludes that there is

reasonable assurance that the applicant has demonstrated that the aging effects associated

with the reactor building closed loop cooling water system components will be adequately

managed so that the intended functions will be maintained consistent with the CLB for the

period of extended operation, as required by 10 CFR 54.21 (a)(3).

The staff also reviewed the applicable UFSAR supplement program descriptions and concludes

that the UFSAR supplement provides an adequate description of the AMPs credited for

managing aging of these components, as required by 10 CFR 54.21(d).

3.3B.2.3.23 Auxiliary Systems NMP2 Reactor Building HVAC System - Summary of Aging

Management Evaluation -ALRA Table 3.3.2.B-23

The staff reviewed ALRA Table 3.3.2.B-23, which summarizes the results of AMR evaluations

for the reactor building HVAC system component-matedal-environment-AERM combinations

not addressed in the GALL Report. These combinations use Notes F through as revised by the

applicant's letter NMPIL 1996 dated November 17, 2005. The staff verified that the applicant

had identified all applicable AERMs and had credited appropriate AMPs for managing them.

The staff also reviewed the applicable USAR supplements for the AMPs to ensure that the

program descriptions describe them adequately.

Aging Effects. ALRA Table 2.3.3.B.24-1 lists individual system components within the scope of

license renewal and subject to an AMR. The component types that do not rely on the GALL

Report for an AMR include external surfaces, piping and fittings, and unit coolers.

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For these component types the applicant identified the following materials, environments, and

AERMS:

* fiberglass exposed to air subject to cracking and loss of material

" copper alloys (zinc < 15 percent) exposed to air subject to loss of heat transfer

" copper alloys (zinc < 15 percent) exposed to raw water subject to loss of heat transfer

" copper alloys (zinc < 15 percent) exposed to raw water, low flow, subject to loss of heat

transfer

The staff reviewed the information in ALRA Section 2.3.3.B.24, Table 2.3.3.B.24-1,

Section 3.3.2.B.23, and Table 3.3.2.8-23.

The staff's review of the information provided in the ALRA found the aging effects of the reactor

building HVAC system component types not addressed by the GALL Report consistent with

industry experience for these combinations of materials and environments. The staff did not

identify any omitted aging effects. Therefore, the staff found that the applicant had identified the

appropriate aging effects for the materials and environments of the reactor building HVAC

system components.

Aping Management Programs. After evaluating the applicant's identification of aging effects for

each of the components the staff evaluated the AMPs to determine whether they are

appropriate for managing the identified aging effects. The staff also verified that the USAR

supplement describes the programs adequately.

ALRA Table 3.3.2.B-23 identifies the following AMPs for managing the aging effects for the

reactor building HVAC system components not addressed by the GALL Report:

• Preventive Maintenance Program

• Open-Cycle Cooling Water System Program

The staff's detailed review of the AMPs is found in SER Sections 3.0.3.3.1 and 3.0.3.2,

respectively.

Conclusion: On the basis of its review, as discussed above, the staff concludes that there is

reasonable assurance that the applicant has demonstrated that the aging effects associated

with the reactor building HVAC system components will be adequately managed so that the

intended functions will be maintained consistent with the CLB for the period of extended

operation, as required by 10 CFR 54.21 (a)(3).

The staff also reviewed the applicable UFSAR supplement program descriptions and concludes

that the UFSAR supplement provides an adequate description of the AMPs credited for

managing aging of these components, as required by 10 CFR 54.21(d).

3.38.2.3.24 Auxiliary Systems NMP2 Reactor Water Cleanup System - Summary of Aging

Management Evaluation -ALRA Table 3.3.2.8-24

The staff reviewed ALRA Table 3.3.2.B-24, which summarizes the results of AMR evaluations

for the reactor water cleanup system relating to those component-material-environment-AERM

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combinations not addressed in the GALL Report. These combinations use Notes F through J as

revised by the applicant's letter NMPIL 2005 dated December 1, 2005. The staff verified that

the applicant had identified all applicable AERMs and had credited appropriate AMPs for

managing them. The staff also reviewed the applicable USAR supplements for the AMPs to

ensure that the program descriptions describe them adequately.

Aging Effects. ALRA Table 2.3.3.B.25-1 lists individual system components within the scope of

license renewal and subject to an AMR. The component types that do not rely on the GALL

Report for an AMR include bolting, heat exchanger, piping and fittings, and valves.

For these component types the applicant identified the following materials, environments, and

AERMS:

" carbon or low alloy steel (yield strength < 100 Ksi) exposed to treated water or steam,

temperature > 482 °F, subject to cumulative fatigue damage

* carbon or low alloy steel (yield strength < 100 Ksi) exposed to treated water or steam,

temperature > 482 °F, low flow, subject to loss of material

The staff reviewed the information in ALRA Section 2.3.3.B.25, Table 2.3.3.B.25-1,

Section 3.3.2.B.24, and Table 3.3.2.B-24.

On the basis of its review of the information provided in the ALRA and the additional information

included in the applicant's response to the RAI the staff found the aging effects of the reactor

water cleanup system component types not addressed by the GALL Report consistent with

industry experience for these combinations of materials and environments. The staff did not

identify any omitted aging effects. Therefore, the staff found that the applicant had identified the

appropriate aging effects for the materials and environments of the reactor water cleanup

system components.

Aging Management Programs. After evaluating the applicant's identification of aging effects for

each of the components the staff evaluated the AMPs to determine whether they are

appropriate for managing the identified aging effects. The staff also verified that the USAR

supplement describes the programs adequately.

ALRA Table 3.3.2.B-24 identifies TLAA and the following AMPs for managing the aging effects

for the reactor water cleanup system components not addressed by the GALL Report:

* One-Time Inspection Program

° Water Chemistry Control Program

The staffs evaluation of the TLAA is addressed in SER Section 4.3. The staffs detailed review

of the AMPs is found in SER Sections 3.0.3.1.4 and 3.0.3.2.2, respectively.

Conclusion: On the basis of its review, as discussed above, the staff concludes that there is

reasonable assurance that the applicant has demonstrated that the aging effects associated

with the reactor water cleanup system components will be adequately managed so that the

intended functions will be maintained consistent with the CLB for the period of extended

operation, as required by 10 CFR 54.21(a)(3).

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The staff also reviewed the applicable UFSAR supplement program descriptions and concludes

that the UFSAR supplement provides an adequate description of the AMPs credited for

managing aging of these components, as required by 10 CFR 54.21 (d).

3.3B.2.3.25 Auxiliary Systems NMP2 Seal Water System - Summary of Aging Management

Evaluation - ALRA Table 3.3.2.B-25

This auxiliary system is listed here for information and completeness. The NMP2 process

sampling system has been removed from the scope of license renewal by the ALRA dated July

14, 2005.

3.3B.2.3.26 Auxiliary Systems NMP2 Service Water System - Summary of Aging Management

Evaluation - ALRA Table 3.3.2.B-26

This auxiliary system is listed here for information and completeness. The AMR results for the

NMP2 service water system are consistent with the GALL Report. The staff's evaluation of

these results is presented in SER Sections 3.3B.2.2.5 and 3.38.2.1

3.3B.2.3.27 Auxiliary Systems NMP2 Spent Fuel Pool Cooling and Cleanup System -

Summary of Aging Management Evaluation - ALRA Table 3.3.2.B-27

The staff reviewed ALRA Table 3.3.2.3-27, which summarizes the results of AMR evaluations

for the spent fuel pool cooling and cleanup system component-material-environment-AERM

combinations not addressed in the GALL Report. These combinations use Notes F through J as

revised by the applicant's letter NMPIL 1996 dated November 17, 2005. The staff verified that

the applicant had identified all applicable AERMs and had credited appropriate AMPs for

managing them. The staff also reviewed the applicable USAR supplements for the AMPs to

ensure that the program descriptions describe them adequately.

Aging Effects. ALRA Table 2.3.3.B.28-1 lists individual system components within the scope of

license renewal and subject to an AMR. The component types that do not rely on the GALL

Report for an AMR include heat exchangers.

For these component types the applicant identified the following materials, environments, and

AERMS:

wrought austenitic stainless steel exposed to demineralized untreated water, subject to

loss of heat transfer and loss of material

The staff reviewed the information in ALRA Section 2.3.3.B.28, Table 2.3.3.B.28-1,

Section 3.3.2.B.27, and Table 3.3.2.8-27. During its review the staff determined that additional

information was needed.

The RAIs are organized in two groups, general and system-specific. There are no general RAls

associated with this system. System-specific a-RAI 3.3.2.A-5-1 is applicable to this system. The

staff's detailed review of the applicant's response to a-RAI 3.3.2.A-5-1 is found in SER

Section 3.3A.2.3.5.

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On the basis of its review of the information provided in the ALRA and the additional information

included in the applicant's response to the RAI the staff found the aging effects of the spent fuel

pool cooling and cleanup system component types not addressed by the GALL Report

consistent with industry experience for these combinations of materials and environments. The

staff did not identify any omitted aging effects. Therefore, the staff found that the applicant had

identified the appropriate aging effects for the materials and environments of the spent fuel pool

cooling and cleanup system components.

Aging Management Programs. After evaluating the applicant's identification of aging effects for

each of the components the staff evaluated the AMPs to determine whether they are

appropriate for managing the identified aging effects. The staff also verified that the USAR

supplement describes the programs adequately.

ALRA Table 3.3.2.B-27 identifies the following AMP for managing the aging effects for the

spent fuel pool cooling and cleanup system components not addressed by the GALL Report:

0 Closed-Cycle Cooling Water System Program

The staff's detailed review of the AMP is found in SER Section 3.0.3.2.8.

Conclusion: On the basis of its review, as discussed above, the staff concludes that there is

reasonable assurance that the applicant has demonstrated that the aging effects associated

with the spent fuel pool cooling and cleanup system components will be adequately managed

so that the intended functions will be maintained consistent with the CLB for the period of

extended operation, as required by 10 CFR 54.21(a)(3).

The staff also reviewed the applicable UFSAR supplement program descriptions and concludes

that the UFSAR supplement provides an adequate description of the AMPs credited for

managing aging of these components, as required by 10 CFR 54.21(d).

3.3B.2.3.28 Auxiliary Systems NMP2 Standby Diesel Generator Fuel Oil System - Summary of

Aging Management Evaluation - ALRA Table 3.3.2.B-28

The staff reviewed ALRA Table 3.3.2.B-28, which summarizes the results of AMR evaluations

for the standby diesel generator fuel oil system component-material-environment-AERM

combinations not addressed in the GALL Report. These combinations use Notes F through J.

The staff verified that the applicant had identified all applicable AERMs and had credited

appropriate AMPs for managing them. The staff also reviewed the applicable USAR

supplements for the AMPs to ensure that the program descriptions describe them adequately.

Agina Effects. ALRA Table 2.3.3.B.29-1 lists individual system components within the scope of

license renewal and subject to an AMR. The component types that do not rely on the GALL

Report for an AMR include piping and fittings.

For these component types the applicant identified the following materials, environments, and

AERMS:

carbon or low alloy steel (yield strength < 100 Ksi) exposed to air subject to loss of

material

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The staff reviewed the information in ALRA Section 2.3.3.B.29, Table 2.3.3.B.29-1,

Section 3.3.2.B.28, and Table 3.3.2.B-28.

The staffs review of the information provided in the ALRA found the aging effects of the

standby diesel generator fuel oil system component types not addressed by the GALL Report

consistent with industry experience for these combinations of materials and environments. The

staff did not identify any omitted aging effects. Therefore, the staff found that the applicant had

identified the appropriate aging effects for the materials and environments of the standby diesel

generator fuel oil system components.

Aqing Management Programs. After evaluating the applicant's identification of aging effects for

each of the components the staff evaluated the AMPs to determine whether they are

appropriate for managing the identified aging effects. The staff also verified that the USAR

supplement describes the programs adequately.

ALRA Table 3.3.2.8-28 identifies the following AMP for managing the aging effects for the

standby diesel generator fuel oil system components not addressed by the GALL Report:

• One-Time Inspection Program

The staffs detailed review of the AMP is found in SER Section 3.0.3.1.4.

Conclusion: On the basis of its review, as discussed above, the staff concludes that there is

reasonable assurance that the applicant has demonstrated that the aging effects associated

with the standby diesel generator fuel oil system components will be adequately managed so

that the intended functions will be maintained consistent with the CLB for the period of extended

operation, as required by 10 CFR 54.21 (a)(3).

The staff also reviewed the applicable UFSAR supplement program descriptions and concludes

that the UFSAR supplement provides an adequate description of the AMPs credited for

managing aging of these components, as required by 10 CFR 54.21(d).

3.3B.2.3.29 Auxiliary Systems NMP2 Standby Diesel Generator Protection (Generator) System

- Summary of Aging Management Evaluation - ALRA Table 3.3.2.B-29

The staff reviewed ALRA Table 3.3.2.B-29, which summarizes the results of AMR evaluations

for the standby diesel generator protection (generator) system

component-material-environment-AERM combinations not addressed in the GALL Report.

These combinations use Notes F through J as revised by the applicant's letter NMPIL 2005

dated December 1, 2005. The staff verified that the applicant had identified all applicable

AERMs and had credited appropriate AMPs for managing them. The staff also reviewed the

applicable USAR supplements for the AMPs to ensure that the program descriptions describe

them adequately.

Aging Effects. ALRA Table 2.3.3.B.30-1 lists individual system components within the scope of

license renewal and subject to an AMR. The component types that do not rely on the GALL

Report for an AMR include external surfaces, heat exchangers, and valves.

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For these component types the applicant identified the following materials, environments, and

AERMS:

* gray cast iron exposed to air subject to loss of material

" copper alloys (zinc < 15 percent) exposed to raw water subject to loss of heat transfer

and loss of material

" copper alloys (zinc < 15 percent) exposed to treated water, temperature > 140 OF, but

< 212 OF, subject to loss of heat transfer

* wrought austenitic stainless steel exposed to treated water, temperature > 140 OF, but

< 212 OF, subject to cracking

The staff reviewed the information in ALRA Section 2.3.3.B.30, Table 2.3.3.B.30-1,

Section 3.3.2.6.29, and Table 3.3.2.B-29.

The staff's review of the information provided in the ALRA found the aging effects of the

standby diesel generator protection (generator) system component types not addressed by the

GALL Report consistent with industry experience for these combinations of materials and

environments. The staff did not identify any omitted aging effects. Therefore, the staff found

that the applicant had identified the appropriate aging effects for the materials and

environments of the standby diesel generator protection (generator) system components.

Aqina Manaaement Programs. After evaluating the applicant's identification of aging effects for

each of the components, the staff evaluated the AMPs to determine whether they are

appropriate for managing the identified aging effects. The staff also verified that the USAR

supplement describes the programs adequately.

ALRA Table 3.3.2.6-29 identifies the following AMPs for managing the aging effects for the

standby diesel generator protection (generator) system components not addressed by the

GALL Report:

* System Walkdown Program

* Open-Cycle Cooling Water System Program

* Closed-Cycle Cooling Water System Program

The staffs detailed review of the AMPs is found in SER Sections 3.0.3.3.2, 3.0.3.2.7, and

3.0.3.2.8, respectively.

Conclusion: On the basis of its review, as discussed above, the staff concludes that there is

reasonable assurance that the applicant has demonstrated that the aging effects associated

with the standby diesel generator protection (generator) system components will be adequately

managed so that the intended functions will be maintained consistent with the CLB for the

period of extended operation, as required by 10 CFR 54.21 (a)(3).

The staff also reviewed the applicable UFSAR supplement program descriptions and concludes

that the UFSAR supplement provides an adequate description of the AMPs credited for

managing aging of these components, as required by 10 CFR 54.21(d).

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3.3B.2.3.30 Auxiliary Systems NMP2 Standby Liquid Control System - Summary of Aging

Management Evaluation -ALRA Table 3.3.2.8-30

This auxiliary system is listed here for information and completeness. The AMR results for the

NMP2 standby liquid control system are consistent with the GALL Report. The staff's evaluation

of these results is presented in SER Sections 3.3B.2.2.1, 3.3B.2.2.2, and 3.3B.2.2.5

3.3B.2.3.31 Auxiliary Systems NMP2 Yard Structures Ventilation System - Summary of Aging

Management Evaluation - ALRA Table 3.3.2.8-31

The staff reviewed ALRA Table 3.3.2.8-31, which summarizes the results of AMR evaluations

for the yard structures ventilation system component-material-environment-AERM combinations

not addressed in the GALL Report. These combinations use Notes F through J. The staff

verified that the applicant had identified all applicable AERMs and had credited appropriate

AMPs for managing them. The staff also reviewed the applicable USAR supplements for the

AMPs to ensure that the program descriptions describe them adequately.

Aping Effects. ALRA Table 2.3.3.B.32-1 lists individual system components within the scope of

license renewal and subject to an AMR. The component types that do not'rely on the GALL

Report for an AMR include unit coolers.

For this component type the applicant identified the following materials, environments, and

AERMS:

copper alloys (zinc < 15 percent) exposed to air, moisture or wetting, temperature

< 140 OF, subject to loss of heat transfer

copper alloys (zinc < 15 percent) exposed to raw water subject to loss of heat transfer

and loss of material

The staff reviewed the information in ALRA Section 2.3.3.B.32, Table 2.3.3.B.32-1,.

Section 3.3.2.B.31, and Table 3.3.2.8-31.

The staff's review of the information provided in the ALRA found the aging effects of the yard

structures ventilation system component types not addressed by the GALL Report consistent

with industry experience for these combinations of materials and environments. The staff did

not identify any omitted aging effects. Therefore, the staff found that the applicant had identified

the appropriate aging effects for the materials and environments of the yard structures

ventilation system components.

Aging Mana-gement Programs. After evaluating the applicant's identification of aging effects for

the component the staff evaluated the AMPs to determine whether they are appropriate for

managing the identified aging effects. The staff also verified that the USAR supplement

describes the programs adequately.

ALRA Table 3.3.2.B-31 identifies the following AMPs for managing the aging effects for the

yard structures ventilation system components not addressed by the GALL Report:

" Preventive Maintenance Program

* Open-Cycle Cooling Water System Program

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Conclusion: On the basis of its review, as discussed above, the staff concludes that there is

reasonable assurance that the applicant has demonstrated that the aging effects associated

with the yard structures ventilation system components will be adequately managed so that the

intended functions will be maintained consistent with the CLB for the period of extended

operation, as required by 10 CFR 54.21(a)(3).

The staff also reviewed the applicable UFSAR supplement program descriptions and concludes

that the UFSAR supplement provides an adequate description of the AMPs credited for

managing aging of these components, as required by 10 CFR 54.21(d).

3.3B.2.3.32 Auxiliary Systems NMP2 Radiation Monitoring System - Summary of Aging

Management Evaluation - ALRA Table 3.3.2.B-32

This auxiliary system is listed here for information and completeness. The AMR results for the

NMP2 radiation monitoring system are consistent with the GALL Report. The staffs evaluation

of these results is presented in SER Sections 3.3B.2.1 and 3.3B.2.2.5.

3.3B.2.3.33 Auxiliary Systems NMP2 Auxiliary Boiler System - Summary of Aging

Management Evaluation - ALRA Table 3.3.2.B-33

The staff reviewed ALRA Table 3.3.2.B-33, which summarizes the results of AMR evaluations

for the auxiliary boiler system cornponent-material-environment-AERM combinations not

addressed in the GALL Report. These combinations use Notes F through J. The staff verified

that the applicant had identified all applicable AERMs and had credited appropriate AMPs for

managing them. The staff also reviewed the applicable USAR supplements for the AMPs to

ensure that the program descriptions describe them adequately.

Aging Effects. ALRA Table 2.3.3.B.33-1 lists individual system components within the scope of

license renewal and subject to an AMR. The component types that do not rely on the GALL

Report for an AMR include external surfaces, filters, pumps, tanks, and valves.

For these component types the applicant identified the following materials, environments, and

AERMS:

* gray cast iron exposed to air subject to loss of material

" wrought austenitic stainless steel exposed to treated water or steam, temperature

> 212 OF, but < 482 °F, subject to cracking

" gray cast iron exposed to treated water, temperature > 140 OF, but < 212 OF, low flow,

subject to loss of material

* gray cast iron exposed to disodium phosphate solution, sodium sulfite solution, subject

to loss of material

" carbon or low alloy steel (yield strength < 100 Ksi) exposed to disodium phosphate

solution, sodium sulfite solution, subject to loss of material

The staff reviewed the information in ALRA Section 2.3.3.B.33, Table 2.3.3.B.33-1,

Section 3.3.2.B.33, and Table 3.3.2.B-33.

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The staff's review of the information provided in the ALRA found the aging effects of the

auxiliary boiler system component types not addressed by the GALL Report consistent with

industry experience for these combinations of materials and environments. The staff did not

identify any omitted aging effects. Therefore, the staff found that the applicant had identified the

appropriate aging effects for the materials and environments of the auxiliary boiler system

components.

Aging Management Programs. After evaluating the applicant's identification of aging effects for

each of the components the staff evaluated the AMPs to determine whether they are

appropriate for managing the identified aging effects. The staff also verified that the USAR

supplement describes the programs adequately.

ALRA Table 3.3.2.B-33 identifies the following AMPs for managing the aging effects for the

auxiliary boiler system components not addressed by the GALL Report:

" System Walkdown Program

" One-Time Inspection Program

* Water Chemistry Control Program

* Selective Leaching of Materials Program

The staffs detailed review of the AMPs is found in SER Sections 3.0.3.3.2, 3.0.3.1.4, 3.0.3.2.2,

and 3.0.3.1.5.

Conclusion: On the basis of its review, as discussed above, the staff concludes that there is

reasonable assurance that the applicant has demonstrated that the aging effects associated

with the auxiliary boiler system components will be adequately managed so that the intended

functions will be maintained consistent with the CLB for the period of extended operation, as

required by 10 CFR 54.21(a)(3).

The staff also reviewed the applicable UFSAR supplement program descriptions and concludes

that the UFSAR supplement provides an adequate description of the AMPs credited for

managing aging of these components, as required by 10 CFR 54.21(d).

3.3B.2.3.34 Auxiliary Systems NMP2 Circulating Water System - Summary of Aging

Management Evaluation -ALRA Table 3.3.2.8-34

This auxiliary system is listed here for information and completeness. The AMR results for the

NMP2 circulating water system are consistent with the GALL Report. The staffs evaluation of

these results is presented in SER Sections 3.3B.2.1 and 3.3B.2.2.5.

3.3B.2.3.35 Auxiliary Systems NMP2 Makeup Water Treatment System - Summary of Aging

Management Evaluation - ALRA Table 3.3.2.8-35

This auxiliary system is listed here for information and completeness. The AMR results for the

NMP2 makeup water treatment system are consistent with the GALL Report. The staff's

evaluation of these results is presented in SER Sections 3.38.2.2.2 and 3.38.2.2.5

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3.3B.2.3.36 Auxiliary Systems NMP2 Radioactive Liquid Waste Management System -

Summary of Aging Management Evaluation - ALRA Table 3.3.2.B-36

This auxiliary system is listed here for information and completeness. The AMR results for the

NMP2 radioactive liquid waste management system are consistent with the GALL Report. The

staff's evaluation of these results is presented in SER Sections 3.38.2.2.2 and 3.3B.2.2.

3.3B.2.3.37 Auxiliary Systems NMP2 Roof Drainage System - Summary of Aging Management

Evaluation - ALRA Table 3.3.2.B-37

The staff reviewed ALRA Table 3.3.2.B-37, which summarizes the results of AMR evaluations

for the roof drainage system component-material-environment-AERM combinations not

addressed in the GALL Report. These combinations use Notes F through J as revised by the

applicant's letter NMPIL 2005 dated December 1, 2005. The staff verified that the applicant had

identified all applicable AERMs and had credited appropriate AMPs for managing them. The

staff also reviewed the applicable USAR supplements for the AMPs to ensure that the program

descriptions describe them adequately.

Aging Effects. ALRA Table 2.3.3.B.37-1 lists individual system components within the scope of

license renewal and subject to an AMR. The component types that do not rely on the GALL

Report for an AMR include piping and fittings.

For these component types the applicant identified the following materials, environments, and

AERMS:

carbon or low alloy steel (yield strength < 100 Ksi) exposed to air, moisture or wetting,

temperature < 140 0F, subject to loss of material

The staff reviewed the information in ALRA Section 2.3.3.B.37, Table 2.3.3.B.37-1,

Section 3.3.2.B.37, and Table 3.3.2.B-37.

The staff's review of the information provided in the ALRA found the aging effects of the roof

drainage system component types not addressed by the GALL Report consistent with industry

experience for these combinations of materials and environments. The staff did not identify any

omitted aging effects. Therefore, the staff found that the applicant had identified the appropriate

aging effects for the materials and environments of the roof drainage system components.

Aqing Management Programs. After evaluating the applicant's identification of aging effects for

each of the components the staff evaluated the AMPs to determine whether they are

appropriate for managing the identified aging effects. The staff also verified that the USAR

supplement describes the programs adequately.

ALRA Table 3.3.2.8-37 identifies the following AMP for managing the aging effects for the roof

drainage system components not addressed by the GALL Report:

0 One-Time Inspection Program

The staffs detailed review of this AMP is found in SER Sections 3.0.3.1.4.

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Conclusion: On the basis of its review, as discussed above, the staff concludes that there is

reasonable assurance that the applicant has demonstrated that the aging effects associated

with the roof drainage system components will be adequately managed so that the intended

functions will be maintained consistent with the CLB for the period of extended operation, as

required by 10 CFR 54.21(a)(3).

The staff also reviewed the applicable UFSAR supplement program descriptions and concludes

that the UFSAR supplement provides an adequate description of the AMP s credited for

managing aging of these components, as required by 10 CFR 54.21(d).

3.3B.2.3.38 Auxiliary Systems NMP2 Sanitary Drains and Disposal System - Summary of

Aging Management Evaluation - ALRA Table 3.3.2.B-38

The staff reviewed ALRA Table 3.3.2.B-38, which summarizes the results of AMR evaluations

for the sanitary drains and disposal system component-material-environment-AERM

combinations not addressed in the GALL Report. These combinations use Notes F through J as

revised by the applicant's letter NMPIL 1996 dated November 17, 2005. The staff verified that

the applicant had identified all applicable AERMs and had credited appropriate AMPs for

managing them. The staff also reviewed the applicable USAR supplements for the AMPS to

ensure that the program descriptions describe them adequately.

Aging Effects. ALRA Table 2.3.3.B.38-1 lists individual system components within the scope of

license renewal and subject to an AMR. The component types that do not rely on the GALL

Report for an AMR include external surfaces and piping and fittings.

For these component types the applicant identified the following materials, environments, and

AERMS:

* gray cast iron exposed to air subject to loss of material

* copper alloys (zinc -< 15 percent) exposed to demineralized untreated water subject to

loss of material

* gray cast iron exposed to demineralized untreated water subject to loss of material

The staff reviewed the information in ALRA Section 2.3.3.B.38, Table 2.3.3.B.38-1,

Section 3.3.2.1.38, and Table 3.3.2.B-38.

The staffs review of the information provided in the ALRA found the aging effects of the

sanitary drains and disposal system component types not addressed by the GALL Report

consistent with industry experience for these combinations of materials and environments. The

staff did not identify any omitted aging effects. Therefore, the staff found that the applicant had

identified the appropriate aging effects for the materials and environments of the sanitary drains

and disposal system components.

Aping Management Proqrams. After evaluating the applicant's identification of aging effects for

each of the components the staff evaluated the AMPs to determine whether they are

appropriate for managing the identified aging effects. The staff also verified that the USAR

supplement describes the programs adequately.

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ALRA Table 3.3.2.B-38 identifies the following AMPs for managing the aging effects for the

sanitary drains and disposal system components not addressed by the GALL Report:

* System Walkdown Program

* One-Time Inspection Program

* Selective Leaching of Materials Program

The staffs detailed review of the AMPs is found in SER Sections 3.0.3.3.2, 3.0.3.1.4, and

3.0.3.1.5, respectively.

Conclusion: On the basis of its review, as discussed above, the staff concludes that there is

reasonable assurance that the applicant has demonstrated that the aging effects associated

with the sanitary drains and disposal system components will be adequately managed so that

the intended functions will be maintained consistent with the CLB for the period of extended

operation, as required by 10 CFR 54.21(a)(3).

The staff also reviewed the applicable UFSAR supplement program descriptions and concludes

that the UFSAR supplement provides an adequate description of the AMPs credited for

managing aging of these components, as required by 10 CFR 54.21(d).

3.38.2.3.39 Auxiliary Systems NMP2 Service Water Chemical Treatment System - Summary

of Aging ManagementEvaluation - ALRA Table 3.3.2.B-39

The staff reviewed ALRA Table 3.3.2.1-39, which summarizes the results of AMR evaluations

for the service water chemical treatment system component-material-environment-AERM

combinations not addressed in the GALL Report. These combinations use Notes F through J.

The staff verified that the applicant had identified all applicable AERMs and had credited

appropriate AMPs for managing them. The staff also reviewed the applicable USAR

supplements for the AMPs to ensure that the program descriptions describe them adequately.

Aging Effects. ALRA Table 2.3.3.B.39-1 lists individual system components within the scope of

license renewal and subject to an'AMR. The component types that do not rely on the GALL

Report for an AMR include piping and fittings and valves.

For these component types the applicant identified the following materials, environments, and

AERMS:

wrought austenitic stainless steel exposed to service water chemical treatment water

subject to loss of material

The staff reviewed the information in ALRA Section 2.3.3.B.39, Table 2.3.3.B.39-1,

Section 3.3.2.B.39,'and Table 3.3.2.B-39.

The staffs review of the information provided in the ALRA found the aging effects of the service

water chemical treatment system component types not addressed by the GALL Report

consistent with industry experience for these combinations of materials and environments. The

staff did not identify any omitted aging effects. Therefore, the staff found that the applicant had

identified the appropriate aging effects for the materials and environments of the service water

chemical treatment system components.

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Aqinq Management Programs. After evaluating the applicant's identification of aging effects for

each of the components the staff evaluated the AMPs to determine whether they are

appropriate for managing the identified aging effects. The staff also verified that the USAR

supplement describes the programs adequately.

ALRA Table 3.3.2.B-39 identifies the following AMP for managing the aging effects for the

service water chemical treatment system components not addressed by the GALL Report:

One-Time Inspection Program

The staffs detailed review of the AMP is found in SER Section 3.0.3.1.4.

Conclusion: On the basis of its review, as discussed above, the staff concludes that there is

reasonable assurance that the applicant has demonstrated that the aging effects associated

with the service water chemical treatment system components will be adequately managed so

that the intended functions will be maintained consistent with the CLB for the period of extended

operation, as required by 10 CFR 54.21 (a)(3).

The staff also reviewed the applicable UFSAR supplement program descriptions and concludes

that the UFSAR supplement provides an adequate description of the AMPs credited for

managing aging of these components, as required by 10 CFR 54.21(d).

3.3B.2.3.40 Auxiliary Systems NMP2 Turbine Building Closed Loop Cooling Water System -

Summary of Aging Management Evaluation - ALRA Table 3.3.2.B-40

The staff reviewed ALRA Table 3.3.2.B-40, which summarizes the results of AMR evaluations

for the turbine building closed loop cooling water system

component-material-environment-AERM combinations not addressed in the GALL Report.

These combinations use Notes F through J as revised by the applicant's letter NMPIL 1996,

dated November 17, 2005. The staff verified that the applicant had identified all applicable

AERMs and had credited appropriate AMPs for managing them. The staff also reviewed the

applicable USAR supplements for the AMPs to ensure that the program descriptions describe

them adequately.

Aging Effects. ALRA Table 2.3.3.B.40-1 lists individual system components within the scope of

license renewal and subject to an AMR. The component types that do not rely on the GALL

Report for an AMR include heat exchangers, piping and fittings, and valves.

For these component types the applicant identified the following materials, environments, and

AERMS:

carbon or low alloy steel (yield strength < 100 Ksi) exposed to demineralized untreated

water subject to loss of material

The staff reviewed the information in ALRA Section 2.3.3.B.40, Table 2.3.3.B.40-1, .3.2.B.40,

and Table 3.3.2.B-40.

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The staff's review of the information provided in the ALRA found the aging effects of the turbine

building closed loop cooling water system component types not addressed by the GALL Report

consistent with industry experience for these combinations of materials and environments. The

staff did not identify any omitted aging effects. Therefore, the staff found that the applicant had

identified the appropriate aging effects for the materials and environments of the turbine

building closed loop cooling water system components.

Aging Management Programs. After evaluating the applicant's identification of aging effects for

each of the components the staff evaluated the AMPs to determine whether they are

appropriate for managing the identified aging effects. The staff also verified that the USAR

supplement describes the programs adequately.

ALRA Table 3.3.2.8-40 identifies the following AMPs for managing the aging effects for the

turbine building closed loop cooling water system components not addressed by the GALL

Report

* Preventive Maintenance Program

* Water Chemistry Control Program

The staffs detailed review of the AMPs is found in SER Sections 3.0.3.3.1 and 3.0.3.2.2.

Conclusion: On the basis of its review, as discussed above, the staff concludes that there is

reasonable assurance that the applicant has demonstrated that the aging effects associated

with the turbine building closed loop cooling water system components will be adequately

managed so that the intended functions will be maintained consistent with the CLB for the

period of extended operation, as required by 10 CFR 54.21 (a)(3).

The staff also reviewed the applicable UFSAR supplement program descriptions and concludes

that the UFSAR supplement provides an adequate description of the AMPs credited for

managing aging of these components, as required by 10 CFR 54.21(d).

3.3B.3 Conclusion

The staff concludes that there is reasonable assurance that the applicant provided sufficient

information to demonstrate that the effects of aging for the NMP2 auxiliary systems

components that are within the scope of license renewal and subject to an AMR will be

adequately managed so that the intended function(s) will be maintained consistent with the CLB

for the period of extended operation, as required by 10 CFR 54.21 (a)(3).

The staff also reviewed the applicable USAR supplement program summaries and concludes

that they adequately describe the AMPs credited for managing aging of the auxiliary systems,

as required by 10 CFR 54.21 (d).

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3.4 Aping Manaaement of Steam and Power Conversion Systems

3.4A NMPI Aging Management of Steam and Power Conversion Systems

This section of the SER documents the staffs review of the applicant's AMR results for the

steam and power conversion systems components and component groups associated with the

following NMP1 systems:

" condensate and condensate transfer system " feedwater/high pressure coolant injection system

• main generator and auxiliary system " main steam system

• condenser air removal and off-gas system * main turbine and auxiliary system

* moisture separator reheater steam system

3.4A.1 Summary of Technical Information In the Amended Application

In ALRA Section 3.4, the applicant provided AMR results for the steam and power conversion

systems components and component groups. In ALRA Table 3.4.1.A, "NMP1 Summary of

Aging Management Programs for the Steam and Power Conversion Systems Evaluated in

Chapter VIII or NUREG-1801," the applicant provided a summary comparison of its AMRs with

the AMRs evaluated in the GALL Report for the steam and power conversion systems

components and component groups.

The applicant's AMRs incorporated applicable operating experience in the determination of

AERMs. These reviews included evaluation of plant-specific and industry operating experience.

The plant-specific evaluation included reviews of condition reports and discussions with

appropriate site personnel to identify AERMs. The applicant's review of industry operating

experience included a review of the GALL Report and operating experience issues identified

since the issuance of the GALL Report.

3.4A.2 Staff Evaluation

The staff reviewed ALRA Section 3.4 to determine if the applicant provided sufficient

information to demonstrate that the effects of aging for the steam and power conversion

systems components that are within the scope of license renewal and subject to an AMR will be

adequately managed so that the intended functions will be maintained consistent with the CLB

for the period of extended operation, as required by 10 CFR 54.21 (a)(3).

The staff performed an onsite audit of AMRs to confirm the applicant's claim that certain

identified AMRs were consistent with the GALL Report. The staff did not repeat its review of the

matters described in the GALL Report; however, the staff did verify that the material presented

in the ALRA was applicable and that the applicant had identified the appropriate GALL AMRs.

The staff's evaluations of the AMPs are documented in SER Section 3.0.3. Details of the staffs

audit evaluation are documented in the Audit and Review Report and are summarized inSER

Section 3.4A.2.1.

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In the onsite audit, the staff also selected AMRs that were consistent with the GALL Report and

for which further evaluation is recommended. The staff confirmed that the applicant's further

evaluations were consistent with the acceptance criteria in SRP-LR Section 3.4.2.2. The staff's

audit evaluations are documented in the Audit and Review Report and are summarized in SER

Section 3.4A.2.2.

In the onsite audit, the staff also conducted a technical review of the remaining AMRs that were

not consistent with, or not addressed in, the GALL Report. The audit and technical review

included evaluating whether all plausible aging effects were identified and evaluating whether

the aging effects listed were appropriate for the combination of materials and environments

specified. The staff's audit evaluations are documented in the Audit and Review Report and are

summarized in SER Section 3.4A.2.3. The staff's evaluation of its technical review is also

documented in SER Section 3.4A.2.3.

Finally, the staff reviewed the AMP summary descriptions in the UFSAR supplement to ensure

that they provided an adequate description of the programs credited with managing or

monitoring aging for the steam and power conversion systems components.

Table 3.4A-1 below provides a summary of the staff's evaluation of NMP1 components, aging

effects and aging effects mechanisms, and AMPs listed in ALRA Section 3.4, that are

addressed in the GALL Report.

Table 3.4A-1 Staff Evaluation for NMPI Steam and Power Conversion Systems

Components In the GALL Report

Component Group Aging Effectl:.; -'AMP in GALL .AMP. inALRA Staff Evaluation

Mechanism "Report".-

Piping and fittings in Cumulative fatigue TLAA, evaluated in TLAA This TLAA is

main feedwater line, damage accordance with evaluated in Section

steam line and 10 CFR 54.21(c) 4.3, Metal Fatigue

AFW piping (PWR Analysis

only)

(Item Number

3.4.1.A-01)

Piping and fittings, Loss of material Water chemistry Water Chemistry Consistent with

valve bodies and due to general and one-time Control Program GALL, which

bonnets, pump (carbon steel only), inspection (B2.1.2), One-Time recommends further

casings, tanks, pitting, and crevice Inspection Program evaluation (See

tubes, tubesheets, corrosion (B2.1.20) Section 3.4A.2.2-2)

channel head and

shell (except main

steam system)

(Item Number

3.4.1.A-02)

Auxiliary feedwater Loss of material Plant-specific None Not applicable,

(AFW) piping due to general, PWR only

(Item Number pitting, and crevice

3.4.1.A-03) corrosion, MIC, and

biofouling

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Compone6t Group :'Aging Effect/ AMP In GALL-" ,AMP'in ALRA'' .Staff Evaluation,

Mechanismn" Repoirt ________. _____. _ - _______ -__..._

Oil coolers in AFW Loss of material Plant specific Not applicable,

system (lubricating due to general PWR only

oil side possibly (carbon steel only),

contaminated with pitting, and crevice

water corrosion and MIC

(item Number

3.4.1.A-04)

External surface of Loss of material Plant specific Systems Walkdown Consistent with

carbon steel due to general Program (B2.1.33) GALL, which

components corrosion recommends further

(Item Number evaluation (See

3.4.1.A-05) Section 3.4A.2.2.4)

Carbon steel piping Wall thinning due to Flow-accelerated Flow-Accelerated Consistent with

and valve bodies flow-accelerated corrosion Corrosion Program GALL, which

(Item Number corrosion (B2.1.9) recommends no

3.4.1.A-06) further evaluation

(See Section

3.4A.2.1)

Carbon steel piping Loss of material Water chemistry Water Chemistry Consistent with

and valve bodies in due to pitting and Control Program GALL, which

main steam system crevice corrosion (B2.1.2), One-Time recommends no

(Item Number Inspection Program further evaluation

3.4.1.A-07) (B2.1.20) (See Section

3.4A.2.1.1)

Closure bolting in Loss of material Bolting integrity Bolting Integrity Consistent with

high-pressure or due to general Program (B2.1.36) GALL, which

high-temperature corrosion; crack recommends no

systems initiation and growth further evaluation

(Item Number due to cyclic (See Section

3.4.1.A-08) loading and/or SCC 3.4A.2.1)

Heat exchangers Loss of material Open-cycle cooing None Not applicable

and due to general water system (condenser hotwell

coolers/condensers (carbon steel only), evaluated in

serviced by pitting, and crevice 3.4.1.A-02 and all

open-cycle cooling corrosion, MIC, and other heat

water biofouling; buildup exchangers do not

(Item Number of deposit due to have this aging

3.4.1.-A-09) biofouling effect/mechanism

(See Section

3.4A.2.3.1)

Heat exchangers Loss of material Closed-cycle None Not applicable

and due to general cooling water (condenser hotwell

coolers/condensers (carbon steel only), system evaluated in

serviced by pitting, and crevice 3.4.1.A-02 and all

closed-cycle cooling corrosion other heat

water exchangers do not

(Item Number have this aging

3.4.1.A-10) effect/mechanism

(See Section

3.4A.2.3.1)

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.Component Group Aging Effect/. AMP in GALL AMP in ALRA Staff Evaluation'

Mechanism . , Report "_______. ____ ______""_-. ..

External surface of Loss of material Aboveground None Not applicable

aboveground due to general carbon steel tanks (external surfaces

condensate storage (carbon steel only), of carbon steel

tank pitting, and crevice components

(Item Number corrosion evaluated in

3.4.1.A-11) 3.4.1 .A-05)

External surface of Loss of material Buried piping and None Not applicable (See

buried condensate due to general, tanks surveillance Section 3.4A.2.2.5)

storage tank and pitting, and crevice

AFW piping corrosion and MIC or

(Item Number

3.4.1.A-12) Buried piping and Not applicable (See

tanks inspection Section 3.4A.2.2.5)

External surface of Loss of material Boric acid corrosion Not applicable,

carbon steel due to boric acid PWR only

components corrosion

(Item Number

3.4.1.A-13)

The staffs review of the NMP1 component groups followed one of several approaches. One

approach, documented in SER Section 3.4A.2.1, discusses the staff's review of the AMR

results for components in the steam and power conversion systems that the applicant indicated

are consistent with the GALL Report and do not require further evaluation. Another approach,

documented in SER Section 3.4A.2.2, discusses the staffs review of the AMR results for

components in the steam and power conversion systems that the applicant indicated are

consistent with the GALL Report and for which further evaluation is recommended. A third

approach, documented in SER Section 3.4A.2.3, discusses the staff's review of the AMR

results for components in the steam and power conversion systems that the applicant indicated

are not consistent with, or not addressed in, the GALL Report. The staffs review of AMPs that

are credited to manage or monitor aging effects of the steam and power conversion systems

components is documented in SER Section 3.0.3.

3.4A.2. 1 AMR Results That Are Consistent with the GALL Report

Summary of Technical Information in the Amended Application. In ALRA Section 3.4.2.A, the

applicant identified the materials, environments, and AERMs. The applicant identified the

following programs that manage the aging effects related to the steam and power conversion

systems components:

ASME Section Xl Inservice Inspection (Subsections IWB, IWC, IWD) Program

Water Chemistry Control Program

Flow-Accelerated Corrosion Program

Closed-Cycle Cooling Water System Program

One-Time Inspection Program

Selective Leaching of Materials Program

Preventive Maintenance Program

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• Systems Walkdown Program

* Bolting Integrity Program_..-.

Staff Evaluation. In ALRA Tables 3.4.2.A-1 through 3.4.2.A-7, the applicant provided a

summary of AMRs for the steam and power conversion systems components, and identified

which AMRs it considered to be consistent with the GALL Report.

For component groups evaluated in the GALL Report for which the applicant has claimed

consistency with the GALL Report, and for which the GALL Report does not recommend further

evaluation, the staff performed an audit and review to determine whether the plant-specific

components contained in these GALL Report component groups were bounded by the GALL

Report evaluation.

The applicant provided a note for each AMR line item. The notes indicate how the information in

the tables aligns with the information in the GALL Report. The staff audited those AMRs with

Notes A through E, which indicate that the AMR is consistent with the GALL Report.

Note A indicates that the AMR line item is consistent with the GALL Report for component,

material, environment, and aging effect. In addition, the AMP is consistent with the AMP

identified in the GALL Report. The staff audited these line items to verify consistency with the

GALL Report and the validity of the AMR for the site-specific conditions.

Note B indicates that the AMR line item is consistent with the GALL Report for component,

material, environment, and aging effect. In addition, the AMP takes some exceptions to the

AMP identified in the GALL Report. The staff audited these line items to verify consistency with

the GALL Report. The staff verified that the identified exceptions to the GALL AMPs had been

reviewed and accepted by the staff. The staff also determined whether the AMP identified by

the applicant was consistent with the AMP identified in the GALL Report and whether the AMR

was valid for the site-specific conditions.

Note C indicates that the component for the AMR line item, although different from, is

consistent with the GALL Report for material, environment, and aging effect. In addition, the

AMP is consistent with the AMP identified by the GALL Report. This note indicates that the

applicant was unable to find a listing of some system components in the GALL Report.

However, the applicant identified a different component in the GALL Report that had the same

material, environment, aging effect, and AMP as the component that was under review. The

staff audited these line items to verify consistency with the GALL Report. The staff also

determined whether the AMR line item of the different component was applicable to the

component under review and whether the AMR was valid for the site-specific conditions.

Note D indicates that the component for the AMR line item, although different from, is

consistent with the GALL Report for material, environment, and aging effect. In addition, the

AMP takes some exceptions to the AMP identified in the GALL Report. The staff audited these

line items to verify consistency with the GALL Report. The staff verified whether the AMR line

item of the different component was applicable to the component under review. The staff

verified whether the identified exceptions to the GALL AMPs had been reviewed and accepted

by the staff. The staff also determined whether the AMP identified by the applicant was

consistent with the AMP identified in the GALL Report and whether the AMR was valid for the

site-specific conditions.

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Note E indicates that the AMR line item is consistent with the GALL Report for material,

environment, and aging effect, but a different AMP is credited. The staff audited these line

items to verify consistency with the GALL Report. The staff also determined whether the

identified AMP would manage the aging effect consistent with the AMP identified by the GALL

Report and whether the AMR was valid for the site-specific conditions.

The staff conducted an audit and review of the information provided in the ALRA, as

documented in the Audit and Review Report. The staff did not repeat its review of the matters

described in the GALL Report; however, the staff did verify that the material presented in the

ALRA was applicable and that the applicant identified the appropriate GALL Report AMRs. The

staffs evaluation is discussed below.

3.4A.2.1.1 Loss of Material Due to Pitting and Crevice Corrosion

In the discussion section of ALRA Table 3.4.1 .A Item 3.4.1 .A-07 the applicant stated that for

main steam carbon steel piping and valve bodies in a treated water environment the aging

effect and aging effect mechanism of loss of material due to pitting and crevice corrosion will be

managed by the Water Chemistry Control Program. For small-bore piping and valves in a

treated water environment an additional program, the One-Time Inspection Program,iwill be

used.

As documented in the Audit and Review Report, the staff questioned the applicant why the

small-bore piping and its One-Time Inspection Program were not included in the AMP

discussion for ALRA Table 3.4.2.A-4. The applicant stated that the NMP1 main steam system

has small-bore carbon steel drain line piping, fitting, and valves. These components were not

reflected accurately in ALRA Table 3.4.2.A-4. In its letter dated December 1, 2005, the

applicant stated that this deficiency was corrected by revising ALRA Table 3.4.2.A-4 to include

the small-bore carbon steel piping, fittings, and valves.

The staff reviewed the applicant's response and found it consistent with the GALL Report and,

therefore, acceptable.

The staff's review found that the applicant appropriately addressed the aging effect and aging

effect mechanism, as recommended by the GALL Report.

3.4A.2.1.2 Loss of Material due to General Corrosion; Crack Initiation and Growth due to Cyclic

Loading and/or SCC

In reviewing ALRA Tables 3.4.2.A-1 through 3.4.2.A-7 the staff noted that the applicant did not

appear to list the AMR results for the extraction steam system. The GALL Report lists the

extraction steam system components exposed to an environment of steam with aging effects

and aging effects mechanisms of wall thinning (due to FAC) and loss of material (due to

general, pitting, and crevice corrosion). For managing this component, material, environment,

and aging effect and aging effect mechanism combination the GALL Report AMPs listed are

GALL AMP XI.M 17, "Flow-Accelerated Corrosion," and GALL AMP XI.M2, "Water Chemistry,"

in some cases augmented by GALL AMP XI.M32, "One-Time Inspection." As documented in

the Audit and Review Report, the staff asked the applicant to explain this difference. The

applicant responded that the AMR results for the NMP1 extraction steam system are included

as part of the feedwater system; however, the applicant acknowledged that in ALRA

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Table 3.4.2.A-2 for the feedwater system it did not identify specifically which piping, fittings, and

valves were applicable to the extraction steam system by references to items in GALL'Report

Chapter VIII, Table C.

In its supplemental letter dated December 1, 2005, the applicant stated that to correct this

difference ALRA Table 3.4.2.A-2 had been revised to identify specifically the components for

the extraction steam system.

The staff reviewed the applicant's response and found it consistent with the GALL Report and,

therefore, acceptable.

The staff's review found that the applicant appropriately addressed the aging effect and aging

effect mechanism as recommended by the GALL Report.

3.4A.2.1.3 Loss of Material Due to General (Carbon Steel Only), Pitting, and Crevice

Corrosion, MIC, and Biofouling, Buildup of Deposit Due to Biofouling for Open-Cycle Cooling

System and Loss of Material Due to General (Carbon Steel Only), Pitting, and Crevice

Corrosion for Closed-Cycle Cooling System.

In RAI 3.4.1.A-1 dated December 23, 2005, the staff stated that in NMP ALRA Table 3.4.1 .A

Items 3.4.1.A-09 and 3.4.1.A-10 the applicant stated that these items are not applicable

because, "All other heat exchangers are of a different material (copper alloys or stainless steel)

and do not have this aging effect and aging effect mechanism." However, both copper alloy and

stainless steel are subject to the aging effect of pitting and crevice corrosion. Therefore, the

staff requested that the applicant clarify why both items were not applicable for NMP1.

In its response by letter dated January 11, 2006, the applicant stated that none of the in-scope

heat exchangers in the NMP1 steam and power conversion systems are cooled by open or

closed-cycle cooling water systems. The applicant stated that the "Discussion" column entries

for these two Table 3.4.1 .A items would be revised to indicate that "these components are not

subject to an AMR in the NMP1 Steam and Power Conversion Systems."

The staff s review found the applicant's response to RAI 3.4.2.A-1 acceptable because for

these two items there are no Table 2 entries. Therefore, the staffs concern described in

RAI 3.4.1 .A-1 is resolved.

Conclusion. The staff evaluated the applicant's claim of consistency with the GALL Report. The

staff also reviewed information pertaining to the applicant's consideration of recent operating

experience and proposals for managing associated aging effects. On the basis of its review, the

staff concludes that there is reasonable assurance that the AMR results, which the applicant

claimed to be consistent with the GALL Report, are consistent with the AMRs in the GALL

Report. Therefore, the staff concludes that the applicant has demonstrated that the effects of

aging for these components will be adequately managed so that their intended function(s) will

be maintained consistent with the CLB for the period of extended operation, as required by

10 CFR 54.2 1(a)(3).

3-407
3.4A.2.2 AMR Results That Are Consistent with the GALL Report, for Which Further

Evaluation is Recommended

Summary of Technical Information in the Amended Application. In Section 3.4.2.C of its

supplemental letter dated August 19, 2005, the applicant provided further evaluation of aging

management as recommended by the GALL Report for the steam and power conversion

systems components. The applicant provided information concerning how it will manage the

following aging effects:

* cumulative fatigue damage

" loss of material due to general, pitting, and crevice corrosion

• loss of material due to general, pitting, and crevice corrosion, MIC, and biofouling

" general corrosion

• loss of material due to general, pitting, crevice, and MIC

Staff Evaluation. For component groups evaluated in the GALL Report for which the applicant

has claimed consistency with the GALL Report, and for which the GALL Report recommends

further evaluation, the staff audited and reviewed the applicant's evaluation to determine

whether it had adequately addressed the issues that were further evaluated. In addition, the

staff reviewed the applicant's further evaluations against the criteria contained in SRP-LR

Section 3.4.2.2. Details of the staffs audit are documented in the staffs Audit and Review

Report. The staff's evaluation of the aging effects is discussed in the following sections.

3.4A.2.2.1 Cumulative Fatigue Damage

In Section 3.4.2.C.1 of its supplemental letter dated August 19, 2005, the applicant stated that

fatigue is a TLAA, as defined in 10 CFR 54.3. Applicants must evaluate TLAAs in accordance

with 10 CFR 54.21 (c)(1). SER Section 4.3 documents the staff's review of the applicant's

evaluation of this TLAA.

3.4A.2.2.2 Loss of Material Due to General, Pitting, and Crevice Corrosion

The staff reviewed Section 3.4.2.C.2 of the applicant's supplemental letter dated August 19,

2005 against the criteria in SRP-LR Section 3.4.2.2.2.

In Section 3:4.2.C.2 of its supplemental letter dated August 19, 2005, the applicant addressed

loss of material due to general, pitting, and crevice corrosion for various carbon steel

components.

SRP-LR Section 3.4.2.2.2 states that the management of loss of material due to general,

pitting, and crevice corrosion should be evaluated further for carbon steel piping and fittings,

valve bodies and bonnets, pump casings, pump suction and discharge lines, tanks, tubesheets,

channel heads, and shells except for main steam system components and for loss of material

due to pitting and crevice corrosion for stainless steel tanks and heat exchanger/cooler tubes.

The Water Chemistry Control Program relies on monitoring and control of water chemistry

based on the guidelines in BWRVIP-29 (EPRI TR-103515), "BWR Water Chemistry Guidelines

- Normal and Hydrogen Water Chemistry," to manage the effects of loss of material due to

3-408
general, pitting, or crevice corrosion. However, corrosion may occur in stagnant flow conditions.

Therefore, the effectiveness of the applicant's Water Chemistry Control Program should be

verified to ensure no corrosion. The GALL Report recommends further evaluation of programs

to manage loss of material due to general, pitting, and crevice corrosion to verify the

effectiveness of the applicant's Water Chemistry Control Program. A one-time inspection of

select components and susceptible locations is an acceptable method to ensure that corrosion

does not occur and that the component's intended function is maintained during the period of

extended operation.

In Section 3.4.2.C.2 of its supplemental letter dated August 19, 2005, the applicant also stated

that for NMP1 this aging effect and aging effect mechanism are managed by the combination of

the Water Chemistry Control Program and One-Time Inspection Program for applicable

systems and components.

The staff reviewed the applicant's Water Chemistry Control and One-Time Inspection Programs

and its evaluations are documented in SER Sections 3.0.3.2.2 and 3.0.3.1.4, respectively.

The AMPs recommended by the GALL Report are GALL AMP XI.M2, "Water Chemistry" and

GALL AMP XI.M32, "One-Time Inspection," for management of this aging effect and aging

effect mechanism. The applicant's Water Chemistry Control Program mitigates the aging

effects and aging effects mechanisms on component surfaces exposed to water as the process

fluid; chemistry programs are used to control water chemistry for impurities (e.g., chloride and

sulfate) that accelerate corrosion and that cause loss of material due to general, pitting, and

crevice corrosion. This program relies on monitoring and control of water chemistry to keep

peak levels of various contaminants below system-specific limits. The applicants One-Time

Inspection Program is a new AMP; its scope includes verification of the effectiveness of the

applicant's Water Chemistry Control Program. Implementation of the applicant's One-Time

Inspection Program in conjunction with its Water Chemistry Control Program to manage the

aging effect and aging effect mechanism provides added assurance that the aging effect and

aging effect mechanism does not occur at locations of stagnant or low flow or that the aging

effect and aging effect mechanism progresses very slowly and the component's intended

function is maintained during the period of extended operation. The staff concludes that with

these two programs the applicant appropriately evaluated AMR results of management of the

loss of material due to general, pitting, and crevice corrosion for steam and power conversion

systems components as recommended in the GALL Report.

Based on the programs identified above, the staff concludes that there is reasonable assurance

that the applicant has met the criteria of SRP-LR Section 3.4.2.2.2. For those line items that

apply to Section 3.4.2.C.2 of the applicant's supplemental letter dated August 19, 2005, the

staff determined that the information in the application is consistent with the GALL Report and

the applicant had demonstrated that the effects of aging will be adequately managed so that the

intended function(s) will be maintained consistent with the CLB during the period of extended

operation, as required by 10 CFR 54.21 (a)(3).

3.4A.2.2.3 Loss of Material Due to General, Pitting, and Crevice Corrosion, Microbiologically

Influenced Corrosion, and Biofouling

The staff reviewed Section 3.4.2.C.3 of the applicant's supplemental letter dated August 19,

2005, against the criteria in SRP-LR Section 3.4.2.2.3.

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In Section 3.4.2.C.3 of its supplemental letter August 19, 2005, the applicant stated that this

aging effect applies to PWRs only.

Because NMP is a BWR the staff found this aging effect and aging effect mechanism not

applicable to NMP.

3.4A.2.2.4 General Corrosion

The staff reviewed Section 3.4.2.C.4 of the applicant's supplemental letter dated August 19,

2005 against the'criteria in SRP-LR Section 3.4.2.2.4.

In Section 3.4.2.C.4 of its supplemental letter August 19, 2005, the applicant addressed loss of

material due to general corrosion on the external surfaces of all carbon steel structures and

components including closure bolting exposed to operating temperatures < 212 0 F.

SRP-LR Section 3.4.2.2.4 states that loss of material due to general corrosion could occur on

the external surfaces of all carbon steel structures and components including closure boltings

exposed to operating temperature less that 212 OF. The GALL Report recommends further

evaluation to ensure that this aging effect and aging effect mechanism is adequately managed.

In Section 3.4.2.C.2 of its supplemental letter August 19, 2005, the applicant also stated that for

NMP1 this aging effect and aging effect mechanism is managed by the Systems Walkdown

Program. The staff reviewed the applicant's Systems Walkdown Program and its evaluation is

documented in SER Section 3.0.3.3.2.

The staff found this program acceptable for managing loss of material due to general corrosion

as visual inspection of external surfaces is performed during various systems walkdown. In

addition the NMP plant-specific operating experience also indicated that this program is

effective in identifying aging effects and aging effects mechanisms that have been observed in

the applicant's plant. Therefore, the staff concludes that there is reasonable assurance that the

applicant appropriately evaluated AMR results of management of the loss of material due to

general corrosion for steam and power conversion systems components as recommended in

the GALL Report.

Based on the programs identified above, the staff concludes that there is reasonable assurance

that the applicant has met the criteria of SRP-LR Section 3.4.2.2.4. For those line items that

apply to Section 3.4.2.C.4 of the applicant's supplemental letter dated August 19, 2005, the

staff determined that the information in the application is consistent with the GALL Report and

the applicant had demonstrated that the effects of aging will be adequately managed so that the

intended function(s) will be maintained consistent with the CLB during the period of extended

operation, as required by 10 CFR 54.21(a)(3).

3.4A.2.2.5 Loss of Material Due to General, Pitting, Crevice, and Microbiologically Influenced

Corrosion

The staff reviewed Section 3.4.2.C.5 of the applicant's supplemental letter dated August 19,

2005, against the criteria in SRP-LR Section 3.4.2.2.5.

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The applicant stated in Section 3.4.2.C.5 of its supplemental letter August 19, 2005, that the

aging effect and aging effect mechanism of loss of material due to general, pitting, crevice, and

MIC is not applicable to NMP1. This discussion applies to PWR systems only and is therefore

not applicable to NMP1. The staff determined that for loss of material due to general, pitting,

crevice, and MIC this aging effect and aging effect mechanism is not applicable to NMP1

because it applies to PWR systems only.

Because NMP has no components from this group the staff determined that this aging effect

and aging effect mechanism is not applicable.

3.4A.2.2.6 Quality Assurance for Aging Management of Nonsafety-Related Components

SER Section 3.0.4 provides the staffs evaluation of the applicant's Quality Assurance Program.

Conclusion. On the basis of its review for component groups evaluated in the GALL Report for

which the applicant claimed consistency with the GALL Report and for which the GALL Report

recommends further evaluation the staff determined that the applicant adequately addressed

the issues further evaluated. The staff found that the applicant had demonstrated that the

effects of aging will be adequately managed so that the intended functions will be maintained

consistent with the CLB for the period of extended operation as required by

10 CFR 54.2 1(a)(3).

3.4A.2.3 AMR Results That Are Not Consistent with or Not Addressed in the GALL

Report

Summary of Technical Information in the Amended Application. In ALRA Tables 3.4.2.A-1

through 3.4.2.A-7, the staff reviewed additional details of the results of the AMRs for material,

environment, AERM, and AMP combinations that are not consistent with the GALL Report, or

that are not addressed in the GALL Report.

In ALRA Tables 3.4.2.A-1 through 3.4.2.A-7, the applicant indicated, via Notes F through J, that

the combination of component type,-material, environment, and AERM does not correspond to

a line item in the GALL Report, and provided information concerning how the aging effect will

be managed. Specifically, Note F indicates that the material for the AMR line item component is

not evaluated in the GALL Report. Note G indicates that the environment for the AMR line item

component and material is not evaluated in the GALL Report. Note H indicates that the aging

effect for the AMR line item component, material, and environment combination is not evaluated

in the GALL Report. Note I indicates that the aging effect identified in the GALL Report for the

line item component, material, and environment combination is not applicable. Note J indicates

that neither the component nor the material and environment combination for the line item is

evaluated in the GALL Report.

Staff Evaluation. For component type, material, and environment combinations that are not

evaluated in the GALL Report, the staff reviewed the applicant's evaluation to determine

whether the applicant had demonstrated that the effects of aging will be adequately managed

so that the intended function(s) will be maintained consistent with the CLB during the period of

extended operation. The staffs evaluation is discussed in the following sections.

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3.4A.2.3.1 Steam and Power Conversion System NMP1 Condensate and Condensate Transfer

System - Summary of Aging Management Evaluation - ALRA Table 3.4.2.A-1

The staff initially reviewed the following ALRA Table 3.4.2.A-1 items in the original LRA for the

NMP1 condensate and condensate transfer system.

Loss of material for gray cast iron external surfaces in an air environment managed by

the Systems Walkdown Program.

* Cracking and loss of strength of polymeric external surfaces managed by the Systems

Walkdown Program.

" Cracking and loss of strength of polymeric piping and fittings in a treated water,

temperature < 140°F, environment managed by the Preventive Maintenance Program.

The applicant stated that neither the component nor the material-environment

combination is evaluated in the GALL Report (Note J).

" Cracking of aluminum alloys (containing copper or zinc as the primary alloying

elements) piping and fittings in a treated water, < 140 OF environment, managed by

One-Time Inspection and Water Chemistry Control Programs. The applicant stated that

this material is not in the GALL Report for this component (Note F).

" Loss of material of gray cast iron pumps in a treated water, temperature < 140 OF,

environment managed by One-Time Inspection, Selective Leaching of Materials, and

Water Chemistry Control Programs. The applicant stated that this aging effect is not in

the GALL Report for this component-material-environment combination (Note H).

" Cracking of aluminum alloy (containing copper or zinc as the primary alloying elements)

valves in a treated water, temperature < 140 °F, environment managed by One-Time

Inspection and Water Chemistry Control Programs. The applicant stated that this

material is not in the GALL Report for this component. (Note F)

" Loss of material of gray cast iron valves in a treated water, temperature < 140 OF,

environment managed by One-Time Inspection, Selective Leaching of Materials, and

Water Chemistry Control Programs. The applicant stated that this material is not in the

GALL Report for this component (Note F).

" Cracking of aluminum alloys (containing copper or zinc as the primary alloying

elements) valves in a treated water < 140 OF, low flow environment managed by

One-Time Inspection and Water Chemistry Control Programs. The applicant stated that

this material is not in the GALL Report for this component (Note F).

The staff evaluation of the cracking and loss of strength of polymeric piping and fittings in a

treated water, temperature < 140 °F, environment managed by the Preventive Maintenance

Program is provided in RAI 3.4-1.

In RAI 3.4-1 dated November 17, 2004, the staff requested the applicant to identify (a) the

specific polymeric materials for these components, (b) the basis for concluding that no other

aging effects occur in this environment, (c) specific tests and inspection methods for these

components including the frequency of inspections, and (d) acceptance criteria and their bases

for determining loss of strength of the polymers.

3-412
In its response by letter dated December 21, 2004, the applicant stated that:

There are three components in the NMPI Condensate System that are made of

an elastomer material and subject to a treated water (temperature <140'F)

environment. These components are expansion joints (EXJBJ-49-08,

EXJBJ-49-09 and EXJBJ-49-10) located at the suction of the Condensate

Pumps.

a. The expansion joints are made of rubber (Chlorobutyl elastomer with

polyester fabric and metal reinforcement.)

b. Rubber in a treated water (temperature <140°F) environment is very

resistant to wear and hardening, but is susceptible to cracking and loss of

strength. Treated water can cause elastomer degradation, and hardening

can occur when the water temperature increases above 130 0F. This

conclusion is based upon industry reports EPRI TR-1 14882, "Non-Class

1 Mechanical Implementation Guideline and Mechanical Tools," Revision

3, and EPRI TR-1 14881, "Aging Effects for Structures and Structural

Components (Structural Tools)," Revision 1.

c. The expansion joints are currently visually inspected periodically and

replaced on a five-year frequency.

d. The Preventive Maintenance Program does not include specific

acceptance criteria for the loss of strength parameter since the expansion

joints are replaced on a five-year frequency. The replacement frequency,

however, was determined by considering the operating conditions and

environment. These same factors also contribute to loss of strength.

Therefore, the current replacement frequency ensures that the expansion

joints are replaced prior to their loss of intended function.

The staff's review found the applicant's response to RAI 3.4-1 acceptable because the applicant

provided appropriate tests and inspection methods for these components including the

frequency of inspections and acceptance criteria and their bases for determining loss of

strength of the polymers. Therefore, the staff's concern described in RAI 3.4-1 is resolved. This

information is reflected in the ALRA..

The applicant stated that neither the component nor the material-environment combination is

evaluated in the GALL Report (Note J).The staff concurred with this statement.

The staff found the AMPs for the cracking of aluminum alloy (containing copper or zinc as the

primary alloying elements) valves in a treated water, < 140 OF environment, managed by

One-Time Inspection and Water Chemistry Control Programs in this environment acceptable.

As discussed in RAI 3.4.2B-2, the Water Chemistry Control Program controls the chemistry to

maintain low concentration of halides so cracking of aluminum alloys (containing copper or zinc

as the primary alloying elements) piping and fittings in a treated water < 140 °F environment

would be unlikely. Aluminum in mild environments forms a protective passive layer that protects

the base metal from further corrosion.

3-413
In RAI 3.4-4 dated November 17, 2004, the staff requested that the applicant discuss both the

basis for not including selective leaching as an aging effect and the operating history of these

valves.

In its response by letter dated December 21, 2004, the applicant stated:

The basis for not including the aging effect of "selective leaching" for the material

"Aluminum alloys containing copper or zinc as primary alloying elements" in an

environment of treated water (temperature < 140F) is the zinc content of the

valves involved. These particular valves have a zinc content of less than 15%. As

such, any copper-zinc alloy material with < 15% zinc is not susceptible to

selective leaching. Since these valves are an aluminum alloy, however, they still

would not be susceptible to selective leaching even if the zinc content was

> 15%.

Industry operating experience and the plant operating experience database were

reviewed for instances where components of this aluminum alloy might have

experienced failures due to corrosion. No such applicable failures were found in

the industry information reviewed or in the plant database. A keyword search of

the CAP database was also performed. Again, no failures due to corrosion of

components fabricated of this aluminum alloy were found.

The staffs review found the applicant's response to RAI 3.4-4 acceptable because the applicant

provided a justification for not considering selective leaching as an aging mechanism for

aluminum alloys containing copper or zinc as primary alloying elements in an environment of

treated water (temperature < 140 OF). Therefore, the staffs concern described in RAI 3.4-4 is

resolved. This information is reflected in the ALRA.

The One-Time Inspection Program activities will utilize visual, volumetric, and other inspection

techniques consistent with industry practice to verify that aging effect does not occur or

progresses at such a slow rate that the intended function of the component would not be

affected adversely. The staffs evaluations of One-Time Inspection and Water Chemistry

Control Programs are in SER Sections 3.0.3.1.4 and 3.0.3.2.2, respectively.

The applicant stated that this material is not in the GALL Report for this component (Note F).

The staff concurred with this statement.

The staffs evaluation of loss of material of gray cast iron pumps in a treated water, temperature

> 140 OF, environment managed by One-Time Inspection, Selective Leaching of Materials, and

Water Chemistry Control Programs is in RAI 3.4-2

In RAI 3.4-2 dated November 17, 2004, the staff requested the applicant to discuss:

" visual, VT, or other inspection methods, frequency of inspections, acceptance criteria

and their bases

* bases for sampling of the pumps to detect selective leaching

3-414
In its response by letter dated December 21, 2005, the applicant stated:

a. For the gray cast iron pumps with an internal environment of treated

water (temperature <140 OF) (i.e., the two Condensate Transfer pumps),

the aging effect requiring management is loss of material. The aging

mechanisms to be managed by the One-Time Inspection Program and

the Water Chemistry Control Program include crevice corrosion, general

corrosion, and pitting corrosion. The One-Time Inspection Program is a

new license renewal (LR) AMP commitment for NMP that is to be

implemented prior to the period of extended operation. This commitment

was made in the original LRA submittal, as supplemented by NMPNS

letter NMP1 L 1880 dated October 29, 2004. As such, program

documents or procedures specific to managing the aging mechanisms

(i.e. crevice corrosion, general corrosion, and pitting corrosion) that

specify inspection methods and acceptance criteria for the two

Condensate Transfer pumps do not currently exist. The frequency of any

future inspections for the aging mechanisms of crevice corrosion, general

corrosion, and pitting corrosion will be based on the findings of the

One-Time Inspection Program. However, as stated in [the original] LRA

Appendix B2.1.20, the One-Time Inspection Program will be implemented

consistent with NUREG-1801, Section XI.M32.

b. As presented in [the original] LRA Sections A1.1.33 and B2.1.21, the

implementation of the Selective Leaching of Materials Program is

discussed in the program description for the One-Time Inspection

Program (see [the original] LRA Sections A1.1.28 and B2.1.20). As

stated above, the One-Time Inspection Program is a new LR AMP

commitment for NMP that is to be implemented prior to the period of

extended operation. As such, program documents or procedures specific

to managing the aging mechanism of selective leaching for the two

Condensate Transfer pumps do not currently exist. However, as stated in

[the original] LRA Section B2.1.21, the Selective Leaching Program will

be implemented consistent with NUREG-1801, Section XI.M33.

c. A determination of whether hardness tests are necessary will be made at

the time of the One-Time Inspection Program implementation. This is

consistent with [the original] LRA Section B2.1.20, which states:

"Inspection techniques may include a one-time visual inspection and

hardness measurement."

Hardness testing will be considered as a possible inspection technique if visual

examination techniques alone cannot determine if selective leaching severe

enough to affect the component intended function is occurring. The use of field

hardness testing will also be contingent on the accessibility of the affected

component surfaces to perform the test. Hardness testing on components

susceptible to selective leaching may be appropriate if the component

configuration and geometry allows. Tubing and other components such as valves

with complex internal geometry do not provide adequate physical access to

internal surfaces requiring examination to allow accurate measurements to be

made.

3-415
The staffs review found the applicant's response to RAI 3.4-2 acceptable because the

applicant's tests and inspection methods are consistent with industry practice and the GALL

Report guidelines. Therefore, the staff's concern described in RAI 3.4-2 is resolved. This

information is reflected in the ALRA.

The applicant stated in its ALRA that this aging effect is not in the GALL Report for this

component-material-environment combination (Note H). The staff concurred with this

statement.

The staff found the aging management of cracking of aluminum alloy (containing copper or zinc

as the primary alloying elements) valves in a treated water, temperature < 140 °F, environment

managed by One-Time Inspection and Water Chemistry Control Programs in this environment

acceptable. As discussed in RAI 3.4.213-2, the Water Chemistry Control Program controls the

chemistry to maintain low concentration of halides so cracking of aluminum alloys (containing

copper or zinc as the primary alloying elements) piping and fittings in a treated water < 140 *F

environment would be unlikely. Aluminum in mild environments forms a protective passive layer

that protects the base metal from further corrosion. The One-Time Inspection Program utilizes

visual, volumetric, and other inspection techniques consistent with industry practice to verify

that aging effect does not occur or progresses at such a slow rate that the intended function of

the component would not be affected adversely. The staffs evaluations of the One-Time

Inspection and Water Chemistry Control Programs are in SER Sections 3.0.3.1.4 and 3.0.3.2.2,

respectively. (This evaluation is also applicable for valves of the same material with a pressure

boundary function in a similar environment).

The applicant stated that this material is not in the GALL Report for this component (Note F).

The staff concurred with this statement.

The staff found the aging management of loss of material of gray cast iron valves in a treated

water, temperature< 140 °F, environment managed by One-Time Inspection, Selective

Leaching of Materials, and Water Chemistry Control Programs acceptable as discussed in

RAI 3A-2.

The applicant stated that this material is not in the GALL Report for this component (Note F).

The staff concurred with this statement.

The staff's evaluations found that the applicant identified the appropriate AMPs for the materials

and environment of the NMP1 condensate and condensate transfer system components.

3.4A.2.3.2 Steam and Power Conversion System NMP1 Feedwater/High Pressure Coolant

Injection System - Summary of Aging Management Evaluation - ALRA Table 3.4.2.A-2

The staff reviewed the following ALRA Table 3.4.2.A-2 items for the NMP1 feedwater/high

pressure coolant injection system:

Cracking in wrought austenitic stainless steel feedwater heaters in a treated water,

temperature > 140 °F, but < 212 OF, environment managed by the One-Time inspection

and Chemistry Control Programs. The applicant stated that neither the component nor

the material-environment combination is evaluated in the GALL Report (Note J).

3-416
Cracking of wrought austenitic stainless steel feedwater heaters in a treated water or

steam, temperature > 212 OF, but < 4820 F, environment managed by the One-Time

Inspection and Chemistry Control Programs. The applicant stated that neither the

component nor the material-environment combination is evaluated in the GALL Report

(Note J).

Cumulative fatigue damage of wrought austenitic stainless steel feedwater heaters in a

treated water or steam, temperature > 212 OF, but < 482 OF, environment managed by

TLAA evaluated in accordance with 10 CFR 54.21(c).The applicant stated that neither

the component nor the material-environment combination is evaluated in the GALL

Report (Note J).

" Loss of material for copper alloy (zinc < 15 percent) oil coolers in a demineralized

untreated water low flow environment managed by Closed -Cycle Cooling Water

Systems Program. The applicant stated that neither the component nor the

material-environment combination is evaluated in the GALL Report (Note J).

" Loss of material in carbon steel or low alloy steel (yield strength < 100 ksi) piping and

fittings in a treated water or steam, temperature > 212 OF, but < 482 OF, environment

managed by the One-Time inspection and Water Chemistry Control Programs. The

applicant stated that this aging effect is not in the GALL Report for this

component-material-environment combination. This line item is for components in the

reactor coolant pressure boundary portion of the main steam or feedwater system (Note

H,16).

* Loss of material in carbon steel, low alloy steel (yield strength < 100 ksi) valves in a

treated water or steam, temperature > 212 OF, but < 482OF, environment managed by

the One-Time inspection and Chemistry Control Programs. The applicant stated that this

aging effect is not in the GALL Report for this component-material-environment

combination. This row is for components in the reactor coolant pressure boundary

portion of the main steam or feedwater system (Note H,16).

* Loss of material in carbon steel or low alloy steel (yield strength < 100 ksi) valves in a

treated water or steam, temperature > 212 OF, but < 482°F, low flow environment

managed by the One-Time Inspection and Chemistry Control Programs. The applicant

stated that this aging effect is not in the GALL Report for this

component-material-environment combination. This line item is for components in the

reactor coolant pressure boundary portion of the main steam or feedwater system (Note

H,16).

The staff requested during its audit that the applicant discuss the specific tests and inspections,

frequency of inspections, and acceptance criteria for cracking in wrought austenitic stainless

steel feedwater heaters in a treated water, temperature > 140 OF, but < 212 OF, environment

managed by the One-Time Inspection and Water Chemistry Control Programs to assure that

the components will perform their intended functions. In its response the applicant stated:

The One-Time Inspection Program is described in [the original] LRA

Section B2.1.20, as supplemented by NMPNS letter NMP1L 1880 dated October

29, 2004. The One-Time Inspection Program is a new program that will be

implemented prior to the period of extended operation. As such, the procedures

needed to answer this question have not yet been developed. However, the

One-Time Inspection Program will be consistent with the GALL Report,

3-417
Section XI.M32 (One-Time Inspection) when implemented. The One-Time

Inspection Program Attribute Assessment (PAA) addresses program

implementation at NMPNS relative to the requirements of Appendix A of

NUREG-1800. The One-Time Inspection PAA is available on-site at NMPNS for

review.

The staff's review found the response acceptable because the applicant's AMPs will be

consistent with industry practice and requirements of the GALL Report.

The staffs evaluations of the One-Time Inspection and Water Chemistry Control Programs are

in Sections SER 3.0.3.1.4 and 3.0.3.2.2, respectively.

The applicant stated that neither the component nor the material-environment combination is

evaluated in the GALL Report (Note J). The staff concurred with this statement.

The staff requested that the applicant discuss the specific tests and inspections, frequency of

inspections, and acceptance criteria for cracking of wrought austenitic stainless steel feedwater

heaters in a treated water or steam, temperature -> 212 OF, but < 482 OF, environment managed

by the One-Time Inspection and Chemistry Control Programs to assure that the components

perform their intended function. In its response the applicant stated:

The One-Time Inspection Program is described in ALRA Section B2.1.20, as

supplemented by NMPNS letter NMP1L 1880 dated October 29, 2004. The

One-Time Inspection Program is a new program that will be implemented prior to

the period of extended operation. As such, the procedures needed to answer this

question have not yet been developed. However, the One-Time Inspection

Program will be consistent with the GALL Report, Section XI.M32 (One-Time

Inspection) when implemented. The One-Time Inspection Program Attribute

Assessment (PAA) addresses program implementation at NMPNS relative to the

requirements of Appendix A of NUREG-1800. The One-Time Inspection PAA is

available on-site at NMPNS for review.

The staff found the response reasonable and acceptable because the applicant's AMPs will be

consistent with industry practice and requirements of the GALL Report.

The staffs evaluations of the One-Time Inspection and Water Chemistry Control Programs are

in SER Sections 3.0.3.1.4 and 3.0.3.2.2, respectively.

The applicant stated that neither the component nor the material-environment combination is

evaluated in the GALL Report (Note J). The staff concurred with this statement.

The staff found the aging management of cumulative fatigue damage of wrought austenitic

stainless steel feedwater heaters in a treated water or steam, temperature_> 212 OF, but

< 482 OF, environment managed by TLAA evaluated in accordance with 10 CFR 54.21(c)

reasonable and acceptable. This item is not evaluated in the original LRA Section 4.3.

The applicant stated that neither the component nor the material-environment combination is

evaluated in the GALL Report (Note J). The staff concurred with this statement.

3-418
The applicant stated as to the loss of material for copper alloy (zinc < 15 percent) oil coolers in

a demineralized untreated water low flow environment managed by Closed -Cycle Cooling

Water Systems Program that neither the component nor the material-environment combination

is evaluated in the GALL Report (Note J). The staff concurred with this statement.

The staff found the aging management of the aging effects for this component by the

Closed-Cycle Cooling Water Systems Program reasonable and acceptable. The staff reviewed

this AMP. The staff evaluation is in SER Section 3.0.3.2.8.

The applicant stated that loss of material in carbon steel or low alloy steel (yield strength < 100

ksi) piping and fittings in a treated water or steam, temperature> 212 OF, but < 482 OF,

environment managed by the One-Time inspection and Water Chemistry Control Programs is

not in the GALL Report for this component-material-environment combination (Note H). The

staff concurred with this statement. The applicant also stated that this line item applies to

components in the reactor coolant pressure boundary portion of the main steam or feedwater

system (Note 16).

The staff found the One-Time inspection and Water Chemistry Control Programs appropriate

AMPs to manage the aging effects for this component in this environment. The staff's

evaluations of the One-Time Inspection and Water Chemistry Control Programs are in SER

Sections 3.0.3.1.4 and 3.0.3.2.2, respectively.

The applicant stated that loss of material in carbon steel or low alloy steel (yield strength < 100

ksi) valves in a treated water or steam, temperature > 212 OF, but < 482 OF, low flow

environment is managed by the One-Time inspection and Chemistry Control Programs. The

applicant stated that this aging effect is not in the GALL Report for this

"component-material-environment" combination. This row in Table 3.4.2.A-2 is for components

in the reactor coolant pressure boundary portion of the main steam or feedwater system

(Note H,16). The staff concurred with this statement. The information provided by the applicant

is reflected in the ALRA.

The staff found the One-Time inspection and Water Chemistry Control Programs appropriate

AMPs to manage the aging effects for this component in this environment. The staff's

evaluations of the One-Time Inspection and Water Chemistry Control Programs are in SER

Sections 3.0.3.1.4 and 3.0.3.2.2, respectively.

The staff's evaluations found that the applicant has identified the appropriate AMPs for the

materials and environment associated with the NMP1 feedwater/high pressure coolant injection

system components. This information is reflected in the ALRA.

3.4A.2.3.3 Steam and Power Conversion System NMPI Main Generator and Auxiliary System

- Summary of Aging Management Evaluation - ALRA Table 3.4.2A-3

This system is listed here for information and completeness. The AMR results for the NMP1

main generator and auxiliary system are consistent with the GALL Report. The staff's

evaluation of these results is in SER Sections 3.4A.2.1.1 and 3.4A2.2.4.

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3.4A.2.3.4 Steam and Power Conversion System NMP1 Main Steam System - Summary of

Aging Management Evaluation - ALRA Table 3.4.2.A-4

This system is listed here for information and completeness. The AMR results for the NMPI

main steam system are consistent with the GALL Report. The staff's evaluation of these results

is in SER Sections 3.4A.2.1.1, 3.4A.2.2.2, and 3AA2.2.4

3.4A.2.3.5 Steam and Power Conversion System NMP1 Condenser Air Removal and Off-Gas

System - Summary of Aging Management Evaluation - ALRA Table 3.4.2A-5

This system is listed here for information and completeness. The AMR results for the NMP1

condenser air removal and off-gas system are consistent with the GALL Report. The staff's

evaluation of these results is presented in SER Sections 3.4A.2.1, 3.4A.2.1.1, 3.4A.2.2.2, and

3.4A2.2.4

3.4A.2.3.6 Steam and Power Conversion System NMP1 Main Turbine and Auxiliary Systems -

Summary of Aging Management Evaluation - ALRA Table 3.4.2.A-6

This system is listed here for information and completeness. The AMR results for the.NMP1

main turbine and auxiliary systems are consistent with the GALL Report. The staff's evaluation

of these results is in SER Sections 3.4A.2.1, 3.4A.2.2.2, and 3.4A2.2.4.

3.4A.2.3.7 Steam and Power Conversion System NMP1 Moisture Separator Reheater Steam

System - Summary of Aging Management Evaluation - ALRA Table 3.4.2A-7

This system is listed here for information and completeness. The AMR results for the NMPI

moisture separator reheater steam system are consistent with the GALL Report. The staff's

evaluation of these results is in SER Sections 3.4A.2.1, 3.4A.2.2.2, and 3.4A2.2.4.

3.4A.3 Conclusion

The staff concludes that there is reasonable assurance that the applicant provided sufficient

information to demonstrate that the effects of aging for the NMP1 steam and power conversion

systems components that are within the scope of license renewal and subject to an AMR will be

adequately managed so that the intended function(s) will be maintained consistent with the CLB

for the period of extended operation, as required by 10 CFR 54.21 (a)(3).

The staff also reviewed the applicable UFSAR supplement program summaries and concludes

that they adequately describe the AMPs credited for managing aging of the steam and power

conversion systems, as required by 10 CFR 54.21(d).

3.4B NMP2 Aging Management of Steam and Power Conversion Systems

This section of the SER documents the staffs review of the applicant's AMR results for the

steam and power conversion systems components and component groups associated with the

following NMP2 systems:

* main condenser air removal system

* condensate system

3-420
* feedwater system

* main steam system

• moisture separator and reheater system

" extraction steam and feedwater heater drain system

" turbine main system

3.4B.1 Summary of Technical Information in the Amended Application

In ALRA Section 3.4, the applicant provided AMR results for the steam and power conversion

systems components and component groups. In ALRA Table 3.4.1..B, "NMP2 Summary of

Aging Management Programs for the Steam and Power Conversion Systems Evaluated in

Chapter VIII of NUREG-1801," the applicant provided a summary comparison of its AMRs with

the AMRs evaluated in the GALL Report for the steam and power conversion systems

components and component groups.

The applicant's AMRs incorporated applicable operating experience in the determination of

AERMs. These reviews included evaluation of plant-specific and industry operating experience.

The plant-specific evaluation included reviews of condition reports and discussions with

appropriate site personnel to identify AERMs. The applicant's review of industry operating

experience included a review of the GALL Report and operating experience issues identified

since the issuance of the GALL Report.

3.4B.2 Staff Evaluation

The staff reviewed ALRA Section 3.4 to determine if the applicant provided sufficient

information to demonstrate that the effects of aging for the steam and power conversion

systems components that are within the scope of license renewal and subject to an AMR will be

adequately managed so that the intended functions will be maintained consistent with the CLB

for the period of extended operation, as required by 10 CFR 54.21 (a)(3).

The staff performed an onsite audit of AMRs to confirm the applicant's claim that certain

identified AMRs were consistent with the GALL Report. The staff did not repeat its review of the

matters described in the GALL Report; however, the staff did verify that the material presented

in the ALRA was applicable and that the applicant had identified the appropriate GALL AMRs.

The staff's evaluations of the AMPs are documented in SER Section 3.0.3. Details of the staff's

audit evaluation are documented in the Audit and Review Report and are summarized in SER

Section 3.4B.2.1.

In the onsite audit, the staff also selected AMRs that were consistent with the GALL Report and

for which further evaluation is recommended. The staff confirmed that the applicant's further

evaluations were consistent with the acceptance criteria in SRP-LR Section 3.4.2.2. The staff's

audit evaluations are documented in the Audit and Review Report and are summarized in SER

Section 3.4B.2.2.

In the onsite audit, the staff also conducted a technical review of the remaining AMRs that were

not consistent with, or not addressed in, the GALL Report. The audit and technical review

included evaluating whether all plausible aging effects were identified and evaluating whether

the aging effects listed were appropriate for the combination of materials and environments

specified. The staff's audit evaluations are documented in the Audit and Review Report and are

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summarized in SER Section 3.4B.2.3. The staff's evaluation of its technical review is also

documented in SER Section 3.4B.2.3.

Finally, the staff reviewed the AMP summary descriptions in the USAR supplement to ensure

that they provided an adequate description of the programs credited with managing or

monitoring aging for the steam and power conversion systems components.

Table 3.4B-1 below provides a summary of the staff's evaluation of NMP2 components, aging

effects and aging effects mechanisms, and AMPs listed in ALRA Section 3.4 that are

addressed in the GALL Report.

Table 3.46-1 Staff Evaluation for NMP2 Steam and Power Conversion Systems

Components in the GALL Report

Component Group AiiAging Effect)' AMP in GALL AMP inALRA Istaff Evaluation

_______________ Mechahlnism Report".._______ ________

Piping and fittings in Cumulative fatigue TLAA, evaluated in TLAA This TLAA is

main feedwater line, damage accordance with evaluated in

steam line and , 10 CFR 54.21(c) Section 4.3, Metal

AFW piping (PWR Fatigue Analysis

only)

(Item Number

3.4.1.1-01)

Piping and fittings, Loss of material Water chemistry Water Chemistry Consistent with

valve bodies and due to general and one-time Control Program GALL, which

bonnets, pump (carbon steel only), inspection (82.1.2), One-Time recommends further

casings, tanks, pitting, and crevice Inspection Program evaluation (See

tubes, tubesheets, corrosion (82.1.20) Section 3.413.22.2)

channel head and

shell (except main

steam system)

(Item Number

3.4.1.3-02)

Auxiliary feedwater Loss of material Plant specific Not applicable,

(AFW) piping due to general, PWR only

(Item Number pitting, and crevice

3.4.1.B-03) corrosion, MIC, and

biofouling

Oil coolers in AFW Loss of material Plant specific Not applicable,

system (lubricating due to general PWR only

oil side possibly (carbon steel only),

contaminated with pitting, and crevice

water corrosion and MIC

(Item Number

3.4.1.1-04)

External surface of Loss of material Plant specific Systems Walkdown Consistent with

carbon steel due to general Program (B2.1.33) GALL, further

components corrosion evaluation

(Item Number recommended (See

3.4.1.1-05) Section 3.4B.2.2.4)

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Component Group Aging Effect! AMP In GALL• `AMP In ALRA Staff Evaluation

Mechanism R;'eport _________________

Carbon steel piping Wall thinning due to Flow-accelerated Flow-Accelerated Consistent with

and valve bodies flow-accelerated corrosion Corrosion Program GALL, which

(Item Number corrosion (B2.1.9) recommends furthef

3.4.1..B-06) evaluation (See Section 3.4B.2.2.4)

Carbon steel piping Loss of material Water chemistry Water Chemistry Consistent with

and valve bodies in due to pitting and Control Program GALL, which

main steam system crevice corrosion (B2.1.2), One-Time recommends no

(Item Number Inspection Program further evaluation

3.4.1.B-07) (B2.1.20) (See Section

3.48.2.1)

Closure bolting in Loss of material Bolting integrity Bolting Integrity Consistent with

high-pressure or due to general Program (B2.1.36) GALL, which

high-temperature corrosion; crack recommends no

systems initiation and growth further evaluation

(Item Number due to cyclic (See Section

3.4.1.8-08) loading and/or SCC 3.4B.2.1)

Heat exchangers Loss of material Open-cycle cooling None Consistent with

and due to general water system GALL, which

coolers/condensers (carbon steel only), recommends no

serviced by pitting, and crevice further evaluation

open-cycle cooling corrosion, MIC, and (See Section

water biofouling; buildup 3.4B.2.1)

(Item Number of deposit due to

3.4.1.8-09) biofouling

Heat exchangers Loss of material Closed-cycle None Not applicable

and due to general cooling water (components not

coolers/condensers (carbon steel only), system subject to an aging

serviced by pitting, and crevice management

closed-cycle cooling corrosion review)

water

(Item Number

3.4.1.B-10)

External surface of Loss of material Aboveground None Not applicable

aboveground due to general carbon steel tanks (external surfaces

condensate storage (carbon steel only), of carbon steel

tank pitting, and crevice components

(Item Number corrosion evaluated in

3.4.1.8-11) 3.4.1.8-05

External surface of Loss of material Buried piping and None Not applicable (See

buried condensate due to general, tanks surveillance Section 3.4B.2.2.5)

storage tank and pitting, and crevice

AFW piping corrosion and MIC or

(Item Number

3.4.1.B-12) Buried piping and Not applicable (See

tanks inspection Section 3.4B.2.2.5)

External surface of Loss of material Boric acid corrosion Not applicable,

carbon steel due to boric acid PWR only

components corrosion

(Item Number

3.4.1.B-13)

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The staff's review of the NMP2 component groups followed one of several approaches. One

approach, documented in SER Section 3.4B.2.1, discusses the staff's review of the AMR

results for components in the steam and power conversion systems that the applicant indicated

are consistent with the GALL Report and do not require further evaluation. Another approach,

documented in SER Section 3.4B.2.2, discusses the staff's review of the AMR results for

components in the steam and power conversion systems that the applicant indicated are

consistent with the GALL Report and for which further evaluation is recommended. A third

approach, documented in SER Section 3.4B.2.3, discusses the staff's review of the AMR

results for components in the steam and power conversion systems that the applicant indicated

are not consistent with, or not addressed in, the GALL Report. The staff's review of AMPs that

are credited to manage or monitor aging effects of the steam and power conversion systems

components is documented in SER Section 3.0.3.

3.4B.2.1 AMR Results That Are Consistent with the GALL Report

Summary of Technical Information in the Amended Application. In ALRA Section 3.4.2.B, the

applicant identified the materials, environments, and AERMs. .The applicant identified the

following programs that manage the aging effects related to the steam and power conversion

systems components:

* Water Chemistry Control Program

* Flow-Accelerated Corrosion Program

* One-Time Inspection Program

* Preventive Maintenance Program

* Systems Walkdown Program

* Bolting Integrity Program

Staff Evaluation. In ALRA Tables 3.4.2.B-1 through 3.4.2.B-7, the applicant provided a

summary of AMRs for the steam and power conversion systems components, and identified

which AMRs it considered to be consistent with the GALL Report.

For component groups evaluated in the GALL Report for which the applicant claimed

consistency with the GALL Report, and for which the GALL Report does not recommend further

evaluation, the staff performed an audit and review to determine whether the plant-specific

components contained in these GALL Report component groups were bounded by the GALL

Report evaluation.

The applicant provided a note for each AMR line item. The notes indicate how the information in

the tables aligns with the information in the GALL Report. The staff audited those AMRs with

Notes A through E, which indicate that the AMR is consistent with the GALL Report.

Note A indicates that the AMR line item is consistent with the GALL Report for component,

material, environment, and aging effect. In addition, the AMP is consistent with the AMP

identified in the GALL Report. The staff audited these line items to verify consistency with the

GALL Report and the validity of the AMR for the site-specific conditions.

Note B indicates that the AMR line item is consistent with the GALL Report for component,

material, environment, and aging effect. In addition, the'AMP takes some exceptions to the

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AMP identified in the GALL Report. The staff audited these line items to verify consistency with

the GALL Report. The staff verified that the identified exceptions to the GALL AMPs had been

reviewed and accepted by the staff. The staff also determined whether the AMP identified by

the applicant was consistent with the AMP identified in the GALL Report and whether the AMR

was valid for the site-specific conditions.

Note C indicates that the component for the AMR line item, although different from, is

consistent with the GALL Report for material, environment, and aging effect. In addition, the

AMP is consistent with the AMP identified by the GALL Report. This note indicates that the

applicant was unable to find a listing of some system components in the GALL Report.

However, the applicant identified a different component in the GALL Report that had the same

material, environment, aging effect, and AMP as the component that was under review. The

staff audited these line items to verify consistency with the GALL Report. The staff also

determined whether the AMR line item of the different component was applicable to the

component under review and whether the AMR was valid for the site-specific conditions.

Note D indicates that the component for the AMR line item, although different from, is

consistent with the GALL Report for material, environment, and aging effect. In addition, the

AMP takes some exceptions to the AMP identified in the GALL Report. The staff audited these

line items to verify consistency with the GALL Report. The staff verified whether the AMR line

item of the different component was applicable to the component under review. The staff

verified whether the identified exceptions to the GALL AMPs had been reviewed and accepted

by the staff. The staff also determined whether the AMP identified by the applicant was

consistent with the AMP identified in the GALL Report and whether the AMR was valid for the

site-specific conditions.

Note E indicates that the AMR line item is consistent with the GALL Report for material,

environment, and aging effect, but a different aging management program is credited. The staff

audited these line items to verify consistency with the GALL Report. The staff also determined

whether the identified AMP would manage the aging effect consistent with the AMP identified

by the GALL Report and whether the AMR was valid for the site-specific conditions.

The staff conducted an audit and review of the information provided in the ALRA, as

documented in the Audit and Review Report. The staff did not repeat its review of the matters

described in the GALL Report; however, the staff did verify that the material presented in the

ALRA was applicable and that the applicant identified the appropriate GALL Report AMRs. The

staffs evaluation is discussed below.

3.4B.2.1.1 Loss of Material Due to Pitting and Crevice Corrosion

In the discussion section for Item 3.4.1 .B-07 of ALRA Table 3.4.1.B the applicant stated that for

main steam carbon steel piping and valve bodies in a treated water environment loss of

material due to pitting and crevice corrosion is managed by the Water Chemistry Control

Program. For small-bore piping and valves in a treated water environment an additional AMP,

the One-Time Inspection Program, is used.

As documented in the Audit and Review Report, the staff asked the applicant why small-bore

piping and the One-Time Inspection Program were not included in the AMP discussion for

ALRA Table 3.4.2.B-4. The applicant stated that the main steam system has small-bore carbon

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steel drain line piping, fitting, and valves. These components were not reflected accurately in

ALRA Table 3.4.2.B-4. By letter dated December 1, 2005, the applicant stated to correct this

deficiency ALRA Table 3.4.2.B-4 had been revised to include the small-bore carbon steel

piping, fittings, and valves.

The staffs review found that the applicant appropriately addressed the aging effect and aging

effect mechanism as recommended by the GALL Report.

Conclusion. The staff evaluated the applicant's claim of consistency with the GALL Report. The

staff also reviewed information pertaining to the applicant's consideration of recent operating

experience and proposals for managing associated aging effects. On the basis of its review, the

staff concludes that there is reasonable assurance that the AMR results, which the applicant

claimed to be consistent with the GALL Report, are consistent with the AMRs in the GALL

Report. Therefore, the staff concludes that the applicant had demonstrated that the effects of

aging for these components will be adequately managed so that their intended function(s) will

be maintained consistent with the CLB for the period of extended operation, as required by

10 CFR 54.21(a)(3).

3.4B.2.2 AMR Results That are Consistent with the GALL Report, for Which Further

Evaluation is Recommended

Summary of Technical Information in the Amended Application. In Section 3.4.2.C of its

supplemental letter dated August 19, 2005, the applicant provided further evaluation of aging

management as recommended by the GALL Report for the steam and power conversion

systems components. The applicant provided information concerning how it will manage the

following aging effects:

" cumulative fatigue damage

" loss of material due to general, pitting, and crevice corrosion

" loss of material due to general, pitting, and crevice corrosion, microbiologically

influenced corrosion, and biofouling

* general corrosion

" loss of material due to general, pitting, crevice, and microbiologically influenced

corrosion

Staff Evaluation. For component groups evaluated in the GALL Report for which the applicant

has claimed consistency with the GALL Report, and for which the GALL Report recommends

further evaluation, the staff audited and reviewed the applicant's evaluation to determine

whether it adequately addressed the issues that were further evaluated. In addition, the staff

reviewed the applicant's further evaluations against the criteria contained in SRP-LR

Section 3.4.2.2. Details of the staffs audit are documented in the staffs Audit and Review

Report. The staffs evaluation of the aging effects is discussed in the following sections.

3.4B.2.2.1 Cumulative Fatigue Damage

In Section 3.4.2.C.1 of its letter dated August 19, 2005, the applicant stated that fatigue is a

TLAA as defined in 10 CFR 54.3. Applicants must evaluate TLAAs according to

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10 CFR 54.21 (c)(1). SER Section 4.3 documents the staff's review of the applicant's evaluation

of this TLAA.

3.4B.2.2.2 Loss of Material Due to General, Pitting, and Crevice Corrosion

The staff reviewed Section 3.4.2.C.2 of the applicant's supplemental letter dated August 19,

2005, against the criteria of SRP-LR Section 3.4.2.2.2.

In Section 3.4.2.C.2 of its letter dated August 19, 2005, the applicant addressed loss of material

due to general, pitting, and crevice corrosion for various carbon steel components.

SRP-LR Section 3.4.2.2.2 states that the management of loss of material due to general,

pitting, and crevice corrosion should be evaluated further for carbon steel piping and fittings,

valve bodies and bonnets, pump casings, pump suction and discharge lines, tanks, tubesheets,

channel heads, and shells except for main steam system components and for loss of material

due to pitting and crevice corrosion for stainless steel tanks and heat exchanger/cooler tubes.

The Water Chemistry Control Program relies on monitoring and control of water chemistry

based on the guidelines in BWRVIP-29 (EPRI TR-103515), "BWR Water Chemistry Guidelines

- Normal and Hydrogen Water Chemistry," to manage the effects of loss of material due to

general, pitting, or crevice corrosion. However, corrosion may occur at in stagnant flow

conditions. Therefore, the effectiveness of the applicant's Chemistry Control Program should be

verified to ensure no corrosion. The GALL Report recommends further evaluation of programs

to manage loss of material due to general, pitting, and crevice corrosion to verify the

effectiveness of the applicant's Water Chemistry Control Program. A one-time inspection of

select components and susceptible locations is an acceptable method to ensure no corrosion

and maintenance of the component's intended function during the period of extended operation.

In Section 3.4.2.C.2 of its letter dated August 19, 2005, the applicant also stated that for NMP2

this aging effect and aging effect mechanism is managed by the combination of the Water

Chemistry Control Program and the One-Time Inspection Program for the applicable systems

and components.

The staff reviewed the applicant's Water Chemistry Control and One-Time Inspection

Programs; the staffs evaluations are documented in SER Sections 3.0.3.2.2 and 3.0.3.1.4,

respectively.

The AMPs recommended by the GALL Report for management of this aging effect and aging

effect mechanism are GALL AMPs XI.M2 and XI.M32. The applicant's Water Chemistry Control

Program mitigates the aging effects and aging effects mechanisms on component surfaces

exposed to water as the process fluid. Chemistry Programs control water chemistry for

impurities (e.g., chloride and sulfate) that accelerate and cause loss of material due to general,

pitting, and crevice corrosion. This program relies on monitoring and control of water chemistry

to keep peak levels of various contaminants below system-specific limits. The One-Time

Inspection Program's scope includes verification of the effectiveness of the Water Chemistry

Control Program. Implementation of the One-Time Inspection Program in conjunction with the

Water Chemistry Control Program to manage this aging effect and aging effect mechanism

provides added assurance that (a) the aging effect and aging effects mechanism does not

occur at stagnant or low-flow locations or (b) that the aging effect and aging effect mechanism

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progresses so slowly that the component's intended function will be maintained during the

period of extended operation. The staff found that the applicant appropriately evaluated AMR

results involving management of the loss of material due to general, pitting, and crevice

corrosion for steam and power conversion systems components as recommended in the GALL

Report

The staff concludes that there is reasonable assurance that the applicant met the criteria of

SRP-LR Section 3.4.2.2.2. For those line items addressed by Section 3.4.2.C.2 of its letter

dated August 19, 2005, the staff determined that the information in the application is consistent

with the GALL Report and the applicant had demonstrated that the effects of aging will be

adequately managed so that the intended functions will be maintained consistent with the CLB

during the period of extended operation, as required by 10 CFR 54.21(a)(3).

3.4B.2.2.3 Loss of Material Due to General, Pitting, and Crevice Corrosion, Microbiologically

Influenced Corrosion, and Biofouling

The staff reviewed Section 3.4.2.C.3 of the applicant's supplemental letter dated August 19,

2005, against the criteria of SRP-LR Section 3.4.2.2.3.

In Section 3.4.2.C.3 of its letter dated August 19, 2005, the applicant stated that this aging

effect applies to PWRs only.

Because NMPNS is a BWR design the staff found this aging effect not applicable to NMP2.

3.4B.2.2.4 General Corrosion

The staff reviewed Section 3.4.2.C.4 of the applicant's supplemental letter dated August 19,

2005, against the criteria of SRP-LR Section 3.4.2.2.4.

In Section 3.4.2.C.4 of its letter dated August 19, 2005, the applicant addressed loss of material

due to general corrosion on the external surfaces of all carbon steel structures and components

including closure bolting exposed to operating temperatures < 212 OF.

SRP-LR Section 3.4.2.2.4 states that loss of material due to general corrosion could occur on

the external surfaces of all carbon steel structures and components including closure boltings

exposed to operating temperature less that 212 OF. The GALL Report recommends further

evaluation to ensure that this aging effect and aging effect mechanism is adequately managed.

In the ALRA, the applicant also stated that for NMP2 this aging effect and aging effect

mechanism is managed by the Systems Walkdown Program. The staff reviewed the applicant's

Systems Walkdown Program. The staff's evaluation is documented in SER Section 3.0.3.3.2.

The staff found this program acceptable for managing loss of material due to general corrosion

by visual inspection of external surfaces performed during various systems walkdowns. In

addition the NMP2 plant-specific operating experience also indicated that this program is

effective in identifying aging effects and aging effects mechanisms in the applicant's plant.

Therefore, the staff finds that the applicant appropriately evaluated AMR results of

management of the loss of material due to general corrosion for steam and power conversion

systems components as recommended in the GALL Report.

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The staff concludes that there is reasonable assurance that the applicant had met the criteria of

SRP-LR Section 3.4.2.2.4. For those line items addressed by Section 3.4.2.C.4 of its letter

dated August 19, 2005, the staff determined the information in the application is consistent with

the GALL Report and the applicant had demonstrated that the effects of aging will be

adequately managed so that the intended functions will be maintained consistent with the CLB

during the period of extended operation as required by 10 CFR 54.21(a)(3).

3.4B.2.2.5 Loss of Material Due to General, Pitting, Crevice, and Microbiologically Influenced

Corrosion

The staff reviewed Section 3.4.2.C.5 of the applicant's supplemental letter dated August 19,

2005, against the criteria of SRP-LR Section 3.4.2.2.5.

The applicant stated in Section 3.4.2.C.5 of its letter dated August 19, 2005, that loss of

material due to general, pitting, crevice, and MIC is not applicable to NMP2 because this aging

effect and aging effect mechanism applies to PWR systems only and is therefore not applicable

to NMP2.

The staff determined that the loss of material due to general, pitting, crevice, and MIC aging

effect and aging effect mechanism is not applicable to NMP2 as it applies to PWR systems

only.

Because NMP2 does not have any components from this group the staff determined that this

aging effect and aging effect mechanism is not applicable.

3.4B.2.2.6 Quality Assurance for Aging Management of Nonsafety-Related Components

SER Section 3.0.4 provides the staffs evaluation of the applicant's Quality Assurance Program.

Conclusion. On the basis of its review, for component groups evaluated in the GALL Report for

which the applicant had claimed consistency with the GALL Report, and for which the GALL

Report recommends further evaluation, the staff determined that the applicant adequately

addressed the issues that were further evaluated. The staff found that the applicant had

demonstrated that the effects of aging will be adequately managed so that the intended

functions will be maintained consistent with the CLB for the period of extended operation, as

required by 10 CFR 54.21(a)(3).

3.4B.2.3 AMR Results That Are Not Consistent with or Not Addressed in the GALL

Report

Summary of Technical Information in the Amended Application. In ALRA Tables 3.4.2.8-1

through 3.4.2.B-7, the staff reviewed additional details of the results of the AMRs for material,

environment, AERM, and AMP combinations that are not consistent with the GALL Report, or

that are not addressed in the GALL Report.

In ALRA Tables 3.4.2.8-1 through 3.4.2.8-7, the applicant indicated, via Notes F through J, that

the combination of component type, material, environment, and AERM does not correspond to

a line item in the GALL Report, and provided information concerning how the aging effect will

be managed. Specifically, Note F indicates that the material for the AMR line item component is

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not evaluated in the GALL Report. Note G indicates that the environment for the AMR line item

component and material is not evaluated in the GALL Report. Note H indicates that the aging

effect for the AMR line item component, material, and environment combination is not evaluated

in the GALL Report. Note I indicates that the aging effect identified in the GALL Report for the

line item component, material, and environment combination is not applicable. Note J indicates

that neither the component nor the material and environment combination for the line item is

evaluated in the GALL Report.

Staff Evaluation. For component type, material, and environment combinations that are not

evaluated in the GALL Report, the staff reviewed the applicant's evaluation to determine

whether the applicant had demonstrated that the effects of aging will be adequately managed

so that the intended functions will be maintained consistent with the CLB during the period of

extended operation. The staffs evaluation is discussed in the following sections.

3.4B.2.3.1 Steam and Power Conversion System NMP2 Main Condenser Air Removal System

- Summary of Aging Management Evaluation - ALRA Table 3.4.2.B-1

This system is listed here for information and completeness. The AMR results for the steam

and power conversion system NMP2 main condenser air removal system are consistent with

the GALL Report. The staffs evaluation of these results is presented in SER Sections 3.4B.2.1

and 3AB2.2.2

3.4B.2.3.2 Steam and Power Conversion System NMP2 Condensate System - Summary of

Aging Management Evaluation - ALRA Table 3.4.2.B-2

The staff reviewed ALRA Table 3.4.2.B-2 for the following items:

" Cracking and loss of strength of elastomer external surfaces in an air environment

managed by the Preventive Maintenance Program. The applicant stated that neither the

component nor the material-environment combination is evaluated in the GALL Report

(Note J).

" Cracking and loss of strength of elastomer piping and fittings in a treated water,

temperature < 140 OF, environment managed by the Preventive Maintenance Program.

The applicant stated that neither the component nor the material-environment

combination is evaluated in the GALL Report (Note J).

" Cracking and loss of strength of fiberglass tanks in a treated water, temperature

< 140 OF, environment managed by the One-Time Inspection Program. The applicant

states that neither the component nor the material-environment combination is

evaluated in the GALL Report (Note J).

The staff found management of cracking and loss of strength of elastomer external surfaces in

an air environment by the Preventive Maintenance Program reasonable and acceptable. The

staff s evaluation of the Preventive Maintenance Program is in SER Section 3.0.3.3.1. The staff

requested additional information about tests and inspections in the Preventive Maintenance

Program to manage the aging effects for this material and environment. In its response by letter

dated, November 15, 2005, the applicant provided the information, which is evaluated in SER

Section 3.213.2.3.4.

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The applicant stated that neither the component nor the material-environment combination is

evaluated in the GALL Report. The staff concurred with this statement.

The staffs evaluation of the aging management of cracking and loss of strength of elastomer

piping and fittings in treated water, temperature < 140 OF, environment managed by the

Preventive Maintenance Program is in RAI 3.4-9. The staff found the aging management of this

component in this environment acceptable. The applicant stated that neither the component nor

the material-environment combination is evaluated in the GALL Report. The staff concurred

with the applicant's statement.

In RAI 3.4-9 dated November 17, 2004, the staff stated that the original LRA Table 3.4.2.B-2

states that cracking and loss of strength of polymeric piping and fittings in a treated water,

temperature < 140 *F, low-flow environment will be managed by the Preventive Maintenance

Program. The staff requested that the applicant provide the following information:

• composition and/or mechanical and chemical properties of the polymer

" methods of inspection

" frequency of inspections and acceptance criteria and bases thereof

* operating history of these components

In its response by letter dated December 21, 2004, the applicant stated:

The subject elastomeric piping and fittings in a treated water (temperature < 140°F), low

flow environment contained in the [original] LRA Table 3.4.2.B-2, consist of expansion

joints associated with piping connected to the two Condensate Storage Tanks.

(a) The composition of the elastomeric expansion joints is rubber.

(b) The methods of inspection associated with these expansion joints are visual,

dimensional and durometer readings.

(c) Inspection of the expansion joints is performed every two years. Replacement of

the components is scheduled for every 20 years. The acceptance criteria for the various

methods are as follows.

Visual Inspection

• No excessive and deep cracking or cuts of outer cover exposing reinforcing wire,

body, rings or fabric.

* No blistering or local areas of deformation or ply separation.

* No leakage or weeping through bellows or at flange connections.

• No soft or gummy areas.

• No mechanical damage due to maintenance or operating activity.

* If expansion joint has a liner, liner is not damaged.

* Structural members and attachment hardware is not damaged and maintains

structural integrity.

Dimensional Inspection

• Face to face dimensions are within design tolerances.

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Durometer Reading

• Reading between 50-80 (Shur scale).

The inspections and acceptance criteria for the expansion joints are based upon

approved vendor manuals.

(d) The license renewal operating experience database was reviewed for failures of

any of the expansion joints associated with the two Condensate Storage Tanks. No

such failures were found in this database.

In addition, the site CAP database was reviewed for any occurrences of non-conforming

conditions associated with the expansion joints of the two Condensate Storage Tanks.

One corrective action report was written as a result of the latest inspection

(January 2004). This report identified signs of aging occurring but not to the extent that

immediate action was necessary. The expansion joints were found to be leak-free and

structurally intact.

The staff's review found the applicant's response to RAI 3.4-9 acceptable because it provided

methods of inspection, frequency of inspections, and acceptance criteria including their bases.

These are consistent with industry practice and vendor recommendations. In addition the

operating history of these components supports the proposed AMPs. Therefore, the staff's

concern described in RAI 3.4-9 is resolved. This information is reflected in the ALRA.

The staff's evaluation of the aging management of cracking and loss of strength of fiberglass

tanks in a treated water, temperature < 140 *F, environment managed by the One-Time

Inspection Program is in a-RAJ 3.4.2.B-1.

In a-RAI 3.4.2.B-1 dated November 22, 2005, the staff requested that the applicant provide

assurance that a one-time inspection alone is adequate to manage the aging effects identified.

Because the tank nozzles were connected to rubber expansion joints or flanges the staff

requested, that the applicant discuss how the aging effects of these joints or flanges would be

managed. In addition the staff requested that the applicant provide the NMPNS operational

experience with these tanks and the bases for identifying the aging effects for the specific

fiberglass (Atlac 382 resin) in this environment.

In its response by letter dated December 5, 2005, the applicant stated:

The tanks included in ALRA Table 3.4.2.B-2 are the NMP2 Condensate Storage

Tanks 2CNS-TKIA and 2CNS-TK-1 B.

The external surfaces of these tanks are inspected periodically under the

Systems Walkdown Program and NMPNS has not observed any age-related

degradation. The operational experience relative to these tanks relative to aging

is that no issues have been raised. The Atlac 382 resin is a propoxylated

bisphenol A fumarate unsaturated polyester resin which has been used for many

years in industrial applications. In particular, the cured resin has excellent

high-temperature properties with outstanding resistance against a broad range of

aqueous acids, salts, and alkaline solutions. Its resistance to strong inorganic

acids and oxidizing media is superior. Manufacturer chemical resistance data for

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Atlac 382 indicates the resin resists degradation by de-ionized water, distilled

water, and sea water at service temperatures up to 210 *F. A specific example

for a severe industrial application in which a fiberglass tank constructed with

Atlac 382 resin has been used is a chlorine chill and filtration tower that has been

in service for at least 25 years. Therefore, low-temperature treated water is a

very benign environment for these tanks. Based on this information, the

One-Time Inspection Program alone has been determined to be adequate to

manage aging of the internal surfaces of these tanks. Since the GALL Report

and the EPRI Tools documents do not address fiberglass material, the aging

effects of cracking and loss of strength were obtained from industry information

sources on the internet that are dedicated to fiberglass material.

Rubber expansion joints and flanges are included under the ALRA line item for

piping and fittings with the Material of Elastomer and the Environment of Treated

Water, Temperature 140 *F. Cracking and loss of strength of these components

is managed by the Preventive Maintenance Program. External surfaces of these

components are included under the ALRA line item of External Surfaces, with the

Material of Elastomer and the Environment of Air. Cracking and loss of strength

of the elastomer external surfaces are also managed by the Preventive

Maintenance Program. Visual inspection is performed for cracking and other

evidence of degradation, and Durometer Hardness Testing is performed that will

detect any hardening or loss of strength.

The staffs review of the tests and inspections and operational experience with these tanks and

the bases for identifying the aging effects for the specific fiberglass Atlac 382 resin) in this

environment found that the applicant had provided an adequate justification for the

management of the aging effects for this component. Therefore, the staffs concern described

in a-RAI 3.4.2.8-1 is resolved.

The applicant stated that neither the component nor the material-environment combination is

evaluated in the GALL Report. The staff concurred with the applicant's statement.

The staffs above evaluations staff found that the applicant identified the appropriate AMPs for

the materials and environment of the condensate system components.

3.4B.2.3.3 Steam and Power Conversion System NMP2 Feedwater System - Summary of

Aging Management Evaluation -ALRA Table 3.4.2.B-3

This system is listed here for information and completeness. The AMR results for the steam

and power conversion system NMP2 feedwater system are consistent with the GALL Report.

The staffs evaluation of these results is in SER Sections 3.38.2.1, 3B.2.2.2, 3.38.2.2.4.

3.4B.2.3.4 Steam and Power Conversion System NMP2 Main Steam System - Summary of

Aging Management Evaluation - ALRA Table 3.4.2.8-4

The staff reviewed ALRA Table 3.4.2.8-4 for the following items:

Loss of material for wrought austenitic stainless steel piping and fittings in demineralized

untreated water low-flow environment managed by the One-Time Inspection Program.

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The applicant stated that this aging effect is not in the GALL Report for this componentmaterial-environment combination. The applicant also stated that this item is applicable

to components that have an aging effect and aging effect mechanism of loss of material

due to MIC (Note H,14).

Loss of material for wrought austenitic stainless steel "T" quenchers in demineralized

untreated water low-flow environment managed by the One-Time Inspection Program.

The applicant stated that this aging effect is not in the GALL Report for this componentmaterial-environment combination. The applicant also stated that this item is applicable

to components that have an aging effect and aging effect mechanism of loss of material

due to MIC (Note H,14).

The staffs discussion of loss of material for wrought austenitic stainless steel piping and fittings

in demineralized untreated water low-flow environment managed by the One-Time Inspection

Program is in a-RAI 3.4.2.B-2. The staff's evaluation of loss of material for wrought austenitic

stainless steel "T" quenchers in demineralized untreated water low-flow environment managed

by the One-Time Inspection Program is also in a-RAI 3.4.2.B-2.

In a-RAI 3.4.2.B-2 dated November 22, 2005, the staff stated that ALRA Table 3.4.2.B-4

indicates that loss of material in wrought austenitic stainless steel "T" quenchers, piping, and

fittings exposed to demineralized untreated water low-flow environment would be managed by

the One-Time Inspection Program. The staff requested that the applicant provide assurance

that a one-time inspection alone is adequate to manage the aging effect.

In its response by letter dated December 5, 2005, the applicant changed the environment for

these components to treated water and added the Water Chemistry Control Program to the

management for the aging effect.

The staffs review staff concurred that with this change the aging management is now

consistent with the GALL Report and, therefore, the staff found the applicant's response to

a-RAI 3.4.2.B-4 acceptable and the staffs concern described in a-RAI 3.4.2.B-4 is resolved.

The staffs evaluations staff found that the applicant had identified the appropriate aging

management for the materials and environment of the main steam system components.

3.4B.2.3.5 Steam and Power Conversion System NMP2 Moisture Separator and Reheater

System - Summary of Aging Management Evaluation - ALRA Table 3.4.2.8-5

This system is listed here for information and completeness. The AMR results for the steam

and power conversion system NMP2 moisture separator and reheater system are consistent

with the GALL Report. The staffs evaluation of these results is in SER Sections 3.3B.2.1,

3.3B.2.2.2.

3.4B.2.3.6 Steam and Power Conversion System NMP2 Extraction Steam and Feedwater

Heater Drain System - Summary of Aging Management Evaluation - ALRA Table 3.4.2.B-6

This system is listed here for information and completeness. The AMR results for the Steam

and power conversion system NMP2 extraction steam and feedwater heater drain system are

consistent with the GALL Report. The staffs evaluation of these results is in SER

Sections 3.3B.2.1, 3.3B.2.2.2, 3.3B.2.2.4.

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3.4B.2.3.7 Steam and Power Conversion System NMP2 Turbine Main System - Summary of

Aging Management Evaluation - ALRA Table3.4.2.B-7

This system is listed here for information and completeness. The AMR results for the steam

and power conversion system NMP2 turbine main system are consistent with the GALL Report.

The staffs evaluation of these results is in SER Sections 3.3B.2.1, 3.3B.2.2.2, 3.3B.2.2.4.

3.4B.3 Conclusion

The staff concludes that there is reasonable assurance that the applicant provided sufficient

information to demonstrate that the effects of aging for the NMP2 steam and power conversion

systems components that are within the scope of license renewal and subject to an AMR will be

adequately managed so that the intended functions will be maintained consistent with the CLB

for the period of extended operation, as required by 10 CFR 54.21 (a)(3).

The staff also reviewed the applicable USAR supplement program summaries and concludes

that they adequately describe the AMPs credited for managing aging of the steam and power

conversion systems, as required by 10 CFR 54.21(d).

3.5 Aging Management of Structures and Component Supports

3.5A NMP1 Aging Management of Structures and Component Supports

This section of the SER documents the staffs review of the applicant's AMR results for the

structures and component supports components and component groups associated with the

following NMP1 systems, structures, and commodities:

" primary containment structure

" reactor building

* essential yard structures

* fuel handling system

" material handling system

" offgas building

* radwaste solidification and storage building

• screen and pump house building

* turbine building

• vent stack

* waste disposal building

* component supports commodity

* fire stops and seals commodity

3.5A.1 Summary of Technical Information in the Amended Application

In ALRA Section 3.5, the applicant provided AMR results for the structures and component

supports components and component groups. In ALRA Table 3.5.1.A, "NMP1 Summary of

Aging Management Programs for Structures and Component Supports Evaluated in Chapter II

and III of NUREG-1801," the applicant provided a summary comparison of its AMRs with the

AMRs evaluated in the GALL Report for the structures and component supports components

and component groups.

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The applicant's AMRs incorporated applicable operating experience in the determination of

AERMs. These reviews included evaluation of plant-specific and industry operating experience.

The plant-specific evaluation included reviews of condition reports and discussions with

appropriate site personnel to identify AERMs. The applicant's review of industry operating

experience included a review of the GALL Report and operating experience issues identified

since the issuance of the GALL Report.

3.5A.2 Staff Evaluation

The staff reviewed ALRA Section 3.5 to determine if the applicant provided sufficient

information to demonstrate that the effects of aging for the structures and component supports

components that are within the scope of license renewal and subject to an AMR will be

adequately managed so that the intended functions will be maintained consistent with the CLB

for the period of extended operation, as required by 10 CFR 54.21 (a)(3).

The staff performed an onsite audit of AMRs to confirm the applicant's claim that certain

identified AMRs were consistent with the GALL Report. The staff did not repeat its review of the

matters described in the GALL Report; however, the staff did verify that the material presented

in the ALRA was applicable and that the applicant had identified the appropriate GALL AMRs.

The staff's evaluations of the AMPs are documented in SER Section 3.0.3. Details of the staffs

audit evaluation are documented in the Audit and Review Report and are summarized in SER

Section 3.5A.2.1.

In the onsite audit, the staff also selected AMRs that were consistent with the GALL Report and

for which further evaluation is recommended. The staff confirmed that the applicant's further

evaluations were consistent with the acceptance criteria in SRP-LR Section 3.5.2.2. The staff's

audit evaluations are documented in the Audit and Review Report and are summarized in SER

Section 3.5A.2.2.

In the onsite audit, the staff also conducted a technical review of the remaining AMRs that were

not consistent with, or not addressed in, the GALL Report. The audit and technical review

included evaluating whether all plausible aging effects were identified and evaluating whether

the aging effects listed were appropriate for the combination of materials and environments

specified. The staff's audit evaluations are documented in the Audit and Review Report and are

summarized in SER Section 3.5A.2.3. The staffs evaluation of its technical review is also

documented in SER Section 3.5A.2.3.

Finally, the staff reviewed the AMP summary descriptions in the UFSAR supplement to ensure

that they provided an adequate description of the programs credited with managing or

monitoring aging for the structures and component supports components.

Table 3.5A-1 below provides a summary of the staffs evaluation of NMP1 components, aging

effects and aging effects mechanisms, and AMPs listed in ALRA Section 3.5, that are

addressed in the GALL Report.

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Table 3.5A-1 Staff Evaluation for NMPI Structures and Component Supports in the GALL

Report

Component Group Aging Effect) AMPin GALL AMPinALRA I ; Staff Evaluation

Mechanism Report' ,.,.

Common Components of All Types of PWR and BWR Containment

Penetration Cumulative fatigue TLAA, evaluated in TLAA This TLAA is

sleeves, penetration damage (CLB accordance with evaluated in

bellows, and fatigue analysis 10 CFR 54.21(c) Section 4.6,

dissimilar metal exists) "Containment Liner

welds Plate, Metal

(Item Number Containments, and

3.5.1A-01) Penetrations

Fatigue Analysis"

Penetration Cracking for cyclic Containment ISI ASME Section XI Consistent with

sleeves, bellows, loading & crack and Containment Inservice Inspection GALL, which

and dissimilar metal initiation and growth leak rate test (Subsection IWE) recommends further

welds from SCC Program (B2.1.23), evaluation (See

(Item Number 10 CFR 50 Section 3.5A.2.2.1)

3.5.1.A-02) Appendix J

Program (B2.1.26)

Penetration Loss of material Containment ISI Water Chemistry Consistent with

sleeves, penetration due to corrosion and Containment Control Program GALL, which

bellows, and leak rate test (B2.1.2), ASME recommends no

dissimilar metal Section XI Inservice further evaluation

welds Inspection (See Section

(Item Number (Subsection IWE) 3.5A.2.1)

3.5.1.A-03) Program (B2.1.23),

10 CFR 50

Appendix J

Program (B2.126)

Personnel airlock Loss of material Containment ISI ASME Section XI Consistent with

and equipment due to corrosion and Containment Inservice Inspection GALL, which

hatch leak rate test (Subsection IWE) ' recommends no

(Item Number Program (B2.123), further evaluation

3.5.1.A-04) 10 CFR 50 (See Section

Appendix J 3.5A.2.1) Program (B2.1.26)

Personnel airlock Loss of leak Containment leak 10 CFR 50 Consistent with

and equipment tightness in closed rate test and Plant Appendix J GALL, which

hatch - position due to Technical Program (B2.126) recommends no

(Item Number mechanical wear of Specifications further evaluation

3.5.1.A-05) locks, hinges and (See Section

closure mechanism 3.5A.2.1.1)

Seals, gaskets, and Loss of sealant and Containment ISI ASME Section XI Consistent with

moisture barriers leakage through and Containment Inservice Inspection GALL, which

(Item Number containment due to leak rate test (Subsection IWE) recommends no

3.5.1.A-06) deterioration of joint Program (B2.1.23), further evaluation

seals, gaskets, and 10 CFR 50 (See Section

moisture barriers Appendix J 3.5A.2.1)

Program (B2.1.26)

BWR Concrete (Mark II and Ill) Containment and Steel (Mark I, II and Ill) Containment

(Note: NMP1 has a Mark I Containment)

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'Component Group Aging Effect.il AMP In GALL AMP In ALRA Staff Evaluation,,:.ý

,.:'Mechanism•',. Report ,:

Concrete elements: Aging of accessible Containment ISI None Not applicable (See

foundation,walls, and inaccessible Section 3.5A.2.2.1)

dome concrete areas due

(Item Number to leaching of

3.5.1.A-07) calcium hydroxide,

aggressive

chemical attack,

and corrosion of

embedded steel

Concrete elements: Cracks, distortion, Structures None Not applicable (See

foundation and increases in Monitoring Section 3.5A.2.2.1)

(Item Number component stress

3.5.1.A-08) level due to

settlement

Concrete elements: Reduction in Structures None Not applicable (See

foundation foundation strength Monitoring Section 3.5A.2.2.1)

(Item Number due to erosion of

3.5.1.A-09) porous concrete

subfoundation

Concrete elements: Reduction of Plant specific None Not applicable (See

foundation, dome, strength and Section 3.5A.2.2.1)

and wall modulus due to

(Item Number elevated

3.5.1.A-10) temperature

Prestressed Loss of prestress TLAA, evaluated in None Not applicable (See

containment: due to relaxation, accordance with Section 3.5A.2.2.1)

tendons and shrinkage, creep, 10 CFR 54.21(c)

anchorage and elevated

components temperature

(Item Number

3.5.1.A-1 1)

Steel elements: Loss of material Containment ISI Water Chemistry Consistent with

liner plate, due to corrosion in and Containment Control Program GALL, which

containment shell accessible and leak rate test (B2.12), ASME recommends further

(Item Number inaccessible areas Section Xl Inservice evaluation (See

3.5.1 .A-12) Inspection Section 3.5A.2.2.1)

(Subsection IWE)

Program (B2.123),

10 CFR 50

Appendix J

Program (B2.1.26)

Torus Corrosion

Monitoring Program

(B3.3)

Steel elements: Cumulative fatigue TLAA, evaluated in TLAA This TLAA is

vent header, drywell damage (CLB accordance with evaluated in

head, tows, fatigue analysis 10 CFR 54.21 (c) Section 4.6,

downcomers, pool exists) "Containment Liner

shell Plate, Metal

(Item Number Containments, and

3.5.1.A-13) Penetrations

Fatigue Analysis"

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Componint Group -Aging Effect/ AMP In GALL ,_i, 'AMP In ALRA T Staff Evaluation

______________ Mechanism -:,Report _________ ________

Steel elements: Loss of material Protective coating None Not applicable

protected by coating due to corrosion -in monitoring and (no credit for

(Item Number accessible areas maintenance coatings taken)

3.5.1.A-14) only

Prestressed Loss of material Containment ISI None Not applicable

containment: due to corrosion of (PWR only)

tendons and prestressing

anchorage tendons and

components anchorage

(Item Number components

3.5.1.A-15)

Concrete elements: Scaling, cracking, Containment ISI None Not applicable

foundation, dome, and spalling due to (Mark I

and wall freeze-thaw; Containment)

(Item Number - expansion and

3.5.1 .A-1 6) cracking due to

reaction with

aggregate

Steel elements: Cracking due to Containment ISI ASME Section XI Consistent with

vent line bellows, cyclic loads or and Containment Inservice Inspection GALL, which

vent headers, Crack initiation and leak rate test (Subsection IWE) recommends further

downcomers growth due to SCC Program (B2.1.23), evaluation (See

(Item Number 10 CFR 50 Section 3.5A.2.2.1)

3.5.1.A-17) Appendix J

Program (82.126)

Steel elements: Crack initiation and Containment ISI None Not applicable

Suppression growth due to SCC and Containment (Mark I

chamber liner leak rate test Containment)

(Item Number

3.5.1.A-18)

Steel elements: Fretting and lock up Containment ISI None Not applicable

drywell head and due to wear (No fretting or wear

downcomer pipes for these

(Item Number components)

3.5.1.A-19)

Class I Structures

All Groups except All types of aging Structures ASME Section Xl Consistent with

Group 6: accessible effects Monitoring Inservice Inspection GALL, which

interior/exterior (Subsection IWE) recommends no

concrete & steel Program (82.1.23), further evaluation

components Structures (See

(Item Number Monitoring Program Sections 3.5A.2.1

3.5.1.A-20) (82.1.28) and 3.5A.2.2.2)

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.Component Group Aging Effect' AMP in GALL , AMP In ALRA Staff Evaluation.-

Mechanism- Report -

Groups 1-3, 5, 7-9: Aging of Plant specific None Not applicable (See

inaccessible inaccessible Section 3.5A.2.2.2)

concrete concrete areas due

components, such to aggressive

as exterior walls chemical attack,

below grade and and corrosion of

foundation embedded steel

(Item Number

3.5.1.A-21)

Group 6: all AH types of aging Inspection of None Not applicable

accessible/ effects, including Water-Control (No water-control

inaccessible loss of material due Structures or* structures)

concrete, steel, and to abrasion, FERCAJS Army

earthen cavitation, and Corps of Engineers

components corrosion dam inspection and

(Item Number maintenance

3.5.1.A-22)

Group 5: liners Crack initiation and Water Chemistry Water Chemistry Consistent with

(Item Number growth from SCC Program and Control Program GALL, which

3.5.1.A-23) and loss of material Monitoring of spent (B2.1.2) recommends no due to crevice fuel pool water level further evaluation

corrosion (See Section

3.5A.2.1.2)

Groups 1-3, 5,6: all Cracking due to Masonry Wall Masonry Wall Consistent with

masonry block walls restraint, shrinkage, Program (B2.127) GALL, which

(Item Number creep, and recommends no

3.5.1.A-24) aggressive further evaluation

environment (See Section

3.5A.2.1)

Groups 1-3, 5,7-9: Cracks, distortion, Structures None Not applicable (See

foundation and increases in Monitoring Section 3.5A.2.2.2)

(Item Number component stress

3.5.1.A-25) level due to

settlement

Groups 1-3, 5-9: Reduction in Structures None Not applicable (See

foundation foundation strength Monitoring Section 3.5A.2.2.2)

(Item Number due to erosion of

3.5.1.A-26) porous concrete

subfoundation

Groups 1-5: Reduction of Plant-specific None Not applicable (See

concrete strength and Section 3.5A.2.2.2)

(Item Number modulus due to

3.5.1 .A-27) elevated

temperature

Groups 7, 8: liners Crack Initiation and Plant-specific None Not applicable

(Item Number growth due to SCC; (No tank liners

3.5.1.A-28) Loss of material within scope)

due to crevice

corrosion

Component Supports

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Component Group Aging Effect/ AMP in'GALL $ AMP in ALRA Staff S• Evaluation

. . iMechanism Report _-__'____________ _:_____: _______

All Groups: support Aging of component Structures Structures Consistent with

members: anchor supports Monitoring Monitoring Program GALL, which

bolts, concrete (82.1.28) recommends no

surrounding anchor Fire Protection further evaluation

bolts, welds, grout Program (B2.1.16) (See Sections

pad, bolted 3.5A.2.1.3 and

connections, etc. 3.5A.2.2.3)

(Item Number

3.5.1 .A-29)

Groups B1.1, B1.2, Cumulative fatigue TLAA, evaluated in TLAA This TLAA is

and B1.3: support dahlage (CLB accordance with evaluated in

members: anchor fatigue analysis 10 CFR 54.21(c) Section 4

bolts, welds exists)

(Item Number

3.5.1 .A-30)

All Groups: support Loss of material Boric acid corrosion None Not applicable,

members: anchor due to boric acid PWR only

bolts, welds corrosion

(Item Number

3.5.1.A-31)

Groups B1.1, B1.2, Loss of material ISI ASME Section XI Consistent with

and B1.3: support due to Inservice Inspection GALL, which

members: anchor environmental (Subsection IWF) recommends no

bolts, welds, spring corrosion; loss of Program (B2.125) further evaluation

hangers, guides, mechanical function (See Section

stops, and vibration due to corrosion. 3.5A.2.1)

isolators distortion, dirt,

(Item Number overload, etc.

3.5.1 .A-32)

Group B1.1: high Crack initiation and Bolting integrity Bolting Integrity Consistent with

strength low-alloy growth due to SCC Program (B2.1.36) GALL, which

bolts recommends no

(Item Number further evaluation

3.5.1.A-33) (See Section

3.5A.2.1)

The staffs review of the NMP1 component groups followed one of several approaches. One

approach, documented in SER Section 3.5A.2.1, discusses the staff's review of the AMR

results for components in the structures and component supports that the applicant indicated

are consistent with the GALL Report and do not require further evaluation. Another approach,

documented in SER Section 3.5A.2.2, discusses the staffs review of the AMR results for

components in the structures and component supports that the applicant indicated are

consistent with the GALL Report and for which further evaluation is recommended. A third

approach, documented in SER Section 3.5A.2.3, discusses the staff's review of the AMR

results for components in the structures and component supports that the applicant indicated

are not consistent with, or not addressed in, the GALL Report. The staffs review of AMPs that

are credited to manage or monitor aging effects of the structures and component supports

components is documented in SER Section 3.0.3.

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3.5A.2.1 AMR Results That Are Consistent with the GALL Report

Summary of Technical Information in the Amended Application. In ALRA Sections 3.5.2.A and

3.5.2.C, the applicant identified the materials, environments, and AERMs. The applicant

identified the following programs that manage the aging effects related to the structures and

component supports components:

• Water Chemistry Control Program

* Boraflex Monitoring Program

* Inspection of Overhead Heavy Load and Light Load Handling Systems Program

* Fire Protection Program

• One-Time Inspection Program

• ASME Section Xl Inservice Inspection (Subsection IWE) Program

* ASME Section XI Inservice Inspection (Subsection IWF) Program

* 10 CFR 50 Appendix J Program

* Masonry Wall Program

• Structures Monitoring Program

* Bolting Integrity Program

• Protective Coating Monitoring and Maintenance Program

* Torus Corrosion Monitoring Program

Staff Evaluation. In ALRA Tables 3.5.2.A-1 through 3.5.2.A-1 I and Tables 3.5.2.C-1 and

3.5.2.C-2, the applicant provided a summary of AMRs for the structures and component

supports components, and identified which AMRs it considered to be consistent with the GALL

Report

For component groups evaluated in the GALL Report for which the applicant had claimed

consistency with the GALL Report, and for which the GALL Report does not recommend further

evaluation, the staff performed an audit and review to determine whether the plant-specific

components contained in these GALL Report component groups were bounded by the GALL

Report evaluation.

The applicant provided a note for each AMR line item. The notes indicate how the information in

the tables aligns with the information in the GALL Report. The staff audited those AMRs with

Notes A through E, which indicate that the AMR is consistent with the GALL Report.

Note A indicates that the AMR*line item is consistent with the GALL Report for component,

material, environment, and aging effect. In addition, the AMP is consistent with the AMP

identified in the GALL Report. The staff audited these line items to verify consistency with the

GALL Report and the validity of the AMR for the site-specific conditions.

Note B indicates that the AMR line item is consistent with the GALL Report for component,

material, environment, and aging effect. In addition, the AMP takes some exceptions to the

AMP identified in the GALL Report. The staff audited these line items to verify consistency with

the GALL Report. The staff verified that the identified exceptions to the GALL AMPs had been

reviewed and accepted by the staff. The staff also determined whether the AMP identified by

the applicant was consistent with the AMP identified in the GALL Report and whether the AMR

was valid for the site-specific conditions.

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Note C indicates that the component for the AMR line item, although different from, is

consistent with the GALL Report for material, environment, and aging effect. In addition, the

AMP is consistent with the AMP identified by the GALL Report. This note indicates that the

applicant was unable to find a listing of some system components in the GALL Report.

However, the applicant identified a different component in the GALL Report that had the same

material, environment, aging effect, and AMP as the component that was under review. The

staff audited these line items to verify consistency with the GALL Report. The staff also

determined whether the AMR line item of the different component was applicable to the

component under review and whether the AMR was valid for the site-specific conditions.

Note D indicates that the component for the AMR line item, although different from, is

consistent with the GALL Report for material, environment, and aging effect. In addition, the

AMP takes some exceptions to the AMP identified in the GALL Report. The staff audited these

line items to verify consistency with the GALL Report. The staff verified whether the AMR line

item of the different component was applicable to the component under review. The staff

verified whether the identified exceptions to the GALL AMPs had been reviewed and accepted

by the staff. The staff also determined whether the AMP identified by the applicant was

consistent with the AMP identified in the GALL Report and whether the AMR was valid for the

site-specific conditions.

Note E indicates that the AMR line item is consistent with the GALL Report for material,

environment, and aging effect, but a different AMP is credited. The staff audited these line

items to verify consistency with the GALL Report. The staff also determined whether the

identified AMP would manage the aging effect consistent with the AMP identified by the GALL

Report and whether the AMR was valid for the site-specific conditions.

The staff conducted an audit and review of the information provided in the ALRA, as

documented in the Audit and Review Report. The staff did not repeat its review of the matters

described in the GALL Report; however, the staff did verify that the material presented in the

ALRA was applicable and that the applicant identified the appropriate GALL Report AMRs. The

staffs evaluation is discussed below.

3.5A.2.1.1 Loss of Leak Tightness in Closed Position Due to Mechanical Wear of Locks,

Hinges and Closure Mechanisms

As documented in the Audit and Review Report, the staff noted that in ALRA Table 3.5.2.A-1

for component type equipment hatches (including stabilizers) and aging effect and aging effect

mechanisms loss of leak tightness Table 1 line item 3.5.1.B-05 is shown. During the audit the

staff requested that the applicant explain why an NMP2 line item is shown with a NMP1

component type.

In its response by letter dated December 1, 2005, the applicant stated that the line item was an

error. For NMP ALRA Table 3.5.2.A-1 (page 3.5-64) for component type equipment hatches

(including stabilizers) for aging effect and aging effect mechanism loss of leak tightness the

Table 1 reference was changed from Item 3.5.1.13-05 to Item 3.5.1 .A-05.

The staff reviewed the applicant's response and found the correction of the reference to

ALRA Table 3.5.1.A, Item 3.5.1.A-05 as is the proper NMP1 line item.

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The staff's review found that the applicant appropriately addressed the aging effect and aging

effect mechanism as recommended by the GALL Report.

3.5A.2.1.2 Crack Initiation and Growth Due to SCC; Loss of Material Due to Crevice Corrosion

As documented in the Audit and Review Report, the staff noted that in ALRA Table 3.5.2.A-2

for component type liners and aging effect and aging effect mechanism cracking the GALL

Report Volume 2 line item shown is Item III.A5.2-b with ALRA Table 3.5.1.A, Item 3.5.1.A-23.

The Note D shown states that the component is different from the GALL Report line item.

During the audit the staff requested that the applicant explain how this AMR line item

component differs from the GALL Report when GALL Report Item IIl.A5.2-b is also for the

component type liners.

In its response by letter dated December 1, 2005, the applicant stated that the note referenced

should be Note B instead of Note D. The reference would be to Note A except the AMP shown

takes exceptions to the GALL Report AMP. The applicant revised ALRA Table 3.5.2.A-2 to

change Note D to Note B for all AMR line item component liners with the aging effect/

mechanism of cracking.

The staff reviewed the applicant's response and found the correction of Note D to Note B

acceptable because it assigned the proper note to this AMR line item.

The staff's review found that the applicant appropriately addressed the aging effect and aging

effects mechanism, as recommended by the GALL Report.

3.5A.2.1.3 Aging of Component Supports

As documented in the Audit and Review Report, the staff noted that in ALRA Table 3.5.2.A-1

for component type expansion/grouted anchors and aging effect and aging effect mechanism

loss of anchor capacity the GALL Report Volume 2 line items shown are Items 1II.B13.1.4-a and

Ill.B1 .2.3-a with ALRA Table 3.5.1.A, Item 3.5.1.A-29. The environment shown is concrete and

the note states that it is consistent with the GALL Report. During the audit the staff requested

that the applicant explain how this AMR line item is consistent with the GALL Report when the

two GALL Report line items have a component type of concrete surrounding anchor bolts, a

material of concrete, an environment of inside containment, and an aging effect and aging

effect mechanism of reduction in anchor capacity. The logic of this AMR line item was not

consistent with the GALL Report. Such inconsistency also applied to ALRA Tables 3.5.2.A-2,

3.5.2.A-6, 3.5.2.A-8, and 3.5.2.A-9 for component type expansion/grouted anchors. These four

additional AMR line items are shown in the ALRA as associated with the GALL Report Volume

2 Item III.B11.2.3-a only.

In its response by letter dated December 1, 2005, the applicant stated that it had made the

ALRA consistent with the GALL Report for all of its expansion/grouted anchor AMR line items

listed above. The ALRA line item for carbon steel in concrete was revised. In its place the

component type was changed to concrete surrounding anchor bolts, the carbon steel was

replaced with concrete (new line with the current line that starts with concrete), the environment

of concrete was replaced with air, and the rest of the lines remained as displayed. The applicant

used the AERM of loss of anchor capacity instead of reduction in anchor capacity as per the

GALL Report but intended these terms to have exactly the same meaning.

3-444
The staff reviewed the applicant's response and found after revision of the applicant's AMR line

items for the component expansion/grouted anchor (component type concrete surrounding

anchor bolts after revision) are consistent with the GALL Report and therefore acceptable.

As documented in the Audit and Review Report, the staff noted that in ALRA Table 3.5.2.A-1 1

for component type expansion/grouted anchors and aging effect and aging effect mechanism

loss of anchor capacity the GALL Report Volume 2 line item shown is Item Ill.B13.2.3-a with.

ALRA Table 3.5.1.A, Item 3.5.1.A-19. The environment shown is concrete and the note states

that it is consistent with the GALL Report. During the audit the staff requested that the applicant

explain how this AMR line item is consistent with the GALL Report when the GALL Report line

item has a component type of concrete surrounding anchor bolts, a material of concrete, an

environment of inside or outside containment, and an aging effect and aging effect mechanism

of reduction in anchor capacity. The logic of this AMR line item was not consistent with the

GALL Report. The staff asked the applicant to explain why the ALRA Table 3.5.1 .A line item

shown was Item 3.5.1.A-19 instead of Item 3.5.1.A-29.

In its response by letter dated December 1, 2005, the applicant stated that it had made the

ALRA consistent with the GALL Report for the expansion/grouted anchor AMR line item. The

ALRA line for carbon steel in concrete was revised. In its place the component type was

changed to concrete surrounding anchor bolts, the material of carbon steel was replaced with

concrete (new line with the current line that starts with concrete), the environment of concrete

was replaced with air, and the rest of the line remained as displayed. The applicant used the

AERM of loss of anchor capacity instead of reduction in anchor capacity per the GALL Report;'

however it is intended that these items have exactly the same meaning. The ALRA

Table 3.5.1.A, Item 3.5.1.A-19 listed in error was revised to ALRA Table 3.5.1.A,

Item 3.5.1.A-29.

The staff reviewed the applicant's response and found that after revision the applicant's AMR

line item for the component expansion/grouted anchor (now component type, concrete

surrounding anchor bolts, after revision) is consistent with the GALL Report and therefore

acceptable. The staff also found the correction of the reference to ALRA Table 3.5.1.A,

Item 3.5.1.A-29 appropriate.

The staff's review found that the applicant appropriately addressed the aging effect and aging

effect mechanism, as recommended by the GALL Report.

Conclusion. The staff evaluated the applicant's claim of consistency with the GALL Report. The

staff also reviewed information pertaining to the applicant's consideration of recent operating

experience and proposals for managing associated aging effects. On the basis of its review, the

staff concludes that there is reasonable assurance that the AMR results, which the applicant

claimed to be consistent with the GALL Report, are consistent with the AMRs in the GALL

Report. Therefore, the staff concludes that the applicant had demonstrated that the effects of

aging for these components will be adequately managed so that their intended function(s) will

be maintained consistent with the CLB for the period of extended operation, as required by

10 CFR 54.21(a)(3).

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3.5A.2.2 AMR Results That Are Consistent with the GALL Report, for Which Further

Evaluation is Recommended

Summary of Technical Information in the Amended Application. In Section 3.5.2.C of its letter

dated August 19, 2005, the applicant provided further evaluation of aging management as

recommended by the GALL Report for the structures and component supports components.

The applicant provided information concerning how it will manage the following aging effects:

BWR Containment:

" aging of inaccessible concrete areas

" cracking, distortion, and increase in component stress level due to settlement; reduction

of foundation strength due to erosion of porous concrete subfoundations, if not covered

by structures monitoring program

* reduction of strength and modulus of concrete structures due to elevated temperature

* loss of material due to corrosion in inaccessible areas of steel containment shell or liner

plate

" loss of prestress due to relaxation, shrinkage, creep, and elevated temperature

" cumulative fatigue damage

" cracking due to cyclic loading and SCC

Class I Structures:

0 aging of structures not covered by structures monitoring program

• aging management of inaccessible areas

Component Supports:

* aging of supports not covered by structures monitoring program

• cumulative fatigue damage due to cyclic loading

Staff Evaluation. For component groups evaluated in the GALL Report for which the applicant

had claimed consistency with the GALL Report, and for which the GALL Report recommends

further evaluation, the staff audited and reviewed the applicant's evaluation to determine

whether it adequately addressed the issues that were further evaluated. In addition, the staff

reviewed the applicant's further evaluations against the criteria contained in SRP-LR

Section 3.5.2.2. Details of the staff's audit are documented in the staff's Audit and Review

Report. The staffs evaluation of the aging effects is discussed in the following sections.

3.5A.2.2.1 PWR and BWR Containments

The staff reviewed Section 3.5.2.C.1 of the applicant's letter dated August 19, 2005 against the

criteria in SRP-LR Section 3.5.2.2.1, which addresses several areas discussed below.

Aging of Inaccessible Concrete Areas. The staff reviewed Section 3.5.2.C.1.1 of the applicant's

letter dated August 19, 2005 against the criteria in SRP-LR Section 3.5.2.2.1.1.

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In Section 3.5.2.C.1.1 of its letter dated August 19, 2005, the applicant stated that the aging of

inaccessible concrete areas in BWR containments effect and aging effect mechanism is not

applicable to NMP1, a BWR with a Mark I containment. As documented in the Audit and Review

Report, the staff determined through discussions with the applicant's technical personnel that

the aging of inaccessible concrete areas in BWR containments is not applicable because NMP1

is a BWR with a Mark I containment

Because NMP1 has no components from this group the staff found this aging effect and aging

effect mechanism not applicable.

Cracking, Distortion, and Increase in Component Stress Level due to Settlement: Reduction of

Foundation Strenath due to Erosion of Porous Concrete Subfoundations, if Not Covered by

Structures Monitoring Program. The staff reviewed Section 3.5.2.C.1.2 of the applicant's letter

dated August 19, 2005 against the criteria in SRP-LR Section 3.5.2.2.1.2.

In Section 3.5.2.C.1.2 of its letter dated August 19, 2005, the applicant stated that the aging

effect and aging effect mechanism cracking, distortion, and increase in component stress level

due to settlement; and reduction of foundation strength due to erosion of porous concrete

subfoundations in BWR containments is not applicable because NMP1 is a BWR with a Mark I

containment. The staff determined through discussions with the applicant's technical personnel

that this aging effect and aging effect mechanism does not apply because NMP1 is a BWR with

a Mark I containment..

Because NMP1 has no components from this group the staff found this aging effect and aging

effects mechanism not applicable.

Reduction of Strenath and Modulus of Concrete Structures due to Elevated Temperature. The

staff reviewed Section 3.5.2.C.1.3 of the applicant's letter dated August 19, 2005, against the

criteria in SRP-LR Section 3.5.2.2.1.3.

In Section 3.5.2.C.1.3 of its letter dated August 19, 2005, the applicant stated that the aging

effect and aging effect mechanism reduction of strength and modulus of concrete structures

due to elevated temperature in BWR containments is not applicable to NMPI. As documented

in the Audit and Review Report, the staff determined through discussions with the applicant's

technical personnel that this aging effect and aging effect mechanism is not applicable because

NMP1 is a BWR with a Mark I containment.

Because NMP1 has no components from this group the staff found this aging effect and aging

effects mechanism not applicable.

Loss of Material due to Corrosion in Inaccessible Areas of Steel Containment Shell or Liner

Plate. The staff reviewed Section 3.5.2.C.1.4 of the applicant's letter dated August 19, 2005,

against the criteria in SRP-LR Section 3.5.2.2.1.4.

In Section 3.5.2.C.1.4 of its letter dated August 19, 2005, the applicant addressed loss of

material due to corrosion in inaccessible areas of steel containment shell or liner plate in BWR

containments.

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SRP-LR Section 3.5.2.2.1.4 states that loss of material due to corrosion could occur in

inaccessible areas of the steel containment shell or the steel liner plate for all types of BWR

containments. The GALL Report recommends further evaluation of plant-specific programs to

manage this aging effect and aging effect mechanism for inaccessible areas if specific

conditions defined in the GALL Report cannot be satisfied.

For NMP1 the ASME Section Xl Inservice Inspection (Subsection IWE) Program is credited with

managing aging effects and aging effects mechanisms due to corrosion of accessible primary

containment structure carbon steel components comprising the containment pressure

boundary. Inaccessible areas are compared to accessible areas with similar environments. If

warranted additional inspections are performed.

In Section 3.5.2.C.1.4 of its letter dated August 19, 2005, the applicant also stated that NMP1

credits the Water Chemistry Control Program and Torus Corrosion Monitoring Program with

managing aging effects and aging effects mechanisms due to corrosion of primary containment

structure carbon steel components in demineralized untreated water.

The staff reviewed the applicant's ASME Section Xl Inservice Inspection (Subsection IWE),

Water Chemistry Control, and Torus Corrosion Monitoring Programs and its evaluations are in

SER Sections 3.0.3.2.17, 3.0.3.2.2, and 3.0.3.3.7, respectively.

The staff noted in SRP-LR Section 3.5.2.2.1.4 that the GALL Report recommends further

evaluation of plant-specific programs to manage this aging effect and aging effect mechanism

for inaccessible areas if specific conditions defined in the GALL Report cannot be satisfied.

GALL Report Item 61.1.1-a states that for inaccessible areas (embedded containment steel

shell or liner), loss of material due to corrosion is not significant if the following four specific

conditions are satisfied:

(1) Concrete meeting the requirements of ACl 318 or 349 and the guidance of 201.2R was

used for the containment concrete in contact with the embedded containment shell or

liner.

(2) The concrete is monitored to ensure that it is free of Oenetrating cracks that provide a

path for water seepage to the surface of the containment shell or liner.

(3) The moisture barrier, at the junction where the shell or liner becomes embedded, is

subject to aging management activities in accordance with IWE requirements.

(4) Borated water spills and water ponding on the containment concrete floor are not

common and when detected are cleaned up in a timely manner.

The GALL Report recommends a plant-specific AMP for corrosion if any of the four conditions

cannot be satisfied. As documented in the Audit and Review Report, the staff asked the

applicant to explain how each of the four conditions is satisfied at NMP1. The applicant

addressed the four conditions:

(1) NMP1 was designed and constructed with equivalent codes as specified in the GALL

Report

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(2) The concrete is monitored in accordance with the applicant's ASME Section XI Inservice

Inspection (Subsection IWE) and Structures Monitoring Programs.

(3) This condition is not applicable to the NMP design.

(4) This condition is not applicable to a BWR design.

The staffs audit and review determined that all of the conditions identified in the GALL Report

are satisfied. The applicant stated that the NMP1 containment was designed and constructed

with codes equivalent to those specified in the GALL Report. Accessible concrete of the

containment structure is monitored for penetrating cracks by the applicant's ASME Section Xl

Inservice Inspection (Subsection IWE) and Structures Monitoring Programs. Operating

experience demonstrates that the aging effect and aging effect mechanism of loss of material

due to corrosion has not been significant for the NMP1 steel containment shell. The staff found

that no additional plant-specific AMP is required to manage inaccessible areas of the steel

containment shell.

Based on the programs identified above, the staff concludes that there is reasonable assurance

that the applicant had met the criteria of SRP-LR Section 3.5.2.2.1.4. For those line items that

apply to Section 3.5.2.C.1.4 of the applicant's letter dated August 19, 2005, the staff determined

that the information in the application is consistent with the GALL Report and the applicant had

demonstrated that the effects of aging will be adequately managed so that the intended

function(s) will be maintained consistent with the CLB during the period of extended operation,

as required by 10 CFR 54.21(a)(3).

Loss of Prestress due to Relaxation, Shrinkage, Creep, and Elevated Temperature. The staff

reviewed Section 3.5.2.C.1.5 of the applicant's letter dated August 19, 2005, against the criteria

in SRP-LR Section 3.5.2.2.1.5.

The applicant stated in Section 3.5.2.C.1.5 of the letter dated August 19, 2005, that the aging

effect and aging effect mechanism loss of prestress due to relaxation, shrinkage, creep, and

elevated temperature in BWR containments is not applicable to NMP1. As documented in the

Audit and Review Report, the staff determined through discussions with the applicant's

technical personnel that because NMP1 is a BWR with a Mark I containment this aging effect

and aging effect mechanism does not apply.

Because NMP has no components from this group the staff found this aging effect and aging

effect mechanism not applicable.

Cumulative Fatigue Damage. In Section 3.5.2.C.1.6 of its letter dated August 19, 2005, the

applicant stated that fatigue is a TLAA as defined in 10 CFR 54.3. Applicants must evaluate

TLAAs in accordance with 10 CFR 54.21(c)(1). SER Section 4.6 documents the staffs review of

the applicant's evaluation of this TLAA.

Cracking due to Cyclic Loading and SCC. The staff reviewed Section 3.5.2.C.1.7 of the

applicant's letter dated August 19, 2005, against the criteria in SRP-LR Section 3.5.2.2.1.7.

In Section 3.5.2.C.1.7 of its letter dated August 19, 2005, the applicant addressed cracking due

to cyclic loading and SCC in BWR containments.

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SRP-LR Section 3.5.2.2.1.7 states that cracking of containment penetrations (including

penetration sleeves, penetration bellows, and dissimilar metal welds) due to cyclic loading or

SCC could occur in all types of PWR and BWR containments. Cracking could occur also in vent

line bellows, vent headers, and downcomers due to SCC for BWR containments. A visual VT-3

examination would not detect such cracks. The GALL Report recommends further evaluation of

the inspection methods implemented to detect these aging effects and aging effects

mechanisms.

In Section 3.5.2.C.1.7 of its letter dated August 19, 2005, the applicant stated that the ASME

Section XI Inservice Inspection (Subsection IWE) Program and 10 CFR 50 Appendix J Program

are credited with managing cracking due to cyclic loading and SCC of primary containment

structure steel components. In addition an augmented VT-1 visual examination will be

performed on containment bellows using enhanced techniques qualified for detecting SCC.

The staff reviewed the applicant's ASME Section XI Inservice Inspection (Subsection IWE) and

10 CFR 50 Appendix J Programs and its evaluations are in SER Sections 3.0.3.2.17and

3.0.3.1.7, respectively.

The staff found that after further evaluation as recommended by the GALL Report for detecting

cracking due to SCC the applicant had elected to perform augmented VT-1 visual examinations

on containment bellows using enhanced techniques qualified for detecting SCC. The staff found

this election consistent with the GALL Report and, therefore, acceptable.

Based on the programs identified above, the staff concludes that there is reasonable assurance

that the applicant has met the criteria of SRP-LR Section 3.5.2.2.1.7. For those line items that

apply to Section 3.5.2.C.1.7 of the applicant's letter dated August 19, 2005, the staff determined

that the information in the application is consistent with the GALL Report and the applicant had

demonstrated that the effects of aging will be adequately managed so that the intended

function(s) will be maintained consistent with the CLB during the period of extended operation,

as required by 10 CFR 54.21 (a)(3).

3.5A.2.2.2 Class I Structures

The staff reviewed Section 3.5.2.C.2 of the applicant's letter dated August 19, 2005, against the

criteria in SRP-LR Section 3.5.2.2.2, which addresses several areas discussed below.

Aging of Structures Not Covered by Structures Monitoring Program. The staff reviewed

Section 3.5.2.C.2.1 of the applicant's letter dated August 19, 2005, against the criteria in

SRP-LR Section 3.5.2.2.2.1.

In Section 3.5.2.C.2.1 of its letter dated August 19, 2005, the applicant addressed the aging of

all Class I structures not covered by the Structures Monitoring Program.

SRP-LR Section 3.5.2.2.2.1 states that the GALL Report recommends further evaluation of

certain structure-aging effect combinations if not covered by the applicant's Structures

Monitoring Program, including (1) scaling, cracking, and spalling due to repeated freeze-thaw

for Groups 1-3, 5, 7-9 structures; (2) scaling, cracking, spalling and increased porosity and

permeability due to leaching of calcium hydroxide and aggressive chemical attack for Groups

1-5, 7-9 structures; (3) expansion and cracking due to reaction with aggregates for Groups 1-5,

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7-9 structures; (4) cracking, spalling, loss of bond, and loss of material due to corrosion of

embedded steel for Groups 1-5, 7-9 structures; (5) cracks, distortion, and increase in

component stress level due to settlement for Groups 1-3, 5, 7-9 structures; (6) reduction of

foundation strength due to erosion of porous concrete subfoundation for Groups 1-3, 5-9

structures; (7) loss of material due to corrosion of structural steel components for Groups 1-5,

7-8 structures; (8) loss of strength and modulus of concrete structures due to elevated

temperatures for Groups 1-5; and (9) crack initiation and growth due to SCC and loss of

material due to crevice corrosion of stainless steel liner for Groups 7 and 8 structures. Further

evaluation is necessary only for structure-aging effect combinations not covered by the

applicant's Structures Monitoring Program.

SRP-LR Section 3.5.2.2.2.1 further states that technical details of the aging management issue

are presented in Subsection 3.5.2.2.1.2 for Items (5) and (6) and Subsection 3.5.2.2.1.3 for

Item (8).

In Section 3.5.2.C.2.1 of its letter dated August 19, 2005, the applicant stated that there are no

Group 6 structures (water control structures) at NMPI.

In addition the applicant stated in Section 3.5.2.C.2.1 of its letter dated August 19, 2005, that

aging management of components in accessible areas of Class I structures will be by general

visual inspections of its Structures Monitoring Program. Aging management is performed for the

following aging effect and aging effect mechanisms: freeze-thaw, leaching of calcium

hydroxide, aggressive chemical attack, reaction with aggregates, corrosion of embedded steel,

and corrosion of structural steel.

Further, the applicant stated in Section 3.5.2.C.2.1 of its letter dated August 19, 2005, that for

NMP1 cracking, distortion, and an increase in component stress level due to settlement for

Group 1-3, 5, 7-9 structures is not significant. Class I structures are founded on impervious

rock. Although evaluated as not significant, the applicant credited its Structures Monitoring

Program with monitoring for settlement. NMP1 does not utilize a dewatering system.

The applicant also stated in Section 3.5.2.C.2.1 of its letter dated August 19, 2005, that for

NMP1 reduction of foundation strength due to erosion of porous concrete subfoundation for

Group 1-3, 5, 7-9 structures is not applicable. Porous concrete is not utilized in the construction

of Class I structures.

In Section 3.5.2.C.2.1 of its letter dated August 19, 2005, the applicant stated that for NMP1

loss of material due to corrosion of structural steel components for Group 1-5, 7-8 structures is

managed by its Structures Monitoring Program. Although NMP1 vent stack steel components

are not identified in the GALL Report these components are also managed using the applicant's

Structures Monitoring Program. Additionally, the applicant credited the ASME Section XI

Inservice Inspection (Subsection IWE) Program in lieu of its Structures Monitoring Program with

managing loss of material due to corrosion of high-strength structural fasteners in

demineralized untreated water.

The staff review and evaluations of the applicant's Structures Monitoring and ASME Section Xl

Inservice Inspection (Subsection IWE) Programs are in SER Sections 3.0.3.2.21 and

3.0.3.2.17, respectively.

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In addition the applicant stated in its letter dated August 19, 2005, that for NMP1 loss of

strength and modulus of concrete structures due to elevated temperatures for Group 1-5

structures is not significant. In Class I structures where general area temperatures do not

exceed 150'F and local area temperatures do not exceed 2000F. These temperatures are not

sufficient to cause this aging effect and aging effect mechanism of the applicable components.

Furthermore, the applicant stated in its letter dated August 19, 2005, that for NMP1 crack

initiation and growth due to SCC and loss of material due to crevice corrosion of stainless steel

liners for Group 7 and 8 structures is not applicable. No tank liners were identified as subject to

an AMR.

The staff's audit and review found that scaling, cracking, and spalling due to repeated

freeze-thaw for Groups 1-3, 5, 7-9 structures; scaling, cracking, spalling and increase in

porosity and permeability due to leaching of calcium hydroxide and aggressive chemical attack

for Groups 1-5, 7-9 structures; expansion and cracking due to reaction with aggregates for

Groups 1-5, 7-9 structures; cracking, spalling, loss of bond, and loss of material due to

corrosion of embedded steel for Groups 1-5, 7-9 structures; cracks, distortion, and increase in

component stress level due to settlement for Groups 1-3, 5, 7-9 structures; and loss of material

due to corrosion of structural steel components for Groups 1-5, 7-8 structures are within the

scope of license renewal and will be adequately managed by the applicant's Structures

Monitoring Program.

As documented in the Audit and Review Report, the staff interviewed members of the

applicant's technical personnel and reviewed relevant operating experience to confirm that

these aging effects and aging effects mechanisms have not been observed or when observed,

corrective action was taken under the applicant's Structures Monitoring Program. The staff

found that the recommendations of the GALL Report have been satisfied and a plant-specific

AMP for these aging effects and aging effects mechanisms of Class I structures is not required.

The staff's audit and review found that reduction of foundation strength due to erosion of

porous concrete subfoundations of Groups 1-3, 5,and 7-9 structures is an absent and

implausible aging effect and aging effect mechanism. The applicant stated that porous concrete

subfoundations were not utilized below the building foundations for Groups 1-3, 5, and 7-9

structures. The staff determined that no AMP is required because this aging effect and aging

effect mechanism does not occur at NMP1.

The staff found the applicant's further evaluation for elevated temperatures acceptable because

change in material properties due to elevated temperatures is an aging effect and aging effect

mechanism requiring no management for the NMP1 Groups 1-5 Class I structures.

The applicant stated in Section 3.5.2.C.2.1 of its letter dated August 19, 2005, that the aging

effects and aging effects mechanisms of crack initiation and growth due to SCC and loss of

material due to crevice corrosion of stainless steel liners for NMP1 Group 7 and 8 structures are

not applicable because no tank liners were identified as subject to AMR. The staff's audit and

review determined that no AMP is required for aging effects and aging effects mechanisms for

stainless steel liners for Group 7 and 8 structures.

Based on the programs identified above, the staff concludes that there is reasonable assurance

that the applicant has met the criteria of SRP-LR Section 3.5.2.2.2.1. For those line items that

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apply to Section 3.5.2.C.2.1 of the applicant's letter dated August 19, 2005, the staff determined

that the information in the application is consistent with the GALL Report and the applicant had

demonstrated that the effects of aging will be adequately managed so that the intended

function(s) will be maintained consistent with the CLB during the period of extended operation,

as required by 10 CFR 54.21 (a)(3).

Aging Management of Inaccessible Areas. The staff reviewed Section 3.5.2.C.2.2 of the

applicant's letter dated August 19, 2005, against the criteria in SRP-LR Section 3.5.2.2.2.2.

In Section 3.5.2.C.2.2 of its letter dated August 19, 2005, the applicant addressed aging

management of inaccessible areas of Class I structures.

SRP-LR Section 3.5.2.2.2.2 states that cracking, spalling, and increases in porosity and

permeability due to aggressive chemical attack and cracking, spalling, loss of bond, and loss of

material due to corrosion of embedded steel could occur in below-grade inaccessible concrete

areas. The GALL Report recommends further evaluation to manage these aging effects and

aging effects mechanisms in inaccessible areas of Groups 1-3, 5, 7-9 structures if specific

conditions defined in the GALL Report cannot be satisfied.

In Section 3.5.2.C.2.2 of its letter dated August 19, 2005, the applicant stated that for NMP1

cracking, spalling, and increases in porosity and permeability due to aggressive chemical attack

and cracking, spalling, loss of bond, and loss of material due to corrosion of embedded steel

are not significant. Ground water tests confirm that no below-grade aggressive environment

exists. The applicant evaluated aggressive chemical attack and corrosion of embedded steel as

not significant but credits the Structures Monitoring Program with monitoring for them. A

regularly scheduled ground water monitoring program will ensure maintenance of a benign

environment. The staffs review and evaluation of the applicant's Structures Monitoring Program

are in SER Section 3.0.3.2.21.

As documented in the Audit and Review Report, the staff determined through discussions with

the applicant's technical personnel and review of the ALRA that the recommendations of the

GALL Report had been satisfied and that a plant-specific AMP for inaccessible concrete of

Class I (Groups 1-3, 5, 7-9) structures was not required for these locally insignificant aging

effect and aging effect mechanisms.

Because NMP has a regularly scheduled for ground water monitoring to ensure that the

below-grade environment remains non-aggressive and has no cracking, spalling, increases in

porosity and permeability, loss of bond, or loss of material for inaccessible concrete, the staff

determined that these aging effects and aging effects mechanisms are not applicable to NMP

Groups 1-3, 5, 7-9 Class I structures.

Based on the programs identified above, the staff concludes that there is reasonable assurance

that the applicant has met the criteria of SRP-LR Section 3.5.2.2.2.2. For those line items that

apply to Section 3.5.2.C.2.2 of the applicant's letter dated August 19, 2005, the staff determined

that the information in the application is consistent with the GALL Report and the applicant had

demonstrated that the effects of aging will be adequately managed so that the intended

function(s) will be maintained consistent with the CLB during the period of extended operation,

as required by 10 CFR 54.21(a)(3).

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3.5A.2.2.3 Component Supports

The staff reviewed Section 3.5.2.C.3 of the applicant's letter dated August 19, 2005, against the

criteria in SRP-LR Section 3.5.2.2.3, which addresses several areas discussed below.

Aping of Supports Not Covered by Structures Monitoring Program. The staff reviewed

Section 3.5.2.C.3.1 of the applicant's letter dated August 19, 2005, against the criteria in

SRP-LR Section 3.5.2.2.3.1.

In Section 3.5.2.C.3.1 of its letter dated August 19, 2005, the applicant addressed aging of

component supports not covered by the Structures Monitoring Program.

SRP-LR Section 3.5.2.2.3.1 states that the GALL Report recommends further evaluation of

certain component support-aging effect and aging effect mechanism combinations not covered

by the applicant's Structures Monitoring Program including (1) reduction in concrete anchor

capacity due to degradation of the surrounding concrete for Groups B1-B5 supports, (2) loss of

material due to environmental corrosion for Groups B2-B5 supports, and (3) reduction/loss of

isolation function due to degradation of vibration isolation elements for Group B4 supports.

Further evaluation is necessary only for structure-aging effect combinations not covered by the

applicant's Structures Monitoring Program.

In Section 3.5.2.C.3.1 of its letter dated August 19, 2005, the applicant stated that aging

management of component supports will be performed through general visual inspections of its

Structures Monitoring Program. Aging management is performed for reduction in concrete

anchor capacity due to degradation of the surrounding concrete, loss of material due to

environmental corrosion, and reduction/loss of isolation function due to degradation of vibration

isolation elements.

The staff found that the applicant's Structures Monitoring Program covers reduction in concrete

anchor capacity due to degradation of the surrounding concrete for Groups B1 through B5

supports, loss of material due to environmental corrosion for Groups B2 through B5 supports,

and reduction/loss of isolation function due to degradation of vibration isolation elements for

Group B4 supports. As per the GALL Report no further evaluation is required and, therefore,

has not been provided.

The staff found that the applicant included the aging effect and aging effect mechanism

combinations within the scope of its Structures Monitoring Program and agreed that no further

evaluation is required. The staff review and evaluation of the applicant's Structures Monitoring

Program are in SER Section 3.0.3.2.21. The staff found the applicant's Structures Monitoring

Program acceptable for managing the aging effect and aging effect mechanism combinations

of component supports for the GALL Report component support Groups B1 through B5 as

those combinations are applicable.

Based on the programs identified above, the staff concludes that there is reasonable assurance

that the applicant has met the criteria of SRP-LR Section 3.5.2.2.3.1. For those line items that

apply to Section 3.5.2.C.3.1 of the applicant's letter dated August 19, 2005, the staff determined

that the information in the application is consistent with the GALL Report and the applicant had

demonstrated that the effects of aging will be adequately managed so that the intended

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function(s) will be maintained consistent with the CLB during the period of extended operation,

as required by 10 CFR 54.21 (a)(3).

Cumulative Fatique Damage due to Cyclic Loading. Fatigue is a TLAA as defined in

10 CFR 54.3. Applicants must evaluate TLAAs in accordance with 10 CFR 54.21(c)(1). SER

Section 4 documents the staff's review of the applicant's evaluation of this TLAA.

3.5A.2.2.4 Quality Assurance for Aging Management of Nonsafety-Related Components

SER Section 3.0.4 includes the staffs evaluation of the applicant's Quality Assurance Program.

Conclusion. On the basis of its review, for component groups evaluated in the GALL Report for

which the applicant had claimed consistency with the GALL Report, and for which the GALL

Report recommends further evaluation, the staff determined that the applicant adequately

addressed the issues that were further evaluated. The staff found that the applicant had

demonstrated that the effects of aging will be adequately managed so that intended functions

will be maintained consistent with the CLB for the period of extended operation, as required by

10 CFR 54.21(a)(3).

3.5A.2.3 AMR Results That Are Not Consistent with or Not Addressed in the GALL

Report

Summary of Technical Information in the Application. In ALRA Tables 3.5.2.A-1 through

3.5.2.A-1 1 and Tables 3.5.2.C-1 and 3.5.2.C-2, the staff reviewed additional details of the

results of the AMRs for material, environment, aging effect requiring management, and AMP

combinations that are not consistent with the GALL Report, or that are not addressed in the

GALL Report.

In ALRA Tables 3.5.2.A-1 through 3.5.2.A-1 1 and Tables 3.5.2.C-1 and 3.5.2.C-2, the applicant

indicated, via Notes F through J, that the combination of component type, material,

environment, and aging effect requiring management does not correspond to a line item in the

GALL Report, and provided information concerning how the aging effect will be managed.

Specifically, Note F indicated that the material for the AMR line item component is not

evaluated in the GALL Report. Note G indicated that the environment for the AMR line item

component and material is not evaluated in the GALL Report. Note H indicated that the aging

effect for the AMR line item component, material, and environment combination is not evaluated

in the GALL Report. Note I indicated that the aging effect identified in the GALL Report for the

line item component, material, and environment combination is not applicable. Note J indicated

that neither the component nor the material and environment combination for the line item is

evaluated in the GALL Report.

Staff Evaluation. For component type, material, and environment combinations that are not

evaluated in the GALL Report, the staff reviewed the applicant's evaluation to determine

whether the applicant had demonstrated that the effects of aging will be adequately managed

so that the intended function(s) will be maintained consistent with the CLB during the period of

extended operation. The staffs evaluation is discussed in the following sections.

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3.5A.2.3.1 Structures and Component Supports NMPI Primary Containment Structure -

Summary of Aging Management Evaluation - ALRA Table 3.5.2.A-1

The staff initially reviewed the original LRA Table 3.5.2.A-1, which summarizes the results of

AMR evaluations for the primary containment structure component groups.

Staff Evaluation. In RAI 3.5.A-1 dated December 9, 2004, the staff noted that in items 3.5.1 A-3

and 3.5.1.A-17 of original LRA Table 3.5.1.A, the applicant had asserted AMR results

consistent with the GALL Report with the exceptions described in AMP 8.2.1.23. The GALL

Report under item B13.1.1.-d recommends further evaluation of the stress corrosion cracking of

containment bellows. In the discussion of these items with the staff the applicant asserted that

crack initiation and growth due to SCC are not applicable to NMP1 vent line bellows. The staff

further noted that in similar environmental conditions NRC IN 92-20 reports thermal growth

SCC of pressure boundary bellows. Therefore, the staff requested that the applicant provide

additional information to address the effectiveness of the applicable AMP(s) to detect

degradation of vent line as well as other containment penetration bellows.

In its response by letter dated January 10, 2005, the applicant provided the following answer:

Although the vent line bellows, vent line headers, and downcomers at NMPI are

not normally subjected to conditions that cause cracking due to cyclic loading

and crack growth due to stress corrosion cracking (SCC), the [original] LRA will

be revised to reflect the recommendations in NUREG- 1611, Table 2, Item 12.

The recommendations in NUREG-1611 identify stress corrosion cracking as an

aging effect requiring management by examination categories E-B and E-F of

the ASME Section Xl Inservice inspection (Subsection IWE) Program ([original]

LRA Section B2.1.23) and by the 10 CFR 50 Appendix J Program ([original] LRA

Section B2.1.26). In addition, per NUREG-1611, an augmented VT-1 visual

examination will be performed using enhanced techniques qualified for detecting

SCC. This augmented inspection will be included as an enhancement to the IWE

inspection program.

The applicant proposed the following revisions to its original LRA:

In Section A1.1.2 the applicant added the following paragraph:

The NMP1 ASME Section XI Inservice Inspection (Subsection IWE) Program is

being enhanced to add an augmented VT-I visual examination of the NMP1

containment penetration bellows. This inspection will be performed using

enhanced techniques qualified for detecting SCC per NUREG-161 1, Table 2,

Item 12.

In Section A2.1.2 the applicant added the following paragraph:

The NMP2 ASME Section XI Inservice Inspection (Subsection IWE) Program is

being enhanced to add an augmented VT-i visual examination of the NMP2

containment penetration bellows. This inspection will be performed using

enhanced techniques qualified for detecting SCC per NUREG-161 1, Table 2,

Item 12.

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In Section B2.1.23 under the "Enhancements" heading the applicant replaced "None" with the

following:

An augmented VT-I visual examination of the NMP1 and NMP2 containment

penetration bellows will be performed using enhanced techniques qualified for

detecting SCC, per NUREG-1611, Table 2, Item 12.

The staff's review found the applicant's response to RAI 3.5.A-1 acceptable. A review of the

ALRA indicated that the applicant had incorporated the enhancements stated in the applicant's

response to RAI 3.5.A-1. The staff found the applicant's proposed revision of the original LRA

to incorporate the augmented inspection of the containment pressure retaining bellows

acceptable. Therefore, the staffs concern described in RAI 3.5.A-1 is resolved. This information

is reflected in the ALRA.

In RAI 3.5.A-2 dated December 9, 2004, the staff asked the applicant to justify the Type B leak

rate testing frequency for monitoring aging degradation of containment pressure boundary

mechanical and electrical penetrations with seals and gaskets, noting that item number

3.5.1 .A-06 of the original LRA Table 3.5.1 .A states that containment ISI (AMP B.2.1.23) and

containment leak rate test (AMP B.2.1.26) are programs for managing aging of seals, gaskets,

and moisture barriers. Original LRA Table 3.5.2.A addresses these components under a

generic category of "polymer in air." However, based on an exception taken in AMP B.2.1.23

this AMP will not be applicable to containment seals and gaskets. The staff requested the

applicant to explain this discrepancy.

In the RAI the staff further noted that the leak rate testing program would monitor aging

degradation of seals and gaskets of equipment hatches and air-locks at NMP1 as they are leak

rate tested after each opening. Therefore, the staff requested that the applicant justify Type B

leak rate testing frequency for adequately monitoring aging degradation of containment

pressure boundary penetrations (mechanical and electrical) with seals and gaskets.

In its response by letter dated January 10, 2005, the applicant provided the following

explanation:

The inspection of the component type "Polymer in Air" is included in the ASME

Section XI Inservice Inspection (Subsection IWE) Program ([original] LRA

Section B2.1.23). The exception described in [original] LRA Section B2.1.23

identifies that the Subsection IWE inservice inspection (ISI) program for NMP1 is

based on the 1998 Edition of ASME Section XI, rather than the 199211995

editions and addenda. This was found acceptable by the NRC in a safety

evaluation report dated August 17, 2000. There is no exception taken to the

performance of examinations for the subject polymeric components.

The aging management of the electrical penetrations and their associated

polymeric components is addressed in the NMPNS LRA supplemental letter

NMP1L 1912, dated January 10, 2005. These components are managed by the

ASME Section Xl Inservice Inspection Program ([original] LRA Section B2.1.23)

and the 10 CFR 50 Appendix J Program ([original] LRA Section B2.1.26). The

mechanical primary containment penetrations for NMPI are seal-welded to the

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containment shell and do not utilize polymeric seals or gaskets for pressure

retention. ..

NMP1 uses Option B for testing of the containment under 10 CFR 50,

Appendix J. Type B testing of containment penetrations follows the guidance

provided in NRC Regulatory Guide 1.163 and Nuclear Energy

Institute (NEI) 94-01. The testing frequency for these components is at least

once per 30 months. However, under Option B, the test frequency may be

extended to 60 months and then 120 months based upon component testing

performance, service conditions and environment, penetration design, and safety

impact of penetration failure. For those components with extended testing

frequencies, an approximately even distribution is tested during each interval

(i.e., 30 months) to minimize the impact of unanticipated random failures and

increase the likelihood of detecting common-mode failures. Based on the above

attributes, there is reasonable assurance that the Type B testing frequency is

adequate for monitoring aging degradation of containment penetrations with

seals and gaskets.

The staffs review found the applicant's response to RAI 3.5.A-2 acceptable. The applicant

asserted that there are no containment pressure boundary mechanical penetrations with

resilient seals and that approximately 25 percent of the pressure boundary electrical

penetrations are Type B tested every 30 months to assure that each electrical penetration is

Type B tested every 120 months. Therefore, the staff's concern described in RAI 3.5.A-2 is

resolved. This information is reflected in the ALRA.

In RAI 3.5.A-3 dated December 9, 2004, the staff requested information about activities and

programs for ensuring the integrity of seals, gaskets, and bolting of the containment pressure

boundary joints, noting that the applicant took exceptions in the containment ISI program

(AMP B.2.1.23) to examinations of seals, gaskets, and bolting of pressure boundary joint

points. The staff further noted that occasional SRV discharges, sustained elevated

temperatures (may be < 150F), and high humidity could contribute to degradation of

containment pressure boundary. Only Type A leak rate testing and associated visual

examination requirements of the Appendix J Program (AMP B.2.1.26) could detect defects and

degradation of containment pressure boundary joint points reliably. The test interval for Type A

leak rate testing could be 10 to 15 years. Therefore, the staff requested that the applicant

provide information about activities and programs used for aging management for the functional

integrity of these pressure boundary joints for NMP1 primary containment.

In its response by letter dated January 10, 2005, the applicant explained:

The exceptions noted by the NRC for the Containment ISI program ([original]

LRA Section B.2.1.23) do not preclude examinations of seals, gaskets, and

bolting of pressure boundary joint points. By letter dated October 28, 1999, NMP

submitted a relief request (RR-IWE/IWL-1) to the NRC which proposed the use

of the 1998 Edition of ASME Section Xl, Subsection IWE, in lieu of the 1992

Edition with the 1992 Addenda of Subsection IWE. The use of the 1998 Edition

provides more practical requirements for the performance, training, qualification,

and scheduling of examinations and provides a uniform set of requirements that

eliminates the need for multiple relief requests. The NRC approved the relief

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request in a safety evaluation report (SER) dated August 17, 2000. As noted in

the NRC SER, Examination Category E-D (Seals, Gaskets, and Moisture

Barriers) and Examination Category E-G (Pressure Retaining Bolting) were

eliminated from the 1998 Code. However, the examination of the pressure

retaining bolting and moisture barriers is now included in Examination Category

E-A, footnote (1)(d) and Item E1.30, respectively. The NRC also determined that

the verification of containment leak-tight integrity through 10 CFR 50, Appendix J

testing provides an adequate method to verify the pressure integrity of bolted

connections, seals, and gaskets.

Containment pressure boundary joint points are examined and leak tested every

two years in accordance with NMP1 instrument surveillance procedure

N1-ISP-LRT-TYB. This procedure measures leakage of Type B Appendix J

Containment boundaries, which include Containment penetrations whose design

incorporates resilient seals, gaskets or sealing compounds, piping penetrations

fitted with expansion bellows, electrical penetrations fitted with flexible metal seal

assemblies, air lock door seals, and doors with resilient seals or gaskets. This

surveillance verifies that the leakage through resilient seals, gaskets, sealant

compounds, piping penetrations, and electrical penetrations is maintained within

specified values in accordance with the NMP1 Technical Specifications and the

NMP1 Appendix J Testing Program Plan.

The staff's review found the applicant's response to RAI 3.5.A-3 acceptable because the

examination process used by the'applicant provides assurance that the containment pressure

boundary joints will retain their integrity during the period of extended operation. Therefore, the

staff's concern described in RAI 3.5.A-3 is resolved. This information is reflected in the ALRA.

In RAI 3.5.A-4 dated December 9, 2004, the staff noted that the original LRA Table 3.5.2.A did

not address load resisting reinforced concrete structures within the drywell shell likely to be

subject to temperatures higher than the established threshold of 150"F. Original LRA item

3.5.1 .A-27 indicates that the operating temperatures are not sufficient to cause aging effects

and aging effects mechanism for these components. Therefore, the staff requested that the

applicant provide additional information to address the following questions related to these

structures:

Are these structures kept within the threshold temperature 150"F by a cooling

system? If yes, please provide a summary of the operating experience related to

the reliability of the cooling ventilation system. If no, provide the method of

monitoring the temperatures of these structures.

In addition, please provide a summary of the results of the last inspections

performed on (1) RPV pedestal supports, (2) the foundation and floor slabs, and

(3) the sacrificial shield wall under the existing Structural Monitoring Program.

In its response by letter dated January 10, 2005, the applicant provided the following

information:

Load resisting reinforced concrete structures within the drywell shell are not

subjected to temperatures higher than the established threshold of 150°F. NMP1

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UFSAR Section VI.E.1.2 states that 150"F is the design basis maximum

temperature limit for the drywell bulk ambient temperature under normal

operation. The reinforced concrete primary containment structure is addressed in

[original] LRA Table 3.5.2.A-1 in the component type "Concrete in Air."

Drywell temperatures are maintained by the safety-related Primary Containment

Area Cooling System which is in-scope for LR and is described in [original] LRA

Section 2.3.3.A.5. The system must be in service to support plant operation;

there is no acceptable unavailability. There are six containment cooling units of

which five must be in operation to maintain the containment below its

temperature limits. All six units in operation maintain the containment at or below

135 OF.

The results of the last inspections performed on (1) RPV pedestal supports,

(2) the foundation and floor slabs, and (3) the sacrificial shield wall under the

existing Structural Monitoring Program show the structures to be in good to

excellent condition.

The staff's review found the applicant's response to RAI 3.5.A-4 acceptable. As the cooling

system is managed programmatically the staff maintains that the affected concrete structures

will not experience temperatures above the threshold limits. Also, the aging of these structures

will be managed under the applicant's structural monitoring program during the period of

extended operation. Therefore, the staff found the applicant's methods of controlling the

temperatures of these structures and of managing their aging acceptable. Therefore, the staff's

concern described in RAI 3.5.A-4 is resolved. This information is reflected in the ALRA.

In RAI 3.5.A-5 dated December 9, 2004, the staff noted that the original LRA Table 3.5.2.C-1

did not address aging effects and AMPs for fasteners and structural steel made of martensitic

precipitation hardenable material. Therefore, the staff requested that the applicant address the

stress corrosion potential of these fasteners and structural steel, considering the hardness of

these materials and the fact that the fasteners are subject to constant moisture and occasional

water due to pipe or valve leakage. The staff requested the applicant to provide the operating

experience with these items at NMPI.

In its response by letter dated January 10, 2005, the applicant explained:

[Original] LRA Table 3.5.2.C-1 identifies fasteners (precipitation hardenable) in

air (for NMP1 only) with no aging effect requiring management. The material for

these fasteners is A-193, Grade B-6 (AISI Type 410). Martensitic stainless steels

are hardened by quenching and tempering similar to high strength carbon and

low alloy stainless steels, but have better corrosion resistance than carbon and

low alloy steels. Precipitation hardenable stainless steels are typically used for

parts requiring high strength applications. The minimum specified tempering

temperature for A-193, Grade B-6 (AISI Type 410) is 1 100IF, resulting in a yield

strength of approximately 100 ksi. Throughout NMP1, these fasteners are

in-scope due to two intended functions: (1) structural support for NSR and

(2) structural/functional support For stress corrosion cracking to occur,

significant moisture must be present. Martensitic, precipitation hardenable

stainless steels are susceptible to stress corrosion cracking in most waters.

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However, stress corrosion cracking will not occur at temperatures <1401F even

in a moist or occasionally wet environment. Many of the component supports are

for heating, ventilation, and'air conditioning (HVAC) equipment, with these

fasteners exposed to indoor air in the Turbine Building, the Waste Disposal

Building, and the Offgas Building, which do not see sustained temperatures

> 1401F. In addition, susceptibility to stress corrosion cracking increases with

increasing yield strength, with most failures occurring at yield strengths > 140

ksi. Since the yield strength of A-193, Grade B-6 (AISI Type 410) is

approximately 100 ksi, it is very unlikely that stress corrosion cracking will occur.

NUREG-1801, Section XI.M18, "Bolting Integrity," states that cracking must be

monitored for bolts with yield strengths exceeding 150 ksi. Therefore, the fact

that stress corrosion cracking is not identified as an aging effect requiring

management for the fasteners is consistent with NUREG-1 801. A review of the

operating experience for NMP1 for the stress corrosion cracking of martensitic

precipitation hardenable stainless steels found no instances of this occurring.

The staff s review found the applicant's response to RAI 3.5.A-5 acceptable as the staff agreed

that (1) SCC of the components made from the martensitic precipitation hardenable stainless

steels used at NMP1 is unlikely and (2) the applicant's position is consistent with the GALL

Report. Therefore, the staff's concern described in RAI 3.5.A-5 is resolved.

In RAI 3.5.A-6 dated December 9, 2004, the staff requested that app!icant justify not including

aging management of Class MC supports in original LRA Table 3.5.2.C-1 and in AMP B2.1.25,

noting that Table 3.5.2.C-1 and AMP B2.1.25 did not address any AMR of Class MC supports.

The GALL Report, Section XI.S3, recommends Subsection IWF for examination of supports of

MC components. The staff requested the applicant to provide information on the results of the

aging management review for (1) MC component supports within the NMP1 containment

(including the supports submerged in water), (2) MC component supports outside the

containments (i.e., drywell and torus), and (3) supports for piping penetrating through the

containments designated as MC piping (if any). Furthermore, the staff requested the applicant

to summarize the programs to be used for managing the aging effect of these supports,

including sample size, inspection frequency, personnel qualifications, etc.

In the response by letter dated January 10, 2005, the applicant explained:

Class MC supports are addressed in [the original] LRA Table 3.5.2.C-1. Several

line items in the table correspond to NUREG-1801, Volume 2, Item III.B1.3.1-a,

which is for loss of material for carbon steel ASME Class MC supports. The

description of the scope of the ASME Section XI Inservice Inspection

(Subsection IWF) Program in [the original] LRA Section B2.1.25 inadvertently

omitted Class MC supports. The [original] LRA will be corrected to include Class

MC supports in the scope description.

All NMP1 Class MC supports are included in the ASME Section XI Inservice

Inspection (Subsection IWF) Program. Class MC supports fall into three

component types: (1) "Structural Steel (Carbon and Low Alloy Steel) in Air;"

(2) "Structural Steel (Wrought Austenitic Stainless Steel) in Air;" and

(3) "Wrought Stainless Steel in Treated Water." Therefore, the only aging effect

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is loss of material due to general corrosion, applicable only to the carbon/low

alloy steel supports.

All component supports at NMP1 are examined in accordance with the

requirements of Code Case N-491-1. The sample size and inspection frequency

are as specified in Table 2500-1 of Code Case N-491-1, which requires 100

percent of Class MC supports to be examined each inspection interval, except

that for multiple components other than piping, within a system of similar design,

function, and service, the supports of only one of the multiple components are

required to be examined. The examination method is a visual VT-3 examination.

Nondestructive examination personnel at NMP1 are qualified by examination,

and so certified, in accordance with SNT-TC-1A, per ASME Section Xl. Level I

and Level II personnel are recertified by qualification examinations every 3 years.

Level III personnel are recertified by qualification examinations once every 5

years.

The applicant proposed the following revisions to the original LRA:

The first sentence of [the original] LRA Sections Al.1.3 (page A1-2) and A2.1.3

(page A2-2) is revised as follows:

"The ASME Section Xl Inservice Inspection (Subsection IWF)

Program (referred to herein as the IWF ISl Program) manages

aging of carbon steel component and piping supports, including

ASME Class MC supports, due to general corrosion and wear."

In [the original] LRA Section B2.1.25 (page B-49), under the "Program

Description" heading, the first sentence is revised as follows:

"The ASME Section Xl Inservice Inspection (Subsection IWF)

Program (referred to herein as the IWF ISI Program) is an

existing program that manages aging of carbon steel component

and piping supports, including ASME Class MC supports, due to

general corrosion and wear."

The staffs review found the applicant's response to RAI 3.5.A-6 acceptable. A review of the

ALRA indicates that the applicant had incorporated such provisions in the original LRA sections.

The staff found that the applicant had corrected the errors. Therefore, the staff's concern

described in RAI 3.5.A-6 is resolved.

In RAI 3.5.A-10 dated December 9, 2004, the staff noted that Item 3.5.1.A-21 in the original

LRA Table 3.5.1.A states under its discussion column that "ground water test data confirm that

a below grade aggressive environment does not exist." Therefore, the staff requested that the

applicant provide a quantitative summary of NMP1's past ground water test data to support the

noted statement. The staff also requested the applicant provide, if available, both the

phosphate and phosphoric acid contents of the NMP1 ground water.

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In its response by letter dated January 10, 2005, the applicant indicated that NMP1 and NMP2

are situated adjacent to a very large inland fresh water lake with ground water testing every

six months for the site. The applicant stated that no evidence of aggressive ground water

(pH<5.5, >550 ppm chlorides or sulfates > 1500 ppm) has been found at NMP and that ground

water test data is consistently within the acceptable ranges for nonaggressive ground water as

defined by the GALL Report. The applicant further noted that results from the ground water

tests performed in April and October of 2003 from the two site test wells were pH 6.79-7.83,

chloride 7.7-49 ppm, and sulfate 28-60 ppm. The applicant also noted that due to the

nonaggressive nature of the subsurface conditions phosphate and phosphoric acid

concentrations have not been parts of the chemical analysis.

The staffs review found the applicants response to RAI 3.5.A-10 acceptable. Therefore, the

staff's concern described in RAI 3.5.A-10 is resolved. This information is reflected in the ALRA.

In RAI 3.5.A-12 dated December 9, 2004, the staff noted that Item 3.5.1.A-12 of the original

LRA Table 3.5.1.A states in the discussion column that inaccessible areas are compared

against accessible areas and where warranted additional inspections are performed. Therefore,

the staff requested that the applicant provide related examples of past NMP1

operating/inspection experience and address the deficiencies found and how additional

inspections were relied upon to resolve them.

In its response by letter dated January 10, 2005, the applicant stated that the AERMs for the

original LRA Table Item 3.5.1.A-12, Primary Containment (BWR), are managed by the ASME

Section Xl Inservice Inspection (Subsection IWE) Program described in the original LRA

Section B2.1.23, which states that both industry and plant-specific operating experience relating

to the ASME Section XI Inservice Inspection (Subsection IWE) Program were reviewed. Review

of plant-specific operating experience revealed no identified deficiencies warranting further

evaluation for applicability to adjacent inaccessible areas.

The staff's review found the applicant's response to RAI 3.5.A-1 2 acceptable because no

identified deficiencies warranted further evaluation for applicability to adjacent inaccessible

areas. Therefore, the staff's concern described in RAI 3.5.A-12 is resolved. This information is

reflected in the ALRA.

The staffs review concludes that the applicant had identified adequately the aging effects and

the AMPs credited with managing them for the NMP1 primary containment structure

components not addressed by the GALL Report and that intended functions will be maintained

consistent with the CLB for the period of extended operation as required by

10 CFR 54.21(a)(3).

3.5A.2.3.2 Structures and Component Supports NMP1 Reactor Building - Summary of Aging

Management Evaluation - ALRA Table 3.5.2.A-2

The staff reviewed the original LRA Table 3.5.2.A-2, which summarizes the results of AMR

evaluations for the reactor building component groups.

In RAI 3.5.A-8, dated December 9, 2004, the staff noted that In the original LRA

Tables 3.5.2.A-2, 3.5.2.A-6, 3.5.2.A-8, 3.5.2.A-9, and 3.5.2.A-1 1, the Structures Monitoring

Program is credited with monitoring loss of anchor capacity of expansion/grouted anchors

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(carbon and low alloy steel) in air. Therefore, the staff requested that the applicant address the

methods used for checking anchor bolt torque or bolt tightness to assure that there is no loss of

anchor capacity and to ensure that the Structures Monitoring Program will stipulate clearly

methods for monitoring the anchor capacity of expansion/grouted anchors.

In its response by letter dated January 10, 2005, the applicant stated that in the original LRA

Tables 3.5.2.A-2, 3.5.2.A-6, 3.5.2.A-8, 3.5.2.A-9, and 3.5.2.A-1 1 the Structures Monitoring

Program is credited with monitoring the loss of anchor capacity of expansion/grouted anchors

(carbon and low alloy steel) in air. Two AERMs are identified in the original LRA and the GALL

Report for carbon steel expansion or grouted anchors: (1) loss of material due to general

corrosion and (2) loss of anchor capacity due to local concrete aging mechanisms. The

inspection method to determine potential for loss of anchor capacity of an expansion or grouted

anchor is the identification of local concrete degradation. If local concrete degradation is

identified additional inspections may be required as evaluated under the NMPNS CAP. Anchor

bolt torque or bolt tightness checks are not routine unless the potential for loss of anchor

capacity due to local concrete aging mechanisms is detected. The staff found the applicant's

performance-based approach to ensure no loss of anchor capacity acceptable and RAI 3.5.A-8

is resolved. This information is reflected in the ALRA.

In RAI 3.5.A-9 dated December 9, 2004, the staff noted that the original LRA Tables 3.5.2.A-2

and 3.5.2.A-4 state that no AMP is needed for fasteners/structural steel (wrought austenitic

stainless steel) exposed to low flow treated water with temperature < 140 OF. Item A.5.2.b of

Section III of GALL Report recommends the use of an appropriate Water Chemistry Control

Program to manage aging of stainless steel liners exposed to water. Therefore, the staff

requested that the applicant explain the meaning of the "treated water" referred to above and

explain the NMPI's criteria (e.g., a Water Chemistry Control Program or equivalent) used in

quality control of the treated water. The staff also requested that the applicant provide

information to justify the NMPI's finding that no AMP is needed for the listed items subject to

the above stipulated environment.

In its response by letter dated January 10, 2005, the applicant stated that NMP will revise the

original LRA Tables 3.5.2.A-2 and 3.5.2.A-4 to include crack initiation and growth due to SCC

and loss of material due to crevice corrosion as an AERM for the following component types,

(1) fasteners (wrought austenitic stainless steel) exposed to low flow treated water with

temperature < 140°F and (2) structural steel (wrought austenitic stainless steel) exposed to low

flow treated water with temperature < 140 OF, and will credit the Water Chemistry Control

Program described in the original LRA Section B2.1.2. The applicant stated that NMP1 also

monitors the spent fuel pool water level; therefore, NMP1 will be consistent with GALL Report

Item IIl.A5.2-b. The applicant further stated that the supplemental letter it had committed to

submit by February 28, 2005 (reference NMPIL 1902 dated December 21,2004) will include

such table changes. The applicant also clarified that "treated water" is defined in the original

LRA Table 3.0-1 (footnote on page 3.0-9) as demineralized water chemically treated to remove

oxygen. Corrosion inhibitors can be added to the water. Administrative limits are placed on

dissolved oxygen, contaminants, and in some cases suspended solids. The concentration of

contaminants is controlled by a combination of filtration, ion exchangers, or feed-and-bleed

(dilution) operations.

The staff's review found the applicant's response to RAI 3.5.A-9 acceptable with the proposed

revision to the original LRA Tables 3.5.2.A-2 and 3.5.2.A-4 and clarification of the definition of

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"treated water." Therefore, the staff's concern described in RAI 3.5.A-9 is resolved. This

information is reflected in the ALRA.

In RAI 3.5.A-1 I dated December 9, 2004, the staff noted that the original LRA Tables 3.5.2.A-2,

3.5.2.A-3, 3.5.2.A-6, 3.5.2.A-7, 3.5.2.A-9, 3.5.2.A-1 0, and 3.5.2.A-1 1, state that the Structures•

Monitoring Program is credited with managing aging of concrete in soil both above and below

the ground water table (GWT) and concrete lean fill in soil below the GWT. Because these

concrete elements are inaccessible because of the presence of soil, the staff requested that the

applicant discuss the specific Structures Monitoring Program provisions or methods to be used

to inspect or manage aging effect of such inaccessible concrete.

In its response by letter dated January 10, 2005, the applicant indicated that in the original LRA

Tables 3.5.2.A-2, 3.5.2.A-3, 3.5.2.A-6, 3.5.2.A-7, 3.5.2.A-9, 3.5.2.A-10, and 3.5.2.A-11, the

Structures Monitoring Program is credited with managing aging of concrete in soil (both above

and below the GWT) and of concrete lean fill in soil below the GWT. Although no AERMs are

expected due to the design of the reinforced concrete and the nonaggressive condition of the

ground water and soil the Structures Monitoring Program implementing procedure provides

instructions for the performance of inspections of opportunity when the inaccessible surface(s)

of a buried structure is excavated or exposed. In addition to these inspections of opportunity,

the inspections of similar accessible surfaces or accessible surfaces in the vicinity of the

inaccessible surfaces are used to gauge the condition of the inaccessible surfaces.

The staff's review found the applicant's response to RAI 3.5.A-1 I acceptable because the

applicant's position was consistent with the staff's position for managing aging of concrete in

soil (both above and below the GWT) and of concrete lean fill in soil below the GWT. Therefore,

the staff's concern described in RAI 3.5.A-11 is resolved. This information is reflected in the

ALRA.

In RAI 3.5.A-14 dated December 9, 2004, the staff noted that original LRA Tables 3.5.2.A-2 and

3.5.2.C-2 list aluminum alloys exposed to either air or treated water as items having no aging

effects and no AMP credited with managing their aging. Because cable trays, conduits, ducts,

and tube tracks made of aluminum alloys might be exposed to a chemically aggressive or acidic

environment causing aging of these components the staff requested that the applicant provide

past operating/inspection experience with aging management of the components and justify the

position that no AMP is needed during the period of extended operation.

In its response letter dated January 10, 2005, the applicant stated that cable trays, conduits,

ducts, and tube tracks are not constructed of aluminum alloys at NMP1, where "Aluminum Alloy

in Air" is the component type for fire stops and seals. Review of the NMP plant-specific

operating experience identified no degradation of aluminum alloy components in air or treated

water. Therefore, no specific AMP is required.

The staffs review found the applicant's response to RAI 3.5.A-14 acceptable because review of

plant-specific operating experience by the applicant identified no occurrences of degradation of

aluminum alloy components in air or treated water. Therefore, the staffs concern described in

RAI 3.5.A-14 is resolved. This information is reflected in the ALRA.

The staffs review concludes that the applicant had identified adequately the aging effects and

the AMPs credited with managing them for the NMP1 reactor building components not

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addressed by the GALL Report so that intended functions will be maintained consistent with the

CLB for the period of extended operation as required by 10 CFR 54.21(a).

3.5A.2.3.3 Structures and Component Supports NMP1 Essential Yard Structures - Summary

of Aging Management Evaluation - ALRA Table 3.5.2A-3

The staff reviewed ALRA Table 3.5.2.A-3, which summarizes the results of AMR evaluations for

the essential yard structures component groups.

The staff reviewed the information in ALRA Table 3.5.2.A -3 and determined that the applicant

had identified adequately applicable aging effects and the AMPs credited with managing them

for the NMPI essential yard structures components not addressed by the GALL Report. The

staff found the applicant's AMR results for NMP1 Essential Yard Structures components

acceptable.

The staff's review concludes that the applicant had identified adequately the aging effects and

the AMPs credited with managing them for the NMP1 essential yard structures components not

addressed by the GALL Report so that intended functions will be maintained consistent with the

CLB for the period of extended operation as required by 10 CFR 54.21(a).

3.5A.2.3.4 Structures and Component Supports NMPI Fuel Handling System - Summary of

Aging Management Evaluation - ALRA Table 3.5.2A-4

The staff reviewed ALRA Table 3.5.2.A-4, which summarizes the results of AMR evaluations for

the fuel handling system component groups.

The staff reviewed the information in ALRA Table 3.5.2.A-4 and agreed with the applicant's

assertion that there are no aging effects requiring AMPs for license renewal for the NMP1 Fuel

Handling System components. The staff found the applicant's AMR results for NMP1 Fuel

Handling System components acceptable.

On the basis of its review, the staff therefore, concludes that the applicant had adequately

identified no aging effects and no AMPs required for NMP1 Fuel Handling System components.

The staff concludes that there is reasonable assurance that the intended functions will be

maintained consistent with the CLB for the period of extended operation, as required by 10 CRF

54.21 (a)(3)

3.5A.2.3.5 Structures and Component Supports NMP1 Material Handling System - Summary

of Aging Management Evaluation - ALRA Table 3.5.2A-5

The staff reviewed ALRA Table 3.5.2.A-5, which summarizes the results of AMR evaluations for

the material handling system component groups.

The staff reviewed the information in ALRA Table 3.5.2.A -5 and determined that the applicant

had identified adequately applicable aging effects and the AMPs credited with managing them

for the NMP1 material handling system components not addressed by the GALL Report. The

staff found the applicant's AMR results for NMP1 Material Handling System components

acceptable.

3-466
The staffs review concludes that the applicant had identified adequately no aging effects

requiring AMPs to manage them for the NMP1 material handling system components not

addressed by the GALL Report and that intended functions will be maintained consistent with

the CLB for the period of extended operation as required by 10 CFR 54.21 (a).

3.5A.2.3.6 Structures and Component Supports NMP1 Offgas Building - Summary of Aging

Management Evaluation - ALRA Table 3.5.2.A-6

The staff initially reviewed the original LRA Table 3.5.2.A-6, which summarizes the results of

AMR evaluations for the offgas building component groups.

In RAI 3.5.A-15 dated December 9, 2004, the staff noted that the original LRA Table 3.5.2.A-1

lists structural steel (wrought austenitic stainless steel) exposed to air as having no aging effect

and thus requiring no AMP. Original LRA Tables 3.5.2.A-2, 3.5.2.A-6, and 3.5.2.A-1 I also list

fasteners (wrought austenitic stainless steel) exposed to air as having no aging effect, thus

requiring no AMP. However, because sustained exposure to a chemically aggressive or acidic

outside air environment might age these components the staff requested that the applicant

provide the past operating/inspection experience with aging management of the components

and justify the applicant's position that no AMP is needed during the period of extended

operation.

In its response by letter dated January 10, 2005, the applicant stated that the review of NMP

plant-specific operating experience for degradation of wrought austenitic stainless steel

structural steel and fasteners in air identified no such degradation; thus, there have been no

events identifying AERMs for wrought austenitic stainless steel in air requiring an AMP for their

management. The applicant further stated that because there is no environment to which the

stainless steel components in question could be exposed for extended periods of time that

would result in an AERM and because such an environment, if one could be postulated, would

be abnormal and very short-term compared to the current licensing period and the period of

extended operation its consideration for license renewal would not be warranted. The applicant

asserted that for these reasons the exclusion of any AERMs for these material/environment

combinations is justified.

The staffs review found the applicant's response to RAI 3.5.A-15 acceptable based on

operating experience justification. Therefore, the staff's concem described in RAI 3.5.A-15 is

resolved. This information is reflected in the ALRA.

The staffs review concludes that the applicant had identified adequately no aging effects

requiring no AMPs to manage them for the NMP1 offgas building components not addressed by

the GALL Report and that intended functions will be maintained consistent with the CLB for the

period of extended operation as required by 10 CFR 54.21 (a).

3.5A.2.3.7 Structures and Component Supports NMP1 Radwaste Solidification and Storage

Building - Summary of Aging Management Evaluation - ALRA Table 3.5.2.A-7

The staff initially reviewed the original LRA Table 3.5.2.A-7, which summarizes the results of

AMR evaluations for the radwaste solidification and storage building component groups.

3-467
In RAI 3.5.A-13 dated December 9, 2004, the staff noted that Tables 3.5.2.A-1, 3.5.2.A-2, and

3.5.2.A-7 list the AMR results for polymers in air and treated water. Both the 10 CFR 50

Appendix J Program and the ASME Section Xl Inservice Inspection Program (Subsection IWE)

are credited with managing the aging effects of polymers. For NMP1 Category I structures the

original LRA does not indicate that polymers (e.g., compressive joints and seals, elastomer

sealer or caulking material, fibre, forms, and resin sealing compound, etc.) exposed to soil,

ground water or other aggressive environments are within the scope of license renewal

requiring aging effect management during the period of extended operation. Therefore, the staff

requested that the applicant provide a basis for their exclusion and also the AMR results for

these polymer materials exposed to the soil, ground water, or other aggressive environments.

In its letter dated January 10, 2005, the applicant responded that there are no in-scope

polymers (e.g., compressive joints and seals, elastomer sealer or caulking material, fiber, forms

and resin sealing compound, etc.) in the NMPI primary Containment, Reactor Building, or

Radwaste Building exposed to soil, ground water, or aggressive environments requiring aging

management during the period of extended operation. This is reflected in the original LRA

Sections 2.4.A.1, 2.4.A.2, 2.4.A.8, 3.5.2.A.1, 3.5.2.A.2, and 3.5.2.A.7 and in Tables 2.4.A.1-1,

2.4.2.A.2-1, 2.4.A.8-1, 3.5.2.A-1, 3.5.2.A-2, and 3.5.2.A-7.

The staff's review found the applicant's response to RAI 3.5.A-1 3 acceptable because of the

assertion that there are no in-scope polymers in the NMP1 primary containment, reactor

building, or radwaste building exposed to soil, ground water, or aggressive environments.

Therefore, the staff's concern described in RAI 3.5.A-13 is resolved. This information is

reflected in the ALRA.

On the basis of its review, the staff therefore, concludes that the applicant had identified

adequately no aging effects and no AMPs required to manage them for the NMP1 radwaste

solidification and storage building components not addressed by the GALL Report and that

intended functions will be maintained consistent with the CLB for the period of extended

operation as required by 10 CFR 54.21(a)

3.5A.2.3.8 Structures and Component Supports NMP1 Screen and Pump House Building -

Summary of Aging Management Evaluation - ALRA Table 3.5.2.A-8

The staff reviewed ALRA Table 3.5.2.A-8, which summarizes the results of AMR evaluations for

the screen and pump house building component groups.

The staff reviewed the information in ALRA Table 3.5.2.A -8 and determined that the applicant

had identified adequately applicable aging effects and the AMPs credited with managing them

for the NMP1 screen and pump house building components not addressed by the GALL Report.

The staff found the applicant's AMR results for NMP1 Screen and Pump House Building

components acceptable.

The staff's review concludes that the applicant had identified adequately the aging effects and

the AMPs credited with managing them for the NMP1 screen and pump house building

components not addressed by the GALL Report so that intended functions will be maintained

consistent with the CLB for the period of extended operation as required by 10 CFR 54.21 (a).

3-468
3.5A.2.3.9 Structures and Component Supports NMP1 Turbine Building - Summary of Aging

Management Evaluation - ALRA Table 3.5.2.A-9

The staff reviewed ALRA Table 3.5.2.A-9, which summarizes the results of AMR evaluations for

the turbine building component groups.

The staff reviewed the information in ALRA Table 3.5.2.A -9 and determined that the applicant

had identified adequately applicable aging effects and the AMPs credited with managing them

for the NMP1 turbine building components not addressed by the GALL Report. The staff found

the applicant's AMR results for NMP1 turbine building components acceptable.

The staffs review concludes that the applicant had identified adequately the aging effects and

the AMPs credited with managing them for the NMP1 turbine building components that are not

addressed by the GALL Report so that intended functions will be maintained consistent with the

CLB for the period of extended operation as required by 10 CFR 54.21(a).

3.5A.2.3.10 Structures and Component Supports NMP1 Vent Stack - Summary of Aging

Management Evaluation - ALRA Table 3.5.2.A-10

The staff reviewed ALRA Table 3.5.2.A-1 0, which summarizes the results of AMR evaluations

for the vent stack component groups, and determined that the applicant had identified

adequately applicable aging effects and the AMPs credited with managing them for the NMP1

vent stack components not addressed by the GALL Report. The staff found the applicant's

AMR results for NMP1 Vent Stack components acceptable.

The staffs review concludes that the applicant had identified adequately the aging effects and

the AMPs credited with managing them for the NMP1 vent stack components not addressed by

the GALL Report so that intended functions will be maintained consistent with the CLB for the

period of extended operation as required by 10 CFR 54.21 (a).

3.5A.2.3.11 Structures and Component Supports NMP1 Waste Disposal Building - Summary

of Aging Management Evaluation - ALRA Table 3.5.2.A-1 1

The staff reviewed the information in ALRA Table 3.5.2.A-1 1 and determined that the applicant

had identified adequately applicable aging effects and the AMPs credited with managing them

for the NMP1 waste disposal building components not addressed by the GALL Report. The staff

found the applicant's AMR results for NMP1 Waste Disposal Building components acceptable.

On the basis of its review, the staff concludes that there is reasonable assurance that the

applicant had identified adequately the aging effects and the AMPs credited with managing

them for the NMPI waste disposal building components not addressed by the GALL Report so

that intended functions will be maintained consistent with the CLB for the period of extended

operation as required by 10 CFR 54.21 (a).

3.5A.2.3.12 Structures and Component Supports: Component Supports - Summary of Aging

Management Evaluation - ALRA Table 3.5.2.C-1

The staff initially reviewed the original LRA Table 3.5.2.C-1, which summarizes the results of

AMR evaluations for the component supports component groups for both NMP1 and NMP2.

3-469
In RAI 3.5.A-6 dated December 9, 2004, the staff requested that the applicant justify not

including aging management of Class MC supports in Table 3.5.2.C-1 and in AMP B2.1.25,

noting that the original LRA Table 3.5.2.C-1 and AMP B2.1.25 did not address AMR of Class

MC supports. The GALL Report, Section XI.S3, recommends the use of Subsection IWF for

examination of MC component supports. The staff requested the applicant to provide

information on the results of the AMR for (1) MC component supports within the NMP1

containment (including the supports submerged in water), (2) MC component supports outside

the containments (i.e., drywell and torus), and (3) supports for piping penetrating through the

containments designated as MC piping (if any). Furthermore, the staff asked the applicant to

summarize the programs to be used for managing the aging effect of these supports, including

sample size, inspection frequency, personnel qualifications, etc.

The applicant's response to RAI 3.5A-6, dated January 10, 2005, and its resolution are

provided in SER Section 3.5A.2.3.1.

The staff reviewed the information in ALRA Table 3.5.2.C-1 and determined that the applicant

had identified adequately applicable aging effects and the AMPs credited with managing them

for the NMP1 component supports component groups components not addressed by the GALL

Report. The staff found the applicant's AMR results for NMP1 Waste Disposal Building

components acceptable.

On the basis of its review, the staff concludes that there is reasonable assurance that the

applicant had identified adequately the aging effects and the AMPs credited with managing

them for the NMP1 component supports component groups components not addressed by the

GALL Report so that the intended functions will be maintained consistent with the CLB for the

period of extended operation as required by 10 CFR 54.21 (a).

3.5A.2.3.13 Structures and Component Supports Fire Stops and Seals - Summary of Aging

Management Evaluation - ALRA Table 3.5.2.C-2

The staff reviewed ALRA Table 3.5.2.C-2, which summarizes the results of AMR evaluations for

the fire stops and seals component groups.

The staff reviewed the information in ALRA Table 3.5.2.C-2 and determined that the applicant

had identified adequately applicable aging effects and the AMPs credited with managing them

for the NMP1 fire stops and seals component groups components not addressed by the GALL

Report. The staff found the applicant's AMR results for NMP1 fire stops and seals component

groups components acceptable.

The staff's review concludes that the applicant had identified adequately the aging effects and

the AMPs credited with managing them for the NMP1 fire stops and seals component groups

components not addressed by the GALL Report so that the intended functions will be

maintained consistent with the CLB for the period of extended operation as required by

10 CFR 54.21(a).

3-470
3.5A.3 Conclusion

The staff concludes that there is reasonable assurance that the applicant has provided

sufficient information to demonstrate that the effects of aging for the NMP1 structures and

component supports components that are within the scope of license renewal and subject to an

AMR will be adequately managed so that the intended function(s) will be maintained consistent

with the CLB for the period of extended operation as required by 10 CFR 54.21 (a)(3).

The staff also reviewed the applicable UFSAR supplement program summaries and concludes

that they adequately describe the AMPs credited with managing aging of the structures and

component supports as required by 10 CFR 54.21(d).

3.5B NMP2 Aging Management of Structures and Component Supports

This section of the SER documents the staffs review of the applicant's AMR results for the

structures and component supports components and component groups associated with the

following NMP2 systems, structures, and commodities:

• primary containment structure

" reactor building

* auxiliary service building

" control room building

* diesel generator building

* essential yard structures

• fuel handling system

" main stack

" material handling system

" radwaste building

• screenwell building

• standby gas treatment building

• turbine building

• component supports commodity

• fire stops and seals commodity

3.5B.1 Summary of Technical Information in the Amended Application

In ALRA Section 3.5, the applicant provided AMR results for the structures and component

supports components and component groups. In ALRA Table 3.5.1..B, "NMP2 Summary of

Aging Management Programs for Structures and Component Supports Evaluated in Chapter II

and III of NUREG-1801," the applicant provided a summary comparison of its AMRs with the

AMRs evaluated in the GALL Report for the structures and component supports components

and component groups.

The applicant's AMRs incorporated applicable operating experience in the determination of

AERMs. These reviews included evaluation of plant-specific and industry operating experience.

The plant-specific evaluation included reviews of condition reports and discussions with

appropriate site personnel to identify AERMs. The applicant's review of industry operating

experience included a review of the GALL Report and operating experience issues identified

since the issuance of the GALL Report.

3-471
3.5B.2 Staff Evaluation

The staff reviewed ALRA Section 3.5 to determine if the applicant provided sufficient

information to demonstrate that the effects of aging for the structures and component supports

components that are within the scope of license renewal and subject to an AMR will be

adequately managed so that the intended functions will be maintained consistent with the CLB

for the period of extended operation, as required by 10 CFR 54.21 (a)(3).

The staff performed an onsite audit of AMRs to confirm the applicant's claim that certain

identified AMRs were consistent with the GALL Report. The staff did not repeat its review of the

matters described in the GALL Report; however, the staff did verify that the material presented

in the ALRA was applicable and that the applicant had identified the appropriate GALL AMRs.

The staff's evaluations of the AMPs are documented in SER Section 3.0.3. Details of the staff's

audit evaluation are documented in the Audit and Review Report, dated January 18, 2006, and

are summarized in SER Section 3.5B.2.1.

In the onsite audit, the staff also selected AMRs that were consistent with the GALL Report and

for which further evaluation is recommended. The staff confirmed that the applicant's further

evaluations were consistent with the acceptance criteria in SRP-LR Section 3.5.2.2. The staff's

audit evaluations are documented in the Audit and Review Report and are summarized in SER

Section 3.5B.2.2.

In the onsite audit, the staff also conducted a technical review of the remaining AMRs that were

not consistent with, or not addressed in, the GALL Report. The audit and technical review

included evaluating whether all plausible aging effects were identified and evaluating whether

the aging effects listed were appropriate for the combination of materials and environments

specified. The staff's audit evaluations are documented in the Audit and Review Report and are

summarized in SER Section 3.5B.2.3. The staff's evaluation of its technical review is also

documented in SER Section 3.5B.2.3.

Finally, the staff reviewed the AMP summary descriptions in the USAR supplement to ensure

that they provided an adequate description of the programs credited with managing or

monitoring aging for the structures and component supports components.

Table 3.5B-1 below provides a summary of the staff's evaluation of NMP2 components, aging

effects and aging effects mechanisms, and AMPs listed in ALRA Section 3.5, that are

addressed in the GALL Report.

3-472
Table 3.5B-1 Staff Evaluation for NMP2 Structures and Component Supports in the

GALL Report

Cmponnt Gru gngEfc! AMP .In GALL IAmp in ALRA: I. Staff Evaluation

Mechanism- Report I

Common Components of All Types of PWR and BWR Containment

Penetration Cumulative fatigue TLAA, evaluated In TLAA This TLAA is

sleeves, penetration damage (CLB accordance with evaluated in Section

bellows, and fatigue analysis 10 CFR 54.21(c) 4.6, Containment

dissimilar metal exists) Liner Plate, Metal

welds Containments, and

(Item Number Penetrations

3.5.1.B-01) Fatigue Analysis

Penetration Cracking for cyclic Containment ISI ASME Section XI Consistent with

sleeves, bellows, loading; crack and Containment Inservice Inspection GALL, which

and dissimilar metal initiation and growth leak rate test (Subsection IWE) recommends further

welds from SCC Program (B2.1.23), evaluation (See

(Item Number 10 CFR 50. Section 3.56.2.2.1)

3.5.1.B-02) Appendix J

Program (B2.126)

Penetration Loss of material Containment ISI ASME Section XI Consistent with

sleeves, penetration, due to corrosion and Containment Inservice Inspection GALL, which

bellows, and leak rate test (Subsection IWE) recommends no

dissimilar metal Program (B2.1.23). further evaluation

welds 10 CFR 50 (See Section

(Item Number Appendix J 3.5B.2.1)

3.5.1.B-03) Program (B2.126)

Personnel airlock Loss of material Containment ISI ASME Section XI Consistent with

and equipment due to corrosion and Containment Inservice Inspection GALL, which

hatch leak rate test (Subsection IWE) recommends no

(Item Number Program (B2.1.23), further evaluation

3.5.1.8-04) 10 CFR 50 (See Section

Appendix J 3.5B.2.1)

Program (B2.126)

Personnel airlock Loss of leak Containment leak 10 CFR 50 Consistent with

and equipment tightness in closed rate test and Plant Appendix J GALL, which

hatch position due to Technical Program (82.126) recommends no

(Item Number mechanical wear of Specifications further evaluation

3.5.1.8-05) locks, hinges and (See Section

closure mechanism 3.5B.2.1)

Seals, gaskets, and Loss of sealant and Containment ISI 10 CFR 50 Consistent with

moisture barriers leakage through and Containment Appendix J GALL, which

(Item Number containment due to leak rate test Program (82.126) recommends no

3.5.1.B-06) deterioration of joint further evaluation

seals, gaskets, and (See Section

moisture barriers 3.5B.2.1)

ISI not required, no

moisture barriers

BWR Concrete (Mark II and Ill) Containment and Steel (Mark I, II, and III) Containment

(Note: NMP2 has a Mark II Containment)

3-473
Com po~n"ent "Gro up, .iA'gIing' E,17ect 'AM P 'In' GALCL AMVP In ALRAý'r Staff Evalua ition

_.____....___.... " : Mechanism ,. Report

Concrete elements: Aging of accessible Containment ISI ASME Section XI Not applicable (See

foundation, walls, and inaccessible Inservice Inspection Section 3.51.2.2.1)

dome concrete areas due (Subsection IWL)

(Item Number to leaching of Program (82.124) However, applicant

3.5.1.B-07) calcium hydroxide, chose to monitor

aggressive with ISI Program

chemical attack,

and corrosion of

embedded steel

Concrete elements: Cracks, distortion, Structures Structures Not applicable (See

foundation and increases in Monitoring Monitoring Program Section 3.58.2.2.1)

(Item Number component stress (B2.1.28)

3.5.1.8-08) level due to However, applicant

settlement chose to monitor

with Structures

Monitoring Program

Concrete elements: Reduction in Structures None Not applicable (See

foundation foundation strength Monitoring Section 3.5B.2.2.1)

(Item Number due to erosion of

3.5.1.B-09) porous concrete

subfoundation

Concrete elements: Reduction of Plant-specific None Not applicable (See

foundation, dome, strength and Section 3.58.2.2.1)

and wall modulus due to

(Item Number elevated

3.5.1.B-10) temperature

Prestressed Loss of prestress TLAA, evaluated in None Not applicable (See

containment: due to relaxation, accordance with Section 3.5B.2.2.1)

tendons and shrinkage, creep, 10 CFR 54.21(c)

anchorage and elevated

components temperature

(Item Number

3.5.1.8-11)

Steel elements: Loss of material Containment ISI ASME Section XI Consistent with

liner plate, due to corrosion in and Containment Inservice Inspection GALL, which

containment shell accessible and leak rate test (Subsection IWE) recommends further

(Item Number inaccessible areas Program (B2.123), evaluation (See

3.5.1.1-12) 10 CFR 50 Section 3.58.2.2.1)

Appendix J

Program (12.126)

Steel elements: Cumulative fatigue TLAA, evaluated in TLAA This TLAA is

vent header, drywell damage (CLB accordance with evaluated in Section

head, torus, fatigue analysis 10 CFR 54.21(c) 4.6, Containment

downcomers, pool exists) Liner Plate, Metal

shell Containments, and

(Item Number Penetrations

3.5.1.8-13) Fatigue Analysis

Steel elements: Loss of material Protective coating None Not applicable

protected by coating due to corrosion in monitoring and

(Item Number accessible areas maintenance No credit for

3.5.1.8-14) only coatings taken

3-474
Component Group Aging Effect/ -AMP in GALL AMP in ALRA !. :S:,Staff Evaluation'!

_________ _ " "Mechanism Report, _ _ _ -

Prestressed Loss of material Containment ISI None Not applicable.

containment: due to corrosion of PWR only

tendons and prestressing

anchorage tendons and

components anchorage

(Item Number components

3.5.1.B-15)

Concrete elements: Scaling, cracking, Containment ISI None Not applicable

foundation, dome, and spalling due to

and wall freeze-thaw, NMP2 primary

(Item Number expansion and containment is

3.5.1.B-16) cracking due to enclosed

reaction with (protected) by

aggregate reactor building and does not have

an independent

foundation

Steel elements: Cracking due to Containment ISI ASME Section XI Consistent with

vent line bellows, cyclic loads or and Containment Inservice Inspection GALL, which

vent headers, Crack initiation and leak rate test (Subsection IWE) recommends further

downcomers growth due to SCC Program (B2.1.23), evaluation (See

(Item Number 10 CFR 50 Section 3.58.2.2.1)

3.5.1.B-17) Appendix J

Program (B2.1.26)

Steel elements: Crack initiation and Containment ISI None Not applicable

Suppression growth due to SCC and Containment

chamber liner leak rate test No SCC

(Item Number environment

3.5.1.8-18)

Steel elements: Fretting and lock up Containment ISI None Not applicable

drywell head and due to wear

downcomer pipes No fretting orwear

(Item Number for these

3.5.1.8-19) components

Class I Structures

All Groups except All types of aging Structures Structures Consistent with

Group 6: accessible effects Monitoring Monitoring Program GALL, which

interior/exterior (B2.1.28) recommends no

concrete & steel further evaluation

components (See Sections

(Item Number 3.58.2.1 and

3.5.1.8- 20) 3.58.2.2.2)

Groups 1-3, 5,7-9: Aging of Plant-specific Structures Not applicable (See

inaccessible inaccessible Monitoring Program Section 3.58.2.2.2)

concrete concrete areas due (B2.1.28)

components, such to aggressive

as exterior walls chemical attack,

below grade and and corrosion of

foundation embedded steel

(Item Number

3.5.1.3-21)

3-475
Component Group .":'Aging Effect!•,, AMP In, GALL AMP in ALRA Staff Evaluation'.

Mechanism Report ___, ___. ___. ____ __,. __________. _

Group 6: all All types of aging Inspection of Structures Consistent with

accessible/ effects, including Water-Control Monitoring Program GALL, which

inaccessible loss of material due Structures or (B2.1.28) recommends no

concrete, steel, and to abrasion, FERCAJS Army further evaluation

earthen cavitation, and Corps of Engineers (See Section

components corrosion dam inspection and 3.5B.2.1)

(Item Number maintenance

3.5.1.B-22) Inspections of water

control structures is

part of the

Structures

Monitoring Program

Group 5: liners Crack initiation and Water Chemistry Water Chemistry Consistent with

(Item Number growth due to SCC; Program and Control Program GALL, which

3.5.1.B-23) loss of material due Monitoring of spent (B2.1.2) recommends no

to crevice corrosion fuel pool water level further evaluation

(See Section

3.5B.2.1.1)

Groups 1-3, 5, 6: all Cracking due to Masonry Wall Masonry Wall Consistent with

masonry block walls restraint, shrinkage, Program (B2.127) GALL, which

(Item Number creep, and recommends no

3.5.1.8- 24) aggressive further evaluation

environment (See Section

3.5B.2.1)

Groups 1-3, 5,7-9: Cracks, distortion, Structures None Not applicable (See

foundation and increases in Monitoring Section 3.58.2.2.2)

(Item Number component stress

3.5.1.B-25) level due to

settlement

Groups 1-3, 5-9: Reduction in Structures None Not applicable (See

foundation foundation strength Monitoring Section 3.5B.2.2.2)

(Item Number due to erosion of

3.5.1.B-26) porous concrete

subfoundation

Groups 1-5: Reduction of Plant-specific None Not applicable (See

concrete strength and Section 3.5B.2.2.2)

(Item Number modulus due to

3.5.1.8-27) elevated

temperature

Groups 7, 8: liners Crack Initiation and Plant-specific None Not applicable

(Item Number growth due to SCC;

3.5.1.8-28) Loss of material No tank liners within

due to crevice scope

corrosion

Component Supports

3-476
Component Group Aging Effect! -':AMP In GALL - AMP In ALRA ,Staff Evaluation

'Mechanism.""- Report ____. ___________ _______-_- ______

All Groups: support Aging of component Structures Structures Consistent with

members: anchor supports Monitoring Monitoring Program GALL, which

bolts, concrete (B2.1.28) recommends no

surrounding anchor further evaluation

bolts, welds, grout (See Sections

pad, bolted 3.5B.2.1.2 and

connections, etc. 3.5B2.2.3)

(Item Number

3.5.1 .B-29)

Groups B1.1, B1.2, Cumulative fatigue TLAA, evaluated in TLAA This TLAA is

and B1.3: support damage (CLB accordance with evaluated in

members: anchor fatigue analysis 10 CFR 54.21(c) Section 4

bolts, welds exists)

(Item Number

3.5.1.B-30)

All Groups: support Loss of material Boric acid corrosion None Not applicable,

members: anchor' due to boric acid PWR only

bolts, welds corrosion

(Item Number

3.5.1.1-31)

Groups BI.1, B1.2, Loss of material ISI ASME Section XI Consistent with

and B1.3: support due to Inservice Inspection GALL, which

members: anchor environmental (Subsection IWF) recommends no

bolts, welds, spring corrosion; loss of Program (12.1.25) further evaluation

hangers, guides, mechanical function (See Section

stops, and vibration due to corrosion, 3.5B.2.1)

isolators distortion, dirt,

(Item Number overload, etc.

3.5.1.B-32)

Group B1.1: high Crack initiation and Bolting integrity Bolting Integrity Consistent with

strength low-alloy, growth due to SCC Program (B2.1.36) GALL, which

bolts recommends no

(Item Number further evaluation

3.5.1.6-33) (See Section

3.5B.2.1)

The staff's review of the NMP2 component groups followed one of several approaches. One

approach, documented in SER Section 3.58.2.1, discusses the staff's review of the AMR

results for components in the structures and component supports that the applicant indicated

are consistent with the GALL Report and do not require further evaluation. Another approach,

documented in SER Section 3.5B.2.2, discusses the staff's review of the AMR results for

components in the structures and component supports that the applicant indicated are

consistent with the GALL Report and for which further evaluation is recommended. A third

approach, documented in SER Section 3.5B.2.3, discusses the staff's review of the AMR

results for components in the structures and component supports that the applicant indicated

are not consistent with, or not addressed in, the GALL Report. The staff's review of AMPs that

are credited to manage or monitor aging effects of the structures and component supports

components is documented in SER Section 3.0.3.

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3.5B.2.1 AMR Results That Are Consistent with the GALL Report

Summary of Technical Information in the Amended Application. In ALRA Sections 3.5.2.B and

3.5.2.C, the applicant identified the materials, environments, and AERMs. The applicant

identified the following programs that manage the aging effects related to the structures and

component supports components:

* Water Chemistry Control Program

* Boraflex Monitoring Program

* Inspection of Overhead Heavy Load and Light Load Handling Systems Program

* Fire Protection Program

* ASME Section XI Inservice Inspection (Subsection IWE) Program

• ASME Section XI Inservice Inspection (Subsection IWL) Program

• ASME Section XI Inservice Inspection (Subsection IWF) Program

* 10 CFR 50 Appendix J Program

• Masonry Wall Program

* Structures Monitoring Program

• Bolting Integrity Program

* Protective Coating Monitoring and Maintenance Program

Staff Evaluation. In ALRA Tables 3.5.2.B-1 through 3.5.2.B-13 and Tables 3.5.2.C-1 and

3.5.2.C-2, the applicant provided a summary of AMRs for the structures and component

supports components, and identified which AMRs it considered to be consistent with the GALL

ReporL

For component groups evaluated in the GALL Report for which the applicant had claimed

consistency with the GALL Report, and for which the GALL Report does not recommend further

evaluation, the staff performed an audit and review to determine whether the plant-specific

components contained in these GALL Report component groups were bounded by the GALL

Report evaluation.

The applicant provided a note for each AMR line item. The notes indicate how the information in

the tables aligns with the information in the GALL Report. The staff audited those AMRs with

Notes A through E, which indicate that the AMR is consistent with the GALL Report.

Note A indicates that the AMR line item is consistent with the GALL Report for component,

material, environment, and aging effect. In addition, the AMP is consistent with the AMP

identified in the GALL Report. The staff audited these line items to verify consistency with the

GALL Report and the validity of the AMR for the site-specific conditions.

Note B indicates that the AMR line item is consistent with the GALL Report for component,

material, environment, and aging effect. In addition, the AMP takes some exceptions to the

AMP identified in the GALL Report. The staff audited these line items to verify consistency with

the GALL Report. The staff verified that the identified exceptions to the GALL AMPs had been

reviewed and accepted by the staff. The staff also determined whether the AMP identified by

the applicant was consistent with the AMP identified in the GALL Report and whether the AMR

was valid for the site-specific conditions.

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Note C indicates that the component for the AMR line item, although different from, is

consistent with the GALL Report for material, environment, and aging effect. In addition, the

AMP is consistent with the AMP identified by the GALL Report. This note indicates that the

applicant was unable to find a listing of some system components in the GALL Report.

However, the applicant identified a different component in the GALL Report that had the samematerial, environment, aging effect, and AMP as the component that was under review. The

staff audited these line items to verify consistency with the GALL Report. The staff also

determined whether the AMR line item of the different component was applicable to the

component under review and whether the AMR was valid for the site-specific conditions.

Note D indicates that the component for the AMR line item, although different from, is

consistent with the GALL Report for material, environment, and aging effect. In addition, the

AMP takes some exceptions to the AMP identified in the GALL Report. The staff audited these

line items to verify consistency with the GALL Report. The staff verified whether the AMR line

item of the different component was applicable to the component under review. The staff

verified whether the identified exceptions to the GALL AMPs had been reviewed and accepted

by the staff. The staff also determined whether the AMP identified by the applicant was

consistent with the AMP identified in the GALL Report and whether the AMR was valid for the

site-specific conditions.

Note E indicates that the AMR line item is consistent with the GALL Report for material,

environment, and aging effect, but a different aging management program is credited. The staff

audited these line items to verify consistency with the GALL Report. The staff also determined

whether the identified AMP would manage the aging effect consistent with the AMP identified

by the GALL Report and whether the AMR was valid for the site-specific conditions.

The staff conducted an audit and review of the information provided in the ALRA, as

documented in the Audit and Review Report. The staff did not repeat its review of the matters

described in the GALL Report; however, the staff did verify that the material presented in the

ALRA was applicable and that the applicant identified the appropriate GALL Report AMRs. The

staff's evaluation is discussed below.

3.5B.2.1.1 Crack Initiation and Growth Due to SCC; Loss of Material Due to Crevice Corrosion

As documented in the Audit and Review Report, the staff noted that in ALRA Table 3.5.2.B-2,

for the liners component type and cracking aging effect and aging effect mechanism, the GALL

Report, Volume 2 line item shown is Item III.A5.2-b with ALRA Table 3.5.1.B, Item 3.5.1.B-23.

In the table, Note D indicates that the component is different from the GALL Report line item.

As documented in the Audit and Review Report, the staff requested that the applicant explain

how this AMR line item component is different from the GALL Report when GALL Report

Item III.A5.2-b is also for the component liners.

By letter dated December 1, 2005, the applicant stated that the note referenced should be

Note B instead of Note D. The reference would be to Note A, except that the AMP shown takes

exceptions to the GALL Report AMP. The applicant further stated that ALRA Table 3.5.3.B-2

was revised to change Note D to Note B for all AMR line item component liners with a cracking

aging effect and aging effect mechanism.

3-479
The staff reviewed the applicant's response and found that the correction of Note D to Note B is

acceptable because the proper note was assigned to this AMR line item.

On the basis of its review, the staff found that the applicant had appropriately addressed the

aging effect and aging effect mechanism, as recommended by the GALL Report.

3.5B.2.1.2 Aging of Component Supports

As documented in the Audit and Review Report, the staff noted that in ALRA Table 3.5.2.8-2,

for the expansion/grouted anchors component type and the loss of anchor capacity aging effect

and aging effect mechanism, the GALL Report, Volume 2 line item shown is Item lll.B13.2.3-a

with ALRA Table 3.5.1 .B, Item 3.5.1.B-29. The environment shown is concrete and the note

states that it is consistent with the GALL Report. As documented in the Audit and Review

Report, the staff requested that the applicant to explain how this AMR line item was consistent

with the GALL Report when the GALL Report line item has a component type of concrete

surrounding anchor bolts, a material of concrete, an environment of inside or outside

containment, and an aging effect and aging effect mechanism of reduction in anchor capacity.

The logic of this AMR line item was not consistent with the GALL Report. This also applies to

ALRA Tables 3.5.2.8-4, 3.5.2.B-5, 3.5.2.B-6, 3.5.2.8-8, 3.5.2.8-10, 3.5.2.8-11, and 3.5.2.8-13

for the component type of expansion/grouted anchors. The staff also requested that the

applicant explain why, for ALRA Table 3.5.2.B-1 I component type expansion/grouted anchors

(wrought austenitic stainless steel) in raw water, ALRA Table 3.5.1.A, Item 3.5.1 .A-29 was

shown with a NMP2 component.

By letter dated December 1, 2005, the applicant stated that it made the ALRA consistent with

the GALL Report for all of the expansion/grouted anchor AMR line items listed above. For all

the AMR line items above, except in ALRA Table 3.5.2.1-11, the ALRA current line for carbon

steel in concrete was revised. In its place, the component type is changed to concrete

surrounding anchor bolts, the material of carbon steel was replaced with concrete (new line with

the current line that starts with concrete), the environment of concrete is replaced with air and

the rest of the lines will remain as they are currently displayed. For ALRA Table 3.5.2.8-11, the

ALRA current line for wrought austenitic stainless steel in concrete was revised. In its place, the

component type was changed to concrete surrounding anchor bolts, the material of wrought

austenitic stainless steel is replaced with concrete (new line with the current line that starts with

concrete), the environment of concrete is replaced with raw water and the rest of the line will

remain as currently displayed except for the GALL Report item note and Table I line item. The

ALRA Table 3.5.1.A, Item 3.5.1.A-29 was an error and the applicant revised the cell in the table

to be blank. The cell for the GALL Report item is also blank and the note is changed to Note G.

The applicant used the AERM of loss of anchor capacity instead of reduction in anchor

capacity, per the GALL Report; however, it is intended that these terms have the same

meaning.

The staff reviewed the applicant's response and found that, after revision of the applicant's

AMR line items as described above, these line items for the component expansion/grouted

anchor (now component type, concrete surrounding anchor bolts, after revision) are consistent

with the GALL Report and are, therefore, acceptable.

On the basis of its review, the staff found that the applicant had appropriately addressed the

aging effect and aging effect mechanism, as recommended by the GALL Report.

3-480
As documented in the Audit and Review Report, the staff noted that in ALRA Table 3.5.2.B-11,

for component type expansion/grouted anchors (carbon and low alloy steel in air) and aging

effect and aging effect mechanism loss of anchor capacity, the GALL Report, Volume 2 line

item shown is Item 111.B1.2.3-a with Table 3.5.1.B, Item 3.5.1.A-29. However, no environment

was shown and the note states that it is consistent with the GALL Report. As documented in the

Audit and Review Report, the staff requested that the applicant explain how this AMR line item

was consistent with the GALL Report when the GALL Report line item had a component type of

concrete surrounding anchor bolts, a material of concrete, an environment of inside or outside

containment and an aging effect and aging effect mechanism of reduction in anchor capacity.

The logic of this AMR line item was not consistent with the GALL Report. Also, the staff

requested that the applicant explain why the ALRA Table 3.5.1.B line item shown is

Item 3.5.1.A-29 instead of Item 3.5.1.8-29.

By letter dated December 1, 2005, the applicant stated that it made the ALRA consistent with

the GALL Report for the expansion/grouted anchor AMR line item listed above. The ALRA

current line for carbon steel with no environment shown was revised. In its place, the

component type was changed to concrete surrounding anchor bolts, the material of carbon

steel is replaced with concrete (new line with the current line that starts with concrete), the

missing environment was replaced with air and the rest of the line remains as currently

displayed, except the Table 1 entry. The applicant used the AERM of loss of anchor capacity

instead of reduction in anchor capacity per the GALL Report; however, it is intended that these

terms have the same meaning. The Table 1 entry of Item 3.5.1 .A-29 was an error and was

revised to Item 3.5.1.8-29.

The staff reviewed the applicant's response and found that after revision of the applicant's AMR

line item as described above, this line item for the component expansion/grouted anchor (now

component type, concrete surrounding anchor bolts, after revision) is consistent with the GALL

Report and is therefore acceptable. The staff also found the correction of the reference to

ALRA Table 3.5.1.8, Item 3.5.1.B-29 appropriate.

On the basis of its review the staff found that the applicant had appropriately addressed the

aging effect and aging effect mechanism, as recommended by the GALL Report.

As documented in the Audit and Review Report, the staff noted that in ALRA Table 3.5.2.C-1,

for the component type expansion/grouted anchors (carbon and low alloy steel in air) and aging

effect and aging effect mechanism of loss of anchor capacity, the GALL Report, Volume 2 line

item shown is Item ilI.81.2.3-a with the Table 1 line items shown as Items 3.5.1.A-29 and

3.5.1.B-29. The environment shown is concrete and the note states that it is consistent with the

GALL Report. As documented in the Audit and Review Report, the staff requested that the

applicant explain how this AMR line item is consistent with the GALL Report, when the GALL

Report line item has a component type of concrete surrounding anchor bolts, a material of

concrete, an environment of inside or outside containment and an aging effect and aging effect

mechanism of reduction in anchor capacity. The logic of this AMR line item was not consistent

with the GALL Report. This also applies to ALRA Table 3.5.2.C-1 for component type

expansion/grouted anchors (wrought austenitic stainless steel in air).

By letter dated December 1, 2005, the applicant stated that it made the ALRA consistent with

the GALL Report for all of its expansion/grouted anchor AMR line items listed above. For the

AMR line item for expansion/ grouted anchors on Table 3.5.2.C-1 (Page 3.5-126) above, the

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ALRA current line for carbon steel in concrete was revised. In its place, the component type

was changed to concrete surrounding anchor bolts, the material of carbon steel is replaced with

concrete (new line with the current line that starts with concrete), the environment of concrete is

replaced with air and the rest of the line remains as currently displayed. For the AMR line item

for expansion/ grouted anchors on Table 3.5.2.C-1 (Page 3.5-127) above, the ALRA current

line for wrought austenitic stainless steel in concrete was revised. In its place, the component

type was changed to concrete surrounding anchor bolts, the material of wrought austenitic

stainless steel was replaced with concrete (new line with the current line that starts with

concrete), the environment of concrete was replaced with air and the rest of the line remains as

currently displayed except the Table 1 line items. The Table I item should be Item 3.5.11.B-29

only since the line is for NMP2 only. The lines for aging management by the ASME Section XI

IWF remain as they are currently entered on ALRA Table 3.5.2.C-1 (Pages 3.5-126 and

3.5-127). The applicant used the AERM of loss of anchor capacity instead of reduction in

anchor capacity per the GALL Report; however, the applicant intended that these terms have

exactly the same meaning.

The staff reviewed the applicant's response and found that after revision of the applicant's AMR

line items, as described above, these line items for the component expansion/grouted anchor

are consistent with the GALL Report and are therefore acceptable.

On the basis of its review, the staff found that the applicant had appropriately addressed the

aging effect and aging effect mechanism, as recommended by the GALL Report.

Conclusion. The staff evaluated the applicant's claim of consistency with the GALL Report. The

staff also reviewed information pertaining to the applicant's consideration of recent operating

experience and proposals for managing associated aging effects. On the basis of its review, the

staff concludes that there is reasonable assurance that the AMR results, which the applicant

claimed to be consistent with the GALL Report, are consistent with the AMRs in the GALL

Report. Therefore, the staff concludes that the applicant had demonstrated that the effects of

aging for these components will be adequately managed so that their intended function(s) will

be maintained consistent with the CLB for the period of extended operation, as required by

10 CFR 54.21(a)(3).

3.5B.2.2 AMR Results That are Consistent with the GALL Report, for Which Further

Evaluation is Recommended

Summary of Technical Information in the Amended Application. In Section 3.5.2.C of its letter

dated August 19, 2005, the applicant provided further evaluation of aging management as

recommended by the GALL Report for the structures and component supports components.

The applicant provided information concerning how it will manage the following aging effects:

BWR Containment:

" aging of inaccessible concrete areas

" cracking, distortion, and increase in component stress level due to settlement; reduction

of foundation strength due to erosion of porous concrete subfoundations, if not covered

by structures monitoring program

" reduction of strength and modulus of concrete structures due to elevated temperature

3-482
* loss of material due to corrosion in inaccessible areas of steel containment shell or liner

plate

• loss of prestress due to relaxation, shrinkage, creep, and elevated temperature

" cumulative fatigue damage

" cracking due to cyclic loading and SCC

Class I Structures:

" aging of structures not covered by structures monitoring program

* aging management of inaccessible areas

Component Supports:

" aging of supports not covered by structures monitoring program

" cumulative fatigue damage due to cyclic loading

Staff Evaluation. For component groups evaluated in the GALL Report for which the applicant

had claimed consistency with the GALL Report, and for which the GALL Report recommends

further evaluation, the staff audited and reviewed the applicant's evaluation to determine

whether it adequately addressed the issues that were further evaluated. In addition, the staff

reviewed the applicant's further evaluations against the criteria contained in SRP-LR

Section 3.5.2.2. Details of the staffs audit are documented in the staffs Audit and Review

Report. The staffs evaluation of the aging effects is discussed in the following sections.

3.58.2.2.1 BWR Containments

The staff reviewed Section 3.5.2.C.1 of its letter dated August 19, 2005 against the criteria in

SRP-LR Section 3.5.2.2.1, which addresses several areas discussed below.

Apinq of Inaccessible Concrete Areas. The staff reviewed Section 3.5.2.C.1.1 of the applicant's

letter dated August 19, 2005 against the criteria in SRP-LR Section 3.5.2.2.1.1.

In Section 3.5.2.C.1.1 of its letter dated August 19, 2005, the applicant addressed aging of

inaccessible concrete areas in BWR containments.

SRP-LR Section 3.5.2.2.1.1 states that cracking, spalling, and increases in porosity and

permeability due to leaching of calcium hydroxide and aggressive chemical attack; and

cracking, spalling, loss of bond, and loss of material due to corrosion of embedded steel could

occur in inaccessible areas of PWR concrete and steel containments; BWR Mark II concrete

containments; and Mark III concrete and steel containments. The GALL Report recommends

further evaluation of plant-specific programs to manage the aging effects and aging effects

mechanisms for inaccessible areas if specific conditions defined in the GALL Report cannot be

satisfied.

In Section 3.5.2.C.1.1 of its letter dated August 19, 2005, the applicant stated that, for NMP2,

the aging of inaccessible concrete areas due to leaching of calcium hydroxide, aggressive

chemical attack, and corrosion of embedded steel are not significant for concrete components

of the primary containment structure. The concrete was designed in accordance with

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ACI 318-71 and ACI 318-77 and constructed in accordance with ACl 301, which meets the

intent of ACI 201.2R-77. This ensures a durable concrete that is dense, well-cured, has low

permeability, and for which cracking is well controlled. Additionally, NMP2 is not exposed to

aggressive ground water. As part of the Structures Monitoring Program, a regularly scheduled

ground water monitoring will be implemented to ensure that a benign environment is

maintained.

In addition, in letter dated August 19, 2005, the applicant stated that, although evaluated as not

significant, NMP2 credits the ASME Section Xl Inservice Inspection (IWL) Program to monitor

for aging of inaccessible concrete areas. Inaccessible concrete areas are compared against

accessible concrete areas with similar environments. If warranted, additional inspections are

performed. The staff reviewed the applicant's ASME Section Xl Inservice Inspection (IWL)

Program; the staff's evaluation is documented in SER Section 3.0.3.2.18.

On the basis of its audit and review, the staff found that cracking, spalling and increases in

porosity and permeability of inaccessible containment concrete due to leaching of calcium

hydroxide and aggressive chemical attack; and cracking, spalling, loss of bond, loss of material

of inaccessible containment concrete due to corrosion of embedded steel are not plausible

aging effects and aging effects mechanisms due to the nonexistence of these aging effect and

aging effect mechanisms in accordance with the GALL Report. As documented in the Audit and

Review Report, through interviews with the applicant's technical staff and review of applicable

documentation, the staff found that the NMP2 concrete containment is designed in accordance

with ACI 318 and constructed of concrete using ingredients conforming to ACI and ASTM

standards, in accordance with the recommendations of the GALL Report. In addition, ground

water sample testing monitoring has demonstrated that an aggressive environment does not

exist at NMP2 for inaccessible concrete. NMPNS has demonstrated that aggregates used for

containment concrete were in accordance with ACI 301, which meets the intent of

ACI 201.2R-77 for good quality concrete. The staff determined that the recommendations of the

GALL Report have been satisfied and a plant-specific AMP for inaccessible containment

concrete is not required.

Based on the programs identified above, the staff concludes that there is reasonable assurance

that the applicant has met the criteria of SRP-LR Section 3.5.2.2.1.1. For those line items that

apply to Section 3.5.2.C.1.1 of the applicant's letter dated August 19, 2005, the staff

determined that the information in the application is consistent with the GALL Report and the

applicant had demonstrated that the effects of aging will be adequately managed so that the

intended function(s) will be maintained consistent with the CLB during the period of extended

operation, as required by 10 CFR 54.21(a)(3).

Cracking, Distortion, and Increase in Component Stress Level due to Settlement; Reduction of

Foundation Strength due to Erosion of Porous Concrete Subfoundations, if Not Covered by

Structures Monitoring Program. The staff reviewed Section 3.5.2.C.1.2 of the applicant's letter

dated August 19, 2005, against the criteria in SRP-LR Section 3.5.2.2.1.2.

In Section 3.5.2.C. 1.2 of its letter dated August 19, 2005, the applicant addressed cracking,

distortion, and increase in component stress level due to settlement; and reduction of

foundation strength due to erosion of porous concrete subfoundations in BWR containments.

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SRP-LR Section 3.5.2.2.1.2 states that cracking, distortion, and increase in component stress

level due to settlement could occur in PWR concrete and steel containments and BWR Mark II

concrete containments and Mark III concrete and steel containments. Also, reduction of

foundation strength due to erosion of porous concrete subfoundations could occur in all types of

PWR and BWR containments. Some plants may rely on a de-watering system to lower the site

ground water level. If the plant's CLB credits a de-watering system, the GALL Report

recommends verification of the continued functionality of the de-watering system during the

period of extended operation. The GALL Report recommends no further evaluation if this

activity is included within the scope of the applicant's Structures Monitoring Program.

In Section 3.5.2.C.1.2 letter dated August 19, 2005, the applicant stated that, for NMP2,

cracking, distortion, and an increase in component stress level due to settlement is not

significant. The primary containment structure is founded on impervious rock. Although

evaluated as not significant, NMP2 credits the Structures Monitoring Program to monitor for

settlement. NMP2 does not utilize a de-watering system. The staff reviewed the applicant's

Structures Monitoring Program; the staff's corresponding evaluation is documented in SER

Section 3.0.3.2.21.

In Section 3.5.2.C.1.2 of its letter dated August 19, 2005, the applicant further stated that, for

NMP2, reduction of foundation strength due to erosion of porous concrete subfoundation is not

applicable. Porous concrete is not utiized in the construction of the primary containment

structure.

On the basis of its audit and review, the staff found that cracking, distortion, and increase in

component stress level due to containment settlement and reduction of containment foundation

strength due to erosion of porous concrete subfoundations are not plausible aging effects and

aging effects mechanisms due to the nonexistence of these aging effect and aging effect

mechanisms. The applicant stated that the aging effects and aging effects mechanisms due to

settlement are not expected at NMP2 for the containment structure since it is founded on

impervious rock. In addition, porous concrete was not utilized in the construction of the primary

containment structure. The staff determined that an AMP is not required since these aging

effect and aging effect mechanisms do not occur at NMPNS. However, the applicant

conservatively elected to use its Structures Monitoring Program to monitor for settlement, which

the staff found acceptable.

Based on the programs identified above, the staff concludes that there is reasonable assurance

that the applicant had met the criteria of SRP-LR Section 3.5.2.2.1.2. For those line items that

apply to Section 3.5.2.C.1.2 of the applicant's letter dated August 19, 2005, the staff determined

that the information in the application is consistent with the GALL Report and the applicant had

demonstrated that the effects of aging will be adequately managed so that the intended

function(s) will be maintained consistent with the CLB during the period of extended operation,

as required by 10 CFR 54.21(a)(3).

Reduction of Strength and Modulus of Concrete Structures due to Elevated Temperature. The

staff reviewed Section 3.5.2.C.1.3 of the applicant's letter dated August 19, 2005 against the

criteria in SRP-LR Section 3.5.2.2.1.3.

3-485
In Section 3.5.2.C.1.3 of its letter dated August 19, 2005, the applicant addressed reduction of

strength and modulus of concrete structures due to elevated temperature in BWR

containments.

SRP-LR Section 3.5.2.2.1.3 states that reduction of strength and modulus of elasticity due to

elevated temperatures could occur in PWR concrete and steel containments and BWR Mark II

concrete containments and Mark III concrete and steel containments. The GALL Report

recommends further evaluation if any portion of the concrete containment components exceeds

specified temperature limits [i.e., general area temperature 66 °C (150 °F) and local area

temperature 93 °C (200 'F)].

In Section 3.5.2.C.1.3 of its letter dated August 19, 2005, the applicant stated that, for NMP2,

reduction of strength and modulus of concrete structures due to elevated temperature is not

significant. In the primary containment structure, general area temperatures do not exceed

150'F and local area temperatures do not exceed 200°F. These temperatures are not sufficient

to result in this aging effect or aging effect mechanism for the applicable components.

The applicant stated, in letter dated August 19, 2005, that, for the NMP2 primary containment,

this aging effect and aging effect mechanism are not applicable to NMPNS. The applicant

stated that during normal operation, all areas within the containment building do not experience

elevated temperatures > 150°F general and > 200°F local. Therefore, change in material

properties (reduction of strength and modulus of concrete) due to elevated temperature is not

an aging effect or aging effect mechanism requiring management for the NMPNS containment

concrete. As documented in the Audit and Review Report, the staff determined through

discussions with the applicant's technical staff that operating experience indicates that the

containment concrete has never experienced any aging effects and aging effects mechanisms

due to elevated temperatures.

On the basis that NMPNS does not have a containment concrete elevated temperature aging

effect and aging effect mechanism, the staff found that this aging effect and aging effect

mechanism are not applicable to NMPNS.

Loss of Material due to Corrosion in Inaccessible Areas of Steel Containment Shell or Liner

Plate. The staff reviewed Section 3.5.2.C.1.4 of the applicant's letter dated August 19, 2005

against the criteria in SRP-LR Section 3.5.2.2.1.4.

In Section 3.5.2.C.1.4 of its letter dated August 19, 2005, the applicant addressed loss of

material due to corrosion in inaccessible areas of steel containment shell or liner plate in BWR

containments.

SRP-LR Section 3.5.2.2.1.4 states that loss of material due to corrosion could occur in

inaccessible areas of the steel containment shell or the steel liner plate for all types of BWR

containments. The GALL Report recommends further evaluation of plant-specific programs to

manage this aging effect and aging effect mechanism for inaccessible areas if specific

conditions defined in the GALL Report cannot be satisfied.

For NMP2, the ASME Section XI Inservice Inspection (IWE) Program is credited for managing

aging effects and aging effects mechanisms due to corrosion of accessible primary

containment structure carbon steel components 'comprising the containment pressure

3-486
boundary. Inaccessible areas are compared against accessible areas with similar

environments. If warranted, additional inspections are performed. The staff reviewed the

applicant's ASME Section Xl Inservice Inspection (IWE) Program; the staff's evaluation is

documented in SER Section 3.0.3.2.17.

As documented in the Audit and Review Report, the staff noted that the GALL Report

recommends further evaluation of plant-specific programs to manage this aging effect and

aging effect mechanism for inaccessible areas if specific conditions defined in the GALL Report

cannot be satisfied. In the GALL Report, Item B1.1.1-a states that, for inaccessible areas

(embedded containment steel shell or liner), loss of material due to corrosion is not significant if

the following four specific conditions are satisfied:

(1) Concrete meeting the requirements of ACI 318 or 349 and the guidance of 201.2R was

used for the containment concrete in contact with the embedded containment shell or

liner.

(2) The concrete is monitored to ensure that it is free of penetrating cracks that provide a

path for water seepage to the surface of the containment shell or liner.

(3) The moisture barrier, at the junction where the shell or liner becomes embedded, is

subject to aging management activities in accordance with IWE requirements.

(4) Borated water spills and water ponding on the containment concrete floor are not

common and when detected are cleaned up in a timely manner.

The GALL Report states that if any of the four conditions cannot be satisfied, a plant-specific

AMP for corrosion is recommended. As documented in the Audit and Review Report, the staff

requested that the applicant provide an explanation for how each of the four conditions are

satisfied at NMP2. The applicant addressed the four conditions as follows:

(1) NMP2 was designed and constructed with equivalent codes as specified in the GALL

Report.

(2) The concrete is monitored in accordance with the applicant's ASME Section Xl Inservice

Inspection (IWE) and Structures Monitoring Programs.

(3) This condition is not applicable to the NMPNS design.

(4) This condition is not applicable to a BWR design.

On the basis of its audit and review, the staff determined that all of the conditions identified in

the GALL Report are satisfied. The applicant stated that the NMP2 containment was designed

and constructed with equivalent codes as those specified in the GALL Report. Accessible

concrete of the containment structure is monitored for penetrating cracks under the applicant's

ASME Section Xl Inservice Inspection (IWE) and Structures Monitoring Programs. Operating

experience demonstrates that the aging effect and aging effect mechanism of loss of material

due to corrosion has not been significant for the NMP2 steel containment shell. The staff found

that no additional plant-specific AMP is required to manage inaccessible areas of the steel

containment shell.

Based on the programs identified above, the staff concludes that there is reasonable assurance

that the applicant had met the criteria of SRP-LR Section 3.5.2.2.1.4. For those line items that

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apply to Section 3.5.2.C.1.4 of the applicant's letter dated August 19, 2005, the staff determined

that the information in the application is consistent with the GALL Report and the applicant had

demonstrated that the effects of aging will be adequately managed so that the intended

function(s) will be maintained consistent with the CLB during the period of extended operation,

as required by 10 CFR 54.21 (a)(3).

Loss of Prestress due to Relaxation, Shrinkaqe,. Creep, and Elevated Temperature. The staff

reviewed Section 3.5.2.C.1.5 of the applicant's letter dated August 19, 2005 against the criteria

in SRP-LR Section 3.5.2.2.1.5.

The applicant stated, in Section 3.5.2.C.1.5 of its letter dated August 19, 2005, that, for the loss

of prestress due to relaxation, shrinkage, creep and elevated temperature in BWR

containments, this aging effect and aging effect mechanism are not applicable to NMP2.

Prestressed tendons were not utilized in the construction of the primary containment structure

for NMP2. As documented in the Audit and Review Report, the staff determined through

discussions with the applicant's technical staff that the loss of prestress due to relaxation,

shrinkage, creep and elevated temperature in BWR containments does not apply to NMP2

since its primary containment does not contain prestressed tendons.

On the basis that NMP2 does not have any components from this group, the staff found that

this aging effect and aging effect mechanism are not applicable to NMP2.

Cumulative Fatigue Damage. In Section 3.5.2.C.1.6 of its letter dated August 19, 2005, the

applicant stated that fatigue is a TLAA, as defined in 10 CFR 54.3. Applicants must evaluate

TLAAs in accordance with 10 CFR 54.21(c)(1). SER Section 4.6 documents the staffs review of

the applicant's evaluation of this TLAA.

Cracking due to Cyclic Loading and SCC. The staff reviewed Section 3.5.2.C.1.7 of the

applicant's letter dated August 19, 2005 against the criteria in SRP-LR Section 3.5.2.2.1.7.

In Section. 3.5.2.C.1.7 of its letter dated August 19, 2005, the applicant addressed cracking due

to cyclic loading and SCC in BWR containments.

SRP-LR Section 3.5.2.2.1.7 states that cracking of containment penetrations (including

penetration sleeves, penetration bellows, and dissimilar metal welds) due to cyclic loading or

SCC could occur in all types of PWR and BWR containments. Cracking could also occur in vent

line bellows, vent headers and downcomers due to SCC for BWR containments. A visual VT-3

examination would not detect such cracks. The GALL Report recommends further evaluation of

the inspection methods implemented to detect these aging effects and aging effects

mechanisms.

In Section 3.5.2.C.1.7 of its letter dated August 19, 2005, the applicant stated that, for NMP2,

the ASME Section Xl Inservice Inspection (Subsection IWE) Program and 10 CFR 50

Appendix J Program are credited for managing cracking due to cyclic loading and SCC of

primary containment structure steel components. In addition, an augmented VT-1 visual

examination will be performed on containment bellows using enhanced techniques qualified for

detecting SCC.

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The staff reviewed the applicant's ASME Section Xl Inservice Inspection (Subsection IWE)

Program and 10 CFR 50 Appendix J Program; the staff's evaluations are documented in SER

Sections 3.0.3.2.17 and 3.0.3.1.7, respectively.

Based on the applicant's further evaluation, as recommended in the GALL Report for detecting

cracking due to SCC, the staff found that the applicant had elected to perform augmented

VT-1 visual examinations on containment bellows using enhanced techniques qualified for

detecting SCC. The staff found that this is consistent with the GALL Report and is therefore

acceptable.

Based on the programs identified above, the staff concludes that there is reasonable assurance

that the applicant had met the criteria of SRP-LR Section 3.5.2.2.1.7. For those line items that

apply to Section 3.5.2.C.1.7 of the applicant's letter dated August 19, 2005, the staff determined

that the information in the application is consistent with the GALL Report and the applicant had

demonstrated that the effects of aging will be adequately managed so that the intended

function(s) will be maintained consistent with the CLB during the period of extended operation,

as required by 10 CFR 54.21 (a)(3).

3.5B.2.2.2 Class I Structures

The staff reviewed Section 3.5.2.C.2 of the applicant's letter dated August 19, 2005, against the

criteria in SRP-LR Section 3.5.2.2.2, which addresses several areas discussed below.

Aging of Structures Not Covered by Structures Monitoring Program. The staff reviewed

Section 3.5.2.C.2.1 of the applicant's letter dated August 19, 2005, against the criteria in

SRP-LR Section 3.5.2.2.2.1.

In Section 3.5.2.C.2.1 of its letter dated August 19, 2005, the applicant addressed the aging of

all Class I structures which are not covered by the Structures Monitoring Program.

SRP-LR Section 3.5.2.2.2.1 states that the GALL Report recommends further evaluation of

certain structure/aging effect combinations if they are not covered by the applicant's structures

monitoring program. This includes: (1) scaling, cracking, and spalling due to repeated

freeze-thaw for Groups 1-3, 5, 7-9 structures; (2) scaling, cracking, spalling and increase in

porosity and permeability due to leaching of calcium hydroxide and aggressive chemical attack

for Groups 1-5, 7-9 structures; (3) expansion and cracking due to reaction with aggregates for

Groups 1-5, 7-9 structures; (4) cracking, spalling, loss of bond, and loss of material due to

corrosion of embedded steel for Groups 1-5, 7-9 structures; (5) cracks, distortion, and increase

in component stress level due to settlement for Groups 1-3, 5, 7-9 structures; (6) reduction of

-foundation strength due to erosion of porous concrete subfoundation for Groups 1-3, 5-9

structures; (7) loss of material due to corrosion of structural steel components for Groups 1-5,

7-8 structures; (8) loss of strength and modulus of concrete structures due to elevated

temperatures for Groups 1-5; and (9) crack initiation and growth due to SCC and loss of

material due to crevice corrosion of stainless steel liner for Groups 7 and 8 structures. Further

evaluation is necessary only for structure/aging effect combinations not covered by the

applicant's structures monitoring program.

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SRP-LR Section 3.5.2.2.2.1 further states that technical details of the aging management issue

are presented in Subsection 3.5.2.2.1.2 for items (5) and (6) and Subsection 3.5.2.2.1.3 for

item (8).

In Section 3.5.2.C.2.1 of its letter dated August 19, 2005, the applicant stated that there are no

Group 6 structures (water control structures) at NMP2.

In addition, in letter dated August 19, 2005, the applicant stated that aging management of

components in accessible areas of Class I structures will be performed through general visual

inspections of its Structures Monitoring Program. Aging management is performed for the

following aging effect and aging effect mechanisms: freeze-thaw, leaching of calcium

hydroxide, aggressive chemical attack, reaction with aggregates, corrosion of embedded steel,

and corrosion of structural steel. The staff reviewed the applicant's Structures Monitoring

Program; the staff's corresponding evaluation is documented in SER Section 3.0.3.2.21.

In the letter, the applicant further stated that, for NMP2, cracking, distortion, and an increase in

component stress level due to settlement for Group 1-3, 5, 7-9 structures is not significant.

Class I structures are founded on impervious rock. Although evaluated as not significant, NMP2

credits the Structures Monitoring Program for monitoring settlement. NMP2 does not.utilize a

de-watering system.

In the letter, the applicant stated that, for NMP2, reduction of foundation strength due to erosion

of porous concrete subfoundation is not applicable since the Class I structures were designed

and analyzed to ACI 318-71 and ACI 318-77. Nonetheless, NMP2 manages the aging of these

components with the Structures Monitoring Program.

In the letter, the applicant stated that, for NMP2, loss of material due to corrosion of structural

steel components for Group 1-5, 7-8 structures is managed by its Structures Monitoring

Program. Although the NMP2 vent stack steel components and reactor cavity plug liner are not

identified in the GALL Report, these components are also managed by the Structures

Monitoring Program.

In addition, the applicant stated in the letter dated August 19, 2005, that for NMP2, loss of

strength and modulus of concrete structures due to elevated temperatures for Group 1-5

structures is not significant. In Class I structures, general area temperatures do not exceed

150°F and local area temperatures do not exceed 200 *F. These temperatures are not sufficient

to result in this aging effect and aging effect mechanism for the applicable components.

Furthermore, in its letter, the applicant stated that, for NMP2, crack initiation and growth due to

SCC and loss of material due to crevice corrosion of stainless steel liners for Group 7 and 8

structures is not applicable. No tank liners were identified as subject to an AMR.

On the basis of its review, the staff found that scaling, cracking, and spalling due to repeated

freeze-thaw for Groups 1-3, 5, 7-9 structures; scaling, cracking, spalling and increase in

porosity and permeability due to leaching of calcium hydroxide and aggressive chemical attack

for Groups 1-5, 7-9 structures; expansion and cracking due to reaction with aggregates for

Groups 1-5, 7-9 structures; cracking, spalling, loss of bond, and loss of material due to

corrosion of embedded steel for Groups 1-5, 7-9 structures; cracks, distortion, and increase in

component stress level due to settlement for Groups 1-3, 5, 7-9 structures; and loss of material

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due to corrosion of structural steel components for Groups 1-5, 7-8 structures are within the

scope of license renewal and will be adequately managed by the applicant's Structures

Monitoring Program.

As documented in the Audit and Review Report, the staff interviewed members of the

applicant's technical staff and reviewed relevant operating experience to confirm that these

aging effects and aging effects mechanisms have not been observed or, when observed,

corrective action was taken under the Structures Monitoring Program. The staff determined that

the recommendations of the GALL Report have been satisfied and that a plant-specific AMP for

these aging effects and aging effects mechanisms for Class I structures is not required.

On the basis of its audit and review, the staff found that reduction of foundation strength due to

erosion of porous concrete subfoundations of Groups 1-3, 5,and 7-9 structures is not a

plausible aging effect and aging effect mechanism due to the nonexistence of the aging effect

and aging effect mechanism. The applicant stated that porous concrete subfoundations were

not utilized below the building foundations for Groups 1-3, 5, and 5-9 structures. The staff

determined that an AMP is not required since this aging effect and aging effect mechanism

does not occur at NMP2. However, the applicant conservatively elected to manage the aging of

these components with its Structures Monitoring Program.

The staff found the applicant's further evaluation for elevated temperatures acceptable since

change in material properties due to elevated temperatures is an aging effect and aging effect

mechanism that does not require management for NMP2 Groups 1-5 Class I structures.

In letter dated August 19, 2005, the applicant stated that the aging effects and aging effects

mechanisms of crack initiation and growth due to SCC and loss of material due to crevice

corrosion of stainless steel liners for NMP2 Group 7 and 8 structures are not applicable since

no tank liners were identified as subject to an AMR. On the basis of its audit and review, the

staff determined that no AMP is required for the above aging effects and aging effects

mechanisms for stainless steel liners for Group 7 and 8 structures.

Based on the programs identified above, the staff concludes that there is reasonable assurance

that the applicant had met the criteria of SRP-LR Section 3.5.2.2.2.1. For those line items that

apply to Section 3.5.2.C.2.1 of the applicant's letter dated August 19, 2005, the staff determined

that the information in the application is consistent with the GALL Report and the applicant had

demonstrated that the effects of aging will be adequately managed so that the intended

function(s) will be maintained consistent with the CLB during the period of extended operation,

as required by 10 CFR 54.21 (a)(3).

Aginq Management of Inaccessible Areas. The staff reviewed Section 3.5.2.C.2.2 of the

applicant's letter dated August 19, 2005 against the criteria in SRP-LR Section 3.5.2.2.2.2.

In Section 3.5.2.C.2.2 letter dated August 19, 2005, the applicant addressed aging

management of inaccessible areas of Class I structures.

SRP-LR Section 3.5.2.2.2.2 states that cracking, spalling, and increases in porosity and

permeability due to aggressive chemical attack and cracking, spalling, loss of bond, and loss of

material due to corrosion of embedded steel could occur in below-grade inaccessible concrete

areas. The GALL Report recommends further evaluation to manage these aging effects and

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aging effects mechanisms in inaccessible areas of Groups 1-3, 5, 7-9 structures, if specific

conditions defined in the GALL Report cannot be satisfied.

In Section 3.5.2.C.2.2 of its letter dated August 19, 2005, the applicant stated that, for NMP2,

cracking, spalling, and increases in porosity and permeability due to aggressive chemical

attack; and cracking, spalling, loss of bond, and loss of material due to corrosion of embedded

steel are not significant. Ground water tests confirm that a below-grade aggressive environment

does not exist. Although evaluated as not significant, the applicant credited the Structures

Monitoring Program to monitor for aggressive chemical attack and corrosion of embedded

steel. A regularly scheduled ground water monitoring program will be implemented to ensure

that a benign environment is maintained. The staff reviewed the applicant's Structures

Monitoring Program; the staffs corresponding evaluation is documented in SER

Section 3.0.3.2.21.

As documented in the Audit and Review Report, the staff determined, through discussions With

the applicant's technical staff and review of the ALRA, that the recommendations of the GALL

Report have been satisfied and a plant-specific AMP for inaccessible concrete of Class I

(Groups 1-3, 5, 7-9) structures is not required for these nonexistent aging effect and aging

effect mechanisms.

On the basis that NMPNS does not currently have an aggressive environment aging effect or

aging effect mechanism for inaccessible concrete, with regularly scheduled ground water

monitoring to be implemented to ensure the below-grade environment remains nonaggressive,

the staff determined that these aging effects and aging effects mechanisms (cracking, spalling,

increases in porosity and permeability, loss of bond, loss of material) are not applicable to

NMPNS Groups 1-3, 5, 7-9 Class I structures.

Based on the programs identified above, the staff concludes that there is reasonable assurance

that the applicant had met the criteria of SRP-LR Section 3.5.2.2.2.2. For those line items that

apply to Section 3.5.2.C.2.2 of the applicant's letter dated August 19, 2005, the staff determined

that the information in the application is consistent with the GALL Report and the applicant had

demonstrated that the effects of aging will be adequately managed so that the intended

function(s) will be maintained consistent with the CLB during the period of extended operation,

as required by 10 CFR 54.21 (a)(3).

3.5B.2.2.3 Component Supports

The staff reviewed Section 3.5.2.C.3 of its letter the applicant's letter dated August 19, 2005,

against the criteria in SRP-LR Section 3.5.2.2.3, which addresses several areas discussed

below.

Aging of Supports Not Covered by Structures Monitorina Program. The staff reviewed

Section 3.5.2.C.3.1 of the applicant's letter dated August 19, 2005 against the criteria in

SRP-LR Section 3.5.2.2.3.1.

In Section 3.5.2.C.3.1 of its letter dated August 19, 2005, the applicant addressed aging of

component supports not covered by the Structures Monitoring Program.

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SRP-LR Section 3.5.2.2.3.1 states that the GALL Report recommends further evaluation of

certain component support aging effect and aging effect mechanism combinations if they are

not covered by the applicant's structures monitoring program. This includes: (1) reduction in

concrete anchor capacity due to degradation of the surrounding concrete, for Groups B1-B5

supports; (2) loss of material due to environmental corrosion, for Groups B2-B5 supports; and

(3) reduction/loss of isolation function due to degradation of vibration isolation elements, for

Group B4 supports. Further evaluation is necessary only for structure/aging effect combinations

not covered by the applicant's structures monitoring program.

In Section 3.5.2.C.3.1 of its letter dated August 19, 2005, the applicant stated that aging

management of component supports will be performed through general visual inspections of its

Structures Monitoring Program. Aging management is performed for the following aging effect

and aging effect mechanism combinations: reduction in concrete anchor capacity due to

degradation of the surrounding concrete, loss of material due to environmental corrosion, and

reduction/loss of isolation function due to degradation of vibration isolation elements.

The staff found that the applicant's Structures Monitoring Program covers reduction in concrete

anchor capacity due to degradation of the surrounding concrete, for Groups 81 through B5

supports; loss of material due to environmental corrosion, for Groups B2 through B5 supports;

and reduction/loss of isolation function due to degradation of vibration isolation elements, for

Group B4 supports. In accordance with the GALL Report, no further evaluation is required by

the applicant and, therefore, no further evaluation has been provided.

The staff found that the applicant included the above aging effect and aging effect mechanism

combinations within the scope of the Structures Monitoring Program and agreed that no further

evaluation is required. The staff reviewed the applicant's Structures Monitoring Program; the

staff's corresponding evaluation is documented in SER Section 3.0.3.2.21. The staff found that

the applicant's Structures Monitoring Program is acceptable for managing the above aging

effect and aging effect mechanism combinations of component supports for the GALL Report

component support Groups B1 through B5, as those combinations are applicable.

Based on the programs identified above, the staff concludes that there is reasonable assurance

that the applicant had met the criteria of SRP-LR Section 3.5.2.2.3.1. For those line items that

apply to Section 3.5.2.C.3.1 of the applicant's letter dated August 19, 2005, the staff determined

that the information in the application is consistent with the GALL Report and the applicant had

demonstrated that the effects of aging will be adequately managed so that the intended

function(s) will be maintained consistent with the CLB during the period of extended operation,

as required by 10 CFR 54.21 (a)(3).

Cumulative Fatigue Damaqe due to Cyclic Loading. Fatigue is a TLAA, as defined in

10 CFR 54.3. Applicants must evaluate TLAAs in accordance with 10 CFR 54.21(c)(1). SER

Section 4.6 documents the staff's review of the applicant's evaluation of this TLAA.

3.58.2.2.4 Quality Assurance for Aging Management of Nonsafety-Related Components

SER Section 3.0.4 provides the staff's evaluation of the applicant's Quality Assurance Program.

Conclusion. On the basis of its review, for component groups evaluated in the GALL Report for

which the applicant claimed consistency with the GALL Report, and for which the GALL Report

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recommends further evaluation, the staff determined that the applicant had adequately

addressed the issues that were further evaluated. The staff found that the applicant had

demonstrated that the effects of aging will be adequately managed so that the intended

functions will be maintained consistent with the CLB for the period of extended operation, as

required by 10 CFR 54.21(a)(3).

3.5B.2.3 AMR Results That Are Not Consistent with or Not Addressed in the GALL

Report

Summary of Technical Information in the Amended Application. In ALRA Tables 3.5.2.B-1

through 3.5.2.B-13 and Tables 3.5.2.C-1 and 3.5.2.C-2, the staff reviewed additional details of

the results of the AMRs for material, environment, aging effect requiring management, and

AMP combinations that are not consistent with the GALL Report, or that are not addressed in

the GALL Report.

In ALRA Tables 3.5.2.B-1 through 3.5.2.B-13 and Tables 3.5.2.C-1 and 3.5.2.C-2, the applicant

indicated, via Notes F through J, that the combination of component type, material,

environment, and aging effect requiring management does not correspond to a line item in the

GALL Report and provided information concerning how the aging effect will be managed.

Specifically, Note F indicates that the material for the AMR line item component is not evaluated

in the GALL Report. Note G indicates that the environment for the AMR line item component

and material is not evaluated in the GALL Report. Note H indicates that the aging effect for the

AMR line item component, material, and environment combination is not evaluated in the GALL

Report. Note I indicates that the aging effect identified in the GALL Report for the line item

component, material, and environment combination is not applicable. Note J indicates that

neither the component nor the material and environment combination for the line item is

evaluated in the GALL Report.

Staff Evaluation. For component type, material, and environment combinations that are not

evaluated in the GALL Report, the staff reviewed the applicant's evaluation to determine

whether the applicant had demonstrated that the effects of aging will be adequately managed

so that the intended function(s) will be maintained consistent with the CLB during the period of

extended operation. The staffs evaluation is discussed in the following sections.

3.5B.2.3.1 Structures and Component Supports NMP2 Primary Containment Structure -

Summary of Aging Management Evaluation - ALRA Table 3.5.2.B-1

The staff reviewed ALRA Table 3.5.2.B-1, which summarizes the results of AMR evaluations for

the primary containment structure component groups.

The staffs initial review of the original LRA Table 3.5.2.B-1 identified areas in which additional

information was necessary. The applicant responded to the staff's RAls as discussed below.

In RAI 3.5.B-1, dated December 9, 2004, the staff requested that the applicant provide

information regarding the aging management of pressure boundary bellows by noting that in

item 3.5.1..B-17 of the original LRA Table 3.5.1 .B, the applicant identifies that the AMR results

are consistent with the GALL Report, with the exceptions described in the ASME Section Xl

Inservice Inspection (Subsection IWE) Program. The GALL Report, under Item BI.1.1-d

recommends further evaluation regarding the SCC of containment bellows. In the discussion of

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these items with the staff, the applicant asserted that crack initiation and growth due to SCC is

not applicable to the NMP2 vent line bellows. The staff also noted that the NMP2 containment

does not have vent line bellows. However, in similar environmental conditions, IN 92-20

indicates the existence of thermal growth and SCC of pressure boundary bellows. Therefore,

the staff requested that the applicant provide additional information to address the effectiveness

of the applicable aging management program(s) that detect (or would detect) degradation of

stainless steel bellows in drywell and suppression chamber of the NMP2 containment.

In its response, by letter dated January 10, 2005, the applicant stated that although the

penetration sleeves, penetration bellows, and dissimilar metal welds at NMP2 are not normally

subjected to conditions that cause cracking due to cyclic loading and crack growth due to stress

corrosion cracking, the original LRA will be revised to reflect the recommendations in

NUREG-1611, Table 2, Item 12. The recommendations in NUREG-1611 identify stress

corrosion cracking as an AERM by examination categories E-B and E-F of the ASME

Section Xl Inservice Inspection (Subsection IWE) Program (AMP B2.1.23) and by the

10 CFR 50 Appendix J Program (AMP B2.1.26). In addition, per NUREG-161 1, an augmented

VT-1 visual examination will be performed using enhanced techniques qualified for detecting

SCC. This augmented inspection will be included as an enhancement to the ASME Section Xl

Inservice Inspection (Subsection IWE) Program. The associated revisions to the original LRA

are shown in the response to RAI 3.5.A-1, dated January 10, 2005.

The applicant's proposal for revising the original LRA sections is documented in its response to

RAI 3.5.A-1. The staff found the applicant's approach of revising the original LRA to incorporate

the augmented inspection of the containment pressure retaining bellows in the NMP2

containment acceptable as proposed. A review of the ALRA indicates that the applicant had

incorporated the proposed additions. Therefore, the staff's concern described in RAI 3.5.B-1 is

resolved.

In RAI 3.5.B-2, dated December 9, 2004, the staff noted that item number 3.5.1..B-06 of original

LRA Table 3.5.1..B states that the ASME Section XI Inservice Inspection (Subsection IWE)

Program and 10 CFR 50 Appendix J Program are programs for manage aging of seals,

gaskets, and moisture barriers. The original LRA Table 3.5.2.B discusses these components

under a generic category of polymer in air. However, based on exception taken to the ASME

Section Xl Inservice Inspection (Subsection IWE) Program, this AMP will not be applicable for

aging management of containment seals and gaskets. Therefore, the staff requested that the

applicant explain the discrepancy.

Furthermore, the staff noted that, for seals and gaskets of equipment hatches and air-locks at

NMP2, the leak rate testing program would monitor the aging degradation of seals and gaskets,

as they are leak rate tested after each opening. Therefore, the staff requested that the

applicant justify that Type B leak rate testing frequency is adequate for monitoring aging

degradation of containment pressure boundary penetrations (mechanical and electrical) with

seats and gaskets.

In response, by letter dated January 10, 2005, the applicant provided the following information:

The inspection of the component type "Polymer in Air" is included in the ASME

Section XI Inservice Inspection (Subsection IWE) Program ([original] LRA

Section B2.1.23). The exception described in [original] LRA Section B2.1.23

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identifies that the Subsection IWE inservice inspection (ISI) program for NMP2 is

based on the 1998 Edition of ASME Section XI, rather than the 199211995

editions and addenda. This was found acceptable by the NRC in a safety

evaluation report dated August 17, 2000. There is no exception taken to the

performance of examinations for the subject polymeric components.

The aging management of the electrical penetrations and their associated

polymeric components is addressed in the NMPNS [original] LRA supplemental

letter NMP1L 1912, dated January 10, 2005. These components are managed

by the ASME Section Xl Inservice Inspection Program ([original] LRA

Section B2.1.23) and the 10 CFR 50 Appendix J Program ([original] LRA

Section B2.1.26). The mechanical primary containment penetrations for NMP2

are seal-welded to the liner and do not utilize polymeric seals or gaskets for

pressure retention.

NMP2 uses Option B for testing of the containment under 10 CFR 50, Appendix J. Type

B testing of containment penetrations follows the guidance provided in RG 1.163 and

NEI 94-01. The testing frequency for these components is at least once per 30 months.

However, under Option B, the test frequency may be extended to 60 months and then

120 months based upon component testing performance, service conditions and

environment, penetration design, and safety impact of penetration failure. For those

components with extended testing frequencies, an approximately even distribution is

tested during each interval (i.e., 30 months) to minimize the impact of unanticipated

random failures and increase the likelihood of detecting common-mode failures. Based

on the above attributes, there is reasonable assurance that the Type B testing frequency

is adequate for monitoring aging degradation of containment penetrations with seals

and gaskets.

Based on its review, the staff found the applicant's response to RAI 3.5.B-2 acceptable. The

applicant stated that there are no containment pressure boundary mechanical penetrations with

resilient seals and approximately 25 percent of the pressure boundary electrical penetrations

are Type B tested every 30 months in a way that would assure that each electrical penetration

is Type B tested every 120 months. This is consistent with NEI 94-01 (as endorsed by

RG 1.163) allows for 10-year interval for Type B testing, if they meet specific performance

criteria. Therefore, the staff's concern described in RAI 3.5.B-2 is resolved. This information is

reflected in the ALRA.

In RAI 3.5.B-3, dated December 9, 2004, the staff identified that the applicant is taking

exceptions in the ASME Section Xl Inservice Inspection (Subsection IWE) Program to preclude

examinations of seals, gaskets, and bolting of pressure boundary joint points. Occasional SRV

discharges, sustained elevated temperatures (maybe < 150°F), and high humidity, could

contribute to degradation of containment pressure boundary. Only Type A leak rate testing and

associated visual examination requirements of 10 CFR 50, Appendix J Program could be relied

upon to detect defects and degradation of containment pressure boundary joint points. The test

interval for Type A leak rate testing could be 10 to 15 years. Based on the above information,

the staff requested that the applicant provide information regarding the activities and programs

that are used for aging management and functional integrity of these pressure boundary joints

for the NMP2 primary containment.

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In its response, by letter dated January 10, 2005, the applicant provided the following

information:

The exceptions noted by the NRC for the Containment ISI program ([original]

LRA Section B.2.1.23) do not preclude examinations of seals, gaskets, and

bolting of pressure boundary joint points. By letter dated October 28, 1999, NMP

submitted a relief request (RR-IWE/IWL-1) to the NRC which proposed the use

of the 1998 Edition of ASME Section Xl, Subsection IWE, in lieu of the 1992

Edition with the 1992 Addenda of Subsection IWE. The use of the 1998 Edition

provides more practical requirements for the performance, training, qualification,

and scheduling of examinations and provides a uniform set of requirements that

eliminates the need for multiple relief requests. The NRC approved the relief

request in a safety evaluation report (SER) dated August 17, 2000. As noted in

the NRC SER, Examination Category E-D (Seals, Gaskets, and Moisture

Barriers) and Examination Category E-G (Pressure Retaining Bolting) were

eliminated from the 1998 Code. However, the examination of the pressure

retaining bolting and moisture barriers is now included in Examination Category

E-A, footnote (1)(d) and Item E1.30, respectively. The NRC also determined that

the verification of Containment leak-tight integrity through 10 CFR 50,

Appendix J testing provides an adequate method to verify the pressure integrity

of bolted connections, seals, and gaskets.

Containment pressure boundary joint points are examined and leak tested every

two years in accordance with an NMP2 instrument surveillance procedure. This

procedure measures leakage of Type B Appendix J Containment boundaries,

which include Containment penetrations whose design incorporates resilient

seals, gaskets or sealing compounds, piping penetrations fitted with expansion

bellows, electrical penetrations fitted with flexible metal seal assemblies, air lock

door seals, and doors with resilient seals or gaskets. This surveillance verifies

that the leakage through resilient seals, gaskets, sealant compounds, piping

penetrations, and electrical penetrations is maintained within specified values in

accordance with the NMP2 Technical Specifications and the NMP2 Appendix J

Testing Program Plan.

Based on its review, the staff found the examination process used by the applicant acceptable,

as it provides assurance that the containment pressure boundary joints will retain their integrity

during the period of extended operation. Therefore, the staffs concern described in RAI 3.5.B-3

is resolved.

In RAI 3.5.B-4, dated December 9, 2004, the staff requested that the applicant provide

information regarding the aging management of primary containment liner and inaccessible

areas by noting that the NMP2 primary containment structure is a steel lined reinforced

concrete structure. The original LRA item 3.5.1 .B-12, related to the primary containment liner,

states that "Inaccessible areas are compared against accessible areas and where warranted,

additional inspections are performed." Therefore, the staff requested that the applicant: (1)

describe the operating experience related to the liner corrosion in the accessible, as well as

inaccessible areas; (2) provide acceptance criteria used when the liner is left without repair; and

(3) provide information regarding any augmented inspections that had been implemented as

required by IWE-1240. Furthermore, the staff requested that the applicant provide this

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information for containment wall liner in drywell and suppression chamber, barrier slab liners,

and for the liners above the insulation concrete. -

In its response, by letter dated January 10, 2005, the applicant provided the following

-information:

The NMP2 primary containment liner is comprised of the drywell and

suppression pool liners. The AERM associated with [the original] LRA Table Item

3.5.1.B-12, "Primary Containment (BWR)," is addressed in the ASME Section XI

Inservice Inspection (Subsection IWE) Program (original LRA Section B2.1.23).

As stated in [the original] LRA Section B2.1.23, both industry and NMP

plant-specific operating experience relating to the IWE IS Program was

reviewed.

(1) The review of plant-specific operating experience revealed no

deficiencies adjacent to inaccessible areas that warranted further

evaluation. As a result of the latest inspection, the liner was found to be in

good to excellent condition. The IWE inspections noted the existence of

minor areas of surface corrosion and degraded coatings on the liner.

Since the noted corrosion was very minor in nature, there was no

structural integrity impact as a result of the corrosion. The degraded

coatings were addressed via the NMPNS CAP.

(2) For acceptance for continued service, components must comply with the

rules of Article IWE-3000, which provides acceptance standards for

components of steel containments and liners of concrete containments.

For the containment steel shell or liner, material loss exceeding 10

percent of the nominal containment wall thickness, or material loss that is

projected to exceed 10 percent of the nominal containment wall thickness

before the next examination, must be documented. Such areas where

conditions exceed this acceptance criteria are either: (1) subjected to a

further detailed visual examination, (2) submitted to engineering for an

acceptance evaluation, or (3) corrected by repair or replacement, in

accordance with IWE-3000, IWE-3122, and 10 CFR 50.55a.

(3) Containment surface areas requiring augmented examination are

identified in Table IWE-2500-1, Examination Category E-C, which are

those required by IWE-1240. When required, augmented ultrasonic

examinations will be performed on Class MC components. These

augmented exams will be performed and accepted to the requirements of

the 1998 Edition of ASME Section Xl, Subsection IWE. Detailed visual

examinations of surface areas are identified by IWE-1242. The extent of

examination shall be 100 percent for each inspection period until the

areas examined remain essentially unchanged for the next inspection

period. No augmented examinations have been identified for NMP2.

(4) A general inspection of the suppression pool from the platform found the area to

be in excellent condition. Platform beams located above the drywell floor were

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found to be in excellent condition. The containment liner, reactor pedestal liner,

and pre-cast concrete beam liner appeared to be in excellent condition.

Based on description of the process used by the applicant in identifying corrosion of liner and

areas of augmented inspection, the staff found that the aging management of the NMP2

primary containment is acceptable. Therefore, the staffs concern described in RAI 3.5.B-4 is

resolved.

In RAI 3.5.B-5 dated December 9, 2004, the staff requested that the applicant provide

information regarding the aging management of the concrete and steel structures inside the

primary containment. The staff noted that original LRA Table 3.5.2.B does not address load

resisting reinforced concrete and steel structures within the drywell and suppression pool.

These structures are likely to be subjected to high temperatures, water environment, and very

limited accessibility (it is not clear, if the inside surfaces of pedestals are accessible). Therefore,

the staff requested that the applicant provide the following information related to these

structures:

the range of actual temperatures recorded in the drywell, inner suppression pool, and

outer suppression pool

a summary of the results of the last inspections performed on the RPV pedestal

(inside and outside), the star truss, and the reactor support skirt and its anchorages in

the pedestal concrete

In its response by letter dated January 10, 2005, the applicant provided the following

information:

The normal operating temperature for the drywell is less than 150 °F. The average

drywell air temperature is maintained between 100 OF and 150 OF by the Drywell

Cooling System.

The normal operating temperature for the suppression pool is less than 111 OF. The

suppression pool air temperature is maintained less than 111 °F and the water

temperature is maintained less than 85°F. If either of these values is reached,

suppression pool cooling is placed in service.

The results of the last inspections performed on (1) the RPV pedestal (inside and

outside), (2) the star truss, and (3) the reactor support skirt and its anchorages in the

pedestal concrete, under the existing Structures Monitoring Program, show the

structures to be in good condition. There were no instances of degradation reported

for these components.

The staff found that the applicant's approach in controlling the drywell and suppression

chamber and managing the aging of the structures inside the primary containment acceptable.

Therefore, the staffs concern described in RAI 3.5.B-5 is resolved. This information is reflected

in the ALRA.

In RAI 3.5.B-6, dated December 9, 2004, the staff requested that the applicant provide

justification for not managing the aging of the fasteners and structural steel made of martensitic

precipitation hardenable material. The staff indicated that the original LRA Table 3.5.2.C-1 does

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not address aging effects and AMPs for fasteners and structural steel that are made of

martensitic precipitation hardenable material. The staff requested that the applicant discuss the

stress corrosion potential of these fasteners and structural steel, considering the hardness of

these materials, and that the fasteners are subjected to 100 percent moisture or occasional

water environment due to pipe or valve leakage. In addition, the staff requested that the

applicant provide the operating experience related to these items at NMP2.

In its response, by letter dated January 10, 2005, the applicant provided the following

information:

[Original] LRA Table 3.5.2.C-1 identifies structural steel (precipitation hardenable) in

air (for NMP2 only) with no aging effect requiring management. The structural steel

material is SA-564, Grade 630 (17-4PH). Precipitation hardened stainless steels

contain alloying elements that form strengthening precipitates (particles) when heat

treated for a specified time period, allowing these alloys to be hardened by heat

treatment. Alloy 17-4PH is strengthened by forming martensite and by precipitation

hardening. For nuclear applications, the typical minimum specified tempering

temperature for SA-564, Grade 630 (17-4PH) is I 100°F, resulting in a yield strength of

approximately 115 ksi. Throughout NMP2, the structural steel is in-scope for LR due to

two intended functions: (1) structural support for NSR and (2) structural/functional

support. The structural steel provides no safety-related functions for NMP2. For stress

corrosion cracking to occur, significant moisture must be present. Martensitic,

precipitation hardenable stainless steels are susceptible to stress corrosion cracking in

most waters. However, stress corrosion cracking will not occur at temperatures

< 140 °F even in a moist or occasionally wet environment. Many of the component

supports are for HVAC equipment with the structural steel exposed to indoor air in

various plant buildings, which will not see temperatures > 140 OF. In addition,

susceptibility to stress corrosion cracking increases with increasing yield strength, with

most failures occurring at yield strengths > 140 ksi. Since the yield strength of SA-564,

Grade 630 (17-4PH) is approximately 115 ksi, it is very unlikely that stress corrosion

cracking will occur. A review of the operating experience for NMP2 for the stress

corrosion cracking of martensitic, precipitation hardenable stainless steels found no

instances of this occurring.

Based on its review, the staff found the applicant's response to RAI 3.5.B-6 acceptable as the

staff agrees that SCC of the components made from the martensitic precipitation hardenable

stainless steels used at NMP2 is unlikely and that the applicant's position is consistent with the

GALL Report. Therefore, the staffs concern described in RAI 3.5.B-6 is resolved.

In RAI 3.5.B-7, dated December 9, 2004, the staff noted that the original LRA Table 3.5.2.C-1

and the ASME Section Xl Inservice Inspection (Subsection IWF) Program do not address aging

management review related to Class MC supports. GALL Report Section XI.S3 recommends

the use of Subsection IWF for examination of supports of MC components. Therefore, the staff

requested that the applicant provide the results of the aging management review for: MC

component supports within the NMP2 containment (including the supports submerged in water)

and supports for piping penetrating through the containments designated as MC piping (if any).

Furthermore, the staff requested that the applicant provide a summary of AMPs that will be

used for managing the aging of these supports, including sample size, inspection frequency,

and personnel qualification, etc.

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In its response, by letter dated January 10, 2005, the applicant provided the following

information:

Class MC supports are addressed in [the original] LRA Table 3.5.2.C-1.

Several line items in the table correspond to NUREG-1801, Volume 2, Item

Ill.B13.3.1-a, which is for loss of material for carbon steel ASME Class MC

supports. The description of the scope of the ASME Section XI Inservice

Inspection (Subsection IWF) Program in [the original] LRA Section B2.1.25

inadvertently omitted Class MC supports. The [original] LRA will be revised to

include Class MC supports in the scope description. The [revisions to the

original] LRA are provided in the response to RAI 3.5.A-6 above.

All NMP2 Class MC supports are included in the ASME Section Xl Inservice

Inspection (Subsection IWF) Program. Class MC supports fall into two component

types: (1) "Structural Steel (Carbon and Low Alloy Steel) in Air," and (2) "Structural

Steel (Wrought Austenitic Stainless Steel) in Air." Therefore, the only aging effect is

loss of material due to general corrosion applicable only to the carbon/low alloy steel

supports. NMP2 has no submerged Class MC supports.

All component supports at NMP2 are examined in accordance with the requirements

of Code Case N-491-1. The sample size and inspection frequency are as specified in

Table 2500-1 of Code Case N-491-1, which requires 100 percent of Class MC

supports to be examined each inspection interval, except that for multiple components

other than piping, within a system of similar design, function, and service, the supports

of only one of the multiple components are required to be examined. The examination

method is a visual VT-3 examination.

Nondestructive examination personnel at NMP2 are qualified by examination and so

certified, in accordance with SNT-TC-1A, per ASME Section Xl. Level I and Level II

personnel are recertified by qualification examinations every 3 years. Level III

personnel are recertified by qualification examinations once every 5 years.

The staff found the applicant's proposal to incorporate the aging management of NMP2

Class MC supports in ALRA Sections A2.1.13, and in B2.1.5 acceptable. A review of the these

ALRA sections indicate that the applicant had incorporated the provisions as noted in its

response to RAI 3.5A-6. Therefore, the staffs concern described in RAI 3.5.8-7 is resolved.

On the basis of its review, as discussed above, the staff concludes that there is reasonable

assurance that the applicant has demonstrated that the aging effects associated with the

primary containment structure components will be adequately managed so that the intended

functions will be maintained consistent with the CLB for the period of extended operation, as

required by 10 CFR 54.21(a)(3).

3.5B.2.3.2 Structures and Component Supports NMP2 Reactor Building - Summary of Aging

Management Evaluation - ALRA Table 3.5.2.B-2

The staff reviewed ALRA Table 3.5.2.B-2, which summarizes the results of AMR evaluations for

the reactor building component groups.

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The staffs review of the original LRA Table 3.5.2.B-2 identified areas in which additional

information was necessary to complete the review. The applicant responded to the staffs RAls

as discussed below.

In RAI 3.5.B-11, dated December 9, 2004, the staff noted that the original LRA Item 3.5.1..B-21

in Table 3.5.1.B and Item 3.5.1.B-07 in Table 3.5.1.1 state in the discussion columns that "ground water test data confirm that a below grade aggressive environment does not exist."

Therefore, the staff requested that the applicant provide a quantitative summary of NMP2's past

ground water test data to support the above assertion and to also to provide, if available, both

the phosphate and phosphoric acid contents of the NMP2 ground water.

In its response, by letter dated January 10, 2005, the applicant stated:

NMP1 and NMP2 are situated adjacent to a very large inland fresh water lake.

Groundwater testing is currently performed every six (6) months for the NMP site. No

evidence of aggressive ground water (pH<5.5, > 550 ppm chlorides, or sulfates

>1500 ppm) has been found at NMP. Groundwater test data is consistently within the

acceptable ranges for non-aggressive ground water as defined by NUREG-1801.

Results from the ground water tests performed in April and October of 2003 from the

two site test wells were as follows: pH 6.79-7.83; chloride 7.7-49 ppm; and sulfate

28-60 ppm. Due to the non-aggressive nature of the subsurface conditions, phosphate

and phosphoric acid concentrations have not been part of the chemical analysis.

Based on its review, the staff found the applicant's response to RAI 3.5.8-11 acceptable

because the ground water test data fully verify that NMPNS ground water is nonaggressive.

Therefore, the staff's concern described in RAl 3.5.B-11 is resolved.

In RAI 3.5.8-8, dated December 9, 2004, the staff stated that in the original LRA

Tables 3.5.2.8-2, 3.5.2.8-3, 3.5.2.B-4, 3.5.2.8-5, 3.5.2.8-6, 3.5.2.B-8, 3.5.2.B-10, 3.5.2.8-11,

3.5.2.8-12 and 3.5.2.1-13, the Structures Monitoring Program is credited to manage aging of

concrete, concrete lean fill and treated wood in soil (both above and below the GWT), and

polymer in soil below the GWT. Since these concrete elements and treated wood are

inaccessible because of the presence of soil, the staff requested that the applicant discuss the

specific provisions or methods stipulated in the Structures Monitoring Program that will be used

to inspect or manage aging of these inaccessible components.

In its response, by letter dated January 10, 2005, the applicant stated:

NMP [original] LRA Tables 3.5.2.8-2, 3.5.2.8-3, 3.5.2.1-4, 3.5.2.1-5, 3.5.2.8-6,

3.5.2.B-8, 3.5.2.1-10, 3.5.2.B-11, 3.5.2.B-12, and 3.5.2.B-13 credit the Structures

Monitoring Program (SMP) to manage aging of concrete, concrete lean fill and treated

wood in soil (both above and below the GWT), and polymer in soil below the GWT.

The SMP implementing procedure provides instructions for the performance of

inspections of opportunity when the inaccessible surface(s) of a buried structure is

excavated or exposed. The use of NMP site-specific characteristics, industry

experience data, and/or testing records of items under similar conditions is also

employed.

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Inspections of accessible areas adjacent to inaccessible areas are also utilized. As an

example, the inspection of interior areas below grade can provide indications of

degradation for polymer sealing materials if ground water in-leakage is starting to

occur. As stated in [the original] LRA Section B2.1.28, enhancements to the SMP will

include water tight penetration inspections.

Based on the information provided in the ALRA that no evidence of aggressive ground water

has been found at NMPNS and that groundwater test data is consistently within the acceptable

ranges for non-aggressive ground water as defined by the GALL Report, the staff found that the

applicant's position for managing aging of concrete, concrete lean fill and treated wood in soil

and polymer in soil below the GWT is consistent with the applicable staff position and is

acceptable. Therefore, the staffs concern described in RAI 3.5.B-8 is resolved.

In RAI 3.5.B-13, dated December.9, 2004, the staff stated that the original LRA

Tables 3.5.2.6-2 and 3.5.2.B-6 list aluminum alloys exposed to either air or treated water as

items having no aging effects and no AMP is credited to manage their aging. Items such as

cable trays, conduits, ducts, and tube tracks that are made of aluminum alloys might be

exposed to a chemically aggressive or acidic outside environment resulting in aging of these

components. Therefore, the staff requested that the applicant discuss past operating/inspection

experience with respect to aging management of the above listed components and justify the

NMP2 conclusion that no AMP is needed during the period of extended operation.

In its response, by letter dated January 10, 2005, the applicant stated:

Cable trays, conduits, ducts, and tube tracks are not constructed of aluminum alloys at

NMP2. For NMP2, Aluminum Alloy in Air" is the component type for overpressurization

vent panels in the Reactor Building and the phase bus duct enclosure, which is part of

Essential Yard Structures. A review of the NMP plant-specific operating experience did

not identify any occurrences of degradation of aluminum alloy components in air or

treated water. Therefore, no specific aging management program is required.

The staff found that the NMPNS plant-specific operating experience described in the applicant's

response is adequate and acceptable. Therefore, the staff's concern described in RAI 3.5.B-13

is resolved.

Information provided by the applicant to the above staff RAIs has been incorporated in the

ALRA submitted by letter dated July 14, 2005.

On the basis of its review, as discussed above, the staff concludes that there is reasonable

assurance that the applicant has demonstrated that the aging effects associated with the

reactor building components will be adequately managed so that the intended functions will be

maintained consistent with the CLB for the period of extended operation, as required by

10 CFR 54.21(a)(3).

3.5B.2.3.3 Structures and Component Supports NMP2 Auxiliary Service Building - Summary of

Aging Management Evaluation - ALRA Table 3.5.2.B-3

The staff reviewed ALRA Table 3.5.2.B-3, which summarizes the results of AMR evaluations for

the auxiliary service building component groups.

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The staff's initial review of the original LRA Table 3.5.2.B-3 identified areas in which additional

information was necessary. The applicant responded to the staff's RAls as discussed below.

In RAI 3.5.8-9, dated December 9, 2004, the staff stated that in the original LRA

Tables 3.5.2.B-2, 3.5.2.B-4, 3.5.2.B-5, 3.5.2.B-6, 3.5.2.B-8, 3.5.2.8-10, 3.5.2.B-11, 3.5.2.B-13

and 3.5.2.C-1, the Structures Monitoring Program (SMP) is credited to monitor the loss of

anchor capacity of expansion/grouted anchors (carbon and low alloy steel) in air. Therefore, the

staff requested that the applicant discuss the methods used for checking of anchor bolt torque

or bolt tightness to assure that there is no loss of anchor capacity for the above anchors and to

ensure that the Structures Monitoring Program will clearly stipulate methods for monitoring the

anchor capacity of expansion/grouted anchors.

In its response, by letter dated January 10, 2005, the applicant stated that:

With respect to [original] LRA Tables 3.5.2.13-2, 3.5.2.B-4, 3.5.2.B-5, 3.5.2.8-6,

3.5.2.B-8, 3.5.2.B-10, 3.5.2.B-11, 3.5.2.B-13, and 3.5.2.C-1, the SMP is credited with

monitoring the loss of anchor capacity of expansion/grouted anchors (carbon and low

alloy steel) in air. Two AERMs are identified in the [original] LRA and NUREG-1801 for

carbon steel expansion or grouted anchors: (1) loss of material due to general

corrosion and (2) loss of anchor capacity due to local concrete aging mechanisms.

The inspection method to determine if there is a potential for loss of anchor capacity of

an expansion or grouted anchor is the identification of concrete degradation local to

the anchor. If local concrete degradation is identified, additional inspections may be

required as determined by evaluations performed under the NMPNS CAP.

Checking of anchor bolt torque or bolt tightness is not routinely performed unless the

potential for loss of anchor capacity due to local concrete aging mechanisms is

identified.

The staff found that the methods described in the applicant's response above, for checking of

NMPNS expansion anchor bolt to assure that there is no loss of anchor capacity for the

anchors, is consistent with the applicable staff position and is acceptable. Therefore, the staffs

concern described in RAI 3.5.B-9 is resolved.

In RAI 3.5.8-10, dated December 9, 2004, the staff stated that the original LRA

Tables 3.5.2.1-2, 3.5.2.8-7 and 3.5.2.C-1 indicate that no AMP is needed for

fasteners/structural steel (wrought austenitic stainless steel exposed to low flow treated water

with temperature less than 140 °F. GALL Report Section III, Item A5.2.b recommends the use

of an appropriate water chemistry program to manage aging of stainless steel liners exposed to

water. Therefore, the staff requested that the applicant explain the meaning of the "treated

water referred to above and explain the NMP2 criteria (e.g., a water chemistry control program

or equivalent used in quality control of the treated water). The staff also requested that the

applicant provide information to justify the NMP2 conclusion that no AMP is needed for the

listed items subject to the environment stipulated above.

In its response, by letter dated January 10, 2005, the applicant stated:

NMP will revise [the original] LRA Tables 3.5.2.B-2, 3.5.2.B-7, and 3.5.2.C-1 to include

crack initiation and growth due to SCC and loss.of material due to crevice corrosion as

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an AERM for the following component types: (1) "fasteners (wrought austenitic

stainless steel) exposed to low flow treated water with temperature less than 140 OF,"

and (2) "structural steel (wrought austenitic stainless steel) exposed to low flow treated

water with temperature less than 140 OF," and will credit the Water Chemistry Control

Program described in [original] LRA Section B2.1.2. The supplemental letter that

NMPNS has previously committed to submit by February 28, 2005 (reference NMPNS

letter NMP1L 1902 dated December 21, 2004) will include the above-described table

changes.

"Treated water" is defined in the original LRA Table 3.0-1 (footnote on page 3.0-9), as

follows:

The water source is demineralized water that is chemically treated to remove

oxygen. Corrosion inhibitors can be added to the water. Administrative limits are

placed on dissolved oxygen and contaminants, and in some cases suspended

solids. The concentration of contaminants is controlled by a combination of

filtration, ion exchangers, or feed-and bleed (dilution) operations.

The staff found that with the applicant's proposed revisions to the affected tables, as discussed

above, are adequate and acceptable. Therefore, the staff's concern described in RAI 3.5.1-10

is resolved.

In RAI 3.5.B-12, dated December 9, 2004, the staff stated that the original LRA Table 3.5.2.B-6

credits NMP2's Structures Monitoring Program to manage aging of polymers situated in soil

below the ground water table (GWT). Since these polymers are inaccessible, the staff

requested that the applicant explain how, and at what frequency, the Structures Monitoring

Program is used to manage both the cracking and the loss of strength aging effects of the

polymers in soil below the GWT.

In its response, by letter dated January 10, 2005, the applicant stated that:

The SMP is designed to perform periodic inspections of station structures and

structural components to identify degradation and correct conditions prior to loss of

function. The periodic inspections are performed on the accessible portions of the

structures and structural components. Inspections of accessible areas adjacent to

inaccessible areas provide an indirect assessment of the condition of the inaccessible

areas. For example, if the inspection of interior areas below grade identifies ground

water in-leakage, this condition could be an indication of degradation of polymer

sealing materials. In this case, the evaluation of the in-leakage condition would include

both the accessible and inaccessible areas and corrective actions would be taken as

appropriate.

The SMP also has a specific requirement to inspect inaccessible areas when the

opportunity presents itself. When the inaccessible area becomes exposed or

excavated, an inspection is performed under the SMP. The parameters monitored and

acceptance criteria applied to the inaccessible area are the same as those applied to

the accessible areas.

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Based upon the above, the SMP provides reasonable assurance that the intended

functions of the inaccessible portions of structures and structural components,

including polymers below the ground water table, are maintained within the current

licensing basis requirements.

The staff found that the applicant's response is consistent with the applicable staff position

covering aging management of polymers situated in soil below the GWT and, as such, is

acceptable. Therefore, the staffs concern described in RAI 3.5.B-12 is resolved.

On the basis of its review, as discussed above, the staff concludes that there is reasonable

assurance that the applicant has demonstrated that the aging effects associated with the

auxiliary service building components will be adequately managed so that the intended

functions will be maintained consistent with the CLB for the period of extended operation, as

required by 10 CFR 54.21(a)(3).

3.5B.2.3.4 Structures and Component Supports NMP2 Control Room Building - Summary of

Aging Management Evaluation - ALRA Table 3.5.2.8-4

The staff reviewed ALRA Table 3.5.2:8-4, which summarizes the results of AMR evaluations for

the control room building component groups.

The staff reviewed the information provided in ALRA Table 3.5.2.B-4, and determined that the

applicant has adequately identified applicable aging effects, and the AMPs credited for

managing the aging effects for the NMP2 Control Room Building components that are not

addressed by the GALL Report. The staff found the applicant's AMR results for NMP2 Control

Room Building components acceptable.

On the basis of its review, as discussed above, the staff concludes that there is reasonable

assurance that the applicant has demonstrated that the aging effects associated with the

control room building components will be adequately managed so that the intended functions

will be maintained consistent with the CLB for the period of extended operation, as required by

10 CFR 54.2 1(a)(3).

3.5B.2.3.5 Structures and Component Supports NMP2 Diesel Generator Building - Summary

of Aging Management Evaluation -ALRA Table 3.5.2.1-5

The staff reviewed ALRA Table 3.5.2.B-5, which summarizes the results of AMR evaluations for

the diesel generator building component groups.

The staff reviewed the information provided in Table 3.5.2.B -5 of the ALRA, and determined

that the applicant has adequately identified applicable aging effects, and the AMPs credited for

managing the aging effects for the NMP2 Diesel Generator Building components that are not

addressed by the GALL Report. The staff found the applicant's AMR results for NMP2 Diesel

Generator Building components acceptable.

On the basis of its review, as discussed above, the staff concludes that there is reasonable

assurance that the applicant has demonstrated that the aging effects associated with the diesel

generator building components will be adequately managed so that the intended functions will

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be maintained consistent with the CLB for the period of extended operation, as required by

10 CFR 54.21(a)(3).

3.5B.2.3.6 Structures and Component Supports NMP2 Essential Yard Structures - Summary

of Aging Management Evaluation - ALRA Table 3.5.2.B-6

The staff reviewed ALRA Table 3.5.2.B-6, which summarizes the results of AMR evaluations for

the essential yard structures component groups.

The staff reviewed the information provided in Table 3.5.2.8 -6 of the ALRA, and determined

that the applicant has adequately identified applicable aging effects, and the AMPs credited for

managing the aging effects for the NMP2 Essential Yard Structures components that are not

addressed by the GALL Report. The staff found the applicant's AMR results for NMP2 Essential

Yard Structures components acceptable.

On the basis of its review, as discussed above, the staff concludes that there is reasonable

assurance that the applicant has demonstrated that the aging effects associated with the

essential yard structures components will be adequately managed so that the intended

functions will be maintained consistent with the CLB for the period of extended operation, as

required by 10 CFR 54.21(a)(3).

3.58.2.3.7 Structures and Component Supports NMP2 Fuel Handling System - Summary of

Aging Management Evaluation - ALRA Table 3.5.2.8-7

The staff reviewed ALRA Table 3.5.2.8-7, which summarizes the results of AMR evaluations for

the fuel handling system component groups.

The staff reviewed the information provided in ALRA Table 3.5.2.8-7, and determined that the

applicant has adequately identified applicable aging effects, and the AMPs credited for

managing the aging effects for the NMP2 Fuel Handling System components that are not

addressed by the GALL Report. The staff found the applicant's AMR results for NMP2 Fuel

Handling System components acceptable.

On the basis of its review, as discussed above, the staff concludes that there is reasonable

assurance that the applicant has demonstrated that the aging effects associated with the fuel

handling system components will be adequately managed so that the intended functions will be

maintained consistent with the CLB for the period of extended operation, as required by

10 CFR 54.21(a)(3).

3.58.2.3.8 Structures and Component Supports NMP2 Main Stack - Summary of Aging

Management Evaluation - ALRA Table 3.5.2.8-8

The staff reviewed ALRA Table 3.5.2.8-8, which summarizes the results of AMR evaluations for

the main stack component groups.

The staff reviewed the information provided in Table 3.5.2.8 -8 of the ALRA, and determined

that the applicant has adequately identified applicable aging effects, and the AMPs credited for

managing the aging effects for the NMP2 Main Stack components that are not addressed by

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the GALL Report. The staff found the applicant's AMR results for NMP2 Main Stack

components acceptable.

On the basis of its review, as discussed above, the staff concludes that there is reasonable

assurance that the applicant has demonstrated that the aging effects associated with the main

stack component components will be adequately managed so that the intended functions will be

maintained consistent with the CLB for the period of extended operation, as required by

10 CFR 54.21(a)(3).

3.5B.2.3.9 Structures and Component Supports NMP2 Material Handling System - Summary

of Aging Management Evaluation - ALRA Table 3.5.2.B-9

The staff reviewed ALRA Table 3.5.2.B-9, which summarizes the results of AMR evaluations for

the material handling system component groups.

The staff reviewed the information provided in Section 3.5.2.B.9 and Table 3.5.2.B -9 of the

ALRA, and determined that the applicant has adequately identified applicable aging effects, and

the AMPs credited for managing the aging effects for the NMP2 Material Handling System

components that are not addressed by the GALL Report. The staff found the applicant's AMR

results for NMP2 Material Handling System components acceptable.

On the basis of its review, as discussed above, the staff concludes that there is reasonable

assurance that the applicant has demonstrated that the aging effects associated with the

material handling system components will be adequately managed so that the intended

functions will be maintained consistent with the CLB for the period of extended operation, as

required by 10 CFR 54.21(a)(3).

3.5B.2.3.10 Structures and Component Supports NMP2 Radwaste Building - Summary of

Aging Management Evaluation - ALRA Table 3.5.2.B-1 0

The staff reviewed ALRA Table 3.5.2.B-10, which summarizes the results of AMR evaluations

for the radwaste building component groups.

The staff reviewed the information provided in ALRA Table 3.5.2.B-10, and determined that the

applicant has adequately identified applicable aging effects, and the AMPs credited for

managing the aging effects for the NMP2 Radwaste Building components that are not

addressed by the GALL Report. The staff found the applicant's AMR results for NMP2

Radwaste Building components acceptable.

On the basis of its review, as discussed above, the staff concludes that there is reasonable

assurance that the applicant has demonstrated that the aging effects associated with the

radwaste building components will be adequately managed so that the intended functions will

be maintained consistent with the CLB for the period of extended operation, as required by

10 CFR 54.21(a)(3).

3.5B.2.3.1 1 Structures and Component Supports NMP2 Screenwell Building - Summary of

Aging Management Evaluation - ALRA Table 3.5.2.B-1 I

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The staff reviewed ALRA Table 3.5.2.B-11, which summarizes the results of AMR evaluations

for the screenwell building component groups.

The staff reviewed the information provided in ALRA Table 3.5.2.B -11, and determined that the

applicant has adequately identified applicable aging effects, and the AMPs credited for

managing the aging effects for the NMP2 Screenwell Building components that are not

addressed by the GALL Report. The staff found the applicant's AMR results for NMP2

Screenwell Building components acceptable.

On the basis of its review, as discussed above, the staff concludes that there is reasonable

assurance that the applicant has demonstrated that the aging effects associated with the

screenwell building components will be adequately managed so that the intended functions will

be maintained consistent with the CLB for the period of extended operation, as required by

10 CFR 54.21(a)(3).

3.5B.2.3.12 Structures and Component Supports NMP2 Standby Gas Treatment Building -

Summary of Aging Management Evaluation - ALRA Table 3.5.2.B-12

The staff reviewed ALRA Table 3.5.2.B-12, which summarizes the results of AMR evaluations

for the standby gas treatment building component groups.

The staff reviewed the information provided in ALRA Table 3.5.2.B-12, and determined that the

applicant has adequately identified applicable aging effects, and the AMPs credited for

managing the aging effects for the NMP2 standby gas treatment building components that are

not addressed by the GALL Report. The staff found the applicant's AMR results for NMP2

Standby Gas Treatment Building components acceptable.

On the basis of its review, the staff concludes that there is reasonable assurance that the

applicant has adequately identified the aging effects, and the AMPs credited for managing the

aging effects for the NMP2 standby gas treatment building components that are not addressed

by the GALL Report, so that the intended functions will be maintained consistent with the CLB

for the period of extended operation, as required by 10 CFR 54.21 (a)(3).

3.5B.2.3.13 Structures and Component Supports NMP2 Turbine Building - Summary of Aging

Management Evaluation - ALRA Table 3.5.2.B-13

The staff reviewed ALRA Table 3.5.2.B-13, which summarizes the results of AMR evaluations

for the turbine building component groups.

The staff reviewed the information provided in ALRA Table 3.5.2.B -13, and determined that the

applicant has adequately identified applicable aging effects, and the AMPs credited for

managing the aging effects for the NMP2 Turbine Building components that are not addressed

by the GALL Report. The staff found the applicant's AMR results for NMP2 Turbine Building

components acceptable.

On the basis of its review, as discussed above, the staff concludes that there is reasonable

assurance that the applicant has demonstrated that the aging effects associated with the

turbine building components will be adequately managed so that the intended functions will be

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maintained consistent with the CLB for the period of extended operation, as required by 10 CFR 54.21 (a)(":

3.5B.2.3.14 Structures and Component Supports Component Supports - Summary of Aging

Management Evaluation - ALRA Table 3.5.2.C-1

The staff reviewed ALRA Table 3.5.2.C-1, which summarizes the results of AMR evaluations for

the Component Supports component groups.

The staff's review of original LRA Table 3.5.2.C-1 identified an area in which additional

information was necessary. The applicant responded to the staff's RAI as discussed below.

The staff initial review in RAI 3.5.B-7, dated December 9, 2004, the staff noted that the original

LRA Table 3.5.2.C-1 and the ASME Section XI Inservice Inspection (Subsection IWF) Program

do not address AMR related to Class MC supports. The GALL Report, Section XI.S3

recommends the use of Subsection IWF for examination of supports of MC components.

Therefore, the staff requested that the applicant provide the results of the AMR for MC

component supports within the NMP2 containment (including the supports submerged in water)

and supports for piping penetrating through the containments designated as MC piping (if any).

Furthermore, the staff requested that the applicant provide a summary of program(s) that will

be used for managing the aging of these supports, including sample size, inspection frequency,

and personnel qualification, etc.

The applicant's response and the staffs resolution to RAI 3.5.B-7 are provided in SER

Section 3.5B.2.3.1.

On the basis of its review, as discussed above, the staff concludes that there is reasonable

assurance that the applicant has demonstrated that the aging effects associated with the

component supports components will be adequately managed so that the intended functions

will be maintained consistent with the CLB for the period of extended operation, as required by

10 CFR 54.21(a)(3).

3.5B.2.3.15 Structures and Component Supports Fire Stops and Seals - Summary of Aging

Management Evaluation - ALRA Table 3.5.2.C-2

The staff reviewed ALRA Table 3.5.2.C-2, which summarizes the results of AMR evaluations for

the Fire Stops and Seals component groups.

The staff reviewed the information provided in Table 3.5.2.C-2 of the ALRA and determined that

the applicant has adequately identified applicable aging effects, and the AMPs credited for

managing the aging effects for the NMP2 Fire Stops and Seals components that are not

addressed by the GALL Report. The staff found the applicant's AMR results for NMP2 Fire

Stops and Seals components acceptable.

On the basis of its review, as discussed above, the staff concludes that there is reasonable

assurance that the applicant has demonstrated that the aging effects associated with the fire

stops and seals components will be adequately managed so that the intended functions will be

maintained consistent with the CLB for the period of extended operation, as required by

10 CFR 54.21(a)(3).

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3.5B.3 Conclusion

The staff concludes that the applicant provided sufficient information to demonstrate that the

effects of aging for the NMP2 structures and component supports components that are within

the scope of license renewal and subject to an AMR will be adequately managed so that the

intended function(s) will be maintained consistent with the CLB for the period of extended

operation, as required by 10 CFR 54.21(a)(3).

The staff also reviewed the applicable USAR supplement program summaries and concludes

that they adequately describe the AMPs credited for managing aging of the structures and

component supports, as required by 10 CFR 54.21(d).

3.6 Aging Management of Electrical and Instrumentation and Controls

This section of the SER documents the staff's review of the applicant's AMR results for the

electrical and instrumentation and controls (I&C) components and component groups

associated with the following NMPNS commodities:

* cables and connectors

a non-segregated/switchyard bus

0 containment electrical penetrations

0 switchyard components

3.6.1 Summary of Technical Information in the Application

In ALRA Section 3.6, the applicant provided AMR results for the electrical and I&C systems

components and component groups. In ALRA Table 3.6.1, Summary of Aging Management

Evaluations in Chapter VI of NUREG-1801 for Electrical Components, the applicant provided a

summary comparison of its AMRs with the AMRs evaluated in the GALL Report for the

electrical and I&C components and component groups.

The applicant incorporated the applicable operating experience in the determination of AERMs.

These reviews included evaluation of plant-specific and industry operating experience. The

plant-specific evaluation included reviews of condition reports and discussions with appropriate

site personnel to identify AERMs. The applicant's review of industry operating experience

included a review of the GALL Report and operating experience issues identified since the

issuance of the GALL Report.

3.6.2 Staff Evaluation

The staff reviewed ALRA Section 3.6 to determine if the applicant provided sufficient

information to demonstrate that the effects of aging for the electrical and I&C components that

are within the scope of license renewal and subject to an AMR will be adequately managed so

that the intended functions will be maintained consistent with the CLB for the period of extended

operation, as required by 10 CFR 54.21 (a)(3).

During the weeks of September 19, and October 24, 2005, the staff performed an onsite audit

of AMRs, to confirm the applicant's claim that certain identified AMRs were consistent with the

GALL Report. The staff did not repeat its review of the matters described in the GALL Report;

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however, the staff did verify that the material presented in the ALRA was applicable and that the

applicant had identified the appropriate GALL AMRs. The staff s evaluations of the AMPs are

documented in SER Section 3.0.3. Details of the staffs audit are described in its Audit and

Review report for the NMPNS ALRA, dated January 18, 2006.

The staff confirmed that the applicant's further evaluations were consistent with the 'acceptance

criteria in SRP-LR Section 3.6.2.2 summarized in SER Section 3.6.2.2.

The staff also performed a technical review of the remaining AMRs that were not consistent

with, or not addressed in, the GALL Report. The technical review included evaluating whether

all plausible aging effects were identified and evaluating whether the aging effects listed were

appropriate for the combination of materials and environments specified. The staffs evaluations

are summarized in SER Section 3.6.2.3.

Finally, the staff reviewed the AMP summary descriptions in the Unit I UFSAR and Unit 2

USAR supplements to ensure that they adequately described the programs credited with

managing or monitoring aging for the electrical and instrumentation and controls components.

Table 3.6-1 below provides a summary of the staffs evaluation of components, aging effects

and aging effects mechanisms, and AMPs listed in ALRA Section 3.6, that are addressed in the

GALL Report.

Table 3.6-1 Staff Evaluation for Electrical and Instrumentation and Controls Systems

Components in the GALL Report

Component Group Aging Effectn 'AMP In GALL. AMP in ALRA-! Staff Evaluation

-Mechanism Report ___. ___. ____; __" __._____1__

Electrical Degradation due to Environmental TLAA This TLAA is

equipment subject various aging qualification of evaluated in

to 10 CFR 50A9 mechanisms electric components Section 4.4,

environmental 'Environmental

qualification (EQ) Qualification (EQ)"

requirements

(Item Number

3.6.1-01)

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ZComponent Group 1, Aging Effectil AMP in GALL• , ' AMP in ALRA Staff Evaluation

. Mechanism. 'Report _________________ ________________

Electrical cables Embrittlement, Aging management Non-EQ Electrical Consistent with

and connections not cracking, melting, program for - Cables and GALL, which

subject to discoloration, electrical cables Connections recommends no

10 CFR 50.49 EQ swelling, or loss of and connections not Program further evaluation

requirements dielectric strength subject to (B2.1.29) (See Section

(Item Number leading to reduced 10 CFR 50.49 EQ 3.6.2.1)

3.6.1-02) insulation requirements

resistance (IR);

electrical failure

caused by thermalV

thermoxidative

degradation of

organics; radiolysis

and photolysis

[ultraviolet (UV)

sensitive materials

only] of organics;

radiation-induced

oxidation; moisture

intrusion

Electrical cables Embrittlement, Aging management Non-EQ Electrical Consistent with

used in cracking, melting, program for Cables and GALL, which

instrumentation discoloration, electrical cables Connections used recommends no

circuits not subject swelling, or loss of used in in Instrumentation further evaluation

to 10 CFR 50A9 dielectric strength instrumentation Circuits Program (See Section

EQ requirements leading to reduced circuits not subject (B2.1.30) 3.6.2.1)

that are sensitive to IR; electrical failure to 10 CFR 50A9

reduction in caused by thermal/ EQ requirements

conductor insulation thermoxidative

resistance (IR) degradation of

(Item Number organics;

3.6.1-03) radiation-induced

oxidation; moisture

intrusion

Inaccessible Formation of water Aging management Non-EQ Consistent with

medium-voltage trees; localized program for Inaccessible GALL, which

(2 kV to 15 kV) damage leading to inaccessible Medium-Voltage recommends no

cables (e.g., electrical failure medium-voltage Cables Program further evaluation,

installed in conduit (breakdown of cables not subject (B2.1.31) NMP2 only (see

or direct buried) not insulation), caused to 10 CFR 50A9 Section 3.6.2.1)

subject to by moisture EQ requirements

10 CFR 50.49 EQ intrusion and water

requirements trees

(Item Number

3.6.1-04)

Electrical Corrosion of Boric acid corrosion Not Applicable Not applicable,

connectors not connector contact PWR only

subject to surfaces caused by

10 CFR 50.49 EQ intrusion of borated

requirements that water

are exposed to

borated water

leakage

(Item Number

3.6.1-05)

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The staffs review of the NMPNS component groups follows one of several approaches. One

approach, as documented in Section 3.6.2.1, involved the staffs review of the AMR results for

components in the electrical and instrumentation and controls that the applicant indicated are

consistent with the GALL Report and do not require further evaluation. Another approach,

documented in Section 3.6.2.2, involved the staff's review of the AMR results for components in

the electrical and I&C systems that the applicant indicated are consistent with the GALL Report

and for which further evaluation is recommended. A third approach, documented in

Section 3.6.2.3, involved the staff's review of the AMR results for components in the electrical

and instrumentation and controls that the applicant indicated are not consistent with, or not

addressed in, the GALL Report. The staff's review of AMPs that are credited to manage or

monitor aging effects of the electrical and I&C components is documented in SER

Section 3.0.3.

3.6.2.1 AMR Results That Are Consistent with the GALL Report, for Which Further

Evaluation is Not Recommended

Summary of Technical Information in the Application. In ALRA Section 3.6.2.1, the applicant

identified the materials, environments, and aging effects requiring management. The applicant

identified the following programs that manage the aging effects related to the electrical and I&C

components:

* Non-EQ Electrical Cables and Connections Program

* Non-EQ Electrical Cables and Connections Used In Instrumentation Circuits Program

• Non-EQ Inaccessible Medium-Voltage Cables Program

Staff Evaluation. In ALRA Table 3.6.2.C-1 through 3.6.2.C-4, the applicant provided a summary

of AMRs for the electrical and I&C components, and identified which AMRs it considered to be

consistent with the GALL Report..

For component groups evaluated in the GALL Report for which the applicant has claimed

consistency with the GALL Report, and for which the GALL Report does not recommend further

evaluation, the staff performed an audit and review to determine whether the plant-specific

components contained in these GALL Report component groups were bounded by the GALL

Report evaluation.

The applicant provided a note for each AMR line item. The notes (A through F) described how

the information in the tables aligns with the information in the GALL Report. For ALRA

Table 3.6.2.C-1 through 3.6.2.C-4, the applicant provided Notes A and C. The staff audited

those AMRs with Notes A and C, which indicated that the AMR was consistent with the GALL

Report.

Note A indicated that the AMR line item is consistent with the GALL Report for component,

material, environment, and aging effect. In addition, the AMP is consistent with the AMP

identified in the GALL Report. The staff audited these line items to verify consistency with the

GALL Report and the validity of the AMR for the site-specific conditions.

Note C indicated that the component for the AMR line item is different, but consistent with the

GALL Report for material, environment, and aging effect. In addition, the AMP is consistent with

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the AMP identified by the GALL Report. This note indicates that the applicant was unable to find

a listing of some system components in the GALL Report. However, the'applicant identified a

different component in the GALL Report that had the same material, environment, aging effect.

and AMP as the component that was under review. The staff audited these line items to verify

consistency with the GALL Report. The staff also determined whether the AMR line item of the

different component was applicable to the component under review and whether the AMR was

valid for the site-specific conditions.

The staff conducted an audit and review of the information provided in the ALRA, as

documented in the NMPNS audit and review report. The staff did not repeat its review of the

matters described in the GALL Report; however, the staff did verify that the material presented

in the ALRA was applicable and that the applicant had identified the appropriate GALL Report

AMRs.

The staff reviewed the ALRA to confirm that the applicant: (1) provided a brief description of the

system, components, materials, and environment; (2) stated that the applicable aging effects

were reviewed and evaluated in the GALL Report; and (3) identified those aging effects for the

electrical and I&C systems components that are subject to an AMR. On the basis of its audit

and review, the staff determined that, for AMRs not requiring further evaluation, as identified in

ALRA Table 3.6.1, the applicant's references to the GALL Report are acceptable and no further

staff review is required.

Conclusion. The staff evaluated the applicant's claim of consistency with the GALL Report. The

staff also has reviewed information pertaining to the applicant's consideration of recent

operating experience and proposals for managing associated aging effects. On the basis of its

review, the staff concludes that there is reasonable assurance that the AMR results, which the

applicant claimed to be consistent with the GALL Report, are consistent with the AMRs in the

GALL Report. Therefore, the staff concludes that the applicant has demonstrated that the

effects of aging for these components will be adequately managed so that their intended

function(s) will be maintained consistent with the CLB for the period of extended operation, as

required by 10 CFR54.21(a)(3).

3.6.2.2 AMR Results That Are Consistent with the GALL Report, for Which Further

Evaluation Is Recommended

Summary of Technical Information in the Amended Application. In Section 3.6.2.C of a letter

dated August 19, 2005, the applicant provided further evaluation of aging management as

recommended by the GALL Report for the electrical and I&C systems components. The

applicant provided information concerning how it will manage the following aging effects:

electrical equipment subject to environmental qualification

Staff Evaluation. For component groups evaluated in the GALL Report for which the applicant

has claimed consistency with the GALL Report, and for which the GALL Report recommends

further evaluation, the staff audited and reviewed the applicant's evaluation to determine

whether it adequately addressed the issues that were further evaluated. In addition, the staff

reviewed the applicant's further evaluations against the criteria contained in SRP-LR

Section 3.6.2.2. Details of the staffs audit are documented in the staffs Audit and Review

Report. The staffs evaluation of the aging effects is discussed in the following sections.

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3.6.2.2.1 Electrical Equipment Subject to Environmental Qualification

In Section 3.6.2.C.1 of a letter dated August 19, 2005, the applicant stated that environmental

qualification is a TLAA, as defined in 10 CFR 54.3. Applicants must evaluate TLAAs in

accordance with 10 CFR 54.21 (c)(1). SER Section 4.4 documents the staffs review of the

applicant's evaluation of this TLAA.

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

SER Section 3.0.4 provides the staffs evaluation of the applicant's quality assurance program.

Conclusion. On the basis of its review, for component groups evaluated in the GALL Report for

which the applicant has claimed consistency with the GALL Report, and for which the GALL

Report recommends further evaluation, the staff determines that the applicant adequately

addressed the issues that were further evaluated. The staff found that the applicant has

demonstrated that the effects of aging will be adequately managed so that the intended

functions will be maintained consistent with the CLB for the period of extended operation, as

required by 10 CFR 54.21(a)(3).

3.6.2.3 AMR Results That Are Not Consistent With or Not Addressed in the GALL Report

Summary of Technical Information in the Amended Application. In ALRA Tables 3.6.2.C-1

through 3.6.2.C-4, the staff reviewed additional details of the results of the AMRs for material,

environment, AERM, and AMP combinations that are not consistent with the GALL Report, or

that are not addressed in the GALL Report.

In ALRA Tables 3.6.2.C-1 through 3.6.2.C-4, the applicant indicated, via Notes F through J, that

the combination of component type, material, environment, and AERM does not correspond to

a line item in the GALL Report, and provided information concerning how the aging effect will

be managed. Specifically, Note F indicates that the material for the AMR line item component is

not evaluated in the GALL Report. Note G indicates that the environment for the AMR line item

component and material is not evaluated in the GALL Report. Note H indicates that the aging

effect for the AMR line item component, material, and environment combination is not evaluated

in the GALL Report. Note I indicates that the aging effect identified in the GALL Report for the

line item component, material, and environment combination is not applicable. Note J indicates

that neither the component nor the material and environment combination for the line item is

evaluated in the GALL Report.

Staff Evaluation. For component type, material, and environment combinations that are not

evaluated in the GALL Report, the staff reviewed the applicant's evaluation to determine

whether the applicant had demonstrated that the effects of aging will be adequately managed

so that the intended function(s) will be maintained consistent with the CLB during the period of

extended operation. The staffs evaluation is discussed in the following sections.

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3.6.2.3.1 Electrical and I&C Systems Cables and Connectors - Summary of Aging

Management Evaluation - ALRA Table 3.6.2.C-1

In ALRA Tables 3.6.2.C-1 through Table 3.6.2.C-4, the staff reviewed additional details of the

results of the AMRs for material, environment, AERM, and AMP combinations not consistent

with the GALL Report or not addressed in the GALL Report.

In ALRA Tables 3.6.2.C-1 through Table 3.6.2.C-4 the applicant indicated via Note J that

neither the identified component nor the material-environment combination is evaluated in the

GALL Report and provided information for how the aging effect will be managed. Specifically

Note J indicated that neither the component nor the material-environment combination for the

line item is evaluated in the GALL Report. For component type and material-environment

combination not evaluated in the GALL Report the staff reviewed the applicant's evaluation to

determine whether the applicant had demonstrated that the effects of aging will be adequately

managed so that intended functions will be maintained consistent with the CLB during the

period of extended operation.

The staffs evaluation is addressed in the following sections.

Electrical and I&C Systems Cables and Connectors

The staff reviewed ALRA Table 3.6.2.C-1, which summarizes aging management evaluations

for cables and connectors categorized into component types: (1) conductor insulation for

electrical cables and connectors, (2) conductor insulation for electrical cables in circuits

sensitive to reduction in conductor insulation resistance, (3) conductor connectors, and (4) fuse

holders. The conductor insulation for electrical cables and connectors, electrical cables in

circuits sensitive to reduction in conductor insulation resistance, and fuse holders excluding

metallic clamps are evaluated in Section 3.6.2.1. The staff evaluations for conductor connectors

and metallic clamps of fuse holders are provided in this section.

Conductor Connectors

Technical Information in ADplication - In the ALRA, the applicant stated that conductor

connectors include splices (butt or bolted), crimp-type lugs, and terminal blocks connecting

cable conductors to other cables or electrical devices. The applicant credited the Non-EQ

Electrical Cable Metallic Connections Inspection Program with managing the aging effects of

the conductor connectors.

Aging Effect - In ALRA Table 3.6.2.C-1 the applicant identified loosening of bolted connections

as the AERM.

Aging Management Program - The applicant credited the Non-EQ Electrical Cable Metallic

Connections Inspection Program with managing the potential aging effect for conductor

connectors.

Staff Evaluation.

Aging Effect - In ALRA Table 3.6.2.C-1 the applicant identified loosening of bolted connections

as the AERM. The staff agreed that the applicant in the ALRA correctly identified the aging

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effects of conductor connectors. Loosening of the bolted connections can be caused by thermal

cycling, ohmic heating, electrical transients, vibrations, chemical contamination, corrosion, and

oxidation

Aging Management Program - The applicant will credit the Non-EQ Electrical Cable Metallic

Connections Inspection Program to manage the potential aging effect for conductor connectors.

The staff evaluation of this AMP is in SER Section 3.0.3.3.5.

The staffs review concludes that the applicant adequately identified the aging effects and that

its inspection program adequately detects loosening of conductor connectors to ensure that the

component's intended functions will be maintained consistent with the CLB for the period of

extended operation as.required by 10 CFR 54.21(a)(3).

Fuse Holders

Technical Information in Application. In the ALRA, the applicant stated that only fuse holders

located outside active devices and not parts of larger assemblies are included in the program.

The applicant also stated that the fuse holders typically are constructed of blocks of rigid

insulating material like phenolic resins. Metallic clamps are attached to the blocks to hold each

end of the fuse. The clamps can be spring-loaded clips that allow fuse ferrules or blades to slip

in or they can be bolted lugs to which fuse ends are bolted. The clamps typically are made of

copper. In the ALRA Table 3.6.2.C-1 Material column the applicant categorized the fuse holder

components into insulator materials and copper alloy clamps. The applicant stated that the

aging of the fuse holder insulation material will be managed under Non-EQ Electrical Cables

and Connection Program (Section B2.1.29) evaluated in Section 3.6.2.1. The metallic damp

parts of the fuse holders are evaluated in this section. The applicant stated in Table 3.6.2.C-1

that the metallic damps of the fuse holders are subject to Fuse Holder Inspection Program.

Staff Evaluation.

Aging Effect- In ALRA Table 3.6.2.C-1 the applicant identified loss of electrical continuity as the

AERM. The staff agreed that the applicant in the ALRA correctly identified the aging effects for

fuse holder metallic clamps.

The loss of electrical continuity in the fuse holder metallic damps can be caused by one or

more of the following aging stressors: moisture, fatigue, ohmic heating, mechanical stress,

vibration, thermal cycling, electrical transients, chemical contamination, oxidation, and

corrosion.

Aging Management Program - The applicant stated that fuse holder metallic clamps may be

tested using either thermography or contact resistance. The staff evaluation of this Fuse Holder

Inspection Program is in SER Section 3.0.3.3.4

The staffs review concludes that the applicant adequately identified the aging effects and that

its adequate AMP for fuse holder clamps reasonably assures maintenance of the component's

intended functions consistent with the CLB for the period of extended operation as required by

10 CFR 54.2 1(a)(3).

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3.6.2.3.2 Electrical and I&C Systems Non-Segregated/ Switchyard Bus - Summary of Aging

Management Evaluation - ALRA Table 3.6.2.C-2

The ALRA Table 3.6.2.C-2 summarizes aging management evaluation for (1) Non-segregated

Bus Insulators, (2) Non-Segregated Bus, (3) Non-Segregated Bus Connectors, (4)

Non-Segregated Bus Insulation, (5) Switchyard Bus Conductors, (6) Switchyard Bus

Connectors, (7) Containment Electrical Penetrations, (8) High Voltage Insulators, (9)

Transmission Conductors, and (10) Transmission Conductor Connections.

The staff evaluation of these items is as follows:

* electrical and I&C systems non-segregated phase bus

a switchyard bus conductors

a switchyard bus connectors

• high voltage insulators

0 transmission conductors

• transmission conductor connections

• electrical and I&C systems containment electrical penetrations

Electrical and I&C Systems Non-Segregated Phase Bus. The phase bus is used to connect two

or more elements (equipment like switchgear and transformers) of an electrical circuit. The

isolated phase bus is an electrical bus in which each phase conductor is enclosed by an

individual metal housing separated from an adjacent conductor housing by an air space. A

non-segregated phase bus is an electrical bus constructed with all phase conductors in a

common enclosure without barriers (only air space) between the phases.

In the ALRA, the applicant stated that the materials of construction for the phase bus

components are:

* aluminum

* cement

* metal

* porcelain

* steel

• various organic polymers

The applicant also stated in the ALRA that phase bus components are exposed to an air

environment.

In ALRA Table 3.6.2.C-2 the applicant identified loss of insulation resistance and loosening of

bolted connections as aging effects and aging effects mechanisms of phase bus components

requiring aging management.

The applicant credited the Non-Segregated Bus Inspection Program with managing the

potential aging effects and aging effects mechanisms for the phase bus components. The staff

evaluation of this AMP is in SER Section 3.0.3.3.3

Interim Staff Guidance (ISG)-17, "Proposed Aging Management Program (AMP) XI.E4,

'Periodic Inspection of Bus Ducts,'" includes enclosed bus and enclosure assemblies as the

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structure and/or component of the metal enclosed bus. During the audit and review the staff

noted that ALRA Table 3.6.2.C-2 does not include this component. The staff requested that the

applicant provide justification for not including the enclosure assembly in the structure and/or

component category.

In its letter dated December 1, 2005, the applicant stated that it will revise ALRA

Table 3.6.2.C-2 to include the component types bus duct enclosure and seals and gaskets. The

applicant stated that the intended function for both components is shelter/protection with the

materials of aluminum for the enclosure and polymers for the seals and gaskets both in an

environment of air. The applicant also stated in this letter that there are no aging effects and

aging effects mechanisms requiring management for the aluminum enclosure and the aging

effects and aging effects mechanisms of the seals and gaskets are cracking, hardening, and

shrinkage to be managed by the Structures Monitoring Program. There are no notes for the bus

duct enclosure. Note H is for the seals and gaskets.

The staff performed an onsite audit of AMRs during the weeks of September 19 and

October 24, 2005, for Non-Segregated Bus items and confirmed that the applicant had

identified the applicable aging effects and aging effects mechanisms and listed the appropriate

combination of material, environments, and AMPs that will mange the aging effects and aging

effects mechanisms adequately. The staff agreed that the applicant correctly identified the

aging effects and aging effects mechanisms of phase bus components. In addition the staff

found that there are no aging effects and aging effects mechanisms requiring management for

the aluminum enclosure. The staff also found cracks, foreign debris, excessive dust build-up,

and evidence of water intrusion as additional aging effects and aging effects mechanisms

adequately managed by the Non-Segregated Bus Inspection Program. The applicant credited

its Non-Segregated Bus Inspection Program with aging management of the in-scope

non-segregated phase bus and its Structures Monitoring Program with managing the aging

effects and aging effects mechanisms of the enclosure seals and gaskets. The staff's review

and evaluations of these programs are documented in SER Section 3.0.3.3.3.

The staff performed other evaluations in reviewing the ALRA:

Switchyard Bus Conductors

Technical Information in the Application. The applicant identified aluminum as the component

and air as environment for switchyard bus conductors.

Aging Effect - The applicant stated "None" in the AERM column for switchyard bus conductors.

Aging Management Program - The applicant stated "None" in the AMP column for switchyard

bus conductors.

Staff Evaluation.

Aging Effect - By letter dated November 29, 2005, the staff requested additional information for

the statement "None" in the AERM column for switchyard bus conductors. By letter dated

December 5, 2005, the applicant stated that the switchyard bus conductors are made of

aluminum. The NMPNS environment is nonaggressive with little air pollution and no heavy

industry or saltwater. In a nonaggressive environment aluminum forms a passive oxide layer

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which arrests further oxidation/corrosion and loss of material (LOM) does not occur. NMPNS

operating experience indicates no wind-induced abrasion and fatigue failure of the switchyard

bus conductors. Tubular conductors are used at NMPNS and the wind speed encountered at

NMPNS is not high enough to degrade them. The staff agreed that there is no AERM for

switchyard bus conductors.

Aging Management Program - By letter dated November 29, 2005, the staff requested

additional information for the statement "None" in the AMP column for switchyard bus

conductors. By letter dated December 2005, the applicant stated that (1) there are no

corrosion-related AMPs because aluminum forms an oxide layer which arrests further oxidation,

(2) in the operating experience at NMPNS no wind-induced abrasion or fatigue failure of these

conductors has been observed, and (3) because of the design of the tubular conductors

significantly higher wind conditions than those that typically occur at NMPNS would be needed

to cause wind-related degradation.

Conclusion. The staff agrees that based on the justifications provided by the applicant, no AMP

is required for the switchyard bus conductor line item in Table 3.6.2.C-2.

Switchyard Bus Connectors

Technical Information in the Application. The applicant identified aluminum and steel as

materials and air as environment for switchyard bus connectors.

Aging Effect - The applicant stated "Loosening of Bolted Connections" in the AERM column for

switchyard bus connectors.

Aging Management Program - The applicant stated "Preventive Maintenance Program" in the

AMP column for switchyard bus connectors.

Aging Effect - The staff agreed that the applicant in the ALRA correctly identified the aging

effect of the switchyard bus connectors.

Aging Management Program - The applicant's current Preventive Maintenance Program does

not address maintenance of electrical components. By letter dated November 29, 2005, the

staff requested additional information for inspections of electrical components in the Preventive

Maintenance Program. By letter dated December 5, 2005, the applicant stated that under the

Preventive Maintenance Program the transmission conductor connections undergo visual

inspections, thermography testing, and corona measurement to detect loosened connections so

they can be retightened or otherwise corrected as necessary.

With the commitment (NMP1 Commitment 31 and NMP2 Commitment 29) from the applicant

that under the Preventive Maintenance Program, as discussed in SER Section 3.0.3.3.1, the

transmission conductor connections undergo visual inspections, thermography testing, and

corona measurement the staff found that the Preventive Maintenance Program is an adequate

AMP for switchyard bus connectors.

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Conclusion. On the basis of its review, as discussed above, the staff concludes that there is

reasonable assurance that the applicant has demonstrated that the aging effects of the

non-segregated/switchyard bus components will be adequately managed so that the intended

functions will be maintained consistent with the CLB for the period of extended operation, as

required by 10 CFR 54.21(a)(3).

3.6.2.3.3 Electrical and I&C Systems Containment Electrical Penetrations - Summary of Aging

Management Evaluation - ALRA Table 3.6.2.C-3

In the ALRA Table 3.6.2.C-3 the applicant summarized aging management evaluations for

Switchyard Components categorized into component types (1) High Voltage Insulators,

(2) Transmission Conductors, and (3) Transmission Conductor Connections.

High Voltaqe Insulators

Technical Information in the ADplication. The applicant identified cement, porcelain, and metal

as materials and air as the environment for high voltage insulators.

Aging Effect- The applicant stated "None" in the AERM column for all three materials.

Aging Management Program - The applicant stated "None" in the AMP column for all three

materials.

Staff Evaluation.

Aging Effect - By letter dated November 29, 2005, the staff requested additional information for

the statement "None" in the AMP column for cement, porcelain, and metal. By letter dated -

December 5, 2005, the applicant stated that to be conservative it would revise Table 3.6.2.C-4

for consistency with GALL Report Revision 1. The three line items for high voltage insulators at

the top of Table 3.6.2.C-4 were revised to include 2 AERM line items, one with the AERM

column entry "Loss of Insulation Resistance" and the other with the AERM column entry "Loss

of Material."

IN 93-95 documents degradation of insulator performance and ultimate loss of power due to

salt build-up on the insulators for plants located in saltwater marine environments. The

applicant stated that NMPNS is located on a lake, not in a saltwater marine environment.

Further, the applicant stated that its periodic inspections of its Preventive Maintenance Program

indicate no loss of material (LOM) or mechanical wear on transmission conductors due to wind.

The staff found this revision consistent with the GALL Report Revision and acceptable.

Aging Management Program - By letter dated November 29, 2005, the staff requested

additional information for the statement "None" in the AMP column for cement, porcelain, and

metal. By letter dated December 5, 2005, the applicant stated that to be conservative it would

revise Table 3.6.2.C-4 to state "Preventive Maintenance Program" in the AMP column. The

applicant stated that its Preventive Maintenance Program includes visual inspections,

thermography, and corona measurement.

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Conclusion. On the basis of its review, as discussed above, the staff concludes that there is

reasonable assurance that the applicant has demonstrated that the aging effects of the

switchyard components will be adequately managed so that the intended functions will be

maintained consistent with the CLB for the period of extended operation, as required by

10 CFR 54.21(a)(3).

Transmission Conductors

Technical Information in the ADolication. The applicant identified aluminum conductor, steel

reinforced as the material and air as the environment for transmission conductors.

Aging Effect- The applicant stated "None" in the AERM column for transmission conductors.

Aging Management Program - The applicant stated "None" in the AMP column for transmission

conductors.

Staff Evaluation.

Aging Effect - By letter dated November 29, 2005, the staff requested additional information for

the statement "None" in the AMP column for transmission conductors. By letter dated

December 5, 2005, the applicant stated that plant operating experience and the design of these

conductors indicate no loss of conductor strength due to corrosion to the extent necessary to

affect the ability of the conductors to perform their intended function. They are fabricated of

stranded aluminum wound around a steel stranded core with no organic insulating material

around them. For aluminum core steel reinforced conductors any degradation would begin as a

loss of zinc from the galvanized steel core wire strands. Corrosion rates depend on suspended

particle chemistry, sulfur dioxide (SO2) concentration in air, precipitation, fog chemistry, and

meteorological conditions, a very slow process even slower in rural areas with less

concentration of suspended particles and SO2 in the atmosphere than urban areas. NMPNS is

in a rural area.

The National Electric Safety Code (NESC) requires that tension on installed conductors be a

maximum of 60 percent of the ultimate conductor strength. The NESC also sets the maximum

tension to which a conductor can be subject under heavy load requirements including wind, ice,

and temperature. Ontario Hydroelectric performed tests of 80-year old transmission conductors

that showed a 30 percent loss of conductor strength. These were typical transmission

conductors that can reach 1000 feet in length. With 30 percent loss there is still significant

margin between the NESC requirement and the actual tested conductor strength. At NMPNS

transmission conductor runs are shorter than those included in the Ontario Hydroelectric test.

The longest transmission conductor run at NMPNS is approximately 515 feet. Because NMPNS

is located in a rural area, the tension of these shorter runs would be less than what is typical in

transmission conductor runs, and the Ontario Hydroelectric tests for 80-year old conductors

demonstrated significant margins between NESC requirements and test results the applicant's

opinion is that for the period of extended operation the AERM of loss of conductor strength

would not affect the intended function of these conductors significantly.

Based on the applicant's site-specific data the staff concludes that there is reasonable

assurance that corrosion of transmission conductors is a very slow aging process even slower

in rural areas with generally fewer suspended particles and lower sulphur dioxide concentration

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in the air than urban areas; therefore, loss of conductor strength due to transmission conductor

corrosion is not an AERM.

Conclusion. On the basis of its review, as discussed above, the staff concludes that the

applicant has demonstrated the transmission conductors have no AERM. The staff concludes

that there is reasonable assurance that the intended functions will be maintained consistent

with the CLB for the period of extended operation, as required by 10 CFR 54.21 (a)(3).

Transmission Conductor Connections

Technical Information in the Application. The applicant identified aluminum and steel as

materials and air as the environment for transmission conductor connections.

Aging Effect - The applicant stated "Loosening of Bolted Connections" in the AERM column for

transmission conductor connections.

Aging Management Program - The applicant stated "Preventive Maintenance Program" in the

AMP column for transmission conductor connections.

Staff Evaluation.

Aging Effect - The staff agreed that the applicant in the ALRA correctly identified the aging

effect of the transmission conductor connections.

Aging Management Program - By letter dated November 29, 2005, the staff requested

additional information for the statement "Preventive Maintenance Program" in the AMP column.

By letter dated December 2005, the applicant stated that under the Preventive Maintenance

Program the transmission conductor connections undergo visual inspections, thermography

testing, and corona measurement to detect loosened connections so they can be retightened or

otherwise corrected as necessary.

Based on the applicant's information that its Preventive Maintenance Program includes visual

inspections and thermography or corona measurement the staff concludes that there is

reasonable assurance that the applicant's AMP is adequate for transmission conductor

connections.

Conclusion. On the basis of its review, as discussed above, the staff concludes that there is

reasonable assurance that the applicant has demonstrated that the aging effects of the

transmission conductors connections components will be adequately managed so that the

intended functions will be maintained consistent with the CLB for the period of extended

operation, as required by 10 CFR 54.21 (a)(3).

3.6.2.3.4 Switchyard Components - Summary of Aging Management Evaluation - ALRA

Table 3.6.2.C-4

During the staff audit and review during the weeks of September 19 and October 24, 2005, the

staff reviewed ALRA Table 3.6.2.C-4, which summarizes the results of AMR evaluations for the

containment electrical penetrations component groups.

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The applicant stated in ALRA Section 3.6.2.1.3 that the construction materials for the

containment electrical penetration are various organic polymers. The containment electrical

penetrations are exposed to an adverse local environment of heat or radiation and air. The

aging effects and aging effects mechanisms of the containment electrical penetration requiring

management are loss of insulation resistance and loss of tightness. The applicant credited the

ASME Section XI Inservice Inspection (Subsection IWE); Non-EQ Cables and Connections,

and 10 CFR Appendix J Programs with managing the aging effects and aging effects

mechanisms for the containment penetrations.

In ALRA Section 3.6.2.1.3 the applicant stated that the penetration assembly primary insulation

materials are various organic polymers. During the audit and review it was not clear to the staff

why the metals and inorganic materials (cable fillers, epoxies, potting compounds, connector

pins, plugs, and facial grommets) of non-EQ electrical/l&C penetration assemblies did not

require an AMR.

In its letter dated December 1, 2005, the applicant stated that electrical penetrations at NMP

contain no cable fillers, epoxies, potting compounds, connector pins, plugs, or facial grommets

within the steel sleeve and that the penetration interior is inerted with nitrogen.

The applicant further stated that aging of inaccessible seal material on the ends of the sleeves

is managed by its 10 CFR Appendix J Program. The staff found the applicant's response

acceptable because containment electrical penetrations at NMP contain no organic materials

and the potential aging effects and aging effects mechanisms of penetration wiring insulation

will be addressed by the Non-EQ Cables and Connections Program. In addition the leak test

performed as required by the applicant's Appendix J Program will test the boundary function of

the non-EQ electrical and I&C penetrations. The applicant's Non-EQ Electrical Cables and

Connections and 10 CFR Appendix J Programs are evaluated in SER Sections 3.0.3.1.8 and

3.0.3.1.7, respectively.

On the basis of its review, as discussed above, the staff concludes that there is reasonable

assurance that the applicant has demonstrated that the aging effects of the containment

electrical penetrations components will be adequately managed so that the intended functions

will be maintained consistent with the CLB for the period of extended operation, as required by

10 CFR 54.2 1(a)(3).

3.6.3 Conclusion

The staff concludes that the applicant provided sufficient information to determine that the

effects of aging for the electrical and instrumentation and controls components, that are within

the scope of license renewal and subject to an AMR, will be adequately managed so that the

intended functions will be maintained consistent with the CLB for the period of extended

operation required by 10 CFR 54.21(a)(3).

The staff also reviewed the applicable UFSAR and USAR supplemental program summaries

and concludes that they adequately describe the AMPs credited for managing of the electrical

and instrumentation and controls required by 10 CFR 54.21(d).

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3.7 Conclusion for.Aqing Mana-qement Review Results

The staff reviewed the information in ALRA Section 3, "Aging Management Review Results,"

and Appendix B, "Aging Management Programs and Activities." On the basis of its review, the

staff concludes that the applicant had demonstrated that the aging effects will be adequately

managed so that intended functions will be maintained consistent with the CLB for the period of

extended operation, as required by 10 CFR 54.21 (a)(3). The staff also reviewed the applicable

NMP1 UFSAR and NMP2 USAR supplements program summaries and concludes that the

supplements adequately describe the AMPs credited with managing aging, as required by

10 CFR 54.21(d).

The staff concludes that there is reasonable assurance that the activities authorized by the

renewed licenses will continue to be conducted in accordance with the CLB, and any changes

made to the CLB, for compliance with 10 CFR 54.21(a)(3) are in accordance with the Atomic

Energy Act of 1954, as amended, and NRC regulations.

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SECTION 4

TIME-LIMITED AGING ANALYSES

4.1 Identification of Time-Limited Aging Analyses

This section discusses the identification of time-limited aging analyses (TLAAs). Constellation

Energy Group, LLC (CEG or the applicant) discusses the TLAAs in Sections 4.2 through 4.7 of

its amended license renewal application (ALRA). Safety evaluation report (SER) Sections 4.2

through 4.8 document the review of the TLAAs conducted by the staff of the U.S. Nuclear

Regulatory Commission (NRC or the staff).

TLAAs are certain plant-specific safety analyses that involve time-limited assumptions defined

by the current operating term. Pursuant to Title 10, Section 54.21 (c)(1), of the Code of Federal

Regulations [10 CFR 54.21(c)(1)], the applicant for license renewal must provide a list of

TLAAs, as defined in 10 CFR 54.3.

In addition, pursuant to 10 CFR 54.21(c)(2), an applicant must provide a list of plant-specific

exemptions granted under 10 CFR 50.12 that are based on TLAAs. For any such exemptions,

the applicant must provide an evaluation that justifies the continuation of the exemptions for the

period of extended operation.

4.1.1 Summary of Technical Information in the Amended Application

To identify the TLAAs, the applicant evaluated calculations for the Nine Mile Point Nuclear

Station (NMPNS) against the six criteria specified in 10 CFR 54.3. The applicant indicated that

it had identified the calculations that met the six criteria by searching the current licensing basis

(CLB). The CLB includes the Nine Mile Point Unit 1 (NMP1) updated safety analysis report

(UFSAR), Nine Mile Nuclear Point Unit 2 (NMP2) updated safety analysis report (USAR),

engineering calculations, technical reports, engineering work requests, licensing

correspondence, and applicable vendor reports. In ALRA Table 4.1-1, "Time-Limited Aging

Analyses Applicable to NMPNS," the applicant listed the applicable TLAAs in the following

categories:

* reactor vessel neutron embrittlement analysis

* metal fatigue analysis

* environmental qualification (EQ)

* containment liner plate, metal containments, and penetrations fatigue analysis

* other plant-specific TLAAs

Pursuant to 10 CFR 54.21(c)(2), the applicant stated that it did not identify any exemptions

granted under 10 CFR 50.12 that were based on a TLAA, as defined in 10 CFR 54.3.

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4.1.2 Staff Evaluation

In ALRA Section 4.1, the applicant identified the TLAAs applicable to NMP1 and NMP2. The

staff reviewed the information to determine if the applicant had provided adequate information

to meet the requirements of 10 CFR 54.21(c)(1) and 10 CFR 54.21(c)(2).

As defined in 10 CFR 54.3, TLAAs are analyses that meet the following six criteria:

(1) involve systems, structures, and components that are within the scope of license

renewal, as delineated in 10 CFR 54.4(a),

(2) consider the effects of aging,

(3) involve time-limited assumptions defined by the current operating term (40 years),

(4) are determined to be relevant by the applicant in making a safety determination,

(5) involve conclusions, or provide the basis for conclusions, related to the capability of

the system, structure, and component to perform its intended functions, as delineated

in 10 CFR 54.4(b),

(6) are contained or incorporated by reference in the current licensing basis (CLB).

The applicant provided a list of common TLAAs from NUREG-1800, "Standard Review Plan for

Review of License Renewal Applications for Nuclear Power Plants" (SRP-LR), dated July 2001.

The applicant listed those TLAAs applicable to NMP1 and NMP2 in ALRA Table 4.1-1,

"Time-Limited Aging Analyses Applicable to NMPNS."

As required by 10 CFR 54.21(c)(2), an applicant must provide a list of all the exemptions

granted under 10 CFR 50.12 that are based on a TLAA and evaluated and justified for

continuation through the period of extended operation. In its ALRA, the applicant stated that

each active exemption was reviewed to determine whether the exemption was based on a

TLAA. The applicant did not identify any TLAA-based exemptions. On the basis of the

information provided by the applicant with regard to the process used to identify TLAA-based

exemptions, as well as the results of the applicant's search, the staff concludes that there is

reasonable assurance that the applicant identified no TLAA-based exemptions that are justified

for continuation through the period of extended operation, in accordance with

10 CFR 54.21(c)(2).

4.1.3 Conclusion

On the basis of its review, the staff concludes that there is reasonable assurance that the

applicant has provided an acceptable list of TLAAs, as required by 10 CFR 54.21 (c)(1). The

staff has also confirmed that no exemptions to 10 CFR 50.12 have been granted on the basis of

a TLAA, as required by 10 CFR 54.21 (c)(2).

4.2 Reactor Vessel Neutron Embrittlement Analysis

During plant service, neutron irradiation reduces the fracture toughness of ferritic steel in the

reactor pressure vessel (RPV) beltline region of light-water nuclear power reactors. Areas of

review to ensure that the RPV has adequate fracture toughness to prevent ductile or brittle

failure during normal and off-normal operating conditions for NMP1 and NMP2 are

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(1) upper-shelf energy (USE), (2) pressure-temperature (P-T) limits/adjusted reference

temperature (ART), (3) Boiling Water Reactor Vessel and Internals Project (BWRVIP)-05

analysis for elimination of circumferential weld inspection, and (4) analysis of the axial weld

failure probability. The adequacy of the analyses for these four areas is reviewed for the period

of extended operation.

The ART is defined as the sum of the initial (unirradiated) reference temperature (initial RTNDT),

the mean value of the adjustment in reference temperature caused by irradiation (delta RTNDT),

and a margin term. The delta RTNDT is the product of a chemistry factor (CF) and a fluence

factor. The CF is dependent upon the amount of copper and nickel in the material and may be

determined from the tables in Regulatory Guide (RG) 1.99, Revision 2, "Radiation

Embrittlement of Reactor Vessel Materials," or from surveillance data. The fluence factor is

dependent upon the neutron fluence. The margin term is dependent upon whether the initial

RTNDT is a plant-specific or a generic value and whether the CF was determined using the

tables in RG 1.99, Revision 2, or surveillance data. The margin term is used to account for

uncertainties in the values of the initial RTNDT, the copper and nickel contents, the fluence, and

the calculation methods. Revision 2 of RG 1.99 describes the methodology to be used in

calculating the margin term. The mean RTNoT is the sum of the initial RTNDT and the delta RTNDT

without the margin term. The delta RTNDT and ART calculations meet the criteria of

10 CFR 54.3(a); therefore, they are considered as TLAAs.

The ART values are used in the analysis for the ART for the RPV material due to neutron

embrittlement .and the P-T limits analysis. The mean RTNDT values are used in the analysis of

the circumferential weld examination relief and the axial weld failure probability.

Appendix G of 10 CFR Part 50 provides the staff's criteria for maintaining acceptable levels of

USE for the RPV beltline materials of operating reactors throughout the licensed lives of the

facilities. The rule requires RPV beltline materials to have a minimum USE value of 75 ft-lbs in

the unirradiated condition and to maintain a minimum USE value above 50 ft-lbs throughout the

life of the facility, unless it can be demonstrated through analysis that lower values of USE

would provide an acceptable margin of safety against fracture equivalent to those required by

the American Society of Mechanical Engineers (ASME) Code Section XI, Appendix G. The rule

also mandates that the methods used to calculate USE values must account for the effects of

neutron irradiation on the material's USE values and must incorporate any relevant RPV

surveillance capsule data that are reported through implementation of a plant's

10 CFR Part 50, Appendix H, RPV material surveillance program.

RG 1.99, Revision 2, provides an expanded discussion regarding the calculation of Charpy USE

values and describes two methods for determining Charpy USE values for RPV beltline

materials, depending on whether or not a given RPV beltline material is represented in the

plant's RPV material surveillance program. If surveillance data are not available, the Charpy

USE is determined in accordance with Position 1.2 in RG 1.99, Revision 2. If surveillance data

are available, the Charpy USE should be determined in accordance with Position 2.2 in

RG 1.99, Revision 2. These methods refer to RG 1.99, Revision 2, Figure 2, which indicates

that the percentage drop in Charpy USE is dependent on the amount of copper in the material

and the neutron fluence. Since the analyses performed in accordance with

10 CFR Part 50 Appendix G are based on a flaw with a depth equal to one-quarter of the vessel

wall thickness (1/4t), the neutron fluence used in the Charpy USE analysis is the neutron

fluence at the 1/4t depth location.

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The applicant described its evaluation of this TLAA in ALRA Section 4.2, "Neutron

Embrittlement of the Reactor Vessel and Internals." In order to demonstrate that neutron

embrittlement does not significantly impact RPV and vessel internals integrity during the license

renewal term, the applicant included discussion of the following topics related to neutron

embrittlement in the ALRA:

* Upper-Shelf Energy (Section 4.2.1),

* Pressure-Temperature Limits/Adjusted Reference Temperatures (Section 4.2.2),

• Elimination of Circumferential Weld Inspection (NMP1 only) (Section 4.2.3),

• Axial Weld Failure Probability (Section 4.2.4).

4.2.1 Upper-Shelf Energy

4.2.1.1 Summary of Technical Information in the Amended Application

In ALRA Section 4.2.1, the applicant summarized the evaluation of the USE calculations for the

period of extended operation. RPV materials undergo a transition in fracture behavior from

brittle to ductile as the temperature of the material increases. Charpy V-notch tests are

conducted in the nuclear industry to monitor changes in the fracture behavior during irradiation.

Neutron irradiation to fluences above approximately 1 x 1017 n/cm2 causes an upward shift in

the ductile-to-brittle transition temperature and a drop in USE. To satisfy the acceptance criteria

for USE contained in 10 CFR 50, Appendix G, the RPV beltline materials must have a Charpy

USE of no less than 50 ft-lbs throughout the life of the RPV unless it can be demonstrated that

lower values of Charpy USE will provide margins of safety against fracture equivalent to those

required by the ASME Code Section Xl, Appendix G. Appendix B of BWRVIP-74-A, "BWR

Vessel and Internals Project, BWR Reactor Pressure Vessel Inspection and Flaw Evaluation

Guidelines," presents an equivalent margin analysis establishing the minimum USE limits for

beltline materials used in boiling water reactor (BWR)/2 through BWRP6 RPV designs, as well

as the plant applicability verification form for equivalent margin analysis corresponding to

irradiation for 54 effective full power years (EFPY). The minimum USE values, equivalent

margin analysis USE limit criteria, and bounding criteria for decrease in Charpy USE were

accepted by the NRC in the safety evaluation (SE) for BWRVIP-74-A.

4.2.1.2 Staff Evaluation

Section IV.A.1.a, Appendix G of 10 CFR Part 50 requires, in part, that the RPV beltline

materials have Charpy USE values in the transverse direction for base metal and along the

weld for weld material of no less than 50-ft-lbs, unless it is demonstrated in a manner approved

by the Director, Office of Nuclear Reactor Regulation, that lower values of Charpy USE will

ensure margins of safety against fracture equivalent to those required by ASME Code

Section XI, Appendix G.

By letter dated April 30, 1993, the Boiling Water Reactor Owners Group (BWROG) submitted

NEDO-32205-A, "Equivalent Margin Analysis for Low Upper Shelf Energy in BWR/2 Through

BWR/6 Vessels," to demonstrate that BWR RPVs could meet margins of safety against fracture

equivalent to those required by ASME Code Section XI, Appendix G for Charpy USE values

less than 50 ft-lbs. In a letter dated December 8, 1993, the staff concludes that there is

reasonable assurance that the topical report demonstrated that the evaluated materials have

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margins of safety against fracture equivalent to ASME Code Section Xl, Appendix G, in

accordance with 10 CFR Part 50, Appendix G. In that report, the BWROG derived through

statistical analysis the unirradiated USE values for materials that originally did not have

documented unirradiated Charpy USE values. Using these statistically-derived Charpy USE

values, the BWROG predicted the USE values through 40 years of operation in accordance

with RG 1.99, Revision 2. According to this

RG, the decrease in USE is dependent upon the amount of copper in the material and the

neutron fluence predicted for the material. The BWROG analysis determined that the minimum

allowable Charpy USE value in the transverse direction for base metal and along the weld for

weld material was 35 ft-lbs.

General Electric (GE) performed an update to the USE equipment margin analysis (EMA),

which is documented in Electric Power Research Institute (EPRI) TR-1008872, "BWR Vessel

and Internals Project, BWR Reactor Pressure Vessel Inspection and Flaw Evaluation

Guidelines," BWRVIP-74-A, June 2003. The staffs approval of EPRI TR-1008872 was

documented in a letter from Mr. W. H. Bateman to Mr. C. Terry, dated September 16, 2003.

The analysis in EPRI TR-1008872 determined the reduction in the unirradiated Charpy USE

resulting from neutron irradiation using the methodology in RG 1.99, Revision 2. Using this

methodology and a correction factor of 65 percent for conversion of the longitudinal properties

to transverse properties, the lowest Charpy USE at 54 EFPY for all BWR/3-6 plates was

projected to be 45 ft-lbs. The correction factor for specimen orientation in plates is based on

NRC Branch Technical Position MTEB 5-2. The EMA acceptance criteria specified in the

staff-approved report for BWRVIP-74-A, are based on the percent reduction in the unirradiated

Charpy USE values resulting from neutron radiation using the methodology in RG 1.99,

Revision 2. The acceptance criteria that are specified in the BWRVIP-74-A report indicate that

the maximum allowable reduction in USE value is 29.5 percent for the BWR/2 plates,

23.5 percent for the BWRJ3-6 plates, and 39 percent for the BWR/2-6 welds.

Staffs Assessment of the NMP1 USE Evaluation. Since the analysis in the BWRVIP-74-A

report is a generic analysis, the applicant submitted plant-specific information in ALRA

Table 4.2-1a for NMP1. In addition, its letter dated March 22, 2004, demonstrates in greater

detail that the limiting beltline materials of the NMP1 RPV will meet the criteria in the

BWRVIP-74-A report at the end of the license renewal period.

The applicant, in ALRA Section 4.2 and in the March 22, 2004, letter (as referenced in the

ALRA), demonstrated compliance with all the requirements of 10 CFR Part 50, Appendix G,

related to the USE (determined by Charpy impact tests) for all RPV beltline materials. The

staffs safety evaluation (SE) dated April 26, 1994, concluded that the NMP1 RPV plates have

an adequate margin of safety against fracture until a projected end of license of 25 EFPY for all

levels of conditions (A, B, C, and D) and meet the criteria in ASME Section Xl, Code

Case N-512. Since the predicted USE for the limiting plate will fall below 50 ft-lbs before the

end of the current license, and during the period of extended operation, the applicant used an

EMA in accordance with the requirements of ASME Section X1 Code Case N-512 to

demonstrate that the RPV has margins of safety against fracture equivalent to those required

by ASME Section XI, Appendix G, to support operation beyond 25 EFPYs and operation during

the period of extended operation. The applicant proposed to use the staff-approved generic

EMA analysis (BWRVIP-74-A) for the evaluation of the USE values of the beltline plate and

weld materials of the NMP1 RPV.

4-5
In order to demonstrate that the BWRVIP-74-A methodology is applicable to the NMP1 RPV,

the applicant, by letter dated March 22, 2004, provided a comparison of the results of the

BWRVIP-74-A and the MPM Technology Inc. EMA analyses in relation to the initial USE values,

the material joule-resistance (J-R) curves, the stresses, and the Jappliedvalues, and it identified

the difference in the results of the two analyses. These attributes are discussed below.

(1) The initial USE values, as discussed above, will affect the projected USE values of the

irradiated beltline materials. The initial USE values that were used in the

BWRVIP-74-A report and in the MPM analyses are 49 ft-lbs and 52 ft-lbs, respectively.

Based on these values, the staff concludes that the initial USE value that was used in

the BWRVIP-74-A EMA analysis would provide more conservative results than the

MPM EMA analysis.

(2) The applicant compared the USE-J,c correlations shown in the two analyses. The staff

previously determined in its SE dated April, 26, 1994, that a USE value of 40 ft-lbs,

would provide an acceptable J0.1 (the J value at 0.1 inch of crack extension) value for

the RPV material, whereby the material would have an adequate margin of safety

against fracture. The J01 values for the BWRVIP-74-A and MPM analyses that

correspond to 40 ft-lbs are 222 in-lb/in 2 and 298 in-lb/in 2, respectively. Based on these

values, the staff concludes that the J 01 values from the BWRVIP-74-A analysis are

more conservative than the J,1 values from the MPM analysis. Therefore, the staff

agreed with the applicant that the BWRVIP-74-A J-R curves bound the MPM J-R

curves. This conclusion justifies the use of the BWRVIP-74-A EMA analysis for the

evaluation of the USE of the NMP1 RPV beltline materials.

(3) Since both the analyses used the same transient (100 °F/hr cooling rate) in calculating

the stresses under service loadings A and B, the staff agreed with the applicant's

conclusion that the stress calculations did not affect the difference in the EMA values

of the BWRVIP-74-A and MPM analyses for service loadings A and B. In the SE,

dated April 26, 1994, the staff established that the calculated stresses under service

loadings C and D were not limiting. Therefore, the applicant did not perform stress

calculations for service loadings C and D.

(4) The staff reviewed the Japp,.,values of the limiting beltline materials of NMP1 and

determined that the minor difference (4.2 percent) between the results from the

BWRVIP-74-A and MPM analyses is acceptable.

The staff reviewed the submitted calculations related to the aforementioned attributes and

found that the application of the BWRVIP-74-A methodology in the assessment of USE for

NMP1 RPV beltline materials is comparable MPM's methodology. Therefore, the staff

concludes that the evaluation, described below, of USE for the RPV beltline materials at NMP1

using the BWRVIP-74-A EMA is acceptable.

The staff reviewed the applicant's projections of the NMP1 USE values for the RPV beltline

materials that are provided in ALRA Table 4.2-1a. The staff noted that the USE values are

based on irradiation for 54 EFPY, which corresponds to an average capacity factor of 90

percent over 60 years. This is consistent with the bounding analyses in the BWRVIP-74-A

report and is conservative with respect to the NMP1 operating history to date. The applicant

projected that the peak vessel fluence at the inside surface for NMP1 at the end of 54 EFPY

would be 5.21 x 10" n/cm 2 (E > 1.0 MeV) and the vessel fluence at the 1/4t location (i.e., at a

location 1/4 of the way through the RPV wall from the clad-to-base metal boundary) would be

4-6
3.39 x 1016 n/cm2 (E > 1.0 MeV). The staff also noted that neutron transport modeling was

carried out in (r-0) and (r-z) geometry using the DORT two-dimensional discrete ordinates code

and the BUGLE-96 cross section library. In addition, the staff noted that NMP1 uses an NRC

staff-approved fluence methodology. In its SE dated October 27, 2003, the staff concludes that

the applicant used a staff-approved method that includes the attributes described in

RG 1.190. Therefore, the staff found the proposed vessel fluence at the inside surface as well

as at the 1/4t location to be acceptable for the calculation of the USE at 54 EFPY.

The projections of USE for the NMP1 RPV's limiting beltline plates and weld materials were

made based on percentage decrease in USE as determined by RG 1.99, Revision 2, at 114t of

the vessel wall. The acceptable USE (measured in transverse orientation) value for BWRJ2

plates and weld materials based on the BWRVIP-74-A analysis is 35 ft-lbs. The application of

the staff-approved BWRVIP-74-A methodology for projecting the USE values entails the use of

the following variables:

* copper content of the beltline plate and weld materials

* neutron fluence at 1/4t of the vessel at the beltline region

* initial USE values of the beltline materials

* percent of decrease from initial USE value for the extended period of operation

(54 EFPY)

* projected USE value at 54 EFPY

* acceptable USE values at 54 EFPY, in accordance with the BWRVIP-74-A criteria

These values are listed in Tables 4.2 and 4.3 of the March 22, 2004, letter, as referenced in the

ALRA, and in ALRA Table 4.2-1a. The staff has confirmed the validity of these values and

concludes that the NMP1 limiting beltline weld will remain above 50 ft-lbs through 54 EFPY.

Therefore, the staff determined that the NMP1 limiting beltline weld USE value will meet the

requirements of 10 CFR Part 50, Appendix G, through the period of extended operation.

However, the USE values for both of the NMP1 limiting RPV beltline plates are projected to fall

below 50 ft-lbs before the end of the period of extended operation. Table 4.3 of the

March 22, 2004, letter indicates that the projected values for both of the NMP1 limiting beltline

plates (G-8-1 and G-307-4) will remain above the BWRVIP-74-A minimum allowable USE of 35

ft-lbs through the period of extended operation) and, therefore, have margins equivalent to

those of ASME Section Xl, Appendix G. The projected USE value for the NMP1 beltline plate

G-8-1 for 54 EFPY is 40 ft-lbs, which exceeds the minimum value of 35 ft-lbs specified in the

BWRVIP-74-A EMA analysis. The projected USE value for the NMP1 beltline plate G-307-4 is

37.2, which exceeds the minimum required value of 35 ft-lbs by 5.9 percent. SER Table 4.2-1

provides the staff's summary of the RV USE analysis for NMP1 and NMP2.

The applicant stated that there is a difference of 4.2 percent in predicting the USE values

between the EMA analyses using BWRVIP-74-A and those using the MPM Technology

methodologies. This difference in value falls within the margin of 5.9 percent for the predicted

USE value of the most limiting beltline plate material. Therefore, the staff concludes that there

is reasonable assurance that applicability of the BWRVIP-74-A EMA analysis to the NMP1

beltline materials is acceptable. In addition, the staff found that this analysis provides

4-7
reasonable assurance that these materials have margins of safety against fracture equivalent to

those required by 10 CFR Part 50, Appendix G.

Staff's Assessment of the NMP2 USE Evaluation. ALRA Table 4.2-2a includes the projected

USE values for the RPV beltline materials for NMP2. The applicant based these values on

irradiation for 54 EFPY, which corresponds to an average capacity factor of 90 percent over 60

years and is consistent with the bounding analyses in BWRVIP-74-A. The applicant indicated

that the projected USE values for the limiting beltline weld materials and the limiting beltline

plate materials for NMP2 will remain above 50 ft-lbs throughout the period of extended

operation, based on a projected fluence value of 9.70 x 10"' n/cm2 (E > 1.0 MeV) at the 1/4t

location. The staff compared the initial USE values and the percentage of copper for all the

plates and weld metals in the beltline region of NMP2 to those values in the reactor vessel

integrity database (RVID) and confirmed that the values were conservative or consistent with

the values in the RVID.

The staff noted that in NMP2 the most limiting beltline material, Plate C-3147-1, has a projected

USE value of 62.3 ft-lbs, which is above the 50 ft-lb criterion. SER Table 4.2-1 provides the

staff's summary of the RV USE analysis for NMP1 and NMP2. Since the USE value for the

limiting beitline material at the expiration of the extended license is projected to be above

50 ft-lbs, the USE values for the NMP2 limiting beltline materials comply with the criteria of

10 CFR Part 50, Appendix G. Therefore, the staff found that the USE values for NMP2 are

acceptable.

Table 4.2-1 Reactor Vessel USE Analysis Summary for NMPI and NMP2

RV.Beltline - Accepnce, Component Acceptable (YiN)

Component, Criterion for'USE Value for 54 EFPY.

NMPI Percent Drop 19.2 Percent Drop Yes

Lower Shell Plate < 29.5 percent drop in USE ft-lb [TLAA satisfies

(Heat No. G-8-1) in the USE ft-lb 10 CFR 54.21(c)(1)(ii)]

value (1)

NMP1 Percent Drop 24.9 Percent Drop Yes

Upper Shell Plate < 29.5 percent drop in USE ft-lb [TLAA satisfies

(Heat No. G-307-4) in the USE ft-lb 10 CFR54.21(c)(1)(fi)]

value (1)

NMP1 Projected USE 64 ft-lbs Yes

Circumferential > 50 ft-lbs [TLAA satisfies

Weld (SAW) 10 CFR 54.21(c)(1)(ii)]

(Heat No.1248)

NMP2 Projected USE 62.3 ft-lbs Yes

Number 2 > 50 ft-lbs [TLAA satisfies

Shell Plate 10 CFR 54.21(c)(1)(5)]

(Heat No. C3147-1)

4-8
RV Beitline Acceptance Componenti Acceptable " /

-Component Criterion for USE Value for 54 EFPY

NMP2 Projected USE 76.5 ft-lbs Yes

Number I > 50 ft-lbs [TLAA satisfies

Shell Plate 10 CFR 54.21(c)(1)(ii)]

(Heat No. C3147-2)

NMP2 Projected USE 74 ft-lbs Yes

Axial Weld (SAW) > 50 ft-lbs [TLAA satisfies

(Heat No. 10 CFR 54.21(c)(1)(ii)]

5P5657/0931)

NOTE:

(1) Acceptance criteria for beltline plates and welds established by elastic-plastic fracture

mechanics analysis in BWRVIP-74-A (as discussed in BWRVIP-74 SE pages 4-10, 4-11 and

4-15).

4.2.1.3 UFSAR and LUSAR Supplements

The applicant provided UFSAR and USAR supplement summary descriptions of its TLAA

evaluation of USE calculations in ALRA Sections A1.2.1.1 and A2.2.1.1, respectively. On the

basis of its review of the UFSAR and USAR supplements, the staff concludes that there is

reasonable assurance that the summary descriptions of the applicant's actions to address the

USE calculations are adequate.

4.2.1.4 Conclusion

On the basis of its review, as discussed above, the staff concludes that there is reasonable

assurance that the applicant had demonstrated, pursuant to 10 CFR 54.21(c)(1)(ii), that for the

USE TLAA, the analyses have been projected to the end of the period of extended operation.

The staff also concludes that the UFSAR supplement contains an appropriate summary

description of the USE TLAA evaluation, as required by 10 CFR 54.21(d).

4.2.2 Pressure-Temperature (P-T) Umits

4.2.2.1 Summary of Technical Information in the Amended Application

In ALRA Section 4.2.2, the applicant summarized the evaluation of the P-T limits for the period

of extended operation. Appendix G of 10 CFR 50 requires that the RPV be operated within

established P-T limits during heatup and cooldown. These limits specify the maximum allowable

pressure as a function of reactor coolant temperature. NMP1 and NMP2 technical specifications

(TSs) contain P-T limit curves for heatup, cooldown, inservice leakage testing, and hydrostatic

testing, and they limit the maximum rate of change of reactor coolant temperature. The P-T limit

curves are periodically revised to account for changes in fracture toughness of the RPV

components due to anticipated neutron embrittlement effects for higher accumulated fluences.

Calculation of P-T limit curves using the projected fluence at the end of the period of extended

operation would result in unnecessarily restrictive operating curves; however, projection of the

ART, which is used in development of the curves, to the end of the period of extended

operation provides assurance that development of P-T limit curves will be feasible up to the

4-9
maximum predicted EFPY. There are no regulatory requirements for the maximum ART for

BWRs. The need to minimize the ART is driven by operational considerations.

Calculations that project ART values at NMP satisfy the criteria of 10 CFR 54.3(a). As such, any

related analysis is a TLAA. Projections of ART values for beltline materials, based on

extrapolation using the most recent fluence results and fracture toughness data from

surveillance capsule and P-T operating curve reporting, are found in ALRA Tables 4.2-3 and

4.2-4 for NMP1 and NMP2, respectively. The NMPI values were computed for 46 EFPY, based

on adding irradiation corresponding to an average capacity factor of 90 percent during the

20-year period of extended operation to the 28 EFPY exposure currently projected for the end

of the original license term. The NMP2 values are based on irradiation for 54 EFPY, which

corresponds to an average capacity of 90 percent over 60 years.

By letter dated October 27, 2003, the staff concludes that the supporting fluence calculations

were performed using methods consistent with RG 1.190. For NMP1 and NMP2, projections of

the ART values for the beltline materials have been made for the period of extended operation,

providing reasonable assurance that it will be possible to prepare P-T curves that will permit

continued plant operation. The P-T curves (and the related technical specifications) will

continue to be updated either as required by 10 CFR Part 50, Appendix G to assure that the

operational limits will remain valid at the current cumulative neutron fluence levels, or on an

as-needed basis to provide appropriate operational flexibility. Therefore, re-evaluation of the

P-T limits to consider the period of extended operation by using 10 CFR Part 50, Appendix G

will be performed by the applicant in accordance with 10 CFR Part 54.21 (c)(1)(iii), as clarified

by the applicant's response dated December 5, 2005.

4.2.2.2 Staff Evaluation

By letters dated November 15, 2002, and August 15, 2003, the applicant submitted its current

P-T limit curves for NMP1 and NMP2, respectively, that were calculated for exposures within

the 32 EFPY operating period anticipated during the original 40-year plant licenses. The staff

approved the P-T limit curves for NMP1 and NMP2 by SEs dated October 27, 2003, and

January 27, 2004, respectively. The applicant plans to update its P-T limit curves, either as

required by 10 CFR Part 50, Appendix G, to assure the operational limits remain valid at the

current cumulative neutron fluence levels, or on an as-needed basis to provide appropriate

operational flexibility. The staff found the applicant's plan to manage the P-T limits acceptable

because the change in P-T curves will be implemented by the license amendment process

(i.e., modifications of technical specifications) and will meet the requirements of 10 CFR 50.60

and 10 CFR Part 50, Appendix G. This is consistent with SRP-LR Section 4.2.2.1.3; therefore,

the staff found this acceptable.

4.2.2.3 UFSAR and USAR Supplements

The applicant provided UFSAR and USAR supplement summary descriptions of its TLAA

evaluation of P-T limits in ALRA Sections A1.2.1.2 and A2.2.1.2, respectively. On the basis of

its review of the UFSAR and USAR supplements, the staff concludes that the summary

descriptions of the applicant's actions to address the P-T limits are adequate.

4-10
4.2.2.4 Conclusion

On the basis of its review, as discussed above, the staff concludes that there is reasonable

assurance that the applicant had demonstrated, pursuant to 10 CFR 54.21(c)(1)(iii), that for the

P-T limits TLAA the effects of aging on the intended function(s) will be adequately managed for

the period of extended operation. The staff also concludes that the UFSAR supplement

contains an appropriate summary description of the P-T limits TLAA evaluation for the period of

extended operation, as required by 10 CFR 54.21(d).

4.2.3 Elimination of Circumferential Weld Inspection (NMP1 Only)

4.2.3.1 Summary of Technical Information in the Amended Application

In ALRA Section 4.2.3, the applicant summarized the evaluation of the elimination of

circumferential weld inspections for the period of extended operation. Relief from RPV

circumferential weld examination requirements under GL 98-05, "Boiling Water Reactor

Licensees Use Of The BWRVIP-05 Report To Request Relief From Augmented Examination

Requirements On Reactor Pressure Vessel Circumferential Shell Welds," is based on

probabilistic assessments that predict an acceptable probability of failure per reactor operating

year. The analysis is based on RPV metallurgical conditions as well as flaw indication sizes and

frequencies of occurrence that are expected at the end of the licensed operating period. By

letter dated April 7, 1999, the NRC granted such relief to NMP1 for the remainder of its current

40-year license term. NMP2 has not submitted a relief request for the remainder of its 40-year

licensed operating period. Therefore, the supporting evaluation applies only to NMP1. The

associated circumferential weld examination relief analysis for NMP1 satisfies the criteria of

10 CFR 54.3(a); as such, this analysis is considered a TLAA.

The applicant provided the following disposition with respect to the conditional probability of

vessel failure:

Appendix E of the Final Safety Evaluation of the BWR Vessel and Internals

Project, BWRVIP-05 Report, documented an evaluation of the impact of

plant life extension from 32 EFPY to 64 EFPY on the conditional probability

of vessel failure, P(FIE). This assessment reported that combining the P(FIE)

due to circumferential weld failure with the frequency of cold

overpressurization events results in a total vessel failure frequency as high

as 5 X 10-7/yr at 64 EFPY. In the SER for BWRVIP-74-A, the NRC staff

determined that the analysis provides a technical basis for relief from the

current inservice inspection requirements of ASME Section Xl for volumetric

examination of circumferential welds as they may apply for the license

renewal period.

Assumptions made in accepting the analysis discussed above are: (1) that

the applicable neutron fluence is the end-of-life mean fluence, and (2) that

the applicable chemistry values are mean values based on vessel types. The

results of a scoping evaluation using comparable plant-specific parameters

(presented in Table 4.2-5) indicate that projected values of mean and upper

bound RTNDT for the limiting circumferential weld at NMP1 is below the

bounding mean RTNDT determined by the NRC staff. Thus, there is

4-11
reasonable assurance the P(FIE) due to NMP1 RPV circumferential weld

failure is bounded by the NRC analysis.

4.2.3.2 Staff Evaluation

The technical basis for relief is discussed in the staffs final SE concerning the BWRVIP-05

report, which is enclosed in a July 28, 1998, letter from Mr. G. C. Lainas, NRC, to Mr. C. Terry,

BWRVIP Chairman. In this letter, the staff concludes that since the failure frequency for

circumferential welds in BWR plants is significantly below the criterion specified in RG 1.154,

"Format and Content of Plant-Specific Pressurized Thermal Shock Safety Analysis Reports for

Pressurized Water Reactors," the continued inspection would result in a negligible decrease in

an already acceptably low value of RPV failure. Therefore, elimination of the inservice

inspection (ISI) for RPV circumferential welds is justified.

The staff's letter indicated that BWR applicants may request relief from ISI requirements of

10 CFR 50.55a(g) for the volumetric examination of circumferential RPV welds by

demonstrating that (1) at the expiration of the license, the circumferential welds satisfy the

limiting conditional failure probability for circumferential welds in the staffs July 28,1998, SE,

and (2) the applicants have implemented operator training and established procedures that limit

the frequency of cold over-pressure events to the frequency specified in the staff's

July 28, 1998, SE. The letter indicated that the requirements for inspection of circumferential

RPV welds during an additional 20-year license renewal period would be re-assessed, on a

plant-specific basis, as part of any BWR LRA. Therefore, the applicant must request relief from

inspection of circumferential welds during the license renewal period per 10 CFR 50.55a.

Section A.4.5 of the BWRVIP-74"-A report indicates that the staffs SE for the BWRVIP-05

report conservatively evaluated the BWR RPVs to 64 EFPY, which is 10 EFPY greater than

what is realistically expected for the end of the license renewal period. The staff used the mean

RTNOT value for materials to evaluate failure probability of BWR circumferential welds at 32 and

64 EFPY in the staffs SE dated July 28, 1998. The neutron fluence used in this evaluation was

the neutron fluence at the weld inside surface.

Since the staffs analysis discussed in the BWRVIP-74-A report is a generic analysis, the

applicant submitted plant-specific information to demonstrate that the NMP1 beltline materials

meet the criteria specified in the report. To demonstrate that the NMP1 vessel has not become

embrittled beyond the basis for the relief, the applicant, in ALRA Table 4.2-5, supplied material

data at 64 EFPY for the limiting NMPI circumferential welds so that the staff could compare it

with the material data of the 64 EFPY reference case. The reference case can be found in

Appendix E of the staffs SE of the BWRVIP-05 report.

The NMP1 material data included amounts of copper and nickel, CF, the neutron fluence, delta

RTNDT, initial RTNDT, and mean RTNDT values of the limiting circumferential weld at 64 EFPY. The

staff has verified the data for the copper and nickel content and the initial RTNDT values for

NMPI beltline materials by comparing them with the corresponding data in the RVID

maintained by the NRC. The 64 EFPY mean RTNDT value for NMP1 is 22.3 *F. The staff has

checked the applicant's calculations for the 64 EFPY mean RTNDT value for the NMP1

circumferential weld using the data presented in ALRA Table 4.2-5 and found them accurate.

The 64 EFPY mean RTNDT value for NMP1 is less than the 64 EFPY mean RTNOT value of

113.2 0F used by the NRC for determining the conditional failure probability of a circumferential

4-12
weld. It should be noted that the 64 EFPY mean RTNDT value from the staffs SE dated July 28,

1998, is for a Combustion Engineering weld, which is applicable to NMP1, since Combustion

Engineering welded the circumferential welds in the NMP1 Vessel. Since the NMP1 64 EFPY

mean RTNDT value is less than the 64 EFPY value from the staff SE dated July 28, 1998, the.

staff concludes that the NMP1 RPV conditional failure probabilities are bounded by the staff

analysis. SER Table 4.2-2 describes the staffs analysis of the NMP1 RV circumferential weld

inspection relief.

The applicant stated that the procedures and training used to limit cold over-pressure events

will be the same as those approved by the NRC when NMP1 requested the relief for the current

license period, by letter dated December 10, 1998, "Proposed Alternatives for Examination of

Reactor Pressure Vessel Shell Welds." The applicant stated that the procedures and training

requirements identified in the NMP1 request to use the BWRVIP-05 report are provided in the

document, "Safety Evaluation by the Office of Nuclear Reactor Regulation Related to

Alternatives for Examination of Reactor Pressure Vessel Shell Welds, Nine Mile Point Nuclear

Station, Unit 1," (attached to NRC letter to Niagra Mohawk Power Corporation dated

April 7, 1999). The applicant further stated that the original LRA Section 4.2.3, and the

associated UFSAR supplement Section A1.2.1.3, reference the SE letters identified above. The

staff found this acceptable because the applicant identified the requested references and will

include them in ALRA Section 4.2.3 and the associated UFSAR supplement Section A1.2.1.3.

The applicant indicated in the ALRA (Commitment Item 3 for NMP1) that it will apply for relief

from circumferential weld inspections for the period of extended operation. In addition, the

applicant indicated that supporting analyses, procedural controls, and operator training will be

completed prior to the period of extended operation to confirm that the RPV circumferential

weld failure probability remains acceptable for the period of extended operation.

The staff found that the applicant's evaluation for this TLAA is acceptable because the NMP1

64 EFPY conditional failure probabilities for the RPV circumferential welds are bounded by the

NRC analysis in the staffs SE dated July 28, 1998, and the applicant will be using procedures

and training to limit cold over-pressure events during the period of extended operation. This

analysis satisfies the evaluation requirements of the staffs SE dated July 28,1998; however,

the applicant is still required to request relief for the circumferential weld examination for the

extended period of operation in accordance with 10 CFR 50.55a.

Table 4.2-2 RV Circumferential Weld Inspection Relief Analysis

RV MaterialL. TLAABasis Acceptance 'NVNMPt Value , NMP2 Value,.

* C.I! riterion (F) .F)(F) 

Limiting BWRVIP-05 22.3 (NMP) N/A

Circumferential Mean RTNDT < 113.2 22.4 (Staff)

Weld Value in °F

NMP2 has not submitted a relief request for the elimination of circumferential weld

inspections for the remainder of its 40-year licensed operating period, therefore, the

TLAA for the circumferential welds does not apply to NMP2.

4-13
TLAAs for the circumferential weld mean RT~OT values were in all cases determined to

be acceptable under 10 CFR 54.21 (c)(1)(i) or (ii).

4.2.3.3 UFSAR Supplement

The applicant provided a UFSAR supplement summary description of its TLAA evaluation of the

elimination of circumferential weld inspections in ALRA Section A1.2.1.3. On the basis of its

review of the UFSAR supplement, the staff concludes that the summary description of the

applicant's actions to address the elimination of circumferential weld inspection is adequate.

4.2.3.4 Conclusion

On the basis of its review, as discussed above, the staff concludes that there is reasonable

assurance that the applicant has demonstrated, pursuant to 10 CFR 54.21(c)(1)(ii), that for the

elimination of circumferential weld inspection TLAA, the analyses have been projected to the

end of the period of extended operation. The staff also concludes that the UFSAR supplement

contains an appropriate summary description of the elimination of circumferential weld

inspection TLAA evaluation for the period of extended operation, as required by

10 CFR 54.21(d).

4.2.4 Axial Weld Failure Probability

4.2.4.1 Summary of Technical Information in the Amended Application

In ALRA Section 4.2.4, the applicant summarized the evaluation of the axial weld failure

probability for the period of extended operation. In the safety evaluation (SE) presented in the

"Supplement to Final Safety Evaluation of the BWR Vessel and Internals Project BWRVIP-05

Report," the staff indicated that the RPV failure frequency due to failure of the limiting axial

welds in the BWR fleet at the end of 40 years of operation is less than 5 x 10e per reactor year,

given the assumptions on flaw density, distribution, and location described in the SE.

4.2.4.2 Staff Evaluation

In its July 28, 1998, letter to Mr. C. Terry, the BWRVIP Chairman, the staff identified a concern

about the failure frequency of axially-oriented welds in BWR RPVs. In response to this concern,

the BWRVIP supplied evaluations of axial weld failure frequency in letters dated

December 15, 1998, and November 12, 1999. The staffs SE on these analyses is enclosed in a

March 7, 2000, letter from Mr. J. Strosnider, NRC, to Mr. C. Terry, BWRVIP Chairman.

By letter dated October 18, 2001, the staff issued "Acceptance for Referencing of EPRI

Proprietary Report TR-1 13596, 'BWR Vessel and Internals Project, BWR Reactor Pressure

Vessel Inspection and Flaw Evaluation Guidelines (BWRVIP-74-A)' and Appendix A,

'Demonstration of Compliance with the Technical Information Requirements of the License

Renewal Rule (10 CFR 54.21),'" which endorsed the axial weld failure probability analysis for

the period of extended operation.

The staff noted that the NMP1 and NMP2 RPVs are fabricated by Combustion Engineering.

The staff performed a generic analysis for Combustion Engineering-fabricated RPVs using the

Pilgrim Nuclear Power Plant as a model. The Pilgrim Nuclear Power Plant model demonstrated

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that a mean RTNOT of 114 OF resulted in a failure frequency of 5 x 10.6 per reactor-year of

operation. The applicant calculated, and the staff confirmed, that the limiting axial weld mean

RTNDT value for NMP1 and NMP2 at 64 EFPY is less than 114 OF. SER Table 4.2-3 describes

the staffs analysis of the NMP1 and NMP2 RV axial weld failure probability. The results of

these calculations support the conclusion that the failure frequencies for NMP1 and NMP2 will

be less than 5 x 10' per reactor-year of operation at the end of their period of extended

operation. Therefore, this analysis is acceptable.

Table 4.2-3 RV Axial Weld Probability of Failure Analysis

IRV Material TLAA Basis AccePtance NMPI Value' NMP2 Vaue

Criterion (OF) I('0F) (OF)

Limiting Axial BWRVIP-05 31.3 (NMP) -5.0 (NMP)

Weld Mean RTNDT < 114.0 31.0 (Staff) -5.0 (Staff)

Value in _F

4.2.4.3 UFSAR and USAR Supplements

The applicant provided UFSAR and USAR supplement summary descriptions of its TLAA

evaluation of axial weld failure probability in ALRA Sections A1.2.1.4 and A2.2.1.3, respectively.

On the basis of its review of the UFSAR and USAR supplements, the staff concludes that the

summary descriptions of the applicant's actions to address the axial weld failure probability are

adequate.

4.2.4.4 Conclusion

On the basis of its review, as discussed above, the staff concludes that there is reasonable

assurance that the applicant had demonstrated, pursuant to 10 CFR 54.21(c)(1)(ii), that for the

axial weld failure probability TLAA, the analyses have been projected to the end of the period of

extended operation. The staff also concludes that the UFSAR supplement contains an

appropriate summary description of the axial weld failure probability TLAA evaluation for the

period of extended operation, as required by 10 CFR 54.21(d).

4.3 Metal Fatigue Analysis

A metal component subjected to cyclic loading at loads less than the static design load may fail

due to fatigue. Metal fatigue of components is evaluated based on an assumed number of

transients or cycles for the current operating term. The validity of such metal fatigue analysis is

reviewed for the period of extended operation.

The applicant discussed the fatigue design of NMPNS components in ALRA Section 4.3. The

applicant indicated that designated plant events used for the fatigue design of components

were counted and categorized. ALRA Table 4.3-1 lists NMP1 design transients and Table 4.3-2

lists NMP2 design transients. A linear projection of transient cycles indicated that the number of

some events, such as heatup and cooldowns, may exceed the number used for the design of

the components during the period of extended operation. The applicant indicated that locations

with a design baseline fatigue usage greater than 0.4 would require additional evaluation. The

applicant committed to implement FatiguePro fatigue monitoring software for locations that

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require additional evaluation to demonstrate acceptable fatigue usage prior to the period of

extended operation.

4.3.1 Reactor Vessel Fatigue Analysis

4.3.1.1 Summary of Technical Information in the Amended Application

The applicant discussed the design of the NMP1 and NMP2 reactor vessels in ALRA

Section 4.3.1. The NMP1 reactor vessel was designed to the ASME Boiler and Pressure Vessel

Code, Section 1-1962; and the NMP2 reactor vessel was designed to the ASME Boiler and

Pressure Vessel Code, Section III, 1971 Edition through Winter 1972 Addenda. The applicant

indicated that the fatigue usage of the pressure boundary components of both units was

evaluated using ASME Section III methods. ALRA Table 4.3-3 lists the limiting design

cumulative usage factors (CUFs) for the NMP1 vessel components, and Table 4.3-4 lists the

limiting design CUFs for the NMP2 vessel components. The applicant indicated that transients

contributing to fatigue usage of these vessel components will be monitored by the NMPNS

Fatigue Monitoring Program (FMP). The FMP is described in ALRA Appendix B. The applicant

concluded that the effects of fatigue on the intended function(s) of RPV components will be

adequately managed by the FMP in accordance with the requirements of

10 CFR 54.21(c)(1)(iii).

4.3.1.2 Staff Evaluation

Components of the NMP2 reactor coolant pressure boundary (RCPB), including the RPV, were

designed to the Class I requirements of the ASME Code. The Class 1 requirements contain

explicit criteria for the fatigue analysis of components. In addition, fatigue of the NMP1 reactor

pressure vessel was evaluated using ASME Section III fatigue criteria.

The specific design criterion for fatigue analysis of RCPB components involves calculating the

CUF. The fatigue damage in the component caused by each thermal or pressure transient

depends on the magnitude of the stresses caused by the transient. The CUF sums the fatigue

damage resulting from each transient. The design criterion requires that the CUF not exceed

1.0.

The staffs review of the original LRA Section 4.3.1 identified areas in which additional

information was necessary to complete the review of the reactor vessel fatigue analysis. The

applicant responded to the staff's RAls as discussed below.

In RAI 4.3.1-3, dated November 10, 2004, the staff stated that the original LRA Table 4.3-1 lists

the design transients for NMP1 and confirmed that these design transients are the same as the

design transients listed in NMP UFSAR Table V-5. In the RAI, the staff stated that Note 2 to the

original LRA Table 4.3-1 indicated that a number of the transients were not counted/monitored

prior to 2000. The note contained the statement: "Data listed for allowable design transients are

incremental values for the balance of the original license term." Therefore, the staff requested

that the applicant clarify the intent of that statement. The staff also requested that the applicant

indicate the method used to estimate the number of cycles prior to the year 2000 for those

design transients identified by Note 2.

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The applicant's response, by letter dated December 6, 2004, has been subsequently

incorporated in the ALRA as discussed below.

The applicant modified the footnotes to the original LRA Table 4.3-1 in its ALRA submittal. Note

4 to the revised table indicates that only transients affecting the feedwater nozzle were

originally monitored because the feedwater nozzle was considered the bounding fatigue usage

location for the NMP1 RPV. The applicant's July 14, 2005, revised response to RAI 4.3.1-3

stated that the transients not monitored prior to the year 2000 involve operation of the shutdown

cooling and emergency cooling systems that affect the reactor recirculation nozzles. The

applicant discovered, in the year 2000, that these shutdown cooling and emergency cooling

transients had not been accounted for in the original fatigue calculations. According to the

applicant, only the transients associated with the emergency condenser (EC) initiation on an

isolated loop and EC initiation on an idle loop produced any significant fatigue usage. The

applicant indicated that an evaluation of the nozzles for these EC initiation transients resulted in

CUFs below 0.1. The applicant further indicated that a review of the NMP1 operating history

found that the number of EC initiations listed in ALRA Table 4.3-1, used for the fatigue

evaluation, is conservative for 40 years of plant operation. The applicant concluded that the

fatigue usage of recirculation nozzles will remain well within the allowable limit during the period

of extended operation. On the basis of the information provided by the applicant, the staff

agreed that the fatigue usage of the reactor recirculation nozzles will remain well within the

allowable limit during the period of extended operation. The staff found the applicant had

adequately demonstrated that the analyses of the recirculation nozzles remain valid for the

period of extended operation. Therefore, the staffs concern described in RAI 4.3.1-3 is

resolved.

In RAI 4.3.1-4, dated November 10, 2004, the staff stated that the original LRA Table 4.3-2 lists

the design transients for NMP2. The table does not list the 75 percent power reduction that is

listed in USAR Table 3.9B-1. Therefore, the staff requested that the applicant explain why this

transient was not included in the original LRA Table 4.3-2 of the application.

In its response, by letter dated December 6, 2004, the applicant indicated that the daily

reduction to 75 percent power was combined with weekly reduction to 50 percent power for

counting purposes. The combined transients are listed as power changes greater than or equal

to 25 percent in the original LRA Table 4.3-2. The applicant listed the smallest number of cycles

for either transient (2000 cycles for the reduction to 50 percent power) as the allowable number

for the combined transients. Therefore, the staff concludes that the applicant used a

conservative value for the number of allowable cycles for the combined transients. The staff

found that the applicant's FMP adequately addresses the NMP2 design transients listed in

USAR Table 3.98-1. Therefore, the staff's concern described in RAI 4.3.1-4 is resolved.

In RAI 4.3.1-1, dated November 10, 2004, the staff stated that in the original LRA Section 4.3.1,

the applicant indicated that the fatigue usage of RPV components will be monitored at critical

locations for NMP1 and NMP2. The applicant stated that the transients contributing to the

fatigue usage will be monitored by the FMP. The applicant further indicated that these locations

would include the components identified in NUREG/CR-6260. Original LRA Tables 4.3-3 and

4.3-4 list the RPV locations that will be monitored by the FMP. These tables do not list all of the

locations identified in NUREG/CR-6260. Therefore, the staff requested that the applicant clarify

that all locations identified in NUREG/CR-6260 will be monitored by the FMP. The staff also

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requested that the applicant provide a complete list of all locations that will be monitored by the

FMP for NMP1 and NMP2.

In its response, by letter dated December 6, 2004, the applicant stated that Tables 1 and 2

contain a comparison of the NMP1 and NMP2 locations monitored by the FMP with those listed

in NUREG/CR-6260. The applicant indicated that some of the monitored locations for NMP1

are described in the original LRA Section 4.3.4. The applicant stated that NMP1 does not have

a residual heat removal (RHR) system; therefore, the NMP1 shutdown cooling return line was

selected as an alternative line for the environmental fatigue assessment. The staff found the

shutdown cooling return line an acceptable alternative to the RHR line listed in

NUREG/CR-6260. The staff concludes that the applicant's FMP monitors the NUREG/CR-6260

locations or acceptable alternatives at NMPI.

Table 2 of the applicant's response lists the NUREG/CR-6260 locations for a newer vintage

BWR. The applicant indicated that most of the NUREG/CR-6260 locations that will be

monitored for NMP2 are listed in the original LRA Table 4.3-4 or discussed in Section 4.3.4.

The applicant also indicated that the NMP2 feedwater line Class 1 piping is listed in the original

LRA Table 4.3-5. The staff noted that the NMP2 RHR locations are actually discussed in the

original LRA Section 4.3.2 and not Section 4.3.4. The staff review of the original LRA

Section 4.3.2 and Tables 4.3-4 and 4.3-5 confirmed that all of the NUREG/CR-6260 locations

have been addressed by the applicant. The staff found that the applicant's FMP monitors the

locations listed in NUREG/CR-6260 at NMP2. Therefore, the staff's concern described in

RAI 4.3.1-1 is resolved.

In RAI 4.3.1-2, dated November 10, 2004, the applicant stated that the original LRA

Tables 4.3-3 and 4.3-4 indicate that stress-based fatigue monitoring will be used to track the

fatigue usage for the NMP1 and NMP2 feedwater nozzles. Therefore, the staff requested that

the applicant describe the method used to estimate the fatigue usage of these nozzles prior to

implementation of the stress-based fatigue monitoring.

In its response, by letter dated December 6, 2004, the applicant indicated that a baseline

fatigue usage value would be established from a calculation using the number of cycles

accumulated to date. The fatigue usage developed from the stress-based monitoring will be

added to this baseline value. The applicant also indicated that the results from the stress-based

monitoring will be used to confirm the conservatism of the baseline fatigue usage value. Based

on industry experience with stress-based fatigue monitoring, the staff expected that

stress-based fatigue monitoring would confirm the conservatism of the applicant's baseline

fatigue usage value. The staff found the applicant's method of estimating the fatigue usage of

the feedwater nozzles prior to implementation of the stress-based fatigue monitoring

acceptable. Therefore, the staffs concern described in RAI 4.3.1-2 is resolved.

4.3.1.3 UFSAR and USAR Supplements

The applicant provided UFSAR and USAR supplement summary descriptions of its TLAA

evaluation of reactor vessel fatigue analysis in ALRA Sections A1.2.2.1 and A2.2.2.1,

respectively. On the basis of its review of the UFSAR and USAR supplements, the staff

concludes that the summary descriptions of the applicant's actions to address the reactor

vessel fatigue analysis are adequate.

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4.3.1.4 Conclusion

On the basis of its review, as discussed above, the staff concludes that the applicant had

demonstrated, pursuant to 10 CFR 54.21 (c)(1)(iii), that for the RPV fatigue TLAA, the effects of

aging on the intended functions will be adequately managed for the period of extended

operation. The staff also concludes that the UFSAR and USAR supplements contain an

appropriate summary description of the RPV fatigue TLAA evaluation for the period of extended

operation, as required by 10 CFR 54.21(d).

4.3.2 ASME Section III Class I Piping and Components Fatigue Analysis (NMP2 Only)

4.3.2.1 Summary of Technical Information in the Amended Application

The applicant discussed the design of the remaining NMP2 RCPB components in ALRA

Section 4.3.2. These components were evaluated using the ASME Section III Class 1 fatigue

criteria. The applicant indicated that the bounding piping locations would by monitored by the

FMP. The bounding locations are listed in ALRA Table 4.3-5. The applicant stated that the

effects of fatigue on the intended functions of ASME Class 1 piping and components will be

adequately managed by the FMP in accordance with the requirements of

10 CFR 54.21(c)(1)(iii).

4.3.2.2 Staff Evaluation

The NMP2 RCPB (ASME Section III, Class 1) piping components were explicitly evaluated for

fatigue. As discussed in the previous section of this SER, the applicant monitors critical fatigue

locations with the FMP. The applicant indicated that, in addition to meeting the ASME criterion

that the CUF remain less than 1.0, the CUF should not exceed 0.1 in the break exclusion zone.

In ALRA Table 4.3-5, the applicant listed the limiting locations for fatigue usage, including the

limiting fatigue usage locations in the pipe break exclusion zone. The applicant indicated that

the FMP will monitor these locations. The applicant also indicated that piping components

equivalent to those identified in NUREG/CR-6260 would also be monitored by the FMP. The

applicant's selection of the NUREG/CR-6260 locations is discussed in the previous section of

this SER. The staff found that these locations, combined with the locations listed in ALRA

Table 4.3-4, including the additional NUREG/CR-6260 locations discussed ALRA Section 4.3.2,

provide an acceptable sample of critical components to monitor the fatigue usage of the NMP2

RCPB during the period of extended operation.

4.3.2.3 USAR Supplement

The applicant provided a USAR supplement summary description of its TLAA evaluation of

ASME Section III Class 1 piping and components fatigue analysis in ALRA Section A2.2.2.2.

On the basis of its review of the USAR supplement, the staff concludes that the summary

description of the applicant's actions to address the ASME Section III Class 1 piping and

components fatigue analysis is adequate.

4.3.2.4 Conclusion

On the basis of its review, as discussed above, the staff concludes that there is reasonable

assurance that the applicant had demonstrated, pursuant to 10 CFR 54.21(c)(1)(iii), that, for the

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ASME Section III Class 1 piping and components fatigue analysis TLAA, the effects of aging on

the intended functions will be adequately managed for the period of extended operation. The

staff also concludes that the UFSAR supplement contains an appropriate summary description

of the ASME Section III Class 1 piping and components fatigue analysis TLAA evaluation for

the period of extended operation, as required by 10 CFR 54.21(d).

4.3.3 Feedwater Nozzle and Control Rod Drive Return Line (CRDRL) Nozzle Fatigue and

Cracking Analyses

4.3.3.1 Summary of Technical Information in the Amended Application

The applicant discussed the feedwater (FW) nozzle and the control rod drive return line

(CRDRL) nozzle fatigue and cracking analyses in ALRA Section 4.3.3. Cracking has occurred

in FW and CRDRL nozzles at several BWRs. NUREG-0619, "BWR Feedwater Nozzle and

Control Rod Drive Return Line Nozzle Cracking," identified actions to address the problem. The

applicant indicated that the NMP1 FWS was modified to meet requirements of NUREG-0619

because of cracking detected in 1977. The applicant stated that no reportable indications were

identified during subsequent inspections. The applicant also indicated that revised fatigue and

crack growth analyses were performed in 1999 based on updated plant data. An annual fatigue

usage of 0.003 was calculated. The applicant stated that no cracking was found in the NMP1

CRDRL nozzle.

The applicant indicated that the NMP2 FW nozzles employ the improved interference fit sparger

design discussed in NUREG-0619. The improved design is less susceptible to fatigue cracking.

However, linear projections of the number of startup and shutdown cycles indicate that the CUF

could exceed 1.0 prior to the period of extended operation. Additionally, the applicant stated

that indications detected in dissimilar welds associated with the NMP2 FW nozzles had been

repaired by a weld overlay process. The applicant indicated that a conservative number of

startup and shutdown cycles was assumed for the crack growth analysis. The applicant stated

that the CRDRL nozzle was cut and capped at NMP2 eliminating the fatigue cracking concern

for NMP2.

The applicant indicated that transients contributing to the fatigue usage of the NMP1 and NMP2

FW nozzles would be tracked by the NMPNS FMP and, if necessary, that corrective actions

would be implemented. The applicant concluded that the effects of fatigue on the intended

function(s) of FW and CRDRL nozzles will be adequately managed by the FMP in accordance

with the requirements of 10 CFR 54.21 (c)(1)(iii).

4.3.3.2 Staff Evaluation

The applicant performed evaluations to address generic industry and plant-specific concerns

related to FW and CRDRL nozzle cracking described in NUREG-0619. FW nozzle cracking was

detected at NMP1 in 1977. The applicant implemented several modifications to minimize

potential cracking, including incorporation of an improved thermal sleeve/feedwater sparger

design. The evaluation of the new design included fatigue and flaw growth analyses. The

applicant updated these analyses in 1999. The applicant relies on the FMP to track the

transients associated with these analyses. The staff found the applicant's FMP will adequately

manage the fatigue and flaw growth analyses of the NMP1 thermal sleeve/feedwater sparger

design during the period of extended operation in accordance with 10 CFR 54.21(c)(1)(iii).

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The applicant projected that the fatigue usage of the NMP1 CRDRL nozzle will remain

significantly below 1.0 during the period of extended operation. The staff found that the fatigue

usage of the CRDRL nozzle had been adequately projected to the end of the period of

extended operation in accordance with 10 CFR 54.21(c)(1)(ii). In addition, the applicant

indicated that NMP1 will continue to perform enhanced inspections of the CRDRL nozzle in

accordance with NMP1 commitments related to NUREG-0619.

The staffs review of the original LRA Section 4.3.3 identified an area in which additional

information was necessary to complete the review of the feedwater nozzle and control rod drive

return line (CRDRL) nozzle fatigue and cracking analyses. The applicant responded to the

staffs RAI as discussed below.

In RAI 4.3.3, dated February 22, 2005, the staff requested that the applicant explain how the

flaw growth analysis of the FW and CRDRL nozzles was dispositioned for the period of

extended operation.

The applicant's July 14, 2005, response to RAI 4.3.3, indicated that the crack growth analysis,

using estimated transient cycles, predicted that the postulated flaw would not grow to an

unacceptable value during the period of extended operation. The applicant performed a crack

growth analysis of the NMP1 CRDRL nozzle in 1994 to demonstrate that small surface flaws

would not grow to unacceptable values within the original 40-year license period. The staff also

found that the applicant had adequately projected the NMP1 CRDRL crack growth analysis to

the end of the period of extended operation in accordance with 10 CFR 54.21(c)(1)(ii). In

addition, the applicant indicated that it would rely on its enhanced ultrasonic inspections

performed at each 10-year inservice inspection interval to detect CRDRL nozzle cracking. The

applicant's inspection program is described in ALRA Section B2.1.37. The applicant's CRDRL

nozzle inspection program will provide assurance that small surface flaws in the CRDRL nozzle

will not grow to unacceptable values during the period of extended operation.

The applicant stated that a linear projection of the NMP2 startup/shutdown cycles to date

indicates that the number assumed in the original design may be exceeded prior to the period

of extended operation. As a consequence, the fatigue usage of the FW nozzles may exceed the

allowable limit during the period of extended operation. The applicant also stated that

indications in the dissimilar metal weld associated with the NMP2 FW nozzles had been

repaired by a weld overlay process. The applicant will track the fatigue usage of the FW nozzle

with the FMP, and will reassess the original fatigue crack growth calculation if necessary. The

staff found that the applicant's FMP, which tracks the number of startup/shutdown cycles, will

adequately manage the fatigue and crack growth analyses of the NMP2 FW nozzles during the

period of extended operation in accordance with 10 CFR 54.21 (c)(1)(iii).

The applicant indicated that the NMP2 CRDRL nozzle was cut and capped, thus eliminating the

fatigue concern with the NMP2 CRDRL nozzle. The staff agreed with the applicant's

assessment.

The applicant indicated that transients contributing to the fatigue usage of NMPI and NMP2

FW nozzles will be tracked by the NMPNS FMP during the period of extended operation. It was

indicated that the FMP will be consistent with GALL Report, Section X.M.1, "Metal Fatigue of

Reactor Coolant Pressure Boundary," prior to the period of extended operation. The applicant

also stated that corrective actions such as reanalysis, enhanced inspection, or

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repair/replacement will be implemented if fatigue trending shows that acceptable fatigue usage

cannot be maintained during the period of extended operation.

GALL Report, Section X.M.1 recommends that the applicant take appropriate corrective actions

to prevent the CUF, including reactor coolant environmental effects, from exceeding the design

Code limit during the period of extended operation. Acceptable corrective actions include a

more rigorous analysis of the component to demonstrate that the design Code limit will not be

exceeded, and repair or replacement of the component. However, the recommendations of the

GALL Report, Section X.M.1 does not specify enhanced inspection as an acceptable corrective

action. The staff noted that the use of an enhanced inspection program, in lieu of meeting the

design fatigue usage, will require prior staff review and approval. An AMP using enhanced

inspection would be a departure from the design basis CUF, described in the UFSAR and,

therefore, would require a separate license amendment pursuant to 10 CFR 50.59.

On the basis of the above discussion, the staff found the applicant's FMP will adequately

manage the fatigue usage and crack growth of the NMP1 and NMP2 FW nozzles during the

period of extended operation in accordance with 10 CFR 54.21(c)(1)(iii). However, the staff

notes that enhanced inspection would be a departure from the design basis CUF, described in

the UFSAR and, therefore, would require a NRC approval pursuant to 10 CFR 50.59. The

staff's concern described in RAI 4.3.3 is resolved.

4.3.3.3 UFSAR and USAR Supplements

The applicant provided UFSAR and USAR supplement summary descriptions of its TLAA

evaluation of FW nozzle and CRDRL nozzle fatigue and cracking analysis in ALRA

Sections A1.2.2.2 and A2.2.2.3, respectively. On the basis of its review of the UFSAR and

USAR supplements, the staff concludes that the summary descriptions of the applicant's

actions to address the FW nozzle and CRDRL nozzle fatigue and cracking analysis are

adequate.

4.3.3.4 Conclusion

On the basis of its review, as discussed above, the staff concludes that there is reasonable

assurance that the applicant had demonstrated, pursuant to 10 CFR 54.21(c)(1)(iii), regarding

the NMP1 and NMP2 FW nozzle fatigue and cracking analyses TLAA, that the effects of aging

on the intended function(s) will be adequately managed for the period of extended operation.

The staff further concludes that the applicant has provided an acceptable evaluation to

demonstrate that the NMPI CRDRL nozzle fatigue and crack growth analyses have been

adequately projected to the end of the period of extended operation in accordance with

10 CFR 54.21(c)(1)(ii). The staff also concludes that the UFSAR and USAR supplements

contain appropriate summary descriptions of the FW nozzle and the CRDRL nozzle fatigue and

cracking analyses TLAA evaluations for the period of extended operation, as required by

10 CFR 54.21(d).

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4.3.4 Non-ASME Section III Class I Piping and Components Fatigue Analysis

4.3.4.1 Summary of Technical Information in the Amended Application

Non-ASME Section III Class 1 piping and components were designed to ASA B31.1 and ASME

Section III Class 2 and 3 criteria. The piping components require that a stress reduction factor

be applied to the allowable thermal bending stress range if the number of full range cycles

exceeds 7,000. The B31.1 criteria were used in the design of the NMP1 RCPB piping. The

applicant identified several NMP1 systems for further detailed fatigue analyses. These include

locations listed in NUREG/CR-6260, "Application of NUREG/CR-5999 Interim Fatigue Curves to

Selected Nuclear Power Plant Components." The applicant committed to develop baseline

CUFs for these systems prior to the period of extended operation.

The applicant indicated that, if fatigue monitoring of ASME Class 1 piping at NMP2 indicates

higher fatigue usage than expected, then the non-ASME Class 1 piping will be evaluated for

possible fatigue concerns. The applicant concludes that the effects of fatigue on the intended

function(s) of non-ASME Class 1 piping and components included in the FMP will be

adequately managed by the FMP in accordance with the requirements of

10 CFR 54.21(c)(1)(iii).

4.3.4.2 Staff Evaluation

The applicant indicted that the NMP1 RCPB piping was designed to the ASA B31.1-1955 piping

code, which did not require an explicit fatigue analysis of piping system components. The

applicant committed to develop baseline fatigue usage factors for the following selected

portions of the following NMP1 systems prior to the period of extended operation:

* feedwater/high pressure coolant injection system,

* core spray system,

* reactor water cleanup system,

* reactor recirculation system and associated shutdown cooling lines

The staff found the applicant's commitment to develop baseline fatigue usage factors for the

systems listed above acceptable. The applicant indicated that locations where the baseline

fatigue usage factor exceeds 0.4 would be monitored by the NMPNS FMP during the period of

extended operation. As discussed in SER Section 4.3.1.2, the applicant selected the

NUREG/CR-6260 locations or acceptable alternatives for fatigue monitoring at NMP1.

Therefore, the staff found that the locations listed above, combined with the reactor vessel

locations listed in ALRA Table 4.3-3, provide an acceptable sample of critical components to

monitor the fatigue usage of the NMP1 RCPB components during the period of extended

operation.

The staff found that the applicant's FMP will adequately manage the fatigue usage of the NMP1

RCPB components during the period of extended operation in accordance with

10 CFR 54.21(c)(1)(iii).

The design of the remaining NMP1 and NMP2 non-ASME Section III Class I piping systems

are governed by criteria that limit the number of full range stress cycles due to thermal bending

to 7000 cycles. The applicant indicated that if the fatigue monitoring of Class 1 piping indicates

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higher fatigue usage than expected, the non-Class 1 piping will be evaluated for possible

fatigue concerns. The staff noted that the applicant's program monitors locations of high fatigue

usage. The staff found that these locations provide a reasonable sample to monitor the

potential fatigue usage of the non-ASME Class I piping systems at NMP1 and NMP2 because

the monitored locations include the expected plant thermal transient cycles, including plant

startup/shutdown cycles. The staff found that the applicant's FMP, which tracks the number of

expected thermal transient cycles, will adequately manage the fatigue of the NMP1 and NMP2

non-ASME Section III Class 1 piping during the period of extended operation in accordance with

10 CFR 54.21(c)(1)(iii).

4.3.4.3 UFSAR and USAR Supplements

The applicant provided UFSAR and USAR supplement summary descriptions of its TLAA

evaluation of non-ASME Section III Class 1 piping and components fatigue analysis in ALRA

Sections A1.2.2.3 and A2.2.2.4, respectively. On the basis of its review of the UFSAR and

USAR supplements, the staff concludes that the summary descriptions of the applicant's

actions to address the non-ASME Section III Class 1 piping and components fatigue analysis

are adequate.

4.3.4.4 Conclusion

On the basis of its review, as discussed above, the staff concludes that there is reasonable

assurance that the applicant had demonstrated, pursuant to 10 CFR 54.21(c)(1)(iii), regarding

the non-ASME Section III Class 1 piping and components fatigue analysis TLAA, that the

effects of aging on the intended function(s) will be adequately managed for the period of

extended operation. The staff also concludes that the UFSAR and USAR supplements contain

appropriate summary descriptions of the non-ASME Section III Class 1 piping and components

fatigue analysis TLAA evaluation, as required by 10 CFR 54.21(d).

4.3.5 Reactor Vessel Internals Fatigue Analysis

4.3.5.1 Summary of Technical Information in the Amended Application

The applicant discussed the fatigue analysis of the reactor vessel internals (RVI) in ALRA

Section 4.3.5. The applicant indicated that fatigue analysis was not a design requirement for the

RVI at NMPNS. However, fatigue analyses were performed for the core shroud repair at NMP1

and certain locations in the NMP2 RVI. ALRA Table 4.3-6 lists the CUFs associated with these

locations. The applicant committed to further evaluation of those locations where the CUF

exceeds 0.4 prior to the period of extended operation and to take appropriate correctives

actions if necessary. The applicant concluded that the effects of fatigue on the intended

function(s) of the RVI will be adequately managed by the FMP in accordance with the

requirements of 10 CFR 54.21(c)(1)(iii).

4.3.5.2 Staff Evaluation

Even though fatigue analysis of the RVI is not a design requirement at NMPNS, the applicant

evaluated certain locations at NMP1 and NMP2. These locations are listed in ALRA

Table 4.3-6. The NMP1 locations include the core shroud vertical weld repair clamps and the

core shroud stabilizer tie-rod assemblies. The applicant reported a relatively low fatigue usage

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(less than 0.1) for repair clamps for the 40-year design life. The staff concludes that the fatigue

usage will remain within the allowable limit for the period of extended operation. The applicant

also indicated that the tie-rods were designed for a 25-year design life.

The staffs review of the original LRA Section 4.3.6 identified an area in which additional

information was necessary to complete the review of the reactor vessel internals fatigue

analysis. The applicant responded to the staff's RAI as discussed below.

In RAI 4.3.6, dated February 22, 2005, the staff requested that the applicant provide additional

information regarding the disposition after the 25-year design life.

In its response, by letter dated July 14, 2005, the applicant indicated that the 25-year design life

was based on the original license expiration plus 10 years. The applicant also indicated that the

25-year design life was not based on a design limitation relative to any specific component of

the tie-rod assembly. The applicant stated that the projected fatigue usage of the tie-rods would

remain well within the allowable limit of 1.0 during the period of extended operation. The staff

concludes that the applicant has demonstrated that the NMP1 RVI fatigue analyses will remain

valid for the period of extended operation. Therefore, the staff found that the fatigue usage of

the tie-rods has been adequately projected to the end of the period of extended operation in

accordance with 10 CFR 54.21 (c)(1)(ii). In addition, the applicant indicated that potential for

cracking of the RVI components will be managed by the BWRVIP. The BWRVIP is described in

ALRA Section B2.1.8.

The applicant indicated that the controlling loading for the NMP2 RVI locations is flow-induced

vibrations and other dynamic loads. The applicant committed, as stated in Commitment Item 6

in the ALRA, dated July 14, 2005, to evaluate all locations where the 40-year design CUF

exceeds 0.4 prior to the period of extended operation. The applicant indicated that corrective

actions would be taken if the RVI evaluation does not demonstrate acceptable fatigue usage.

Corrective actions acceptable to the staff are part of the NMPNS FMP. The staff found the

applicant's commitment to further evaluation of the limiting NMP2 RVI internal locations prior to

the period of extended operation acceptable. In addition, the applicant indicated that the

potential for RVI cracking is managed by the BWRVIP described in ALRA Section B2.1.8.

Therefore, the staff's concern described in RAI 4.3.6 is resolved.

4.3.5.3 UFSAR and USAR Supplements

The applicant provided UFSAR and USAR supplement summary descriptions of its TLAA

evaluation of RVI fatigue analysis in ALRA Sections A1.2.2.4 and A2.2.2.5, respectively. On the

basis of its review of the UFSAR and USAR supplements, the staff concludes that the summary

descriptions of the applicant's actions to address the RVI fatigue analysis are adequate.

4.3.5.4 Conclusion

On the basis of its review, as discussed above, the staff concludes that there is reasonable

assurance that the applicant had demonstrated, pursuant to 10 CFR 54.21(c)(1)(iii), regarding

the RVI fatigue analysis TLAA, that the effects of aging on the intended function(s) will be

adequately managed for the period of extended operation. The staff also concludes that the

UFSAR and USAR supplements contain appropriate summary descriptions of the RVI fatigue

analysis TLAA evaluation for the period of extended operation, as required by 10 CFR 54.21(d).

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4.3.6 Environmentally Assisted Fatigue

4.3.6.1 Summary of Technical Information in the Amended Application

The applicant indicated that NMP1 and NMP2 will assess the impact of the reactor coolant

environment on a sample of components, including locations equivalent to those listed in

NUREG/CR-6260. The applicant indicated that the evaluation would be completed prior to the

period of extended operation. The applicant concludes that the effects of environmentally

assisted fatigue will be adequately managed for the period of extended operation in accordance

with the requirements of 10 CFR 54.21 (c)(1)(iii).

4.3.6.2 Staff Evaluation

The applicant indicated that the FMP will continue during the period of extended operation and

will assure that design cycle limits are not exceeded. The applicant's FMP tracks transients and

cycles of RCS components that have explicit design transient cycles to assure that these

components remain within their design basis. Generic safety issue (GSI)-1 66, "Adequacy of the

Fatigue Life of Metal Components," raised concerns regarding the conservatism of the fatigue

curves used in the design of the RCS components. Although GSI-1 66 was resolved for the

current 40-year design life of operating components, the staff identified GSI-190, "Fatigue

Evaluation of Metal Components for 60-year Plant Life," to address license renewal. The NRC

closed GSI-190 in December, 1999, concluding:

The results of the probabilistic analyses, along with the sensitivity studies

performed, the iterations with industry (NEI and EPRI), and the different

approaches available to the licensees to manage the effects of aging, lead to

the conclusion that no generic regulatory action is required, and that GSI-190

is closed. This conclusion is based primarily on the negligible calculated

increases in core damage frequency in going from 40 to 60 year lives.

However, the calculations supporting resolution of this issue, which included

consideration of environmental effects, and the nature of age-related

degradation indicate the potential for an increase in the frequency of pipe

leaks as plants continue to operate. Thus, the staff concludes that, consistent

with existing requirements in 10 CFR 54.21, licensees should address the

effects of coolant environment on component fatigue life as aging

management programs are formulated in support of license renewal.

The applicant committed to assess the impact of the reactor coolant environment on a sample

of critical component locations, including the locations equivalent to those identified in

NUREG/CR-6260 prior to the period of extended operation as part of the NMPNS FMP. The

applicant indicated that the FMP will be consistent with NUREG-1 801, Section X.M.1, "Metal

Fatigue of Reactor Coolant Pressure Boundary," prior to the period of extended operation. The

guidance of GALL Report, Section X.M.1 is that the applicant should take appropriate corrective

actions to prevent the CUF, including reactor coolant environmental effects, from exceeding the

design Code limit during the period of extended operation. Acceptable corrective actions

include a more rigorous analysis of the component to demonstrate that the design Code limit

will not be exceeded, and repair or replacement of the component. The staff discussed the

applicant's selection of the NUREG/CR-6260 locations in SER Section 4.3.1.2 The staff found

the applicant's commitment to assess the impact of the reactor coolant environment on a

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sample of critical NMP1 and NMP2 components prior to the period of extended operation

acceptable.

4.3.6.3 UFSAR and USAR Supplements

The applicant provided UFSAR and USAR supplement summary descriptions of its TLAA

evaluation of environmentally assisted fatigue in ALRA Sections A1.2.2.5 and A2.2.2.6,

respectively. On the basis of its review of the UFSAR and USAR supplements, the staff

concludes that the summary descriptions of the applicant's actions to address environmentally

assisted fatigue are adequate.

4.3.6.4 Conclusion

On the basis of its review, as discussed above, the staff concludes that there is reasonable

assurance that the applicant had demonstrated, pursuant to 10 CFR 54.21(c)(1)(iii), that, for the

environmentally assisted fatigue TLAA, the effects of aging on the intended function(s) will be

adequately managed for the period of extended operation. The staff also concludes that the

UFSAR supplement contains an appropriate summary description of the environmentally

assisted fatigue TLAA evaluation for the period of extended operation, as required by

10 CFR 54.21(d).

4.3.7 Fatigue of the Emergency Condenser (NMP1 Only)

4.3.7.1 Summary of Technical Information in the Amended Application

The applicant discussed the fatigue analysis of the NMP1 emergency condenser in ALRA

Section 4.3.7. The applicant indicated that a fatigue analysis of the emergency condenser was

performed after tubing failures attributed to thermal cycling were identified in 1997. The

applicant listed the fatigue usage for the limiting locations in Table 4.3-7. The applicant

indicated that the NMPNS FMP will track the transients specific to the emergency condensers.

The applicant concluded that the effects of fatigue on the intended function(s) of the NMP1

emergency condensers will be adequately managed in accordance with the requirements of

10 CFR 54.21(c)(1)(iii).

4.3.7.2 Staff Evaluation

The applicant indicated that the NMP1 emergency condensers were designed in accordance

with ASME Section III Class 2 and 3 criteria, which do not require an explicit fatigue analysis for

thermal transients. However, tubing failures in 1997 were attributed to thermal fatigue resulting

from leakage past the condensate return line. As part of its corrective action, the applicant

identified applicable thermal transients and performed a fatigue analysis of the condensers. The

limiting locations are shown in ALRA Table 4.3-7. The applicant indicated that these locations

would be monitored by the NMPNS FMP. The staff found that the applicant's FMP will

adequately manage the fatigue usage of the NMP1 condensers during the period of extended

operation in accordance with 10 CFR 54.21(c)(1)(iii).

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4.3.7.3 UFSAR Supplement

The applicant provided a UFSAR supplement summary description of its TLAA evaluation of

fatigue of the emergency condenser in ALRA Section A1.2.2.6. On the basis of its review of the

UFSAR supplement, the staff concludes that the summary description of the applicant's actions

to address the fatigue of the emergency condenser is adequate.

4.3.7.4 Conclusion

On the basis of its review, as discussed above, the staff concludes that there is reasonable

assurance that the applicant had demonstrated, pursuant to 10 CFR 54.21(c)(1)(iii), regarding

fatigue of the emergency condenser TLAA, that the effects of aging on the intended function(s)

will be adequately managed for the period of extended operation. The staff also concludes that

the UFSAR supplement contains an appropriate summary description of the emergency

condenser TLAA evaluation for the period of extended operation, as required by

10 CFR 54.21(d).

4.4 Environmental Qualification

4.4.1 Electrical Equipment EQ

The NRC has established nuclear station EQ requirements in 10 CFR 50, Appendix A,

Criterion 4, and 10 CFR 50.49, which specifically require that an EQ program be established to

demonstrate that certain electrical components located in "harsh" plant environments (i.e.,

those areas of the plant that could be subject to the harsh environmental effects of a

loss-of-coolant accident (LOCA), high-energy line breaks (HELBs), or post-LOCA radiation) are

qualified to perform their safety function in those harsh environments after the effects of

in-service aging. Section 50.49 of 10 CFR requires that the effects of significant aging

mechanisms be addressed as part of environmental qualification. For the purpose of license

renewal, only those components with a qualified life of 40 years or greater would be TLAAs.

The staff reviewed ALRA Section 4.4.1, "Electrical Equipment EQ," in which the applicant

described the technical bases and justification for the NMPNS EQ Program, together with other

plant programs and processes that adequately manage the effects of aging on the intended

function(s) of electrical components for the period of extended operation. The staff reviewed

this section of the ALRA to determine whether the applicant had demonstrated that the effects

of aging on the intended function(s) of the electrical equipment will be adequately managed

through the NMPNS EQ Program, together with other programs and processes, during the

period of extended operations as required by 10 CFR 54.21 (c)(1)(ii).

4.4.1.1 Summary of Technical Information in the Amended Application

In ALRA Section 4.4.1, the applicant summarized the evaluation of electrical equipment EQ for

the period of extended operation. Section 50.49 of 10 CFR requires that certain SR and NSR

electrical equipment remain functional during and after identified DBEs. To establish reasonable

assurance that this equipment can function when exposed to postulated harsh environmental

conditions, applicants are required to determine the equipment's qualified life and to develop a

program that maintains the qualification of that equipment. Determination of qualified life is an

ongoing activity that considers both normal and accident operating environments.

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4.4.1.2 Staff Evaluation

The staff reviewed ALRA Section 4.4.1 to determine whether the applicant had submitted

adequate information to meet the requirement of 10 CFR 54.21(c)(1). For the electrical

equipment identified in ALRA Table 4.1-1, the applicant used 10 CFR 54.21 (c)(1)(iii) in its TLAA

evaluation to demonstrate that the aging effects of EQ equipment will be adequately managed

during the period of extended operation. The staff reviewed the EQ Program to determine

whether it will assure that the electrical and I&C components covered under this program will

continue to perform their intended functions consistent with the CLB for the period of extended

operation. The staff's evaluation of the components' qualification focused on how the EQ

Program manages the aging effects to meet the requirements delineated in 10 CFR 50.49.

The applicant's program activities establish, demonstrate, and document the level of

qualification, qualified configuration, maintenance, surveillance, and replacement requirements

necessary to meet 10 CFR 50.49. Qualified life is determined for equipment within the scope of

the EQ Program and appropriate actions, replacement or refurbishment, are taken prior to or at

the end of qualified life of the equipment so that aging limits or acceptable margins are not

exceeded.

4.4.1.3 UFSAR and USAR Supplements

The applicant provided UFSAR and USAR supplement summary descriptions of its TLAA

evaluation of electrical equipment EQ in ALRA Sections A1.2.3.1 and A2.2.3.1, respectively. On

the basis of its review of the UFSAR and USAR supplements, the staff concludes that the

summary descriptions of the applicant's actions to address electrical equipment EQ are

adequate.

4.4.1.4 Conclusion

On the basis of its review, as discussed above, the staff concludes that there is reasonable

assurance that the applicant had demonstrated, pursuant to 10 CFR 54.21(c)(1)(iii), regarding

the electrical equipment EQ TLAA, that the effects of aging on the intended function(s) will be

adequately managed for the period of extended operation. The staff also concludes that the

UFSAR and USAR supplements contain appropriate summary descriptions of the electrical

equipment EQ TLAA evaluation for the period of extended operation, as required by

10 CFR 54.21(d).

4.4.2 Mechanical Equipment EQ (NMP2 Only)

The staff has established nuclear station EQ requirements in 10 CFR 50, Appendix A,

Criterion 4, which require that an EQ Program be established to demonstrate that nonmetallic

subcomponents comprising SR mechanical equipment located in "harsh" plant environments

(i.e., those areas of the plant that could be subject to the harsh environmental effects of a

LOCA, HELB, or post-LOCA radiation) are qualified to perform their safety function in those

harsh environments after the effects of in-service aging. For the purpose of license renewal,

only those components with a qualified life of 40 years or greater would be TLAAs.

The staff reviewed ALRA Section 4.4.2, "Mechanical Equipment EQ (NMP 2 Only)," in which

the applicant described the technical bases and justification for the NMPNS EQ Program,

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together with other plant programs and processes that adequately manage the effects of aging

on the intended function(s) of mechanical components for the period of extended operation.

The staff reviewed this section of the ALRA to determine whether the applicant had

demonstrated that the effects of aging on the intended function(s) of the mechanical equipment

will be adequately managed through the NMPNS EQ Program, together with other programs

and processes, during the period of extended operations as required by 10 CFR 54.21(c)(1)(iii).

4.4.2.1 Summary of Technical Information in the Application

The applicant stated the NMPNS EQ Program has been established to designate equipment,

demonstrate qualification, and ensure that the correct preventive and corrective maintenance

activities are conducted to maintain equipment qualification (refer to Appendix B3.1).

Furthermore, when required by ongoing analyses of updated or revised test data, accident

profiles, or normal operating environments, re-evaluation of qualified life determinations are

conducted in accordance with EQ Program requirements.

The applicant confirmed that the effects of aging on the intended function(s) will be adequately

managed for the period of extended operation. For components within the scope of the NMPNS

EQ Program, analyses of thermal exposure, radiation exposure, and mechanical cycle aging

that cannot be shown to remain valid for the period of extended operation will be reviewed as

part of the ongoing EQ Program to extend the qualification of components before reaching the

aging limits established in the applicable evaluation, or the components will be refurbished or

replaced. Therefore, the effects of aging on components included in the EQ Program will be

adequately managed in accordance with 10 CFR 54.21(c)(1)(iii).

4.4.2.2 Staff Evaluation

The staff reviewed ALRA Section 4.4.2 to determine whether the applicant submitted adequate

information to meet the requirement of 10 CFR 54.21 (c)(1). For the mechanical equipment

identified in ALRA Table 4.1-1, the applicant used 10 CFR 54.21(c)(1)(iii) in its TLAA evaluation

to demonstrate that the aging effects of EQ equipment will be adequately managed during the

period of extended operation. The staff reviewed the EQ Program to determine whether it will

assure that the nonmetallic materials used in SR mechanical equipment covered under this

program will continue to perform their intended functions consistent with the CLB for the period

of extended operation. The staff's evaluation of the components' qualification focused on how

the EQ Program manages the aging effects to meet the requirements delineated in 10 CFR 50,

Appendix A.

The applicant's program activities establish, demonstrate, and document the level of

qualification, qualified configuration, maintenance, surveillance, and replacement requirements

necessary to meet 10 CFR 50 Appendix A. Qualified life is determined for equipment within the

scope of the EQ Program and appropriate actions, replacement or refurbishment, are taken

prior to or at the end of qualified life of the equipment so that aging limits or acceptable margins

are not exceeded.

The staff also reviewed the USAR supplement for this TLAA and concludes that it provided an

adequate summary description of the TLAA to satisfy 10 CFR 54.21(d).

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The staff concludes that there is reasonable assurance that the applicant has provided an

acceptable demonstration, pursuant to 10 CFR 54.21(c)(1), that, for the environmental

qualification of electrical equipment TLAA, the effects of aging on the intended function(s) will

be adequately managed for the period of extended operation.

4.4.2.3 USAR Supplement

The applicant provided a USAR supplement summary description of its TLAA evaluation of

mechanical equipment EQ in ALRA Section A2.2.3.2. On the basis of its review of the USAR

supplement, the staff concludes that the summary description of the applicant's actions to

address mechanical equipment EQ is adequate.

4.4.2.4 Conclusion

On the basis of its review, as discussed above, the staff concludes that there is reasonable

assurance that the applicant had demonstrated, pursuant to 10 CFR 54.21(c)(1)(iii), regarding

the mechanical equipment EQ TLAA, that the effects of aging on the intended function(s) will

be adequately managed for the period of extended operation. The staff also concludes that the

USAR supplement contains an appropriate summary description of the mechanical equipment

EQ TLAA evaluation for the period of extended operation, as required by 10 CFR 54.21(d).

4.5 Concrete Containment Tendon Prestress Analysis

The NMP1 and NMP2 containments do not employ prestressed concrete designs; therefore,

this TLAA is not applicable to NMPNS.

.4.6 Containment Liner Plate, Metal Containments, and Penetrations Fatigue

Analysis

4.6.1 Torus Shell and Vent System Fatigue Analysis (NMPI Only)

NMP1 is a BWR with a Mark I containment. The Mark I containment consists of a freestanding

steel containment drywell, vent system, and steel pressure suppression chamber (torus).

Large-scale testing of the Mark III containment and in-plant testing of Mark I primary

containment systems identified additional hydrodynamic loads that were not considered in the

original design of the NMP1 containment. The Mark I Owners Group initiated the Mark I

Containment Program to develop a generic load definition and structural analysis techniques.

The staff evaluation of the generic load definition and structural assessment techniques is

contained in NUREG-0661, "Safety Evaluation Report, Mark I Containment Long Term

Program, Resolution of Generic Technical Activity A-7," July 1980. The Mark I Containment

Long Term Program evaluation of hydrodynamic loads included fatigue analyses of the torus

and vent system and fatigue analyses of the torus attached piping.

NMP2 is a BWR with a Mark II containment. The Mark II containment is a reinforced concrete

structure consisting of a drywell chamber located above a pressure suppression chamber.

Except at various penetrations, the primary containment liner is a continuous membrane that

functions as a leak-tight barrier to the release of fission products. The liner is attached to the

concrete wall. The design process assumes that the liner does not carry any loads.

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The containment liner plates, penetration sleeves (including dissimilar metal welds), and

penetration bellows may be designed in accordance with the requirements of ASME Code

Section II1. If a plant's code of record requires a fatigue analysis, then this analysis may be a

TLAA and must be evaluated in accordance with 10 CFR 54.21(c)(1) to ensure that the effects

of aging on the intended functions will be adequately managed for the period of extended

operation.

The adequacy of the fatigue analyses of the metal containment, containment liner plates

(including welded joints), penetration sleeves, dissimilar metal welds, and penetration bellows is

reviewed for the period of extended operation. The fatigue analyses of the pressure boundary

of process piping are reviewed in SER Section 4.3, following the guidance in SRP-LR

Section 4.3.

4.6.1.1 Summary of Technical Information in the Amended Application

The applicant discussed the NMP1 torus shell and vent system fatigue analysis in ALRA

Section 4.6.1. The applicant indicated that a fatigue evaluation was performed for the torus

shell and external support structure and vent header system for hydrodynamic loads associated

with LOCA and safety relief valve (SRV) discharge events. The applicant indicated that the

evaluations were performed in accordance with ASME Section III, Division I (with addenda

through 1977) and Code Case N-197. ALRA Table 4.6-1 provides the bounding fatigue usage

factors for the NMP1 torus shell. The applicant concluded that the fatigue analyses either (1)

remain valid for the period of extended operation in accordance with 10 CFR 54.21(c)(1)(i), or

(2) have been projected to the end of the period of extended operation in accordance with

10 CFR 54.21(c)(1)(ii).

4.6.1.2 Staff Evaluation

The applicant indicated that the NMP1 torus shell and vent header system were evaluated as

part of the Mark I Containment Program. The evaluation included fatigue analyses of the torus

shell and vent header system. These analyses were summarized in the NMP1 Mark I

containment plant-unique analysis report (PUAR). The applicant indicated that the design-basis

accident (DBA) was the major load contributing to the high stresses in the vent header system.

By letter dated December 20, 2005, the applicant indicated that the controlling fatigue usage

factor was 0.86 at the vent header/vent pipe spherical intersection. Since the DBA is a one-time

event, the applicant concluded that.the vent system analysis remains valid for the period of

extended operation. The staff concurred with the applicant that the DBA should be considered a

one-time event for the period of extended operation. As discussed in ALRA Section 4.6.2, the

number of SRV actuations may exceed the number assumed in the Mark I program evaluation

during the period of extended operation (520 estimated versus 500 used in the evaluation). On

the basis of the applicant's statement that most of the fatigue usage is due to the DBA loading,

the staff concludes that additional SRV actions during the period of extended operation will not

have a significant impact on the controlling usage factor for the vent header system. Therefore,

the staff found that the applicant has demonstrated that the vent header system analysis

remains valid for the period of extended operation in accordance with the requirements of

10 CFR 54.21(c)(1)(i).

The applicant indicated that the fatigue usage for the torus shell was insignificant. The applicant

provided 60-year CUF values for the limiting locations on the torus shell. The applicant

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increased the fatigue usage resulting from normal operations by a factor of 1.5 to account for

the period of extended operation. The maximum 60-year CUF is less than 0.1. The staff

concludes that the applicant performed an adequate evaluation to demonstrate that the fatigue

usage will not exceed its allowable limit during the period of extended operation. Therefore, the

staff found that the applicant has projected the torus shell analysis for the period of extended

operation in accordance with the requirements of 10 CFR 54.21(c)(1)(ii).

4.6.1.3 UFSAR Supplement

The applicant provided a UFSAR supplement summary description of its TLAA evaluation of the

torus shell and vent system fatigue analysis in ALRA Section A1.2.4.1. On the basis of its

review of the UFSAR supplement, the staff concludes that the summary description of the

applicant's actions to address the torus shell and vent system fatigue analysis is adequate.

4.6.1.4 Conclusion

On the basis of its review, as discussed above, the staff concludes that there is reasonable

assurance that the applicant had demonstrated, pursuant to 10 CFR 54.21(c)(1)(i), regarding

the vent header system fatigue analysis TLAA, that the analyses remain valid for the period of

extended operation. The applicant has also provided an acceptable demonstration, pursuant to

10 CFR 54.21 (c)(1)(ii), regarding the torus shell, that the analyses have been projected to the

end of the period of extended operation. The staff also concludes that the UFSAR supplement

contains an appropriate summary description of the vent header system fatigue analysis TLAA

evaluation for the period of extended operation, as required by 10 CFR 54.21(d).

4.6.2 Torus Attached Piping Analysis (NMP1 Only)

4.6.2.1 Summary of Technical Information in the Amended Application

The applicant discussed the NMP1 torus attached piping (TAP) fatigue evaluation in ALRA

Section 4.6.2. The applicant indicated that fatigue analysis of TAP was performed as part of the

generic Mark I Containment Program. The applicant indicated that the bounding CUF was less

than 0.5 for the plant design life; therefore, the CUF would remain less than 1.0 for the period of

extended operation. The applicant stated that the generic analysis considered SRV actuations,

operating basis earthquakes, and accident conditions. The applicant indicated that the number

of SRV actuations assumed for the analysis may be exceeded during the period of extended

operation. The applicant committed to monitor the number of SRV actuations with the NMPNS

FMP. The applicant concluded that the TAP fatigue analysis will be managed by the FMP

during the period of extended operation in accordance with 10 CFR 54.21(c)(1)(iii).

4.6.2.2 Staff Evaluation

The staff s review of the original LRA Section 4.6.2 identified an area in which additional

information was necessary to complete the review of the torus attached piping analysis. The

applicant responded to the staff's RAI as discussed below.

In RAI 4.6.2-1, dated November 10, 2004, the staff stated that the applicant indicated that the

existing fatigue usage factors for the NMP1 TAP are less than 0.5 and that, therefore, the

fatigue usage factors will remain less than 1.0 for 60 years of plant operation. The staff

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requested that the applicant identify the location containing the bounding fatigue usage for the

TAP and that the applicant list the design transients, including the number used in the fatigue

analysis and associated fatigue usage, for this bounding location. In addition, the staff

requested that the applicant provide the number of these design transients that have been

experienced since initial plant operation.

In its response, by letter dated December 6, 2004, the applicant indicated that a bounding

analysis of TAP applicable to all BWRs was documented in MPR-751, "Augmented Class 2/3

Fatigue Evaluation Method and Results for Typical Torus Attached and SRV Piping Systems,"

November 1982. The applicant indicated that two NMP1 piping systems were included in the

evaluation. The applicant reported relatively low 40-year CUFs (< 0.1) for these two systems.

The applicant stated that a conservative extrapolation of the CUFs to 60 years still yields a

relatively low CUF.

The above response did not explain why the estimated fatigue usage for NMP1 TAP is

conservative given that the number of past SRV actions is unknown, Therefore, in a follow-up to

RAI 4.6.2-1, dated February 22, 2005, the staff requested that the applicant explain why the

number of design transients have been experienced and why the number assumed in the

fatigue evaluation is bounding given that SRV actuations have not been tracked.

The applicant's July 14, 2005, response and revised ALRA provided additional TAP details. The

TAP was designed for SRV actuations, operating basis earthquakes, and accident conditions.

The applicant's FMP did not monitor the number of past SRV actuations. The applicant

reviewed records pertaining to SRV actuations to estimate the number of past actuations. On

the basis of its estimation of past SRV actuations, the applicant indicated that the projected

number of SRV actuations may exceed the number assumed in the TAP fatigue analysis during

the period of extended operation (520 estimated versus 500 used in the evaluation). The

applicant indicated that the FMP will monitor the number of SRV actuations during the period of

extended operation to ensure that the fatigue usage of the TAP remains within its design limits.

The staff found that the applicant's FMP, which tracks the number of SRV actuations, will

adequately manage the fatigue usage of the TAP during the period of extended operation in

accordance with 10 CFR 54.21(c)(1)(iii). Therefore, the staff's concern described in RAI 4.6.2-1

is resolved.

4.6.2.3 UFSAR Supplement

The applicant provided a UFSAR supplement summary description of its TLAA evaluation of the

TAP analysis in ALRA Section A1.2.4.2. On the basis of its review of the UFSAR supplement,

the staff concludes that the summary description of the applicant's actions to address the TAP

analysis is adequate.

4.6.2.4 Conclusion

On the basis of its review, as discussed above, the staff concludes that there is reasonable

assurance that the applicant had demonstrated, pursuant to 10 CFR 54.21(c)(1)(iii), regarding

the TAP analysis TLAA, that the effects of aging on the intended function(s) will be adequately

managed for the period of extended operation. The staff also concludes that the UFSAR

supplement contains an appropriate summary description of the TAP analysis evaluation for the

period of extended operation, as required by 10 CFR 54.21 (d).

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4.6.3 Torus Wall Thickness (NMPI Only)

4.6.3.1 Summary of Technical Information in the Amended Application

In ALRA Section 4.6.3, the applicant discussed the corrosion allowance for the NMP1 torus wall

thickness. The NMP1 torus suppression chamber is constructed of Grade B steel plates with a

certified minimum thickness of 0.460 inches. The original corrosion allowance of 0.0625 inches

was reduced based on the addition of hydrodynamic loads resulting from LOCA and SRV

actuation. The revised minimum wall thickness is 0.431 inches. NMP1 is required to monitor the

torus wall thickness and corrosion rate in order to establish reasonable assurance that the

minimum wall thickness is not reached. The applicant indicated that the NMP1 Torus Corrosion

Monitoring Program monitors the torus shell thickness to ensure that it is maintained within

acceptable limits. The applicant stated that the effects of loss of material on the intended

function(s) of the torus shell will be adequately managed in accordance with

10 CFR 54.21(c)(1)(iii).

4.6.3.2 Staff Evaluation

The NMP1 Torus Corrosion Monitoring Program has been developed to monitor the torus shell

material thickness and ensure it is maintained within acceptable limits. This program is based

on a commitment to periodically monitor torus condition as described in an NRC SE dated

August 11, 1994 (reference 4.8-63 in the ALRA). The corrosion monitoring activity included in

this TLAA is completed through the Torus Corrosion Monitoring Program described in ALRA

Section B3.3. The staff found that the Torus Corrosion Monitoring Program will adequately

manage the aging effects such that the intended function(s) of the torus shell and support

structure will be maintained consistent with the CLB for the period of extended operation. The

staff evaluation of the Torus Corrosion Monitoring Program is contained in SER

Section 3.0.3.3.7

4.6.3.3 UFSAR Supplement

The applicant provided a UFSAR supplement summary description of its TLAA evaluation of the

torus wall thickness in ALRA Section A1.2.4.3. On the basis of its review of the UFSAR

supplement, the staff concludes that the summary description of the applicant's actions to

address the torus wall thickness is adequate.

4.6.3.4 Conclusion

On the basis of its review, as discussed above, the staff concludes that there is reasonable

assurance that the applicant had demonstrated, pursuant to 10 CFR 54.21(c)(1)(iii), regarding

the torus wall thickness TLAA, that the effects of aging on the intended function(s) will be

adequately managed for the period of extended operation. The staff also concludes that the

UFSAR supplement contains an appropriate summary description of the torus wall thickness

TLAA evaluation for the period of extended operation, as required by 10 CFR 54.21(d).

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4.6.4 Containment Liner Analysis (NMP2 Only)

4.6.4.1 Summary of Technical Information in the Amended Application

The applicant discussed the NMP2 containment liner analysis in ALRA Section 4.6.4. The

applicant indicated that the fatigue analysis of the NMP2 containment liner was performed in

accordance with ASME Section III. The applicant projected the fatigue analysis of the liner to

the end of the period of extended operation in accordance with 10 CFR 54.21(c)(1)(ii).

4.6.4.2 Staff Evaluation

The staffs review of the original LRA Section 4.6.4 identified an area in which additional

information was necessary to complete the review of the containment liner analysis. The staff's

RAI and the applicant's response thereto are discussed below.

RAI 4.6.4-1, dated November 10, 2004, stated that the original LRA Section 4.6.4 stated that a

revised analysis performed prior to the period of extended operation would demonstrate that the

60-year CUF values for all controlling locations would remain less than 1.0. The staff requested

that the applicant provide the current design CUF values for the controlling containment liner

locations. The staff also requested that the applicant explain the basis for the statement that the

revised analysis would demonstrate that the 60-year CUF values for all controlling locations

would remain less than 1.0, given that the revised analysis had not been completed.

In its response, by letter dated December 6, 2004, the applicant indicated that SRV actuation is

the primary contributor to fatigue usage of the containment liner. The applicant indicated that

SRV actuations are occurring at a much slower rate than assumed in the liner analysis. The

applicant multiplied the 40-year CUF by 1.5 to obtain an estimate for 60 years of plant

operation. The projected CUF is well below the allowable limit of 1.0. The ALRA reflects this

evaluation. The staff found the applicant's evaluation conservative since the SRV actuations are

occurring at a much lower rate than was assumed in the liner fatigue evaluation. The staff found

that the applicant had projected the containment liner analysis for the period of extended

operation in accordance with the requirements of 10 CFR 54.21 (c)(1)(ii). Therefore, the staff's

concern described in RAI 4.6.4-1 is resolved.

4.6.4.3 USAR Supplement

The applicant provided a USAR supplement summary description of its TLAA evaluation of

containment liner analysis in ALRA Section A2.2.4.1. On the basis of its review of the USAR

supplement, the staff concludes that the summary description of the applicant's actions to

address the containment liner analyses is adequate.

4.6.4.4 Conclusion

On the basis of its review, as discussed above, the staff concludes that there is reasonable

assurance that the applicant had demonstrated, pursuant to 10 CFR 54.21(c)(1)(ii), regarding

the containment liner analyses TLAA, that the analyses have been projected to the end of the

period of extended operation. The staff also concludes that the USAR supplement contains an

appropriate summary description of the containment liner analyses TLAA evaluation for the

period of extended operation, as required by 10 CFR 54.21(d).

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4.6.5 Fatigue of Primary Containment Penetrations

4.6.5.1 Summary of Technical Information in the Amended Application

The applicant discussed the evaluation of the primary containment penetrations in ALRA

Section 4.6.5. The applicant indicated that the NMP1 drywell was designed as a Class B vessel

in accordance with ASME Code, Section III, 1965 Edition. Therefore, a fatigue analysis of the

drywell and its penetrations was not required. However, the NMP1 TAP penetrations were

evaluated for fatigue as part of the Mark 1 Containment Program. The applicant projected the

NMP1 TAP penetration fatigue analysis to the end of the period of extended operation in

accordance with 10 CFR 54.21(c)(1)(ii).

The applicant indicated that the ASME Class 1 and Class MC portions of the NMP2

penetrations were evaluated for fatigue. The applicant identified bounding penetration fatigue

locations in ALRA Table 4.6-4. The applicant indicated that the fatigue usage of these locations

would be managed by the NMPNS FMP. The applicant stated that fatigue of the NMP2 primary

containment penetrations would be adequately managed for the period of extended operation in

accordance with 10 CFR 54.21 (c)(1)(iii).

4.6.5.2 Staff Evaluation

The applicant indicated that the Mark I containment PUAR did not report a fatigue usage factor

for the NMP1 TAP penetrations. The PUAR contained an assessment of the bounding TAP

locations and concludes the penetrations were acceptable for fatigue. Since the PUAR did not

report the fatigue usage factors, the applicant estimated the fatigue usage for these

penetrations using loads and stress cycles reported in the PUAR. The resulting fatigue usages

were well within the allowable limit of 1.0. The applicant then estimated the 60year fatigue

.usage for the TAP penetrations by multiplying the calculated 40-year fatigue usage by 1.5. The

staff concludes that the applicant performed an adequate evaluation to demonstrate that the

fatigue usage would not exceed its allowable limit during the period of extended operation.

Therefore, the staff found that the applicant had projected the PUAR torus penetration analysis

for the period of extended operation in accordance with the requirements of

10 CFR 54.21 (c)(1)(ii).

The applicant's December 20,2005, submittal identified that additional fatigue analyses had

been performed for 26 TAPs. The applicant indicated that the fatigue analyses assumed 10,000

stress cycles at the maximum stress level to account for all loading conditions. The applicant

stated that the stresses caused by the SRV actuations were only a fraction of the maximum

stress that was used for the fatigue evaluation. The applicant then stated that the TAP fatigue

evaluations remain valid for the period of extended operation. The staff agreed with the

applicant's conclusion that a small increase in the number of SRV actuations during the period

of extended operation would not have a significant impact on the fatigue usage of the TAPs if

the actual stresses caused by the SRV actuations was only a fraction of the total stress used

for the evaluation. On the basis of the applicant's assertion that the stresses due to the SRV

actuations are only a fraction of the maximum stress that was used in the fatigue evaluation,

the staff found that the applicant has adequately demonstrated that the analyses remain valid

for the period of extended operation in accordance with the requirements of

10 CFR 54.21(c)(1)(i).

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The applicant indicated that the NMP2 Class 1 and Class MC penetration assemblies were

evaluated for fatigue. The applicant indicated that the fatigue usage for the majority of the

penetration assemblies was bounded by the attached piping. The bounding piping locations are

monitored by the NMPNS FMP. The applicant identified six penetrations, in ALRA Table 4.6-4,

that were not bounded by the attached piping. The applicant indicated that these penetrations

would be monitored by the NMPNS FMP. The staff found that the applicant's FMP, which tracks

the number of expected thermal transient cycles, will adequately manage the fatigue of the

NMP2 containment penetrations during the period of extended operation in accordance with

10 CFR 54.21(c)(1)(iii).

4.6.5.3 UFSAR and USAR Supplements

The applicant provided UFSAR and USAR supplement summary descriptions of its TLAA

evaluation of fatigue of primary containment penetrations in ALRA Sections A1.2.4.4 and

A2.2.4.2, respectively. On the basis of its review of the UFSAR and USAR supplements, the

staff concludes that the summary descriptions of the applicant's actions to address the fatigue

of primary containment penetrations are adequate.

4.6.5.4 Conclusion

On the basis of its review, as discussed above, the staff concludes that there is reasonable

assurance that the applicant had demonstrated, pursuant to 10 CFR 54.21(c)(1)(i) and

10 CFR 54.21 (c)(1)(ii), regarding the fatigue of the NMP1 primary containment penetrations

TLAA, that the analyses either would remain valid for the period of extended operation or had

been projected to the end of the period of extended operation. The applicant has also provided

an acceptable demonstration, pursuant to 10 CFR 54.21(c)(1)(iii), that the effects of aging on

the intended function(s) of the NMP2 primary containment penetrations will be adequately

managed for the period of extended operation. The staff also concludes that the UFSAR and

USAR supplements contain appropriate summary descriptions of the NMP1 primary

containment penetrations evaluation for the period of extended operation, as required by

10 CFR 54.21(d).

4.6.6 Downcomer and Safetylrelief Valve Discharge Line Fatigue Evaluation (NMP2 Only)

4.6.6.1 Summary of Technical Information in the Amended Application

In its annual update date December 20, 2005, the applicant discussed the evaluation of the

NMP2 downcomer and safety/relief valve discharge lines in ALRA Section 4.6.6. The NMP2

downcomers consists of 121 pipes open to the drywell and submerged 9.5 ft below the low

water level (operating minimum) of the suppression pool, providing a flow path for uncondensed

steam into the pool. A fatigue analysis using ASME Section III Class 1 rules was performed for

the downcomers. The applicant projected the analysis of the NMP2 downcomers to the end of

the period of extended operation in accordance with the requirements of 10 CFR 54.21 (c)(1)(ii)

The applicant also discussed the fatigue evaluation of the SRV line penetrations. The applicant

indicated that 18 SRV lines penetrate the drywell floor via flued head type penetrations. A

fatigue analysis of these penetrations was performed using ASME Section III Class I rules. The

applicant estimated that the fatigue usage would remain below 1.0 during the period of

extended operation. Since the estimated usage was only slightly less than the allowable limit of

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1.0, the applicant committed to perform additional analysis to remove excess conservatism, or

monitor the fatigue usage of the penetrations using the FMP.

4.6.6.2 Staff Evaluation

The applicant indicated that the downcomers were analyzed for a number of load conditions

that included plant upset conditions in combination with various pipe breaks. The plant upset

loads include SRV actuations. The applicant multiplied the fatigue usage due to the plant upset

loads by a factor of 1.5 to project the fatigue usage to the end of the period of extended

operation. The applicant then added this projected upset fatigue usage to the largest fatigue

usage obtained from the pipe break loading conditions. The resulting fatigue usage was well

below the allowable limit of 1.0. The staff found that the applicant adequately projected the

fatigue analysis of the NMP2 downcomers to the end of the period of extended operation by

increasing the fatigue usage of those events that are expected to occur more than once in the

life of the plant by a factor of 1.5.

The applicant indicated that the SRV penetration analysis included both upset and pipe break

loads. The upset loads include SRV actuations. The applicant multiplied the fatigue usage due

to the upset loads by a factor of 1.5 to project the fatigue usage to the end of the period of

extended operation. The applicant then added this projected upset fatigue usage to the fatigue

usage obtained from the pipe break loading conditions. The resulting fatigue usage was below

the allowable limit of 1.0. Even though the projected fatigue usage is less than the allowable

limit, the applicant committed to either perform further analysis to remove excess conservatism

in the calculated fatigue usage factor, or implement fatigue monitoring of the SRV penetrations

prior to the period of extended operation. The staff found the applicant's approach to either

perform additional analysis or institute fatigue monitoring prior to the period of extended

operation acceptable alternatives to manage the fatigue usage of the SRV penetrations.

4.6.6.3 USAR Supplement

The applicant provided a USAR supplement summary description of its TLAA evaluation of the

torus attached piping analysis in ALRA Section A2.2.4.3. On the basis of its review of the USAR

supplement, the staff concludes that the summary description of the applicant's actions to

address the torus attached piping analysis is adequate.

4.6.6.4 Conclusion

On the basis of its review, as discussed above, the staff concludes that there is reasonable

assurance that the applicant had demonstrated, pursuant to 10 CFR 54.21(c)(1)(ii), that for the

NMP2 downcomer analyses have been projected to the end of the period of extended

operation. The staff concludes that the applicant has provided an acceptable demonstration,

pursuant to 10 CFR 54.21(c)(1)(iii), regarding the SRV discharge line fatigue analysis, that the

effects of aging on the intended function(s) will be adequately managed for the period of

extended operation. The staff also concludes that the USAR supplement contains an

appropriate summary description of this TLAA evaluation, sufficient to satisfy the requirements

of 10 CFR 54.21(d).

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4.7 Other Plant-Specific TLAAs

In ALRA Section 4.7, the applicant provided its evaluation of plant-specific TLAAs. The TLAAs

evaluated include the following:

* RPV biological shield (NMP2 only)

* main steam isolation valve corrosion allowance (NMP2 only)

* stress relaxation of core plate hold-down bolts (NMP2 only)

* reactor vessel and reactor vessel closure head weld flaw evaluations (NMP1 only)

4.7.1 RPV Biological Shield (NMP2 Only)

4.7.1.1 Summary of Technical Information in the Application

In ALRA Section 4.7.1, the applicant identified the fracture mechanics analysis (FMA)

for the biological shield wall (BSW) at Nine Mile Point Nuclear Station, Unit 2 (NMP2) as

a TLAA that meets the definition for a TLAA in 10 CFR 54.3.

The accumulation of high energy neutrons on nuclear reactor materials is a timedependent parameter. Inspections of the biological shield wall performed by the

applicant revealed the presence of weld fabrication defects (cracks) in the BSW's

ferritic steel shell. The applicant performed a dynamic crack growth FMA of the defects

to determine whether the BSW was acceptable for continued service or whether the

cracks would require repair. The results of the FMA demonstrated that the majority of

the flaws were acceptable, although a small number of flaws were unacceptable and

subsequently repaired by the applicant. A supporting calculation was performed to

estimate the amount of neutron fluence exposure to the BSW's cylindrical shells and to

re-evaluate the conclusions of the original FMA for flaws left in service using the

estimated neutron fluence exposure. Since the acceptability of the FMA is dependent

on the accumulated neutron fluence dose exposure, the applicant concluded that the

FMA was a TLAA for the NMP2 ALRA.

The staff reviewed ALRA NMP2 Section 4.7.1, and by letter dated December 23, 2005,

the staff requested additional information in aRAI 4.7.1B-1 regarding the applicant's

calculation methodology. The applicant provided its response by letters dated

January 11, 2006, as supplemented by letter dated March 23, 2006, and in a docketed

email response dated March 29, 2006. These submittals provide information to support

the conclusion that ALRA Sections 4.7.1 and A.2.2.5.1 could be deleted from the NMP2

ALRA. The staff evaluated these submittals and the applicant's basis for deleting

Sections 4.7.1 and A.2.2.5.1 from the ALRA in Sections 4.7.1.2 and 4.7.1.3 of this SER.

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4.7.1.2 Staff Evaluation

The applicant's original FMA was docketed in a letter from Niagara Mohawk Power

Corporation (NMPC)1 to NRC's Region I Office dated August 1, 1980. The FMA was

based on the evaluation of dynamic loading on a limiting 0.215 inch.flaw in the BSW.

The applicant calculated that the dynamic stress intensity factor (K,) was 33.2 ksi(in)0-5

for the limiting flaw. The staff reviewed the applicant's FMA and concluded that the

applicant had conservatively demonstrated that K, was less than the dynamic fracture

toughness criterion (KID) of 48.8 ksi(in)r 5, as based on a Charpy-V (Cv) impact energy

of 20 ft-lb for the structural steel. Thus, the staff concurs with the applicant that the

original FMA demonstrated that the limiting flaw in the BSW was structurally stable for

the remainder of the current operating term.

However, since the K10 value was based on a C, impact energy of 20 ft-lb and since C,

impact energies may decrease with increasing neutron fluence exposure, the applicant

concluded that the effects of increasing neutron fluence in the BSW over a 60-year

licensed life (i.e., through 54 EFPY) must be assessed for its impact relative to the

original FMA. Thus, the staff concludes that the applicant made a conservative

conclusion in identifying that the fracture mechanics evaluation for the BSW was a

TLAA for NMP2 as stated in the ALRA. Neutron irradiation embrittlement can reduce

the fracture toughness of ferritic steels (i.e., carbon steel or low alloy steel materials).

Typically, the staff assesses neutron irradiation embrittlement in ferritic steel materials

based on the accumulated fluence exposure of the materials to high energy neutrons

(E > 1.0 MeV). The staff has established, in 10 CFR Part 50, Appendix H, a neutron

fluence value of 1 x 1017 n/cm2 (E > 1.0 MeV) as its threshold for considering neutron

irradiation embrittlement in ferritic steel materials.

The applicant estimated that the neutron fluence of the BSW inside cylinder surface will

be 2.54 x 10'" n/cm2 (E > 1.0 MeV) at 54 EFPY. This value is greater than the staff's

threshold for considering neutron irradiation embrittlement in ferritic steel materials.

Therefore, the applicant used an alternate approach to demonstrate that a neutron

fluence exposure of 2.54 x 1017 n/cm2 (E > 1.0 MeV) would not invalidate the original

FMA. The applicant stated that more recent low-temperature irradiation data for the

structural carbon steels from the Shippingport neutron shield (SNS) tank and high flux

isotope reactor (HFIR) vessel provide a more accurate estimation of embrittlement for

the BSW (Refer to SANDIA Report SAND 92-2420, "Accelerated 54 °C Irradiated Test

of Shippingport Neutron Shield Tank and HFIR Vessel Materials," dated January 1993).

The SANDIA report provides the 30 ft-lb Cv impact test results for ferritic steel test

specimens taken from the SNS tank and HFIR vessel. The test specimens were

irradiated to a neutron fluence exposure of 5.07 x 1017 n/cm 2 (E > 1.0 MeV) at a

controlled test temperature of 130°F prior to Cv impact testing.

1. The owner of Nine Mile Point Nuclear Station prior to its acquisition by

Constellation Energy.

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The SANDIA results projected a maximum shift (increase) of 35 OF in the 30 ft-lb

reference transition temperature for the test specimens and a reduction of

approximately 6 ft-lb in the upper shelf energy (USE) value. The applicant concluded

that, since the projected fluence for the NMP2 BSW is less than the value used in the

SANDIA Report, it would be justified to use the SANDIA results as a basis for reestimating the projected neutron fluence exposure on the BSW through 54 EFPY.

The staff determined that the methodology in SANDIA Report is not an NRC-approved

methodology. Therefore the staff issued aRAI 4.7.1 B-1, dated December 23, 2005, and

requested that the applicant provide an updated neutron fluence calculation for the

BSW, using NRC-approved neutron fluence methodology, to ensure that conclusions of

the original FMA remain valid for the period of extended operation. As an alternative,

the staff stated that the applicant could place a commitment in the NMP2 ALRA to

submit an updated neutron fluence calculation for the BSW for the staff s review and

approval at least two years prior to entering the period of extended operation.

In its response, to aRAI 4.7.1 B-1, by letter dated January 11, 2006, the applicant

stated:

NMPNS will perform a fluence analysis for the period of extended

operation (PEO) using plant specific methodology that is consistent

with Reg. Guide 1.190. This methodology has been approved by the

NRC as part of the NMP1 and NMP2 Pressure-Temperature Curve

analysis review. The fluence analysis will establish whether or not the

maximum fluence at the Biological Shield Wall or the fluence at the

shield wall flaws, on which the ALRA Section 4.7.1 is based, is below

the threshold value above which neutron embrittlement is considered

to be an issue (1017 n/cm2 ). NMPNS will submit the summary of this

analysis to the NRC for review and approval not later than two years

prior to entry into the PEO. Based on the results of this analysis, the

submittal will also include revised ALRA Sections 4.7.1 and A.2.2.5.1,

and any other supporting analysis, as applicable.

The applicant's original fluence value for the BSW was based on calculations carried

out using the two-dimensional discrete ordinates transport (DOT) code that had been

approved for the Nine Mile Point, Units 1 and 2 (NMPI/2). However, the staff concluded

that the DOT code was qualified only for neutron fluences up to and inclusive of

fluences of the NMPI/2 reactor vessels (RVs), and that application of the DOT code to

the BSW is outside the range of the code's qualification. In a conference call held with

the applicant dated January 23, 2006, the staff informed the applicant of this conclusion

on the DOT code and reiterated its request that a supplemental neutron fluence

calculation be submitted for the BSW. This was designated as Open Item 4.7B.1-1 in

the staff SER with Open Items which was issued on March 3, 2006.

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In the applicant's supplemental letter of March 23, 2006, the applicant stated that it had

performed an updated neutron fluence calculation for the BSW and that the revised

neutron fluence value for the BSW was 6.2 x 1016 n/cm2 (E > 1.0 MeV) at 54 EFPY.

This fluence is less than the NRC's threshold value for considering neutron-irradiation

embrittlement in ferritic steel materials.

The applicant further stated in the letter that: (1) neutron irradiation embrittlement is not

an issue for the BSW at NMP2, and (2) the dynamic FMA for the BSW does not need

to be treated as a TLAA for the NMP2 LRA. Based on the result of their new

calculation, the applicant proposed, in the March 23, 2006 letter, to delete TLAA

Section 4.7.1, "RPV Biological Shield (NMP2 Only)," and its USAR Supplement

summary description A.2.2.5.1 from the NMP2 LRA.

In a later communication email dated March 29, 2006, the applicant provided

supplemental information on its neutron fluence methodology to support the updated

neutron fluence value of 6.2 x 1016 n/cm2 (E > 1.0 MeV) for the BWS, as assessed

through 54 EFPY. Taken together, the supplementary information clarified that there is

significant neutron leakage in the axial as well in the azimuthal directions. The

azimuthal leakage reduces the peak neutron fluences and the axial leakage reduces

the total number of neutrons. Consequently, the total number of neutron reaching the

BSW was determined to be smaller than the number of neutrons leaving the outside

surface of the NMP2 RV. The applicant indicated that the azimuthal leakage diminishes

the neutron fluence reaching the inside surface of the BSW (as measured relative to

those emerging from the RV outside surface) as an inverse function of the square of the

distance from the outside RV wall. The azimuthal leakage also reduces the difference

between the maximum and minimum fluences reaching the inside surface of the BSW.

This is caused by the presence of a void between the outside surface of the RV and the

inside surface of the BSW. A neutron scattering away from the radial direction would

have a very low chance of reaching the BSW if a scattering and absorbing medium was

present between the RV and BSW wall surfaces. However, since a void exists between

the wall surfaces, more neutrons would reach the inside surface of the BSW, thus

flattening out the energy distribution of neutrons reaching and absorbed by the inside

BSW wall. Therefore, the neutron fluence for the BSW has a more uniform distribution

and lower average value (6.2'x 10 16 n/cm2 [E > 1.0 MeV]) when compared to the

neutron fluence distribution and average neutron fluence value (1.02 x 1017 n/cm2 [E >

1.0 MeV]) for the outside RV wall surface.

Based on this assessment, the staff concludes that the applicant's revised neutron

fluence value of 6.2 x 1016 n/cm 2 (E > 1.0 MeV) for the BSW at 54 EFPY is acceptable.

The staff further concludes that the revised neutron fluence value supports the

conclusion that neutron irradiation embrittlement of the BSW will not be an issue for the

component during the period of extended operation because the value is less than the

staffs threshold of 1.0 x 101' n/cm2 (E > 1.0 MeV). Therefore, based on this

assessment, the staff concludes that the dynamic FMA for the BSW does not need to

be treated as a TLAA for the NMP2 LRA, and that Sections 4.7.1 and A.2.2.5.1 may be

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deleted from the NMP2 LRA. Therefore, Open Item 4.7B.1-1 identified in the staff

Safety Evaluation Report with Open Items, issued on March 3, 2006, is resolved and

closed.

4.7.1.3 USAR Supplement

The applicant's USAR supplement summary description of TLAA 4.7.1, "RPV Biological

Shield (NMP2 Only)" was provided in NMP2 ALRA Section A.2.2.5.1 and described the

applicant's methodology for re-evaluating the fracture toughness of the NMP2 BSW.

In the applicant's supplement responses to aRAI 4.7.1B-1 dated March 23 and

29, 2006, the applicant provided supplemental information to support the conclusion

that ALRA Sections 4.7.1and A2.2.5.1 could be deleted from the NMP2 ALRA. In SER

Section 4.7.1.2, the staff concluded that the applicant's supplemental responses to the

staff request aRAI 4.7.1 B-1, dated March 23 and 29, 2006, provided an acceptable

basis for the staff to conclude that (1) the neutron fluence value for the BSW at

54 EFPY was less than the staff's threshold value.(as provided in 10 CFR Part 50,

Appendix H) for considering neutron irradiation embrittlement in ferritic steel materials,

(2) the dynamic FMA for the biological shield did not need to be treated as a TLAA for

the NMP2 LRA, and (3) ALRA Sections 4.7.1 and A2.2.5.1, could be deleted from the

NMP2 ALRA. Based on the staff's assessment in SER Section 4.7.1, the staff

concludes that the applicant has provided an acceptable basis for deleting ALRA

Section A.2.2.5.1.

4.7.1.4 Conclusion

On the basis of its review, the staff found that the applicant has provided an acceptable

basis for concluding that the dynamic FMA for the BSW does not need to be treated as

a TLAA for the NMP2 ALRA and that ALRA Sections 4.7.1 and A.2.2.5.1 may be

deleted from the scope of the NMP2 ALRA.

4.7.2 Main Steam Isolation Valve Corrosion Allowance (NMP2 Only)

This TLAA applies only to NMP2. The NMP1 licensing basis did not specify a corrosion

allowance for the NMP1 main steam isolation valves (MSIVs). Therefore NMPNS did not

evaluate the NMP1 MSIV corrosion allowance as a TLAA. However, the NMP1 MSIVs are

evaluated under the NMP Flow-Accelerated Corrosion (FAC) Program and a

manufacturer-specified corrosion allowance has been applied to the NMP1 MSIVs to create

assurance that unacceptable wall thinning will either not occur or be detected and corrected in a

timely manner.

4.7.2.1 Summary of Technical Information in the Amended Application

The MSIV bodies were fabricated from low-alloy steel. During normal plant operation the MSIVs

are exposed to a dry steam environment; however, during refueling outages, they are exposed

to treated water and air. To support a 40-year service life in the environments described above,

a corrosion allowance of 0.120 inches was imposed in addition to the minimum MSIV wall

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thickness required by applicable codes. The calculation used to determine this corrosion

allowance is a TLAA.

Summing the predicted values for corrosion of the MSIVs in the treated water environment, the

air environment, and the steam environment results in a total loss in wall thickness of 0.0256

inches over 60 years.

4.7.2.2 Staff Evaluation

The predicted reduction in MSIV wall thickness is calculated based on the projected exposure

of the valve bodies to water, air, and dry steam environments for the period of extended

operation. Under normal plant operating conditions the MSIVs are exposed to a dry steam

environment. During RPV flood-up at the start of a refueling outage, the MSIVs are flooded

with treated water. For the remainder of the refueling outage the valves are exposed to an air

environment. In order to build conservatism into the corrosion calculation, the exposure times

of MSIVs to the water and air environments are doubled from the typical exposure times during

a refueling outage. The reduction of MSIV wall thickness caused by exposure to each

environment is calculated based on exposure time and the appropriate corrosion rate. The

applicant's calculation used the following corrosion rates and exposure times: 0.0033 inches per

year for 4.6 years of exposure to air, 0.0050 inches per year for 0.66 years of exposure to

treated water; and, 0.00013 inches per year for 54.7 years due to FAC.

In letters dated, January 14, 2005 and July 14, 2005, the applicant responded to staff RAls

4.7.2-1 and 4.7.2-2 regarding the flow accelerated corrosion calculations performed for the dry

steam environment. These RAls requested clarifying information about the applicant's

predictive model for FAC. The applicant's response indicated that the 0.00013 inches per year

corrosion rate is based on piping upstream of the MSIVs, as modeled by the FAC Program

predictive computer model (CHECWORKS). The upstream piping measurements are used for

the MSIVs because non-parallel inner and outer surfaces throughout the MSIV body, and

surface irregularities due to casting, make accurate and repeatable measurements of MSIV wall

thickness difficult. The NMP FAC Program is consistent with industry practice in that

representative components are periodically measured and trended to predict wear in the main

steam system. Thickness measurements of the main steam system piping components for

NMP1 and NMP2 were taken during the most recent refueling outage and did not identify any

significant wall thinning.

The amount of wall thinning based on maximum expected corrosion rates of MSIV bodies

remains bounded by the corrosion allowance assumed in the valve design. Based on the

applicant's conservative analysis of the predicted loss of material, the staff concludes that the

corrosion allowance identified, in conjunction with monitoring performed under the FAC

Program, will ensure MSIVs are capable of performing their intended function for 60 years of

operation.

4.7.2.3 USAR Supplement

The applicant provided a USAR supplement summary description of its TLAA evaluation of the

MSIV corrosion allowance in ALRA Section A2.2.5.2. On the basis of its review of the USAR

supplement, the staff concludes that the summary description of the applicant's actions to

address the MSIV corrosion allowance is adequate.

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4.7.2.4 Conclusion

On the basis of its review, as discussed above, the staff concludes that there is reasonable

assurance that the applicant had demonstrated, pursuant to 10 CFR 54.21(c)(1)(iii), regarding

the MSIV corrosion allowance TLAA, that the effects of aging on the intended function(s) will be

adequately managed for the period of extended operation. The staff also concludes that the

USAR supplement contains an appropriate summary description of the MSIV corrosion

allowance TLAA evaluation for the period of extended operation, as required by

10 CFR 54.21(d).

4.7.3 Stress Relaxation of Core Plate Hold-Down Bolts (NMP2 Only)

4.7.3.1 Summary of Technical Information in the Amended Application

In the original LRA Section 4.7.3, the applicant summarized the evaluation of stress relaxation

of core plate hold-down bolts for the period of extended operation. Hold-down bolts located

around the rim of the core plate are subcomponents of the core plate assembly that ensure the

core plate safety function. Preload in these bolts could be reduced over time by the effects of

intergranular stress corrosion cracking (IGSCC) and fluence; therefore, the staffs SE dated

December 7, 2000, determined that loss of preload should be evaluated as a potential TLAA. In

BWR/2 through BWR/5 RPV designs without core plate wedges installed, these bolts are

required to provide lateral restraint of the core plate in the event of a worst-case weld failure.

For plants with this configuration, BWRVIP-25 recommends visual or ultrasonic examination of

50 percent of the hold-down bolts. NMP1 has core plate wedges installed; therefore,

examination of the core plate hold-down bolts is not required. However, an analysis to justify

deferral of the recommended examination until refueling outage 10 (RFO10) for NMP2 satisfies

the criteria of 10 CFR 54.3(a); therefore, this analysis is a TLAA.

In its ALRA, the applicant provides the following analysis:

NMP2 has implemented all relevant BWRVIP-required inspections as

augmented inservice inspections in accordance with applicable ASME Code

requirements. The existing analysis of loss of preload in the NMP2 hold-down

bolts determined that sufficient preload remains to justify deferral of the

recommended examination until RFO10.

Disposition: 10 CFR 54.21(c)(1)(iii) - The effects of aging on the intended function(s)

will be adequately managed for the period of extended operation.

The subject analysis considered loss of preload caused by both IGSCC and fluence. A

review of the associated calculations and the design basis loads indicates the

following:

The predicted amount of stress relaxation due to IGSCC is insignificant through the

end of the period of extended operation.

When the effect of fluence through the period of extended operation is considered, the

remaining preload is sufficient to withstand all normal and upset condition loadings,

but insufficient to withstand the faulted condition loading. Even with no loss of preload

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due to fluence, the calculation showed very little margin between the initial preload and

the required preload under faulted conditions. The conclusion to the calculation

indicates that reconciliation is necessary in determining why so little margin exists

between required and applied preload.

Due to the difficulty encountered by the industry in performing the recommended

inspections, the BWRVIP is also pursuing an analytical solution to the issue of stress

relaxation of core plate hold-down bolts that may demonstrate sufficient remaining

preload to withstand all design loadings until the end of extended life.

The potential for cracking of components comprising the reactor vessel internals due

to IGSCC is managed by the BWR Vessel Internals Program at NMP2, which

incorporates comprehensive inspection and evaluation guidelines issued by the

BWRVIP and approved by the NRC. Prior to the end of the current license period,

NMP2 will either:

(1) install core plate wedges (as part of a proposed core shroud tie-rod repair) to

eliminate the need for the enhanced inspections of the core plate hold-down bolts as

recommended by BWRVIP-25; or

(2) perform an analysis (incorporating detailed flux/fluence analyses and improved

stress relaxation correlations) to demonstrate that the core plate hold-down bolts can

withstand all normal, emergency, and faulted loads considering the effects of stress

relaxation, until the end of the period of extended operation.

The applicant indicated further that these activities would provide assurance that any stress

relaxation of the NMP2 core plate hold-down bolts will be adequately managed for the period of

extended operation in accordance with 10 CFR 54.21 (c)(1)(iii).

4.7.3.2 Staff Evaluation

Per 10 CFR 54.21(c)(1), applicants for license renewal must demonstrate that TLAAs for

license renewal have been projected through the end of the period of extended operation for

their facilities, remain valid for the period of extended operation, or demonstrate that the effects

of aging that are applicable to the components evaluated by the TLAAs will be managed during

the period of extended operation.

The staffs review of the original LRA Section 4.7.3 identified an area in which additional

information was necessary to complete the review of the stress relaxation of core plate

hold-down bolts.

In an RAI regarding "Part II - Core Plant Hold-Down Bolts (Unit 2)," dated November 22, 2005,

the staff requested additional information from the applicant as relevant to its commitment for

submitting the analysis on the core plate hold-down bolts to the staff for review and approval. In

its response, by letter dated December 5, 2005, the applicant included in its commitment that

the analysis would be submitted for staff review and approval two years prior to entering the

license renewal period.

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The applicant's commitment regarding the core plate hold-down bolts, as stated in Appendix A

of the ALRA and supplemented by letter dated December 5, 2005, is that NMPNS will either: (1)

install core plate wedges (as part of a proposed core shroud tie-rod repair) to eliminate the

need for the enhanced inspections of the core plate hold-down bolts recommended by

BWRVIP-25; or (2) two years prior to entering the period of extended operation, submit an

analysis that incorporates detailed flux/fluence analyses and improved stress relaxation

correlations, in accordance with BWRVIP-25, to demonstrate that the core plate hold-down

bolts and the core plate can withstand all normal, emergency, and faulted loads and effects of

stress relaxation for the period of extended operation. This is Commitment No. 12 in the NMP2

ALRA, as amended in the December 5, 2005, letter from the applicant.

Therefore, based on the review of the ALRA and the applicant's response to the above RAI

Part II, the staff found that the applicant's commitment would provide assurance that any stress

relaxation of the NMP2 core plate hold-down bolts would be adequately managed for the period

of extended operation in accordance with 10 CFR 54.21(c)(1)(iii). Therefore, the staff's concern

described in RAI Part II is resolved.

4.7.3.3 USAR Supplement

The applicant provided a USAR supplement summary description of its TLAA evaluation of

stress relaxation of core plate hold-down bolts in ALRA Section A2.2.5.3 and it was

supplemented by letter dated December 5, 2005. On the basis of its review of the USAR

supplement, and as supplemented by letter dated December 5, 2005, the staff concludes that

the summary description of the applicant's actions to address stress relaxation of core plate

hold-down bolts is adequate.

In addition, by letter dated December 5, 2005, the applicant provided a revised Commitment

No. 12 in Table A2.4 of the NMP2 ALRA, which is identified below:

NMPNS will either: (1) install core plate wedges (as part of a proposed core shroud

tie-rod repair) to eliminate the need for the enhanced inspections of the core plate

hold-down bolts recommended by BWRVIP-25; or (2) perform an analysis

(incorporating detailed flux/fluence analyses and improved stress relaxation

correlations) in accordance to BWRVIP-25 to demonstrate that the core plate

hold-down bolts and the core plate can withstand all normal, emergency, and faulted

loads and effects of stress relaxation for the period of extended operation, and submit

it for staff review and approval 2 years prior to entering the period of extended

operation.

The staff finds that the applicant has adequately included its commitment regarding the core

plate hold-down bolts in Table A2.4 of the NMP2 ALRA and, therefore concludes that the USAR

supplement contains an appropriate summary description of Commitment No. 12 for NMP2.

4.7.3.4 Conclusion

On the basis of its review, as discussed above, the staff concludes that there is reasonable

assurance that the applicant had demonstrated, pursuant to 10 CFR 54.21(c)(1)(iii), regarding

stress relaxation of the core plate hold-down bolts TLAA, that the effects of aging on the

intended function(s) would be adequately managed for the period of extended operation. The

staff also concludes that the USAR supplement contains an appropriate summary description of

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the core plate hold-down bolts TLAA evaluation for the period of extended operation, as

required by 10 CFR 54.21(d).

4.7.4 Reactor Vessel and Reactor Vessel Closure Head Weld Flaw Evaluations

(NMP1 Only)

4.7.4.1 Summary of Technical Information in the Amended Application

In ALRA Section 4.7.4, the applicant summarized the evaluation of the reactor vessel and

reactor vessel closure head weld flaw evaluations for the period of extended operation. During

RF015, augmented examinations identified unacceptable flaw indications in two RPV shell

welds, as indicated in NMPC's letter dated September 14, 1999. During RFO17, UT

examinations identified an unacceptable flaw indication in a closure head meridional weld, as

stated in NMPC's letter dated September 19, 2003. Structural evaluations for these flaws

(performed in accordance with ASME Section Xl, Subsection IWB-3600) indicated that the flaw

characteristics are within the pre-determined acceptability criteria to justify continued operation

without repair of the flaw. Since the acceptability criteria were applicable only through the

original 40-year license term, the subject evaluations satisfy the criteria of 10 CFR 54.3(a). As

such, these analyses are TLAAs.

In its ALRA, the applicant provides the following analysis:

Unacceptable indications in the RPV shell are located in axial weld RVWD-140 and

shell-to-flange circumferential weld RVWD-099. The detected flaws are subsurface

planar flaws located parallel to the centerline of the weld (i.e., the indications in

RVWD-140 were axially-oriented and the indications in RVWD-099 were

circumferentially-oriented). The flaw evaluations considered fatigue crack growth and

irradiation embrittlement (only applicable for the beltline weld, RVWD-140) to 28

EFPY, as indicated in NMPC's letter dated September 14, 1999. The NRC reviewed

the original evaluations and concurred that continued operation with these flaws is

acceptable through 28 EFPY, the end of the current license term, as stated in the

NRC SE dated May 5, 2000. In 2002, these evaluations were reconciled to the

pressure test conditions associated with the updated P-T limit curves; the previously

detected flaws remain acceptable when compared to the updated (lower) allowable

flaw sizes at 28 EFPY.

The unacceptable indication in the closure head is located in weld RVWD-005 and

characterized as a subsurface planar flaw. The flaw evaluation, as described in

NMPC's letter dated September 19, 2003, considered fatigue crack growth due to 240

startup/shutdown cycles (the number of design startup/shutdown cycles for the original

40-year operating term) and determined the flaw to be acceptable for continued

service.

Disposition:

The number of cycles from the time of inspection to the end of the evaluation period is

used to determine crack growth as discussed in NMPC's September 19, 2003. With

the addition of the period of extended operation (20 years), the NMPI RPV can be

expected to accumulate fatigue usage for no more than 25 additional years. During

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this interval, it is unlikely that 240 startup/shutdown cycles will occur. Therefore, the

RPV closure head weld flaw evaluation remains valid for the period of extended

operation in accordance with 10 CFR 54.21(c)(1)(i).

Evaluation, re-examination, and repairs associated with identified flaw indications are

controlled under the NMP1 ASME Inservice Inspection (Subsections IWB, IWC, IWD)

Program, which manages aging of all Class 1, 2, and 3 pressure-retaining

components and their integral attachments. Prior to the period of extended operation,

the RPV weld flaw calculations will be revised to consider additional fatigue crack

growth and the effects of additional irradiation embrittlement for beitline materials

associated with operation for an additional 20 years (i.e., out to at least 46 EFPY). If

the revised calculation shows the identified flaws cannot meet the applicable

acceptance criteria, the indications will be re-examined in accordance with ASME

Section Xl requirements. These activities provide assurance that the potential growth

of identified flaws in the RPV welds will be adequately managed for the period of

extended operation in accordance with 10 CFR 54.21 (c)(1)(iii).

4.7.4.2 Staff Evaluation

The applicant's original flaw evaluation for the flaw located in one of the RPV closure head

meridional welds was provided in NMPC letter (NMP 1L-1776), dated September 19, 2003, and

was approved in the NRC safety evaluation to NMPC dated December 21, 2004. The original

flaw evaluation considered fatigue crack growth due to 240 startup/shutdown cycles (the

number of design startup/shutdown cycles for the 40-year operating term) and determined the

flaw to be acceptable for continued service.

In ALRA Section 4.7.4, the applicant stated that the number of cycles from the time of

inspection to the end of the evaluation period is used to determine crack growth. In addition, the

applicant indicated that with the addition of the period of extended operation (20 years), the

NMP1 RPV can be expected to accumulate fatigue usage for no more than 25 additional years.

The staffs review of ALRA Section 4.7.4 identified an area in which additional information was

necessary to complete the review of the reactor vessel and reactor vessel closure head weld

flaw evaluations.

In RAI 4.7.4-1, dated November 22, 2005, the staff requested that the applicant provide a

commitment to state that the analysis is to be submitted for staff review and approval no later

than two years prior to the period of extended operation.

In its response, by letter dated December 5, 2005, the applicant clarified that from the date of

the inspection (March 2003) through the end of the period of extended operation, it is unlikely

that the number of startup/shutdown cycles that occur will exceed the 240 additional

startup/shutdown cycles that were the bases for the evaluation. Therefore, the staff agreed with

the applicant that the RPV closure head weld flaw evaluation remains valid for the period of

extended operation in accordance with 10 CFR 54.21 (c)(1)(i).

The applicant's original flaw evaluation for the two flaws located in the RPV shell welds was

provided in Niagara Mohawk Power Corporation (NMPC) Letter NMP 1L-1467, dated

September 14, 1999, and approved in the NRC safety evaluation to NMPC dated May 5, 2000.

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The flaw evaluations considered fatigue crack growth and irradiation embrittlement to 28 EFPY,

and the staff concurred that continued operation with these flaws was acceptable only through

28 EFPY, the end of the current license term. Therefore, to address the impact of license

renewal on these flaw evaluations, the applicant, in ALRA Section A1.4 and as supplemented

by its letter dated December 5, 2005, revised Commitment No. 12 for NMP1 regarding the RPV

shell weld flaws:

The RPV weld flaw evaluation will be revised to consider additional fatigue

crack growth and the effects of additional irradiation embrittlement (for

beltline materials) associated with operation for an additional 20 years (i.e.,

out to at least 46 EFPY) and submitted for NRC review and approval no later

than 2 years prior to the period of extended operation. If the revised

calculation shows the identified flaws cannot meet the applicable acceptance

criteria, the indications will be reexamined in accordance with ASME

Section XI requirements.

The applicant's commitment requires the applicant to submit the renewed flaw evaluations for

the flaws in the RPV shell welds to the NRC for staff review and approval at least two years

prior to entering the period of extended operation. The applicant's commitment will ensure that

the staff will have sufficient time to assess the renewed flaw evaluations for acceptability. Based

on this evaluation and the applicant's revision of Commitment 12, the staff concludes that the

applicant will adequately address that the structural integrity of the NMP-1 RPV shell will be

maintained during the period of extended operation. Therefore, the staff's concern described in

RAI 4.7.4-1 is resolved.

4.7.4.3 UFSAR Supplement

The applicant provided a UFSAR supplement summary description of its TLAA evaluation of the

reactor vessel and reactor vessel closure head weld flaw evaluations in ALRA Section A1.2.5.1,

which was supplemented by letter dated December 5, 2005. On the basis of its review of the

UFSAR supplement, the staff concludes that the summary description of the applicant's actions

to address the reactor vessel and reactor vessel closure head weld flaw evaluations is

adequate.

In addition, by letter dated December 5, 2005, the applicant provided a revised Commitment

No. 12, as stated above.

The staff found that the applicant had adequately included its commitment regarding the RPV

weld flaw evaluations in Table A1.4 of the NMP1 ALRA, and therefore concludes that the

UFSAR supplement contains an appropriate summary description of Commitment No. 12 for

NMP1.

4.7.4.4 Conclusion

On the basis of its review, as discussed above, the staff concludes that there is reasonable

assurance that the applicant had demonstrated, pursuant to 10 CFR 54.21(c)(1)(i), regarding

the RPV closure head weld flaw evaluation, that the analyses remain valid for the period of

extended operation. The applicant has also provided an acceptable demonstration, pursuant to

10 CFR 54.21 (c)(1)(iii), regarding potential growth of identified flaws in the RPV welds, that the

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effects of aging on the intended function(s) will be adequately managed for the period of

extended operation. The staff also concludes that the UFSAR supplement contains an

appropriate summary description of the reactor vessel and reactor vessel closure head weld

flaw evaluations TLAA evaluation for the period of extended operation, as required by

10 CFR 54.21(d).

4.7.5 Reactor Water Cleanup System Weld Overlay Fatigue Flaw Growth Evaluations

(NMPI Only)

4.7.5.1 Summary of Technical Information in the Amended Application

Section 54.21(b) of 10 CFR, in part, requires applicants to submit an annual update of their

LRAs. On December 20, 2005, the applicant submitted its annual update for the NMP Units 1

and 2 ALRA. The applicant included a supplemental TLAA Section 4.7.5, "Reactor Water

Cleanup System Weld Overlay Fatigue Flaw Growth Evaluations (NMP-1 Only)" (henceforth the

RWCU Overlay TLAA) within the scope of annual update for the ALRA.

The applicant identified that the design of the reactor water cleanup (RWCU) system includes

two welds (RWCU welds 33-FW-22 and 33 FW-23A) that had experienced IGSCC and

subsequently had been repaired with autstenitic stainless steel weld overlays. The applicant

stated that the majority of the deposited weld metal in the overlays is resistant to IGSCC

because the deposited weld metal is made from an austenitic stainless steel filler metal.

However, the applicant stated that the 0.625 inch of the deposited weld overlay material is

considered to be susceptible to IGSCC due to weld dilution, a phenomena that causes alloy

mixing when the first pass of weld metal is deposited onto the austenitic stainless steel base

metal of the pipe requiring the overlay repair.

The applicant stated that it performed a fatigue flaw growth evaluation of the assumed flaw in

overlays (0.625 inch in depth) based on the methodologies in the following ASME Code Cases:

(1) ASME Code Case N-504 for RWCU weld 33-FW-22, and (2) ASME Code Case N-504-2

for RWCU weld 33-FW-23A. The applicant identified that the fatigue flaw growth analyses for

the RWCU weld overlays are TLAA that conform to the definition in 10 CFR 54.3.

4.7.5.2 Staff Evaluation

The RWCU system is designed to improve the water quality of the NMP1 reactor coolant by

means of a series of high efficiency resin-bed filtration demineralizers. The RWCU system also

includes regenerative and non-regenerative heat exchangers that are used to ensure that the

reactor coolant passing through the RWCU system will re-enter the reactor vessel at the proper

temperature (- 530 'F). The ASME Code Class I portions of the RWCU system include piping,

pump, valve and fitting components that are located inside the containment structure and

extend out of the containment structure inclusive of the second outboard containment isolation

valves for the system. The ASME Code Class 1 portions of the RWCU system serve a reactor

coolant pressure boundary function in addition to the water purification function and heat

exchanger function.

On January 23, 2006, the staff held a teleconference with the applicant to discuss the basis for

approving the RWCU Overlay TLAA. During the teleconference, the staff informed the applicant

that an alternative basis for approving the RWCU Overlay TLAA would be to credit an

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acceptable inspection-based AMP for managing cracking in RWCU welds 33-FW-22 and

33-FW-23A and their repair overlays. The staffs basis for taking this position was that the

applicant had already indicated that it was implementing UT examinations of these weld

overlays and that this would be permissible in accordance with 10 CFR 54.21(c)(1)(iii). The

applicant also informed the staff that the UT examinations of these weld overlays are currently

being performed in accordance with the applicant's BWR Stress Corrosion Cracking Program

discussed in SER Section 3.0.3.2.5.

In RAI 4.7.5A-1, dated April 19, 2006, the staff requested confirmation that the applicant would

use the BWR Stress Corrosion Cracking Program and the UT examinations that are performed

in accordance with the AMP as the basis for: (1) managing IGSCC in RWCU welds 33-FW-22

and 33-FW-23A and their repair overlays, and (2) accepting the RWCU Overlay TLAA in

accordance with 10 CFR 54.21(c)(1)(iii). With respect to NMP1, the staff also requested the

applicant to: (1) update the ALRA to include RWCU welds 33-FW-22 and 33-W-23A and their

repair overlays within the scope of the BWR Stress Corrosion Cracking Program, (2) update the

USAR Supplement summary description to be consistent with the position that

10 CFR 54.21 (c)(1)(iii) will be used as the basis for accepting the RWCU Overlay TLAA, and

(3) include a discussion in the USAR Supplement that specifies that the applicant's BWR Stress

Corrosion Cracking Program will be used as the basis for managing cracking in RWCU welds

33-FW-22 and 33-FW-23A and their repair overlays.

In its response, by letter dated April 21, 2006, the applicant clarified that, pursuant to

10 CFR 54.21(c)(1)(iii), it will use the BWR Stress Corrosion Cracking Program as the basis for

managing cracking in RWCU welds 33-FW-22 and 33-FW-23A and their repair overlays. The

applicant clarified that the BWR Stress Corrosion Cracking Program is normally used to

manage IGSCC of ASME Code Class 1 austenitic steel weld components. In addition, the

applicant also stated that: (1) the BWR Stress Corrosion Cracking Program proposes to use UT

examinations as the inspection technique for examining austenitic stainless steel weld

components that are within the scope of the AMP (including those that have been repaired with

austenitic stainless steel weld overlays), and (2) the UT technique proposed by the BWR Stress

Corrosion Cracking Program for these components is consistent with the guidelines in

NRC-approved Topical Report BWRVIP-75A, "WR Vessel and Internals Project, Technical

Basis for Revisions to Generic Letter 88-01 Inspection Schedules (BWRVIP-75)

[October 1999]," and is capable of detecting and sizing any cracks in the subject welds and

overlays, including those that grow by fatigue. The staff approved Topical Report BWRVIP-75A

in a safety evaluation dated March 14, 2002. The applicant further stated that the BWRVIP-75A

program recommends that the UT examinations be performed on 25 percent of the susceptible

welds every 10 years, with 50 percent of the UT examinations to be completed within the first

six years in the 10-year ISI interval. The applicant also confirmed that the last UT examination

of RWCU weld 33-FW-22 was performed in 2003 and that no cracking was detected in the

deposited overlay weld metal; and that the RWCU weld 33-FW-23A is scheduled to be

reinspected during the 2007 refueling outage.

In GL 88-01, the staff established the following position with respect to performing inspections

of austenitic stainless steel welds that experienced IGSCC and were repaired with austenitic

stainless steel weld overlays:

(1) The weld overlays needed to be conducted in accordance with Subarticle

IWB-3600 of the ASME Boiler and Pressure Vessel Code.

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(2) The welds and their overlays needed to be examined by UT inspectors and UT

procedures qualified to inspect weld overlays in conformance with the staff's

position on inspection methods and personnel.

The "parameters monitored/inspected" program element in GALL AMP XI.M7, "BWR Stress

Corrosion Cracking," states, in part, that the program is used to detect and size cracks by using

those examination and inspection guidelines delineated in NUREG-0313, Revision 2, "Technical

Report on Material Selection and Processing Guidelines for BWR Coolant Pressure Boundary

Piping," January 1988, and GL 88-01, "NRC Position on IGSCC in BWR Austenitic Stainless

Steel Piping," January 25, 1988, or, alternatively, in guidelines of Topical Report BWRVIP-75A.

The "parameters monitored/inspected" program element for GALL AMP XI.M7 does not

distinguish whether the cracking has been initiated by SCC or by fatigue. The applicant has

indicated that it will use the UT examinations of its BWR Stress Corrosion Cracking Program as

the basis for managing cracking in RWCU welds 33-FW-22 and 33-FW-23A and their repair

overlays.

The staff found this as an acceptable approach since it conforms to: (1) the "parameters

monitored/inspected" program element in GALL AMP XI.M7, (2) the staff's position in GL 88-01

for performing UT inspections of austenitic stainless weld overlays repair designs, and (3) with

the changes to GL 88-01 UT inspection schedules that were proposed in Topical Report

BWRVIP-75A.

In addition, the applicant made the following amendments to the ALRA to address the inquiries

in RAI 4.7.5A-1 and the changes to the RWCU Overlay TLAA.

(1) ALRA Table 3.3.2.A-17 was amended to include an AMR entry indicating that

cracking of the wrought austenitic stainless piping to the RWCU heat

exchangers under exposure to the "treated water or steam, temperature

> 212 OF, but < 482 OF" environment will be managed by a TLAA, evaluated in

accordance with 10 CFR 54.21 (c).

(2) ALRA Section 4.7.5 was amended to be consistent with the change in applicant's

position for accepting this TLAA under 10 CFR 54.21 (c)(1)(iii).

(3) ALRA USAR supplement Section A1.2.5.2 was amended to be consistent with

the applicant's position for accepting the RWCU Overlay TLAA under

10 CFR 54.21(c)(1)(iii).

The staff founds these changes to be acceptable because the applicant has made the

appropriate update of its AMR tables and ALRA Sections 4.7.5 and A1.2.5.2 to account

for: (1) the change in applicant's position for accepting the RWCU Overlay TLAA in accordance

with 10 CFR 54.21 (c)(1)(iii), and (2) the basis for using the UT examinations of the BWR Stress

Corrosion Cracking program to manage cracking in RWCU welds 33-FW-22 and 33-FW-23A

and their repair overlays. The staff evaluated the amended version of ALRA Section A1.2.5.2 in

SER Section 4.7A.5.3.

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Based on this assessment, the staff concludes that the applicant has provided: (1) an

acceptable basis for approving the RWCLU Overlay TLAA in accordance with

10 CFR 54.21 (c)(1)(iii), (2) an acceptable AMP to manage cracking in RWCU welds 33-FW-22

and 33-FW-23A and their repair overlays, and (3) appropriate changes to the ALRA to account

for its amended position for accepting this TLAA. Therefore, the staffs concerns described in

RAI 4.7.5A-1 are resolved.

4.7.5.3 USAR Supplement

ALRA Section A.1.2.5.2 summarizes the applicant's USAR Supplement description for the

RWCU Overlay TLAA. In its response to RAI 4.7.5A-1, the applicant provided the following

amended USAR supplement:

A1.2.5.2 Reactor Water Cleanup System Weld Overlay Fatigue Flaw

Growth Evaluations

Fatigue crack growth analyses have been performed for two weld overlays in

the reactor water cleanup system. The repaired welds are located at the inlet

nozzle of the regenerative heat exchanger and the transition pipe between

the upper and lower shells of the regenerative heat exchanger, respectively.

The weld overlays consist of IGSCC-resistant austenitic stainless steel

material and, thus, are not susceptible to continued IGSCC crack

propagation. However, the first 1/16" thick layer of weld metal deposited is

not assumed to be IGSCC-resistant due to weld dilution; thus, it is assumed

to be cracked. A fatigue crack growth analysis for each weld overlay was

performed in accordance with ASME Section XI, Appendix C, with the crack

propagating into the overlay from the hypothetical 1/16" deep crack. The

results of those analyses showed that the welds were acceptable per the

code criteria through the end of the period of extended operation.

Additionally, however, the overlaid welds are UT examined periodically under

the BWR Stress Corrosion Cracking Program, thus ensuring there is no

fatigue crack propagation into the overlays. The maximum interval between

inspections is defined by the requirements of BWRVIP-75A. Therefore, the

aging of the RWCU weld overlays will be adequately managed through the

balance of the initial 40 year licensing term and the period of extended

operation.

The applicant's amended USAR supplement for the RWCU Overlay TLAA appropriately

summarizes how the applicant will apply the BWR Stress Corrosion Cracking Program to

manage cracking in RWCU welds 33-FW-22 and 33-FW-23A and their repair overlays. The

applicant's revised USAR supplement summary description is consistent with the basis in the

applicant's response to RAI 4.7.5A-1, which indicated that, pursuant to

10 CFR 54.21(c)(1)(iii), the applicant will use its BWR Stress Corrosion Cracking Program to

manage cracking in RWCU welds 33-FW-22 and 33-FW-23A and their repair overlays.

In SER Section 4.7.5.2, the staff provided its basis for accepting the RWCU overlay TLAA in

accordance with 10 CFR 54.21(c)(1)(iii) and for accepting the applicant's BWR Stress

Corrosion Cracking Program as the basis for managing cracking in RWCU welds 33-FW-22

and 33-FW-23A and their repair overlays. Since the amended USAR supplement is consistent

4-55
with the applicant's basis for accepting the applicant's RWCU Overlay TLAA under

10 CFR 54.21 (c)(1)(iii) and the staffs evaluation for accepting this TLAA, the staff concludes

that the USAR supplement summary description for the RWCU overlay TLAA is acceptable.

4.7.5.4 Conclusion

On the basis of its review, as discussed above, the staff concludes that there is reasonable

assurance that the applicant has provided an acceptable demonstration, pursuant to

10 CFR 54.21 (c)(1)(iii) that, for the RWCU Overlay TLAA, the effects of aging on the intended

functions for the RWCU will be adequately managed for the period of extended operation. The

staff also concludes that the revised NMP1 USAR supplement contains an appropriate

summary description of the RWCU Overlay TLAA for the period of extended operation, as

required pursuant to 10 CFR 54.21(d).

4.8 Conclusion for Time-Limited Aging Analyses

The staff reviewed the information in ALRA Section 4, "Time-Limited Aging Analyses." On the

basis of its review, the staff concludes that the applicant has provided an adequate list of

TLAAs, as defined in 10 CFR 54.3. Further, the staff concluded that the applicant demonstrated

that: (1) the TLAAs will remain valid for the period of extended operation, as required by

10 CFR 54.21 (c)(1)(i); (2) the TLAAs have been projected to the end of the period of extended

operation, as required by 10 CFR 54.21(c)(1)(ii); or (3) that the aging effects will be adequately

managed for the period of extended operation, as required by 10 CFR 54.21 (c)(1)(iii). The staff

also reviewed the UFSAR and USAR supplements for the TLAAs and found that the

supplements contain descriptions of the TLAAs sufficient to satisfy the requirements of

10 CFR 54.21(d). In addition, the staff concluded that no plant-specific exemptions are in effect

that are based on TLAAs, as required by 10 CFR 54.21 (a)(2).

With regard to these matters, the staff concludes that there is reasonable assurance that the

activities authorized by the renewed licenses will continue to be conducted in accordance with

the CLB, and that any changes made to the CLB, in order to comply with 10 CFR 54.29(a), are

in accordance with the Atomic Energy Act of 1954 and the NRC's regulations.

4-56
SECTION 5

REVIEW BY THE ADVISORY COMMITTEE ON REACTOR

SAFEGUARDS

The NRC staff issued its safety evaluation report (SER) related to the renewal of operating

licenses for Nine Mile Point Nuclear Station, Units 1 and 2 on March 3, 2006. On April 5, 2006

the applicant presented its license renewal application, and the staff presented its review

findings to the ACRS Plant License Renewal Subcommittee. The staff reviewed the applicant's

comments on the SER and completed its review of the license renewal application. The staffs

evaluation is documented in a final SER that was issued by letter dated June 1, 2006.

During the 534nd meeting of the ACRS, July 12, 2006, the ACRS completed its review of the

NMPNS license renewal application and the NRC staffs SER. The ACRS documented its

findings in a letter to the Commission dated August 2, 2006. A copy of this letter is provided on

the following pages of this SER Section.

5-1

ACRSR-2204

August 2, 2006

The Honorable Dale E. Klein

Chairman

U.S. Nuclear Regulatory Commission

Washington, DC 20555-0001

SUBJECT: REPORT ON THE SAFETY ASPECTS OF THE LICENSE RENEWAL

APPLICATION FOR THE NINE MILE POINT NUCLEAR STATION, UNITS 1

AND 2

Dear Chairman Klein:

During the 534!h meeting of the Advisory Committee on Reactor Safeguards, July 12-13, 2006,

we completed our review of the license renewal application for the Nine Mile Point Nuclear

Station (NMPNS), Units I and 2, and the final Safety Evaluation Report (SER) prepared by the

NRC staff. Our Plant License Renewal Subcommittee also reviewed this matter during a

meeting on April 5, 2006. During these reviews, we had the benefit of discussions with

representatives of the staff and the applicant, Constellation Energy Group, LLC (CEG). We

also had the benefit of the documents referenced. This report fulfills the requirement of 10 CFR

54.25, which requires that the ACRS review and report on all license renewal applications.

CONCLUSION AND RECOMMENDATION

1. The programs committed to and established by the applicant to manage age-related

degradation provide reasonable assurance that NMPNS, Units 1 and 2, can be

operated in accordance with their current licensing basis for the period of extended

operation without undue risk to the health and safety of the public.

2. CEG's application for renewal of the operating licenses for NMPNS, Units 1 and 2,

should be approved.

BACKGROUND AND DISCUSSION

NMPNS consists of two General Electric (GE) boiling water reactor (BWR) Units on a site six

miles northeast of Oswego, NY. The current operating licenses will expire on August 22, 2009

for Unit I and October 31, 2026 for Unit 2.. The applicant has requested renewal of these

licenses for an additional 20 years.

Unit 1 uses a Mark 1 containment design consisting of a drywell, a suppression chamber in the

shape of a tows, and a vent system that connects the drywell to the torus. Unit 2 uses a Mark

2 containment structure of reinforced concrete with an inner liner of carbon steel. Unit 1 is

authorized to operate at 1,850 MWt, and Unit 2 at 3,467 MWt. The Unit 1 main condenser is

5-3
cooled by a once-through circulating water system using cooling water from Lake Ontario. Unit

2 has a closed cooling system that uses a natural draft cooling tower.

In the final SER, the staff documented its review of the license renewal application and other

information submitted by the applicant or obtained during the staffs audit and inspection at the

plant site. The staff reviewed the completeness of the applicant's identification of structures,

systems, and components (SSCs) that are within the scope of license renewal; the integrated

plant assessment process; the applicant's identification of plausible aging mechanisms

associated with passive, long-lived structures and components; the adequacy of the applicant's

Aging Management Programs (AMPs); and the identification and assessment of time-limited

aging analyses (TLAAs).

The application demonstrates consistency with, or justifies deviations from, the approaches

specified in the Generic Aging Lessons Learned (GALL) Report. The applicant has correctly

identified those SSCs from both Units that fall within the scope of license renewal. The

applicant performed an aging management review of SSCs within the license renewal scope.

Based on the results of this review, the applicant will apply 43 AMPs. Of these, 9 are fully

consistent with the GALL Report, 27 are consistent with the GALL Report with exceptions or

enhancements, and 7 are plant specific. The staff determined that the AMPs described by the

applicant are appropriate and sufficient to manage aging of long-lived passive components that

are within the scope of license renewal. We concur.

The staff conducted an inspection and an audit for the license renewal application. The

inspection was performed to verify that the scoping and screening methodologies are consistent

with the regulations and are adequately reflected in the application. The audit verified the

appropriateness of the AMPs and the aging management reviews. Based on the inspection

and audit, the staff concluded that these programs are consistent with the descriptions

contained in the CEG license renewal application. The staff also concluded that the existing

programs, to be credited as AMPs for license renewal, are generally functioning well and that

an implementation plan had been established in the applicant's commitment tracking system to

ensure timely completion of the license renewal commitments.

Analyses of neutron embrittlement of the reactor vessels for both units were performed by the

applicant and independently verified by the staff. These analyses demonstrate that the limiting

reactor vessel beltline welds and plate materials will satisfy acceptance criteria for the periods

of extended operation. Both the applicant and the staff chose to use a lifetime capacity factor

of 90 percent for determining neutron fluence.

The staff identified no open items or confirmatory items in the final SER. CEG has made 56

license renewal commitments for NMPNS. Of these commitments, 26 are common to both

Units with 16 commitments applying only to Unit 1 and 14 commitments applying only to Unit 2.

The staff has included appropriate license conditions in the final SER to satisfy the remaining

documentation issues and action items. No changes in the technical specifications are required

for either Unit.

The applicant's initial license renewal application was not of adequate quality. In reviewing the

application, the staff generated 323 Requests for Additional Information (RAls) and 385 audit

questions. The large number of RAIs prompted the applicant to request a delay to prepare an

amended license renewal application. The amended license renewal application was more

complete and of higher quality.

5-4
The staff's evaluation was comprehensive and well documented in the final SER. The

inspection and audit performed by the staff were effective in evaluating the applicant's proposed

and existing programs and TLAAs.

No issues related to the matters described in 10 CFR 54.29(a)(1) and (a)(2) preclude renewal

of the operating licenses for NMPNS, Units I and 2. The programs committed to and

established by the applicant provide reasonable assurance that NMPNS, Units 1 and 2, can be

operated in accordance with their current licensing basis for the period of extended operation

without undue risk to the health and safety of the public. The application for renewal of the

operating licenses for NMPNS, Units I and 2, should be approved.

Sincerely,

/RA/

Graham B. Wallis

Chairman

References:

1. Safety Evaluation Report-Final Related to the License Renewal of Nine Mile Point Nuclear

Station, Units 1 and 2, dated May 30, 2006.

2. Nine Mile Point Nuclear Station, Units I and 2 - Application for Renewed Operating

Licenses, dated May 26, 2004.

3. Audit and Review Report for Plant Aging Management Programs (AMPs) and Aging

Management Reviews (AMRs) - Nine Mile Point Nuclear Station, dated January 5, 2006.

4. Nine Mile Point Nuclear Station Inspection Report 05000220/20050011 and

05000410/20050011, dated March 2, 2006.

5. Safety Evaluation Report with Open Items Related to the License Renewal of the Nine Mile

Point Nuclear Station, Units I and 2, dated March 3, 2006.

5-5

SECTION 6

CONCLUSION

The staff of the U.S. Nuclear Regulatory Commission (NRC or the staff) reviewed the license

renewal application (LRA) and its amended license renewal application (ALRA) for the Nine Mile

Point Nuclear Station (NMPNS), Units I and 2, in accordance with the NRC regulations and

NUREG-1800, "Standard Review Plan for Review of License Renewal Applications for Nuclear

Power Plants," dated July 2001. Title 10, Section 54.29, of the Code of Federal Regulations

(10 CFR 54.29) provides the standards for issuance of a renewed license.

On the basis of its evaluation of the LRA and ALRA, the staff concludes that there is reasonable

assurance that the requirements of 10 CFR 54.29(a) have been met and that all open items

have been resolved.

The staff would like to note that any requirements of Subpart A of 10 CFR Part 51 are to be

documented in the Final Supplement 24 to NUREG-1437, "Generic Environmental Impact

Statement for License Renewal of Nuclear Plants: Regarding Nine Mile Point Nuclear Station

(NMPNS), Units 1 and 2, Final Report," which is scheduled to be issued on May 29, 2006. The

staff further notes that the Draft Supplement 24 to NUREG-1437 was issued for public

comments on September 29, 2005.

6-1

APPENDIX A

COMMITMENTS FOR LICENSE RENEWAL OF NMPNS UNITS I AND 2

During the review of the Nine Mile Point Nuclear Station, Units 1 and 2, original license renewal

application (LRA) and amended license renewal application (ALRA) by the staff of the U.S.

Nuclear Regulatory Commission, the applicant made commitments related to aging

management programs to manage aging effects of structures and components prior to the

period of extended operation. The following table lists these commitments, along with the

implementation schedules and the sources of the commitment

A-1

siAPPENDIX A. NINE MILE POINT, NUCLEAR STATION LICENSE RENEWAL COMMITMENTS UNIT I

NMPI -UPDATED FINAL -: (AIRA . Table A:. : ' COMMITMENT .- SAFETY.ANALYSIS M REPORT FA .. 1.4 : -• ISCMEDULE SOURCE.;'

Items) 'SUPPLEMENT, SHEUL - LOCAION .. ,

Apply for relief from reactor vessel circumferential weld inspections for the period of extended operation. Supporting analyses,

the 

procedural 

period of 

controls, 

extended 

and 

operation 

operator 

to 

training 

support 

will be completed prior to A1.2.1.3 Prior to Period of ALRA Section and confirm that the 

RPV circumferential weld Extended Operation 4.2.3 failure probability remains acceptable for the period of extended operation.

Develop a baseline Cumulative Usage Factor (CUF) for the specified portions of the following systems: (1) Feedwater / High Pressure Coolant Injection (2) Core Spray (3) Reactor Water Cleanup (piping inside the Reactor Coolant Pressure Boundary) 8 and (4) Reactor Recirculation Prior to Period of ALRA Section

Systems Lines). If the 

(and associated Shutdown Cooling A1.2.2.3 Extended Operation 4.3.7 baseline CUF for a specified portion of a

system exceeds 0.4, the limiting locations may require additional

monitoring to demonstrate compliance over the period of extended

operation.

The Fatigue Monitoring Program will track transients specific to the

10 Emergency baseline Cumulative Cooling System Usage Factor with additional usage added to the At.2.2.6 Prior to Period of ALRA Section for the emergency condensers 

as described Extended Operation 4.3.7 in Section 4.3 of the LRA.

Enhance the Fatigue Monitoring Program to (1) ensure that fatigue usage of the torus attached piping and other torus locations does

not exceed the design limits, add ERV lifts as a transient to be counted by the Fatigue Monitoring Program and (2) add the two 11 highest usage torus attached piping Prior to Period of ALRA Section

spray suction locations, the 12-Inch core A1.2.4.2 Poto period 4.6.2 and.

penetration XS-337 

line for Core Spray Pump 111 that enters the torus at Extended Operation Appendix B3.2 and the 3-inch containment spray line that enters the torus at penetration XS-326 as fatigue monitoring locations.

A-3
APEDkA.WN MILE POINT NULA STATION LICENSE RENEWAL COMMITMENTS- UNITJ1

NMPI UPDATED FINAL-

(ALRASAFETYANALYSi i

Table A .' COMMITMENT., REPORT (UFSAR)T IM u A- N SOURCE SACHEDULE, 1.4 6 SUPPLEMENT,'

Itms 6 6 LOCATION

The RPV meld flaw evaluations will be revised to consider

additional fatigue crack growth and the effects of additional

Irradiation embrittlement (for beftline materials) associated with ALRA Section

operation for an additional 20 years (i.e., *out to at least 46 EFPY) 4.7.4

12 and submitted for NRC review and approval no later than 2 years A1.2.5.1 Completed As supplemented

prior to the period of extended operation. If the revised calculation .By NMPIL 2007

shows the Identified flaws cannot meet the applicable acceptance Dated 12/5/05

criteria, the Indications will be reexamined in accordance with

ASME Section Xl requirements._______________________________

A-4
APPENDIX A - NINE MILE POINT NUCLEAR STATION LICENSE RENEWAL COMMITMENTS -UNIT fl.!

NMP1 PAE FINAL-,... (AFLRA, Table~~~"' A, SAFETY ANALYSIS '-. -OMIMNTRPRT(FS 1.4M 2 IT EN ' IMPLEMENTATION U P E E TS H D L RCE Items) - - OCATION',

Enhance the BWR VIP to address the following: (1) BWRVIP,18

open item regarding the Inspection of Inaccessible welds for core

spray system. As such, NMPNS will implement the resolution of this open item as documented in the BWRVIP response and reviewed and accepted by the NRC; (2) The Inspection and evaluation guidelines for steam dryers are currently under development by the BWRVIP committee. Once these guidelines are documented, and reviewed and accepted by the NRC, the actions will be implemented in accordance with the BWRVIP

program; (3) The baseline Inspections recommended in BWRVIP47 for the BWR lower ALRA Appendix plenum components will be 13 incorporated into the appropriate Prior to Period of B2.1.8

documents; and (4) The reinspection 

program and implementing A1.1.12 Extended Operation As supplemented scope and frequency for the grid beam going forward will be By NMPIL 2005 based on BWRVIP-26A guidance for plant specific flaw Dated 12/1/05 analysis and crack growth assessment. The maximum reinspection interval for the grid beam will not exceed 10

years consistent with standard BWRVIP guidance for the core shroud. The reinspection scope will be equivalent to the UT baseline 2005 inspection scope. In addition, the reinspection

scope will include an EVT-1 sample inspection of at least 2 locations with accessible indications within the Initial 6 years of the 10 year Interval. The intent of the EVT-1 Is to monitor the known cracking to confirm flaw analysis crack growth assumptions.

A-5
APPENDIX A NINE MILE POINT NUCLEAR STATION LICENSE RENWA COMMITMENTS- UNIT. I .;

NMPI UPDATED FINAL

(ALRA. 'SAFETY ANALYSIS

1.-4. "- .'SUPPLEMENT -... SOURCE

IeS) COMIMETLEOR (FARTIMLMETTI

Enhance the Closed Cycle Cooling Water System (CCCWS)

Program to (1) Expand periodic chemistry checks of the systems

consistent with the guidelines of EPRI TR-107396;(2) Implement a

program to use corrosion inhibitors In the Reactor Building Closed

Loop (RBCL) Cooling Systems and Control Room HVAC System In

accordance with the guidelines given in EPRI TR-107396; (3) Direct

periodic inspections to monitor for loss of material In the piping of

the CCCWS; (4) Implement a corrosion monitoring program for

larger bore CCCW piping not subject to Inspection under another

15 program; (5) Establish the frequencies to inspect for degradation of A1.1.13 Prior to the Period of ALRA Appendix

components CCCWS, in including heat exchanger tube wall Extended Operation B2.1.11

thinning; (6) Perform a heat removal capability test for the Control

Room HVAC System at least every 5 years; (7) Establish periodic

monitoring, trending, and evaluation of performance parameters for

the RBCL cooling and Control Room HVAC; (8) Provide the

controls and sampling necessary to maintain water chemistry

parameters in CCCWS within the guidelines of EPRI Report TR

107396; and (9) Ensure acceptance criteria are specified in the

implementing procedures for the applicable indications of

degradation.

The Boraflex Monitoring Program will be enhanced to (1) Require

periodic neutron attenuation testing and measurement of boron ALRA Appendix

areal density to confirm the correlation of the conditions of test Prior to Period of B2.1.12

16 coupons to those of Boraflex racks that remain in use during the A1.1.5 Extended Operation As supplemented

period of extended operation; and (2) Establish monitoring and By NMP1L 1996

trending instructions for in-situ test results, silica levels, and coupon Dated 11/17/05

results.

A-6
APPENDIX A'-NINE MILE POINT.NUCLEAR STATION LICENSE RENEWAL COMMITMENTS -UNIT I

N.... ... UPDATED FINAL

(ALRA,. -SAFETY ANALYSI IMP Table A COMMITMENT' REOR "Id SAR - PLEMENTATIO1NSurC

-SUPPEMENTSCHEDULE

Items) ~LOCATION ~--

Enhance the Compressed Air Monitoring Program to (1) Develop

new activities to manage the loss of material, stress corrosion

cracking, and perform periodic system leak checks;(2) Expand the

scope, periodicity, and inspection techniques to ensure that the

aging of certain sub-components of the dryers and compressors

(e.g., valves, heat exchangers) are managed; (3) Develop and

implement activities to address the failure mechanism of stress - Prior to Period of ALRA Appendix 18 corrosion cracking in unannealed red brass piping; (4) Establish A1.1.14 Extended Operation B2.1.14

activities that manage the aging of the Internal surfaces of carbon

steel piping and that require system leak checks to detect

deterioration of the pressure boundaries; and (5) Expand the

acceptance criteria to ensure that the aging of certain

sub-comnponents of the dryers and compressors (e.g., valves, heat

exchangers) are managed.

Enhance the Fuel Oil Chemistry Program to (1) Establish

specifications to perform quarterly trending of water and sediment; ALRA Appendix (2) Provide guidelines for the appropriate use of biocides, corrosion B2.1.16

inhibitors, and/or fuel stabilizers to maintain fuel oil quality; (3) Add As supplemented specifications to periodically inspect the interior surfaces of the By NMPIL 1996

emergency diesel fuel oil storage tanks for evidence of significant Dated 11117/05

21 degradation, including a specific requirement that the tank bottom A1.1.20 Prior to Period of and NMP1L 2005 thickness be determined by UT or other industry recognized Extended Operation Dated 12/1/05

methods; (4) Add specifications for quarterly trending of particulate

contamination analysis results; (5) Ensure acceptance criteria are

specified in the implementing procedures for the applicable

indications of potential degradation; (6) Establish specifications for

periodic opening of the diesel fire pump fuel oil day tank drain; and

(7) Establish specifications to remove water, if found.

A-7
TablA= APENDIXANINE MILE POINT NUCLEAR STATION LINS RENEWAL COMMITMENT UNI IO

NMP1 UPDATED FINAL'--

(ALRA ~~~SAFETY ANALYSIS.. MPEENIO

Table A CMMTMN REPORT (UFSARV' - CEUESOURCIE.;

1.4 SUPPLEMENT -

Items) LOCATION,

Enhance the Structures Monitoring Program to (1) Expand the

program to include the following activities or components in the

scope of License Renewal but not within the current scope of

10 CFR 50.65: (a) the steel electrical transmission towers required Prior to Period of ALRA Appendix

26 for the SBO and recovery paths; (2) Expand the parameters A1.1.34 Extended Operation B2.1.28

monitored during structural Inspections to include those relevant to

aging effects Identified for structural bolting; and (3) Implement

regularly scheduled ground water monitoring to ensure that a

benign environment is maintained.

A-8
..APPENDIX A"; NINE MILE POINT NUCLEAR STATION LICENSE RENEWALCOMMITMENTS .UNIT I

NMPI -'UDATED FINALý -(ALRA 

'6SAFETY ANALYSIS' :`-MPEENAIO -';6: Table A : " ':COMMiTMENT.!: - 6 ýREPORT(UFSARS•U••E 1.'4s " IMPLEMENTATION SOURCE - - SuPPLEMENT Items): SCHEDULE

LOCATION

As acknowledged by the NRC in the referenced RAI, the ASME Code Committee is evaluating the acceptability of roll/expansion techniques as a permanent repair for CRD stub tubes via Code Case N-730. NMP will continue to follow the status of the proposed ASME code case and will implement the final code case, as conditioned by the NRC, once it has been approved. If the code

case is not approved by the ASME, NMP1 will seek NRC approval of the 10/19/05 code case draft on a plant specific basis as conditioned by the NRC.

During the period of extended operation, ALRA Appendix should a CRD stub tube 36 rolled In accordance with the provisio6s B2.1.8

leaking, NMP will implement one 

of the code case resume A1.1.12 August 22, 2009 As supplemented of the following zero leakage permanent repair strategies prior By NMP1L 2004 to startup from the outage in which the leakage was detected: Dated 11/30/05

1. A welded repair consistent with BWRVIP-58-A, "BWRVIP Internal Access Weld Repair" and Code Case N-606-1, as endorsed by the NRC in Regulatory Guide 1.147. 2. A variation of the welded repair geometry specified in BWRVIP-58-A subject to the approval of the NRC using Code Case N-606-1.

3. A future developed mechanical/welded repair method subject to the approval of the NRC.

An EVT-1 examination of the NMP1 feedwater sparger end bracket welds will be added to the BWR Vessel Internals Program. The 38 inspection extent and frequency of the end bracket weld Prior to NMP1 Period of NMP1L 2005

will be the same as the ASME Section XI 

inspection A1.1.12 Extended Operation Dated 12/1/05 Inspection of the

feedwater sparger bracket vessel attachment welds.

A-9
APEDXA -NINE MILE POINT NUCLEAR STATION LICENSE RENEWAL COMMITMENTS Q NITj-_

NMP9 i UPDmATED Fi

Table A SAETY ANALY IS> IMPLEMENTATION. SORC Tal''COMVMITMENT,' REP.ORT fUFSAR).SHDL

1.4 SUPPLEMENT,:'

Items) -`LOCATION' -

The Masonry Wall Program (as managed by the Structures

Monitoring Program) will be enhanced to provide guidance for Al1.1.23 Prior to NMPI Period of NMPl L 2005 39 inspecting NMP1 non-reinforced masonry wails that do not have A1.1.34 Extended Operation Dated 1211/05 bracing and are within scope of license renewal more frequently

than the reinforced masonry walls.

NMP1 will perform an EVT-1 Inspection of the thermal shield to flow Prior to NMP1 Period of NMP1L2005

40 shield weld starting in 2007 and proceeding at a 10 year frequency A1.1.12 Extended Operation Dated 12/1/05

thereafter consistent with the ISI Inspection Interval.

NMPNS will perform volumetric examinations on the NMP1 drywell

shell during the 2007 refueling outage and an engineering

42 evaluation will be performed to determine the actions necessary for A1.1.42 Prior to NMP1 Period of NMP1L 2037

NMP1 operation through the period of extended operation, In Extended Operation Dated 4/4/06

accordance with the NMP1 Drywell Supplemental Inspection

Program.

A-1O
APPEDIXA -NINE MILE POINT NUCLEAR STATION LICENSE RENEWAL CMIMNS-UI

NMP2 UPDATED FINAL I (ALRA -rSAFETY"ANALYSIS 'IMPLEMENTATION"SOURCE

Table A2 -COMMITMENT; SORPOTRUCAR

4 . ~SUPPLEMENT SCHEDUL .4items). LOCATION

For the bounding locations for ASME Class I systems, transients

contributing to fatigue usage will be tracked by the Fatigue

Monitoring Program (FMP) with additional usage added to the

baseline Cumulative Usage Factor (CUF) using the design Cycle Prior to Period of ALRA Section

6 Based Fatigue (CBF) method described in Section 4.3 of the LRA. A2.2.2.2 Extended Operation 4.3.2

If a bounding location with a current CUF value less than or equal

to 0.1 could have its CUF value exceed 0.1 before the end of the

period of extended operation, then the impact on the original break

postulation calculations will be assessed.

If fatigue monitoring of ASME Class 1 piping (described In LRA

8 Section 4.3.2) indicates higher fatigue usage than expected, A2.2.2.4 Prior to Period of ALRA Section

non-ASME Class 1 piping will be evaluated for possible fatigue Extended Operation 4.3.4

concerns.

Revise or evaluate the Cumulative Usage Factor evaluations for

the shroud, core support plate and studs, and jet pumps to remove Prior to Period of ALRA Section

9 conservatism and/or encompass the period of extended opeiation A2.2.2.5 Extended Operation 4.3.5

(e.g., a more extensive fatigue analysis of the jet pumps will be

performed).

For penetrations listed In Table 4.6-4 of the LRA, transients

contributing to fatigue usage will be tracked by the NMPNS FMP Prior to Period of ALRA Section

11 with additional usage added to the baseline Cumulative Usage A2.1.16 Extended Operation 4.6.5

Factor using the design Cycle Based Fatigue method described in

Section 4.3 of the LRA.

. -1

A-11
*APPENDIX( A -NINE MILE POINT NUCLEAR STATION LICENSE RIENEWAL COMMITMEN'T'S; -UNIT 2''

NM2- PATED FINALý',,' SAFETY .. .:. .' ANALYSIS " ! N AT - (ALRA .. ' ",• '""COMMITMENT: REPOORT W "5) I M T OU

Table ~~ SUPPLEMENT; SHEUL

.4 Iems)LOCATION

NMPNS will either.(1) Install core plate wedges (as part of a.

proposed core shroud tie-rod repair) to eliminate the need for the

enhanced Inspections of the core plate hold-down bolts - ALRA Section

recommended by BWRVIP-25; or (2) Perform an analysis 4.7.3

(incorporating detailed flux/fluence analyses and improved stress As supplemented

12 relaxation correlations) in accordance with BWRVIP-25 to A2.2.5.3 October 31, 2024 By NMPIL 2007

demonstrate that the core plate hold-down bolts can withstand all Dated 12/5105

normal, emergency, and faulted loads considering the effects of And NMP1L 2008

stress relaxation, until the end of the period of extended operation Dated 12113105

and submit it for staff review and approval 2 years prior to entering

the period of extended operation. . IIII

A-12
APPENDIX ANINE MILE POINT NUCLEAR STATION LICENSE RENEWAL COMMITMENTS UNIT2

NMP2UPDATED T(A~LReA:: } ).CroMMITMENT.: FINAL`' -ý

, SAEPORTY ANALYI pLM iAlO

..... A 

.4 Iems) REPORT WU&AR SCHEDULE. SOURCE,' -. -SUPPLEMENT.-

Enhance the BWR VIP to address (1) BWRVIP-18, 41 and 42 open items regarding the inspection of inaccessible welds for core spray, jet pump and low pressure coolant injection components, respectively. As such, NMPNS will implement the resolution of these open items as documented in the BWRVIP response and reviewed and accepted by the NRC; (2) The inspection and evaluation guidelines for steam dryers and access hole covers are currently under development by the BWRVIP committee. Once these guidelines are documented, and reviewed and accepted by the NRC, the actions will be implemented in accordance with the BWRVIP program; (3) The baseline inspections recommended in BWRVIP-47 for the BWR lower plenum ALRA Appendix components will be incorporated into the appropriate B2.1.8 program and Implementing 13 documents; and (4) NMPNS will As supplemented

beams similar (in inspection methods, 

perform inspections of the guide A2.1.13 Prior to Period of By NMPpL 2005 scope and frequency of Extended Operation Dated 12/1/05 inspection) to the inspections specified in BWRVIP-47, 'BWR Lower Plenum Inspection and Flaw Evaluation Guidelines," And NMP1L 2008 for the control rod guide tube components. Dated 12/13105 The extent of examination and its frequency will be based on a ten percent sample of the total population, whlch includes all grid beam and beam-to-crevice slots, being inspected within 12 years of entry into the period of extended operation with five percent of the populalion being inspected within the first six years. The sample locations selected for examination will be in areas that are exposed to the highest neutron fluence. The top guide grid beam reinspection requirements will depend on the inspection results; however, at a minimum, the NMP BWRVIP

program will follow the same guidance for the subsequent 12 year interval as defined for the initial 12 year baseline."

A-13
APPENDIX A;- NINE MILE. POINT NUC"LEAR STATION LICENSE RENEWAL COMMITMENTS- UNIT 2

NMP -UPDATED FINAL.-

A......R....... . ... ..... .... . ... SAFETYANALYSIS' IMLEMNTAI. SOURC:

COMMITMENT REPORT (UFSA'R " . C EURCE tabIe Ai.'CEUE

4 tm)SUPPLEMENT .-

.4 -LOCATION, Itms) 

Enhance the Closed Cycle Cooling Water System (CCCWS)

Program to (1) Expand periodic chemistry checks of the system

consistent with the guidelines of EPRI TR-107396; (2) Implement a

program to use corrosion inhibitors In the Reactor Building Closed

Loop Systems (RBCL) and Control Building Ventilation Chilled

Water System (CBVCWS) in accordance with the guidelines given

in EPRI TR-107396; (3) Direct periodic inspections to monitor for

loss of material In the piping of the CCCW systems; (4) Establish

15 the frequencies to inspect for degradation of components in A2.1.14 Prior to the Period of ALRA Appendix

CCCWS, Including heat exchanger tube wall thinning; (5) Establish Extended Operation B2.1.11

periodic monitoring, trending, and evaluation of performance

parameters for the RBCL Cooling and CBVCWS; (6) Specify

chemistry sampling frequency for the CBVCWS; (7) Provide the

controls and sampling necessary to maintain water chemistry

parameters In CCCWS within the guidelines of EPRI Report TR

107396; and (8) Ensure acceptance criteria are specified In the

implementing procedures for the applicable Indications of

degradation.

A-14
:APPENDIX A -NINE MILE POINT NUCLEAR STATION LICENSE RENEWAL COMMITMENTS - UNIT 2

NMP2i -.. ;UDiATED INALYM,'

(ALRA - E-AAYSS IMOLEMENTATI6 COMMITMENT,: REPORT (UFSAR 7-11. C SOURCE.: -'-'

Table ~ SUPPLEMENTiSCHDUL .4 Items) LOAIN -

Enhance the Fuel Oil Chemistry Program to (1) Provide guidelines

for the appropriate use of biocides, corrosion inhibitors, and/or fuel

stabilizers tomaintain fuel oil quality; (2) Add specifications to

sample the diesel fuel oil storage tanks for water and sediment at

least quarterly per the ASTM standard; (3) Add specifications to ALRA Appendix

periodically inspect the interior surfaces of the fuel oil storage B2.1.18

tanks for evidence of significant degradation, including a specific Prior to Period of As supplemented 19 requirement that the tank bottom thickness be determined by UT or A2.1.20 Poto period By NMP1L 1996

other industry recognized methods; (4) Add specifications for Extended Operation Dated 11/17/05

quarterly trending of particulate contamination analysis results; (5) And NMPIL 2005

Ensure acceptance criteria are specified in the Implementing Dated 12/1/05

procedures for the applicable Indications of potential degradation;

(6) Establish specifications to perform quarterly trending of water

and sediment; and (7) Establish specifications to remove water, if

found.

Enhance the Structures Monitoring Program to (1) Expand the

program to include the following activities or components In the

scope of License Renewal but not within the current scope of

10 CFR 50.65: (a) Fire Rated Assemblies & Watertight Penetration

Visual Inspections (b) masonry walls in the Turbine Building and ALRA Appendix 24 Service Water Tunnel serving a fire barrier function (c) the steel A2.1.34 Prior to Period of B2.1.27 and

electrical transmission towers required for the SBO and recovery Extended Operation B2.1.28

paths; (2) Expand the parameters monitored during structural

inspections to include those relevant to aging effects identified for

structural bolting; and (3) Implement regularly scheduled ground

water monitoring to ensure that a benign environment is

maintained.

Develop and implement a Wooden Power Pole Inspection A2..40 Exte Perion Bf.1 .40

Program. Extended Operation B2.1.40

A-15
APPENDIX A -NINE MILE POINT NUCLEAR STATION LICENSE'RENEWAL COMMITMENTS -UNIT 2

UPDATED FINAL ; LMNAO Table .2COMMITMENT- SAFETY ANALYSIS' SCHEDULE O 

SI 1 W --- IMPLEMENTATIONSUPPLEMENT -

.4 Items) LCTO

The spent fuel rack design that currently utilizes Boraflex for Prior to NMP2 Period of NMP1L 1996

36 reactivity control 1i the spent fuel pool will be replaced by a design NA Extended Operation Dated 11/17105

that utilizes Boral for this function.

An EVT-1 examination of the NMP2 feedwater sparger end bracket

welds will be added to the BWR Vessel Internals Program as a

program enhancement. The inspection extent and frequency of

the end bracket weld inspection will be the same as the ASME Prior to NMP2 Period of NMP1L 2005

37 Section XI inspection of the feedwater sparger bracket vessel A2.1.13 Extended Operation Dated 12/1/05

attachment welds. If the final fabrication review of the NMP2

feedwater thermal sleeve concludes that the thermal sleeve hidden

welds are not IGSCC susceptible, thd NMP2 inspections will be

discontinued.

A-16
APPENDIX A NINE MILE POINT NUCLEAR STATION LICENSE RENEWAL COMMITMENTS -UNIT 2

NMP2

(ALRA~~~AFT 

TableA2 COMMITMENT 

ANALYSIS PLMNAI SUC

4 REPORT FSAR SCHEDULE SOURCE -SUPPLEMENT,. Item) -LOCATION'

Enhance the Inaccessible Medium-Voltage Cables not Subject to 10 CFR 50.49 Environmental Qualification Requirements Program as follows: (1) Expand the scope of the existing procedures to provide for manhole Inspections and water removal, (2) Develop a new testing procedure specific to those cables requiring aging management under this Program. The specific type of test

performed will be a proven test for detectng deterioration of the Insulation system due to wetting as described in EPRI

TR-103834-P1-2, such as power factor, partial discharge, or other 38 testing 

industry 

that 

guidance 

is both state-of-the-art and consistent with the latest A2.1.39 Prior to NMP2 Period of NMPIL 2005 at the time the test is performed. (3) establish 

requirement Extended Operation Dated 1211/05 to test cables subject to aging management prior to, and every 10 years during, the period of extended operation, and

(4) establish maintenance requirement to Inspect and remove water, as necessary, from manholes serving cables subject to

aging management. The Inspection frequency will be based upon actual plant experience with water accumulation in the manhole, but in any event, will be at least once every two years. The first

Inspection will be completed prior to the period or extended

operation.

No later than two years prior to entry into the PEO, NMP will submit, for NRC review and approval, the summary of the Reg. Guide 1.190 based analysis that determines the maximum neutron 39 fluence at the NMP2 Biological Shield Wall NMPIL 2015

flaw locations or at the shield wall A2.2.5.1 October 31, 2024 Dated 1/11106 that are the basis for the ALRA Section 4.7.1 TLAA.

The submittal will Include revised ALRA Sections 4.7.1 and

A2.2.5.1, and any other supporting analysis, as applicable.

A-17
APPFNDIY A - MNF MILE PflIPJT NiIr~i FAR STATION LICFNBF R~lJEWAL. COMUFrUENTS 2- COMMnN ~A NMPI nnd NMP2

(ARA' (ALRA, .AFTY ANALYSIS .

Table A" Table"A COMMITMENTA: . REPORT :AV IMPLEMENTATION E 

1.4 2.4 -.. .SUPPLEMENTv SHEULESORC ' 

Items) Item~s) ,LOCATION...

Following the

Incorporate Appendix Al into the NMP1 UFSAR and AO Issuance of the ALRA Section AO Appendix A2 Into the NMP2 USAR. AO renewed Operating

License

In accordance with 10 CFR 54.21(b), during NRC review of ALRA Section

54.2(b),durng N C reiew1.2.1

this application, provide an annual update to the application NMP1L 2009

2 2 to reflect any change to the current licensing basis that NA Completed Dated 12/20/05

materially affects the contents of the License Renewal And NMPIL 2028

Application (LRA). Dated 3/23/06

Supporting analyses will be completed prior to the period of

4 extended operation to confirm that the failure probabilities A1.2.1.4 Prior to Period of ALRA Section

for the limiting RPV axial welds remain bounded for the A2.2.1.3 Extended Operation 4.2.4

period of extended operation.

For those locations where additional fatigue analysis is

required to take advantage of the implicit margin, and to Al .2.2 Prior to Period of ALRA Section 4.3

5 4 more accurately determine cumulative usage factor (CUFs), A2.2.2 Extended Operation and Appendix B3.2

the EPRI FatiguePro fatigue monitoring software will be

Implemented prior to the period of extended operation.

For the critical reactor vessel component locations, shown

6 in Tables 4.3-3 and 4.3-4 of the LRA, additional usage will A1.2.2.1 Prior to Period of ALRA Section

be added to the baseline Cumulative Usage Factor using A2.2.2.1 Extended Operation 4.3.1

one of the methods described In Section 4.3 of the LRA.

Transients contributing to fatigue usage of the FWS nozzles

will be tracked by the Fatigue Monitoring Program (FMP) A1.2.2.2 Prior to Period of ALRA Section

7 7 with additional usage added to the baseline Cumulative A2.2.2.3 Extended Operation 4.3.3

Usage Factor using the Stress Based fatigue method

described in Section 4.3 of the LRA.

A-18
APPENDIX A :NINE MILE POINT NUCLEAR STATION LICENSE RENEWAL'COMMITMENTS -'COMMON FOR NMPI and NMP2. :

~Mpf~ UPDATED FINAL. i.

(ALRAk-- (ALRA, SAFETY ANALYSISIMPEETAIN SUC

Table A -Table A OMTETREPORT (UPsAR SCHEDUL

14 2.4 -SPLMN

Items) Items) LOCTIO

Assess the impact of the reactor coolant environment on a

sample of critical component locations, including locations ALRA Section

9 10 equivalent to those Identified in NUREGICR-6260, as part AI.2.2.5 Prior to Period of 4A3.6 and

of the Fatigue Monitoring Program. These locations will be A2.2.2.6 Extended Operation 4.pend

evaluated by applying environmental correction factors (F..) Appendix 83.2

to existing and future fatigue analyses.

Enhance the Open Cycle Cooling Water System (OCCWS)

Program to (1) Ensure that the applicable commitments

made for GL 89-13, and the requirements in NUREG-1 801,

Section XI.M20 are captured in the implementing

documents for GL 89-13; (2) Incorporate into the OCCWS A1.1.29 Prior to Period of ALRA Appendix

14 14 program, the requirements of the NUREG-1801, Section A2.1.29 Extended Operation B2.1.10

XI.M20 that are more conservative than the GL 89-13

commitments; and (3) Revise the preventive maintenance

and heat transfer performance test procedures to

incorporate specific inspection criteria, corrective actions,

and frequencies.

ALRA Appendix

Revise applicable procedures related to the Crane B2.1.13

17 16 Inspection Program to add specific direction for A1.1.22 Prior to Period of By NMP1L 1996

performance of corrosion inspections, with acceptance A2.1.22 Extended Operation dated 11117105

criteria, for certain hoist lifting assembly components. and NMP1L 2005

dated 12/1/05

A-19
APPENDiX A .NINE MILE POINT NUCLEAR STATION LICENSE RENEWALcoCMMITMENTS COMMON FOR NMPi and NMP2z::;-'t ,

ý'MI' II3 UPOATEOFiNAL'

ALA(ALRA SAFETY ANALYI IPE NTATION1

Table A TableA 'COMMITMENT,' REPORT (UFSAR), SC-E -LE" 5OURCE .

14 24.4 SUPPLEMN

lie mis) Items)": LOCATION:.

Enhance the Fire Protection Program to (1) Incorporate

periodic visual inspections of piping and fittings located In a

non-water environment such as Halon and Carbon Dioxide

fire suppression systems components, to detect evidence

of corrosion and any system mechanical damage that could ALRA Appendix

affect its intended function; (2) Expand the scope of A1.1.17 Prior to Period of B2.1.16

19 17 periodic functional tests of the diesel-driven fire pump to A2.1.17 Extended Operation As supplemented

include inspection of engine exhaust system components to By NMP1L 1996

verify that loss of material is managed; (3) Perform an Dated 11/17/05

engineering evaluation to determine the plant specific

inspection periodicity of fire doors; and (4) Revise Halon

and Carbon Dioxide functional test frequencies to

semi-annual.

A-20
-.APPENDIX A NINE MILE POINT NUCLEAR STATION LICENSE RENEWAL COMMITMENTS- COMMONFOR NMPI and NMP2

NMI P,: .. ~UPDATED FINAL

(ALRAR-L--A ANLSIS ANALYSI IMPLEMENTATION SOURC E 

Table A Tablek. A - COMMITMENT::ý REPORT (UFSARi SCHEDUL

1.~ 2.4 SUPPLEMENT'

Ites) ILis LOATION________

Enhance the Fire Water System Program by revising

applicable existing procedures to (1) Incorporate

inspections to detect and manage loss of material due to

corrosion into existing periodic test procedures; (2) specify

periodic component Inspections to verify that loss of

material Is being managed; (3) add procedural guidance for

performing visual inspections to monitor internal corrosion

and detect biofouling; (4) add requirements to periodically

check the water-based fire protection systems for ALRA Appendix

microbiological contamination; (5) measure fire protection B2.1.17

20 18 system piping wall thickness using non-Intrusive techniques A1.1.18 Prior to Period of As B2.1.17 (e.g., volumetric testing) to detect loss of material due to A2.1.18 Extended Operation supplemented corrosion; (6) establish an appropriate means of recording, By NMP1L1/996

evaluating, reviewing, and trending the results of visual dated 111105

inspections and volumetric testing; (7) define acceptance

criteria for visual inspections and volumetric testing; and (8)

Develop new procedures and PM tasks to implement

sprinkler head replacements and/or inspections to meet

National Fire Protection Association (NFPA) 25,

"Inspection, Testing, and Maintenance of Water-Based Fire

Protection Systems," Section 5.3.1 (2003 Edition)

requirements.

A-21
APPENDIX A - NINE MILE POINT NUCLEAR STATION LICENSE RENEWAL COMMITMENTS -COMMON FOR NMPland NMP2

NMP1 NMP2 .. .. . PDATED3 FINAL

(ALRA (ALRA: ':SAFETY ANALYSISý Table A Table A COMMITMENT REPORT, USR ',,,MPLrMENTATION SOURCE s.

1.4' 2.4 SUPPLEMENT-SCHEDULE

Items) tem I. s) ,,. LOCATION-':

Enhance the Reactor Vessel Surveillance program to (1)

Incorporate the requirements and elements of the

Integrated Surveillance Program (ISP), as documented In

BWRVIP-1 16 and approved by NRC, or an NRC approved

plant-specific program into the Reactor Vessel Surveillance

Program, and include a requirement that if NMPNS

surveillance capsules are tested, the tested specimens will

be stored In lieu of optional disposal. When the NRC

issues a final safety evaluation report (SER) for U1 - August 22, 2007 ALRA Appendix 22 20 BWRVIP-116, NMPNS will address any open items and A2.1.32 U2 - October31, 82.1.19

complete the SER Action Items. Should BWRVIP-116 not 2024

be approved by the NRC, a plant specific reactor vessel

surveillance program will be submitted to the NRC two

years prior to commencement of the period of extended

operation and (2) Project analyses of upper shelf energy

and pressure temperature limits to 60 years using methods

prescribed by Regulatory Guide 1.99, Revision 2, and

Include the applicable bounds of the data, such as

operating temperature and neutron fluence.

Develop and implement a One-Time Inspection Program, A1.1.28, A1.1.33 Prior to Period of ALRA Appendices

23 21 which also includes the attributes for a Selective Leaching B2.1.20 and of Materials Program. of Maerias Proram.A2.1.28, A2.1.33 Extended Operation6211 B2.1.21

Develop and implement a Buried Piping and Tank ALRA Appendix

Inspection Program which Includes a requirement that B2.1.22, as

24 22 before entry into the period of extended operation, if an A1.1.6 Prior to Period of supplemented opportunistic Inspection has not occurred, NMPNS will A2.1.7 Extended Operation By NMP1L 2005

excavate NMP1 and NMP2 degradation susceptible areas Dated 12/1105

to perform focused inspections.

A-22
::'APPENDIX A N NINE MILE POINT NUCLEAR STATION LICENSE RENEwAL COMMITMENTS ,-COMMON FOR NMPi and NMP21 -;...--'.

M N,.'. - . "A UPDATED FINAL.

(ALMA (ALR SAFETY ANALYSIS IMPLEMENIATIIN SOUC .

An augmented VT-i visual examination of the containment

25 23 penetration bellows will be performed using enhanced AI.1.2 Prior to Period of ALRA Appendix techniques qualified for detecting SCC, per NUREG-1611, A2.1.2 Extended Operation B2.1.23 Table 2, Item 12.

27 25 Develop Connection and Program. implement a Non-EQ Electrical Cables and A1.1.24 A2.1.24 Extended Prior to Period Operation of ALRA B2.1.29 Appendix.

Enhance the Non-EQ Electrical Cable and Con nections

Used in Instrumentation Circuit Program to (1) Implement

reviews of calibration or surveillance data for indications of aging degradation affecting instrument circuit performance.

The first reviews will be completed prior to the period of

extended operation and every ten years thereafter, and (2)

In cases where a calibration or surveillance program does ALRA Appendix not include the cabpng system in the testing circuit, or as an A1.1.25 Prior to Period of B2.1.30 as

28 28 alternative above, provide to the requirements review of calibration and procedures results described to perform A2.1.25 Extended Operation By supplemented NMP1L 2005

cable testing to detect deterioration of the insulation Dated 12s1/05

system, such as insulation resistance tests or other testing

judged to be effective in detrming cable insulation

condition. The first test will be completed prior to the period

of extended operation. The test frequency of these cables

shall be determined based on engineering evaluation, but

the test frequency shall be at least once every ten years.

A-23
-APPENDIX AX NINE MILE POINT NUCLEAR STATION LICENSE RENEWAL COMMITMENTS•*- COMMON FOR NMPI and NMP2

NMPI NMP2UPDATDFINAL

(.(ALRA -LRASAFETY ANALYSIS~ MLMNAINSUC

Table A. Table'A. COMMITMEN REPORT (UFSAR) SCHEDUL

14 2.4 SUPPLEMENT

Itemis) Items) L OCATIO

Enhance the Preventive Maintenance Program to (1)

Expand the PM Program to encompass activities for certain

additional components, identified as requiring Aging

Management. Explicitly define the aging management

attributes, Including the systems and the component Al1.1.30 Prior to Period of ALRA Appendix 29 27 types/commodities Included In the program; (2) specifically A2.1.30 Extended Operation B2.1.32

list those activities credited for aging management; (3)

specifically list parameters monitored (4) specifically list the

aging effects detected; (5) establish a requirement that

inspection data be monitored and trended; and (6) establish

detailed parameter-specific acceptance criteria.

Enhance the System Walkdown Program to (1) Train all

personnel performing inspections In the Systems

Walk-down Program to ensure that age related degradation A1.1.35 Prior to Period of ALRA Appendix 30 28 is properly Identified and incorporate this training into the A2.1.35 Extended Operation B2.1.33

site training program; and (2) Specify acceptance criteria

for visual inspections to ensure aging related degradation is

________________properly identified and corrected.

Enhance the Non-Segregated Bus Inspection Program to

(1) expand visual inspections of the bus ducts, their ALRA Appendix

supports and insulation systems; (2) Create new provisions B2.1.34 as

to perform as an alternative to either thermography or supplemented

periodic low range resistance checks of a statistical sample A1.1.27 Prior to Period of By NMP1L 1996

31 29 of the bus ducts accessible bolted connections, a visual A212 xeddOeain dated 11/17/05

inspection for the connections that are covered with heat A212 xeddOeain NMPIL 2005 dated

shrink tape, sleeving, insulating boots, etc; and (3) Define 12/1/05

acceptance criteria for inspection of the bus ducts, their NMPIL 2007

support and insulation systems, and the low range ohmic dated 12/5/05

checks of connections.

A-24
APPENDIX A'- NINE MILE POINT NUCLEAR STATION LICENSE RENEWAL COMMITMENTS-COMMON FOR NMPI and NMP2

Nmpi, NMP2 UPDATED FINAL

(ALRA '(ALRA SFT NLSS

Table A" TableA. COMMITMENT -- AFETYANALS• IMPLEMENTATION ;.,

1.: 2.,,SUPPLEMENT." SHDULE

Item~s)l Item's) -*LOCATION

32 30 Develop and implement d Fuse Holder Inspection Program. A1.1.21 Prior to Period of ALRA Appendix ______A2.1.21 Extended Operation B2.1.35

Enhance the Bolting Integrity Program to (1) The Structures

Monitoring, Preventive Maintenance and Systems

Walk-down Programs will be enhanced to Include

requirements to Inspect bolting for indication of loss of

preload, cracking, and loss of material, as applicable; (2)

Include in NMP administrative and Implementing program A1.1.38 Prior to Period of ALRA Appendix 33 31 documents references to the Bolting Integrity Program and A2.1.37 Extended Operation B2.1.36

Industry guidance; and (3) Establish an augmented inspection program for high-strength (actual yield strength

a 150 ksl) bolts. This augmented program will prescribe

the examination requirements of Tables IWB-2500-1 and

IWC-2500-1 of ASME Section SI for high-strength bolts In

the Class 1 and Class 2 component supports, respectively. ___________

A-25
APPENDIX A'; NINE MILE POINT NUCLEAR STATION LICENSE RENEWAL COMMITMENTS.- COMMON FOR NMPt and NMP2. -

NMP NMP2 U PDATE. F ..

(ALRA (ALRA. SAFETY ANALYSIS

Table A Table A COMMITMENT . REPORTA- f FSR) IMPLEMENTATION sOUCE2.4' SUPPULEMENT,. SHEUE

Itemis) items). "LOCATION

Enhance the Protective Coating Monitoring and

Maintenance Program to (1) specify the visual examination

of coated surfaces for any visible defects Includes

blistering, cracking, flaking, peeling, and physical or

mechanical damage; (2) perform periodic Inspection of

coatings every refueling outage versus every 24 months;

(3) set minimum qualifications for inspection personnel, the

inspection coordinator, and the inspection results evaluator;

34 32 (4) perform thorough visual inspections in areas noted as A1.1.40 Prior to Period of ALRA Appendix

deficient concurrently with the general visual Inspection; (5) A2.1.38 Extended Operation B2.1.38

specify the types of instruments and equipment that may be

used for the Inspection; (6) pre-Inspection reviews of the

previous two monitoring reports before performing the

condition assessment; (7) establishment of guidelines for

prioritization of repair areas and monitoring these areas

until they are repaired; and (8) to require that the inspection

results evaluator determine which areas are unacceptable

and initiate corrective action.

35 33 Develop and implement a Non-EQ Electrical Cable Metallic A1.1.41 Prior to Period of ALRA Appendix

Connections Inspection Program. A2.1.39 Extended Operation B2.1.39

Enhance the program to evaluate component susceptibility- ALRA Appendix B2.1.8 as

37 to loss of fracture toughness. Assessments and A1.1.12 Prior to Period of supplemented

inspections will be performed, as necessary, to ensure that A2.1.13 Extended Operation By NMPpL 1996

intended functions are not impacted by the aging effect Dated 11117/05

The NRC review of BWRVIP-76 is not yet complete. When

the NRC review of BWRVIP-76 is complete, NMPNS will A1.1.12 Prior to Period of ALRA Appendix evaluate the NRC SER and complete SER Action Item, as A2.1.13 Extended Operation B2.1.8

appropriate.

A-26
APPENDIX B: CHRONOLOGY

This appendix contains a chronological listing of routine licensing correspondence between the

U.S. Nuclear Regulatory Commission (NRC) staff and Constellation Energy Group, LLC (CEG).

This appendix also contains other correspondence regarding the NRC staff's review of the Nine

Mile Point Nuclear Sation, Units 1 and 2 (under Docket Nos. 50-220 and 50-410).

May 26, 2004 In a letter (signed by James A. Spina), CEG submitted its application

to renew the operating license of the Nine Mile Point Nuclear Station

(NMPNS), Units 1 and 2. In its submittal, CEG provided an original

signed hard copy of the application, with additional electronic copies

of the application on CDs. Cover Page Through Chapter 4 (ADAMS

Accession No. ML041490223), Appendix A (ADAMS Accession No.

ML041490224), Appendix B (ADAMS Accession No. ML041490225),

Appendix C (ADAMS Accession No. ML041490227), Appendix D

(ADAMS Accession No. ML041490229), LR Boundary Drawings

(ADAMS Accession No. ML041540072)

May 28, 2004 NRC Press Release-04-065: NRC Announces Availability of LRA For

NMPNS, Units 1 and 2 (ADAMS Accession No. ML041490358)

June 1, 2004 In a letter (signed by P. T. Kuo), the NRC acknowledged receipt and.

availability of the License Renewal Application (LRA) for NMPNS,

Units 1 and 2 (ADAMS Accession No. ML041540092)

June 2, 2004 Notice of June 16, 2004 Meeting (signed by R. Auluck) With CEG

Regarding License Renewal For The NMPNS, Units 1 and 2 (ADAMS

Accession No. ML041540386)

June 16, 2004 Slides of June 16, 2004 Meeting Presentation on NMPNS, Units 1

and 2 - LRA (ADAMS Accession No. ML041900140)

June 25, 2004 Notice of July 08, 2004 Meeting (signed by R. Auluck) With CEG

Regarding License Renewal For The NMPNS, Units 1 and 2 to inform

the public of the Forthcoming Public Information Session For The

U.S. NRC Staff To Describe Its License Renewal Process (ADAMS

Accession No. ML041770243)

July 2, 2004 Summary of June 16, 2004 Meeting Between the U.S. NRC Staff and

CEG, Inc Representatives to Discuss the NMPNS, Units 1 & 2 LRA

(ADAMS Accession No. ML041840412)

July 8, 2004 Summary of Public Information Session for the U.S. NRC Staff to

Describe Its License Renewal Process (Enclosure 3 - Slides for

NMPNS) (ADAMS Accession No. ML042240058)

July 15, 2004 In the Federal Register, a "Notice of Acceptance for Docketing of the Application and Notice of Opportunity for Hearing Regarding Renewal

of Facility Operating License Nos. DPR-63 and DPR-69 for an

Additional 20 Year Period" is published, concerning the NMPNS LRA

(ADAMS Accession No. ML041980375)

B-1
July 21,2004 NRC Press Release-04-088: NRC Announces Opportunity For

Hearing On Application To Renew NMP Operating Licenses (ADAMS

Accession No. ML042030444)

July 28, 2004 Notice of Acceptance for Docketing of the Application and Notice of

Opportunity for Hearing Regarding Renewal of Facility Operating

License Nos. DPR-63 and NPF-69 - Correction (ADAMS Accession

No. ML042240564)

July 29, 2004 In a letter (signed by P. T. Kuo) to Mr. Jim Spina of CEG, the NRC

provided Notice of Intent to Prepare an Environmental Impact

Statement and Conduct Scoping Process under the provisions of

10 CFR Part 51, to implement the National Environmental Policy Act

of 1969 (NEPA) for License Renewal for NMPNS, Units I and 2

(ADAMS Accession No. ML042160074)

August 2, 2004 In a letter (signed by P. T. Kuo), the NRC notified CEG that the staff

has prepared a notice of intent advising the public that the NRC

intends to gather information necessary to prepare a plant-specific

supplement to the Commission's "Generic Environmental Impact

Statement for License Renewal of Nuclear Plants," (NUREG-1437) in

support of the review of the applications for the renewal of the NMP

operating licenses, for License Renewal for NMPNS, Units 1 and 2

(ADAMS Accession No. ML042160153)

August 9, 2004 In a letter (signed by P. T. Kuo), the NRC provided a Notice of Intent

to Prepare an Environmental Impact Statement and Conduct Scoping

Process for License Renewal for NMPNS, Units 1 and 2 (ADAMS

Accession No. ML042230182)

August 11, 2004 In a Meeting Summary (signed by N. Le), the NRC staff issued a

summary of the Public Meeting conducted on July 8, 2004, to

describe the NRC license renewal process to the public living near

(ADAMS Accession No. ML042240038)

August 11, 2004 In the Federal Register, (Volume 69, Number 154, pages

48900-48901), a Notice of Intent to Prepare an Environmental Impact

Statement and Conduct Scoping Process in support of the review of

the application for renewal of the NMPNS operating licenses for an

additional 20 years (ADAMS Accession No.)

August 11, 2004 In a letter (signed by P. T. Kuo) to Ms. B. Castro, New York State

Office of Parks, Recreation, and Historic Preservation, to notify a

site-specific Supplemental Environmental Impact Statement (SEIS) to

its "Generic Environmental Impact Statement for License Renewal of

Nuclear Plants" (GELS), NUREG-1437, will be prepared under the

provisions of 10 CFR Part 51, the NRC rules that implement the

National Environmental Policy Act of 1969 (NEPA) regarding NMP

Units 1 and 2 License Renewal Review (Project Review OPRHP No.

03PR0532) (ADAMS Accession No. ML042250207)

B-2
August 11, 2004 In a letter (sirnied by P. T. Kuo),. NRC, to The Honorable Leo R.

Henry, Tuscarora Nation, regarding the U.S. NRC Review of

NMPNS, Units 1 and 2 LRA (ADAMS Accession No. ML042250372)

August 11, 2004 In a letter (signed by P. T. Kuo), NRC, to The Honorable Emerson

Webster, Tonawanda Band of Senecas, regarding the U.S.- NRC

Review of NMPNS, Units I and 2 LRA (ADAMS Accession No.

ML042250412)

August 11, 2004 In a letter (signed by P. T. Kuo), NRC, to The Honorable Ricky L.

Armstrong, Seneca Nation of Indians, regarding the US NRC Review

of NMPNS, Units 1 and 2 LRA (ADAMS Accession No.

ML042250437)

August 11, 2004 In a letter (signed by P. T. Kuo), NRC, to The Honorable Irving

Powless, Jr., Onondaga Nation, regarding the U.S. NRC Review of

NMPNS, Units I and 2 LRA (ADAMS Accession No. ML042260213)

August 11, 2004 In a letter (signed by P. T. Kuo), NRC, to The Honorable Clint Half

Town, Cayuga Nation of New York, regarding the U.S. NRC Review

of NMPNS, Units 1 and 2 LRA (ADAMS Accession No.

ML042260230)

August 11, 2004 In a letter (signed by P. T. Kuo), NRC, to The Honorable Raymond

Halbritter, Oneida Indian Nation of New York, regarding the U.S.

NRC Review of NMPNS, Units 1 and 2 LRA (ADAMS Accession No.

ML042260238)

August 12, 2004 In a letter (signed by P. T. Kuo), NRC, to The Honorable Jim

Ransom, St. Regis Band of Mohawk Indians, regarding the U.S. NRC

Review of NMPNS, Units 1 and 2 LRA (ADAMS Accession

No. ML042260408)

August 12, 2004 In a letter (signed by P. T. Kuo), NRC, to The Honorable M.

Terrance, St. Regis Band Of Mohawk Indians, regarding the U.S.

NRC Review of NMPNS, Units 1 and 2 LRA (ADAMS Accession No.

ML042260460)

August 12, 2004 In a letter (signed by P. T. Kuo), NRC, to The Honorable Barbara

Lazore, St. Regis Band Of Mohawk Indians, regarding the U.S. NRC

Review of NMPNS, Units 1 and 2 LRA (ADAMS Accession No.

ML042260489)

August 20, 2004 In a Meeting Notice (signed by Leslie Field), the NRC staff issued

Notice of forth coming meeting to discuss Environmental Scoping

Process for NMPNS LRA (ADAMS Accession No. ML042330412)

September 1, 2004 Revision of August 20, 2004, Notice Meeting to Discuss the

Environmental Scoping Process for NMPNS, Units 1 and 2 LRA

(ADAMS Accession No. ML042450141)

B-3
September 9, 2004 In an NRC Press release, the NRC announced seeking public input

on Environmental Impact statement for NMPNS operating licenses

(ADAMS Accession No.ML042530638)

September 13, 2004 Notice of Exit Meeting on October 1, 2004 with CEG to Discuss the

Audit of the Methodology for the Scoping & Screening for the LRA for

NMPNS Units 1 & 2 (ADAMS Accession No. ML042570112)

September 15, 2004 In a report (signed by Leslie field), the NRC provided a list of the

references obtained during the site audit to support review of the LRA

for NMPNS, Units I and 2 (ADAMS Accession No. ML050540665)

September 16, 2004 In a letter (signed by P. T. Kuo), NRC, to Ms. Natalie Roy, Oswego

County Health Department, regarding the NMP, Units I and 2,

License Renewal Review (ADAMS Accession No. ML042610263)

September 18, 2004 E-Mail from Farouk Baxter to NRC Regarding Comments on NMP

License Renewal (ADAMS Accession No. ML050040016)

September 22, 2004 NMPNS Responses to U.S. NRC Requests for Additional Information

from NRC Environmental Site Audit Conducted September 22, 2004

(ADAMS Accession No. ML043230144)

September 24, 2004 Letter (signed by L. Michael Treadwell), Executive Director,

Operation Oswego County, to William L. Dam, NRC, Regarding

NMPNS LRA (ADAMS Accession No. ML042860212)

October 4, 2004 In a letter (signed by State Senator Jim Wright, Chairman, the NY

State Energy Committee) expressed strong support for the

relicensing of NMPNS (ADAMS Accession No. ML0428901600)

October 5, 2004 In a Meeting Notice (signed by N. Le), the NRC staff issued Notice of

forth coming meeting to dicuss results of NRC audit and review of

AMPs and AMRs for NMPNS LRA (ADAMS Accession No.

ML042800149), and revised October 25, 2004 (ADAMS Accession

No. ML042990305) to change meeting date to November 5, 2004

October 11, 2004 NRC Requests for Additional Information for the Review of NMPNS,

Units I and 2, LRA (ADAMS Accession No. ML052850264)

October 12, 2004 In a letter (signed by William A. Barclay), Assemblyman 12" District,

NY, to NRC supporting renewal of the operating licenses of NMP

Units 1 and 2 (ADAMS Accession No. ML050050455)

October 20, 2004 In a letter (signed by Leslie Fields), the NRC staff issued RAIs

regarding Severe Accident Mitigation Alternative (SAMA) for the

NRC's review of the NMPNS LRA (ADAMS Accession No.

ML042940508)

October 21, 2004 Transmittal Note from Dennis Vandeputte, NMPNS, to NRC

Forwarding Requested Materials from Site Audit (ADAMS Accession

No. ML043100591)

B-4
October 25, 2004 Revised Notice (signed by N Le) of November 5, 2004 Meeting With

CEG To Discuss The Aging Management Programs And Review For

The LRA Fof NMPNS Units I & 2 (ADAMS Accession No.

ML042990305)

October 26, 2004 Posted Revision 1 to "Audit and Review Plan for Plant Aging

Management Reviews and Programs for the NMPNS, Units I and 2."

(ADAMS Accession No. ML043000333)

October 29, 2004 In a letter (signed by James A. Spina), CEG submitted supplemental

information, resulting from the NRC audits of Aging Management

Programs, to its NMPNS LRA (ADAMS Accession No.

ML043140293)

November 4, 2004 Summary of Meeting (signed by Leslie C. Fields) to provide the public

information that was discussed in a Public Scoping Meetings to

Support Review of NMPNS, Units 1 and 2, LRA held 09/21/2004

(ADAMS Accession No. ML043130425)

November 7, 2004 In a letter (signed by P T Kuo), NRC, to Mr. Michael Stoll, US Fish

and Wildlife regarding LRA For NMPNS Units 1 & 2 (ADAMS

Accession No. ML043140284)

November 9, 2004 In an Audit Trip Report (signed by Dale Thatcher), the NRC staff

provide a summary of scoping audit and review of NMPNS LRA

(ADAMS Accession No. ML04315021 1)

November 10, 2004 NRC Requests for Additional Information for the Review of NMPNS,

Units 1 and 2, LRA (ADAMS Accession No. ML043170655)

November 10, 2004 NMP Units 1 and 2, Response to NRC Request for Information

Regarding the Offsite Power System (ADAMS Accession No.

ML043280420)

November 11, 2004 In a Meeting Summary (signed by N. Le) the staff provided a

summary of discussion between the NRC staff and Constellation

applicant regarding reactor vessel fatigue analysis, containment liner

plate, metal containment and penetration fatigue analysis (ADAMS

Accession No. ML043270634)

November 15, 2004 Re-posted Audit And Review Plan For Plant Aging Management

Reviews And Programs For The NMPNS, Units 1 And 2 (ADAMS

Accession No. ML043210580)

November 15, 2004 Docketing of Responses to Requests for Additional Information

Regarding the Environmental Site Audit Conducted in Support of the

Environmental Review of NMPNS, Units 1 and 2, LRA (ADAMS

Accession No. ML043340314)

November 15, 2004 Docketing of References Obtained During Site Audit Conducted in

Support of Environmental Review of NMPNS, Units 1 and 2, LRA

(ADAMS Accession No. ML050540665)

B-5
November 17, 2004 NRC Request for Additional Information for the Review of NMPNS,

Units 1 and 2, LRA (ADAMS Accession No. ML043220665)

November 17, 2004 NRC Request for Additional Information for the Review of NMPNS,

Units 1 and 2, LRA (ADAMS Accession No. ML043220678)

November 17, 2004 NRC Request for Additional Information for the Review of NMPNS,

Units 1 and 2, LRA (ADAMS Accession No. ML043220679)

November 17, 2004 NRC Requests for Additional Information for the Review of NMPNS,

Units 1 and 2, LRA (ADAMS Accession No. ML043270617)

November 17, 2004 Summary of Meeting (signed by N Le) held on October 28, 2004,

Between the U.S. NRC and CEG to further clarifying the intent of the

staff's questions and the applicant's proposed responses, concerning

the Review for the NMPNS, Units I and 2, LRA (ADAMS Accession

No. ML043270634)

November 18, 2004 Email from P. Tam, NRC, to Gregory Cwalina, regarding

Consideration of Allegation (TAC MC5106, MC5107) (ADAMS

Accession No. ML043240017)

November 19, 2004 NRC Requests for Additional Information for the Review of NMPNS,

Units 1 and 2, LRA.(ADAMS Accession No. ML043280670)

November 19, 2004 In a letter (signed by James A. Spina), CEG submitted supplemental

information, resulting from the NRC audits and ongoing review of

Aging Management Programs, to its NMPNS LRA (ADAMS

Accession No. ML043600531)

November 22, 2004 NRC Requests for Additional Information for Review of NMPNS,

Units 1 and 2, LRA (TAC MC3272 and MC3273) (ADAMS Accession

No. ML043280683)

November 22, 2004 NRC Requests for Additional Information for the Review of NMPNS,

Units 1 and 2, LRA (ADAMS Accession No. ML053290143)

December 3, 2004 NRC Requests for Additional Information for the Review of NMPNS,

Units 1 and 2, LRA (TAC Nos. MC3272 AND MC3273) (ADAMS

Accession No. ML043420049)

December 6, 2004 In a letter (signed by James Spina), CEG submitted supplemental

information resulting from the NRC Audit of Aging Management

Reviews (ADAMS Accession No. ML043490370)

December 6, 2004 In a letter (signed by James Spina), CEG, provided Responses to

NRC Requests for Additional Information Regarding NMPNS LRA

(ADAMS Accession No. ML043490360)

December 6, 2004 In a letter (signed by James Spina), CEG, provided Responses to

NRC Requests for Additional Information Regarding Time-Limited

Aging Analyses (ADAMS Accession No. ML04327064)

B-6
December 6, 2004 In a letter (signed by James Spina), CEG, provided Responses to

NRC Requests for Additional Information Regarding NMPNS LRA

(ADAMS Accession No. ML043490360)

In a letter (signed by P. T. Kuo), the NRC notified CEG that their

December 7, 2004 support of the staff audits activities and CEG's response to the

review of the draft requests for additional information (RAls) has

been less than timely and requested CEG to discuss plan to provide

adequate resources to support the established review schedule for

NMPNS LRA (ADAMS Accession No. ML043450440)

December 8, 2004 NRC Requests for Additional Information for the Review of NMPNS,

Units 1 and 2, LRA (TAC NOS. MC3272 AND MC3273) (ADAMS

Accession No. ML043450450)

December 9, 2004 NRC Requests for Additional Information for the Review of NMPNS,

Units I and 2, LRA (TAC NOS. MC3272 AND MC3273) (ADAMS

Accession No. ML043490666)

December 10, 2004 NRC Requests for Additional Information for the Review of NMPNS,

Units 1 and 2, LRA (TAC NO. MC3272 AND MC3273) (ADAMS

Accession No. ML043500176)

December 17, 2004 In a letter (signed by James Spina), CEG, provided Responses to

NRC Requests for Additional Information Regarding Fire Detection

and Protection Systems (TAC Nos. MC0691 and MC0692) (ADAMS

Accession No. ML043630355)

December 17, 2004. In a letter (signed by James Spina), CEG, provided Responses to

NRC Requests for Additional Information from the Reactor Systems

Branch Review (TACs MC0691 and MC0692) (ADAMS Accession

No. ML043650311)

December 17, 2004 In a letter (signed by James Spina), CEG, provided Responses to

NRC Requests for Ad ADAMS ditional Information Regarding the

Systems Walkdown Program (ADAMS Accession No. ML043650328)

December 21, 2004 NRC Requests for Additional Information for the Review of NMPNS,

Units I and 2, LRA (ADAMS Accession No. ML043570368)

December 21, 2004 In a letter (signed by James Spina), CEG, provided Responses to

NRC Requests for Additional Information Regarding Sections 2.3.2,

2.3.4, and B2. 1.32.(ADAMS Accession No. ML050040315)

December 22, 2004 NRC Request for Additional Information for the Review of NMPNS,

Units 1 and 2, LRA, (TAC Nos. MC3272 AND MC3273) (ADAMS

Accession No. ML043650003)

December 22, 2004 In a letter (signed by James Spina), CEG, provided Responses to

NRC Request for Additional Information Regarding Scoping and

Screening Methodology of NMPNS, Units 1 and 2, LRA (ADAMS

Accession No. ML050040332)

B-7
December 22, 2004 In a letter (signed by James Spina), CEG, provided Responses to

NRC Requests for Additional Information Regarding Sections 2.2,

2.3.3, and 2.3.4 of NMPNS, Units 1 and 2, LRA(TAC Nos. MC3272

and MC3273) (ADAMS Accession No. ML050060182)

December 27, 2004 NRC Request for Additional Information for the Review of NMPNS,

Units 1 and 2, LRA, (TAC Nos. MC3272 and MC3273) (ADAMS

Accession No. ML043650006)

December 29, 2004 Email from P. Tam, NRC, to Peter Farouk Baxter, regarding

concerns with the NMP Offsite Power System (ADAMS Accession

No. ML043650417)

December 30, 2004 Acknowledgment of receipt of letter for renewal of operating licenses

for NMP, Units 1 and 2 addressed to J. Wright, NY State Senator

(ADAMS Accession No. ML051680395)

January 3, 2005 In a letter (signed by James A. Spina), CEG provided its response to

NRC Requests for Additional Information Regarding the Reactor

Recirculation Systems of NMPNS, Units I and 2, LRA (ADAMS

Accession No. ML050110235)

January 3, 2005 In a letter (signed by James A. Spina), CEG provided its response to

the staff letter dated 12/7/2004 regarding the status of the NRC

review schedule for NMPNS LRA (ADAMS Accession No.

MLI050120217)

January 5, 2005 In a letter (signed by N. Le), NRC, to J. Spina, NMP, regarding

Revision of Schedule for the Conduct of Review of NMPNS, Units 1

and 2, LRA (ADAMS Accession No. ML050060421)

January 5, 2005 In a letter (signed by Leslie Fields), the NRC staff issued an

Environmental Scoping Summary Report associated with the staff's

review of the applications by CEG for renewal of the operating

licensees for NMP Units 1 and 2 (ADAMS Accession No.

ML050060373)

January 7, 2005 In a letter (signed by James A. Spina), CEG provided its response to

NRC Request for Additional Information Regarding the NMP Unit 1

Containment System (TAC Nos. MC3272 and MC3273) (ADAMS

Accession No. ML050190296)

January 10, 2005 In a letter (signed by James A. Spina), CEG provided its response to

NRC Requests for Additional Information Regarding Aging

Management of Electrical and Instrumentation and Control Systems

(ADAMS Accession No. ML050190295)

January 10, 2005 NMP Units I and 2, LRA - Responses to NRC Requests for

Additional Information Regarding Structures (TAC Nos. MC3272 and

MC3273) (ADAMS Accession No. ML050190292)

B-8
January 12, 2005 In a Meeting Notice (signed by N. Le), the NRC staff issued Notice of forth coming meeting with CEG to discuss the milestone for the NRC

review schedule of NMPNS LRA (ADAMS Accession No.

ML0501300420)

January 13, 2005 In a Note to File (signed by N Le) the staff docketed additional

information regarding the staff's follow-up questions after having

reviewed CEG letters NMP1L 1899, 1 NMP1L 1900, dated December

17, 2004, and NMP1L 1905, dated 12, 22,2004 (ADAMS Accession

No. ML050270496)

January 13, 2005 NRC Requests for Additional Information for the Review of NMPNS,

Units 1 and 2, License Renewal Application (TAC Nos. MC3272 and

MC3273) (ADAMS Accession No. ML050130283)

January 14, 2005 NMP Units 1 and 2 LRA - Responses to NRC Requests for Additional

Information Regarding the Time-Limited Aging Analysis for Main

Steam Isolation Valve Corrosion Allowance and the Closed-Cycle

Cooling Water System (ADAMS Accession No. ML050250188)

January 20, 2005 NMP Units 1 and 2, LRA - Responses to NRC Requests for

Additional Information Regarding Aging Management of Bolting

(ADAMS Accession No. ML050330463)

January 26, 2005 NMP Units 1 and 2. LRA - Responses to NRC Requests for

Additional Information Regarding Aging Management of Auxiliary

Systems (ADAMS Accession No. ML050390370)

January 31 2005 NMP Units I and 2, LRA - Responses to NRC Requests for

Additional Information Regarding Sections 2.2, 2.3.3, and 2.3.4, and

Scoping and Screening Methodology (ADAMS Accession No.

ML050460233)

January 31, 2005 In a letter (signed by James A. Spina), CEG submitted supplemental

information to revise and supplement its response to the staff RAI on

SAMA for NMPNS LRA (ADAMS Accession No. ML050460312)

January 31, 2005 NMP Units 1 and 2, LRA - Responses to NRC Requests for

Additional Information Regarding RAI for Section 2.3.3 for NMPNS

LRA (ADAMS Accession No. ML050460233)

A public meeting was held in Rockville, Maryland at the NRC

February 2, 2005 Headquarters office between the NRC staff and CEG staff to discuss

the review status and its impact on the NRC review schedule for the

NMPNS LRA. This is documented in a Meeting Summary issued on

March 3, 2005 (ADAMS Accession No. ML0506620124)

February 4, 2005 In a letter (signed by James A. Spina), CEG submitted supplemental

information resulting from the NRC audit and review of AMRs for

NMPNS LRA (ADAMS Accession No. ML050450485)

B-9
February 10, 2005 NRC Requests for Additional Information for the Review of NMPNS,

Units I and 2, LRA (TAC Nos. MC3272 and MC3273) (ADAMS

Accession No. ML050410428)

February 11, 2005 In a summary of a telephone conference conducted on February 11,

2005 (signed by N. Le), the NRC described the discussion between

NRC staff and CEG staff concerning the staff RAts for NMPNS

(ADAMS Accession Number ML050420328)

February 11, 2005 Summary of January 27, 2005 Conference Call Between the U.S.

NRC and CEG, Inc. Concerning the Review for the NMPNS, Units 1

and 2, LRA (ADAMS Accession No. ML050420328)

February 11, 2005 Summary of the January 25, 2005 Conference Call Held with CEG

Inc. Concerning the Review of the NMPNS, Units I and 2, License

Renewal (ADAMS Accession No. ML050420387)

February 11, 2005 NMP Units I and 2, LRA - Submittal of Supplemental Information for

Review of the LRA (TAC Nos. MC3272 and MC3273) (ADAMS

Accession No. ML050560199)

February 14, 2005 In a summary of a telephone conference conducted on February 14,

2005 (signed by N. Le), the NRC described the discussion between

NRC staff and CEG staff concerning the staff follow-up questions

related to CEG supplemental information provided in CEG letter of

11/19/04 and 12/6/04 for NMPNS LRA (ADAMS Accession Number

ML050460138)

February 14, 2005 NMP Units 1 and 2, LRA - Responses to NRC Requests for

Additional Information Regarding the Reactor Vessel and Reactor

Vessel Internal Components (ADAMS Accession No. ML050610059)

February 17, 2005 In a Meeting Notice (signed by R. Lorson), the NRC/ Region I staff

issued Notice of forthcoming meeting with CEG to discuss NRC's

team inspection covering the scoping and aging management

portions of the NMPNS LRA (ADAMS Accession No. ML050480487)

February 22, 2005 NRC Requests for Additional Information for the Review of NMPNS,

Units 1 and 2, LRA (TAC Nos. MC3272 and MC3273) (ADAMS

Accession No. ML050540196)

February 23, 2005 NRC Requests for Additional Information for the Review of NMPNS,

Units I and 2, LRA (TAC Nos. MC3272 and MC3273) (ADAMS

Accession No. ML050540263)

February 23, 2005 NRC Press Release-I-05-008: NRC, Company To Discuss License

Renew Inspection Conducted At NMP Nuclear Power Plant (ADAMS

Accession No. ML050540439)

February 28, 2005 In an NRC Press Release, the NRC announced the postponement of

of the proposed March 3, 2005 public meeting to be held in Scriba,

New York (ADAMS Accession No. ML050590308)

B-1 0
March 1, 2005 Revision - Notice of March 3, 2005 Meeting with Constellation

Generation Group to Discuss NRC's Team Inspection Covering the

Scoping and Aging Management Portions of NMPNS's Application for

a Renewed License (ADAMS Accession No. ML050600423)

March 3, 2005 Summary of Meeting held on February 2, 2005, between the U.S.

NRC Staff and NMPNS, LLC Representatives to discuss NMPNS,

Units 1 and 2 (ADAMS Accession No. ML050620124)

March 3, 2005 NRC Requests for Additional Information for the Review of NMPNS,

Units 1 and 2, LRA (ADAMS Accession No. ML050620591)

March 3, 2005 In a letter (signed by T O'Connor), CEG requested a 90-day grace

period to revcover the quality of the NMPNS LRA (ADAMS Accession

No. ML050680270)

March 3, 2005 The staff posted audit data base resulting from the staff initial audit

and review of the original NMLNS LRA (ADAMS Accession No.

ML050660380)

March 7, 2005 In a letter (signed by P. Kuo), the NRC acknowledged CEG's March

3, 2005, request and its commitment to address quality issues,

including those items the staff discussed on the telephone [and listed

in the letter]. The NRC stopped its review in response to CEG's

request. As a result of this delay, the staff will not meet the standard

22 month review schedule for NMPNS LRA (ADAMS Accession No.

ML050660147)

March 7, 2005 The staff forwarded to CEG the remaining back-logged RAIs for CEG

regarding NMPNS LRA Section 2.0 Tables - Scoping and Screening,

LRA Section 2.3.4.A.5 - T-quenchers, LRA Section 3.1 Tables, LRA

Tables 3.1.2A-4 and 3.1.2.B-4, and LRA section 4.7.2 MSIV

Corrosion Allowance (ADAMS Accession No. ML050680323)

March 8, 2005 NRC Press Release-05-045: NRC Extends Review Schedule For

NMP Nuclear Power Plant License Renewal Request (ADAMS

Accession No. ML050670508)

March 10, 2005 Summary of a Conference Call Held on February 28, 2005, Between

the U.S. NRC and CEG Inc. Concerning the Review for the NMPNS,

Units 1 and 2, LIRA (ADAMS Accession No. ML050690308)

March 11, 2005 In a letter (signed by N. Le), the NRC staff revised the staffs review

schedule for the NMPNS (ADAMS Accession No. ML05050700134)

March 18, 2005 In a letter (signed by N. Le) the staff issued a Meeting Notice to

inform the public of a proposed meeting on March 30, 2005 to

provide time for CEG to discuss with NRC Management their

approach to the Recovery Plan for NMPNS LR activities (ADAMS

Accession No. ML050770042)

B-11
March 25,2005 Email from N. Le, NRC, to P. Mazzaferro, NMP, regarding Backlogged follow-up RAIs for the Aging Management of Auxiliary

Systems for NMP1 and NMP2 LRA - Docket Nos. 50-220 and 50-410

(ADAMS Accession No. ML051010073)

April 19, 2005 Summary of Meeting Held on March 30, 2005, Between the NRC

Staff and the CEG, Inc. Representatives to Discuss the Status of

Their Recovery Effort for NMP, Units 1 and 2, LRA (ADAMS

Accession No. ML051090540)

May 13, 2005 In a letter (signed by T. O'Connor), CEG provided a 60-day Notice

and informed the NRC that CEG intended to complete the recovery

tasks of the NMPNS LRA and will re-submit the information by July

15, 2005 (ADAMS Accession No. ML051440459)

May 20, 2005 Notice of June 9, 2005 Meeting with CEG Regarding the Recovery

Plan of License Renewal for NMP Units 1 & 2 (ADAMS Accession

No. ML051420002)

June 9, 2005 License Renewal IR 05000220-05-006 & 05000410-05-006, on

02/14-18/2005, 02/28/2005 - 0310412005 & 04/04/2005 - 04/08/2005,

NMP Nuclear Power Station, Unit I & Unit 2; Interim report of

inspection of the proposed aging management procedures and

compliance (ADAMS Accession No. ML051610037)

June 9, 2005 Presentation Slides, NMP, Units 1 and 2, LRA Status Update

(ADAMS Accession No. ML051650086)

June 16, 2005 Summary of Meeting held on June 9, 2005, between the U.S. NRC

Staff and CEG, Inc. Representatives to discuss the status of their

recovery effort, NMPNS, Units 1 and 2 (ADAMS Accession No.

ML051670446)

June 16, 2005 Email from N. Le, NRC, to D. Dellario, regarding NMP backlogged

follow-up RAIs for the Aging Management of Auxiliary Systems for

*NMP1 and NMP2 LRA (ADAMS Accession No. ML051730318)

June 17, 2005 Docketing of Additional Information pertaining to LRA of the NMPNS,

Units I and 2 (ADAMS Accession No. ML051750247)

July 14, 2005 Letter from J. Spina, NMP, to NRC regarding Recovery of NMP LRA

Quality (ADAMS Accession No. ML052000163)

July 14, 2005 In a letter, NMP1L 1962, (signed by James A. Spina), CEG provided

an amended LRA (ALRA) which is an enhancement to the original

NMPNS LRA which now has a more refined level of detail of

information (ADAMS Accession No. ML051440459)

July 14, 2005 Amended LRA for NMPNS provided with CEG letter NMP1L 1962

(ADAMS Accession No. ML051440459)

B-12
July 14, 2005 Section 3.0 thru Appendix D, Amended LRA for NMPNS provided

with CEG letter NMP1L 1962 (ADAMS Accession No. ML051440459)

July 14, 2005 In a letter, NMP1L 1963, (signed by James A. Spina), CEG provided

amended LRA (ALRA) reference boundary drawings used in

re-scoping and screening phase (ADAMS Accession No.

ML052000143)

July 14, 2005 In a letter, NMP1L 1958, (signed by James A. Spina), CEG provided

CEG's responses to the previously unanswered RAIs from NRC

(ADAMS Accession No. ML052000147)

July 14, 2005 In a letter, NMP1L 1960, (signed by James A. Spina), CEG provided

CEG's clarification to the previously answered RAIs from NRC

(ADAMS Accession No. ML052000175)

July 14, 2005 NMP LRA - Clarification to Responses to Previously Answered NRC

Requests for Additional Information (ADAMS Accession No.

ML052000173)

July 14, 2005 NMP - Amended LRA, July 2005, Technical Information (ADAMS

Accession No. ML052000186)

July 15,'2005 NRC Briefing for Delivery of the NMP Amended LRA (ADAMS

Accession No. ML052080213)

July 26, 2005 Note to file, docketing of additional information pertaining to LRA of

the NMPNS, Units I and 2 (ADAMS Accession No. ML052120003)

August 5, 2005 Letter from William Holston of NMPNS to Ms. Alyse Peterson

regarding Application for Renewal of Operating Licenses (ADAMS

Accession No. ML052310317)

August 12, 2005 Docketing of Additional Information Pertaining to LRA of the NMPNS,

Units 1 and 2 (ADAMS Accession No. ML052240223)

August 12, 2005 Note to File: Docketing of Additional Information Pertaining to LRA of

the NMPNS, Units 1 and 2 (ADAMS Accession No. ML052270151)

August 19, 2005 In a letter (signed by James A. Spina), CEG provided supplemental

letter for reformatting Sections 3.1.2, 3.2.2, 3.3.2, 3.4.2, 3.5.2, 3.6.2

(ADAMS Accession No. ML0525005723)

September 12, 2005 The staff forwarded a copy of the NRC Audit and Review Plan for

Plant Management Programs and Reviews for NMPNS ALRA. NRC

Audit scheduled for weeks of September 19 and October 24, 2005

(ADAMS Accession No. ML052780304)

September 15, 2005 In a letter (signed by James A. Spina), CEG provided responses to

staff RAls and a table of clarification to its in a section by section

(ADAMS Accession No. ML052700377), Subsequently this

information was superceded by new information by letter dated

Novemebr 17, 2005 (ADAMS Accession No. ML053320201)

B-1 3
September 30, 2005 In a letter (signed by P.T. Kuo), NRC issued the NRC's Draft

NUREG-1437, "Generic Environmental Impact Statement for License

Renewal of Nuclear Plants, Supplement 24, Regarding NMPNS,

Units 1 and 2." (ADAMS Accession Number ML052720075)

October 7, 2005 Docketing of additional information (signed by N Le) for NMP ALRA

Review (ADAMS Accession Number ML05052970005)

October 11, 2005 NRC Requests for Additional Information for the Review of NMPNS,

Units 1 and 2, LRA (ADAMS Accession No. ML052850264)

October 13, 2005 In a letter (signed by N. Le) the staff issued a revised schedule for

the staff review of the NMPNS ALRA and other audit & review

activities (ADAMS Accession No. ML052870573)

October 13, 2005 In a letter (signed by N Le) the staff issued a Meeting Notice to

inform the public of a proposed meeting on November 18, 2005 to

discuss results of the NRC audits and reviews of AMPs and AMRs for

NMPNS ALRA activities (ADAMS Accession No. ML052850010)

October 13, 2005 Docketing of additional information (signed by N Le) for NMP ALRA

Review (ADAMS Accession Number ML052940233)

October 13, 2005 In a letter (signed by L. Fields) the staff issued a Meeting Notice to

inform the public of a proposed meeting on November 17, 2005 to

discuss the draft Supplemental Environmental Impact Statement for

NMPNS ALRA activities (ADAMS Accession No. ML052900180)

October 15, 2005 NRC posted the data base for NMPNS LRA and ALRA NRC audits

and reviews (ADAMS Accession No. ML050660384)

October 24, 2005 Docketing of additional information (signed by N Le) for NMP ALRA

Review (ADAMS Accession Number ML05052970005)

October 28, 2005 NMP, Units I and 2, LRA - Responses to the NRC Requests for

Additional Information Regarding LRA Sections 2.3 and 2.4 (ADAMS

Accession No. ML053120311)

November 2, 2005 NRC Request for Additional Information for the review of NMPNS,

Units 1 and 2, Amended LRA (ADAMS Accession No. ML053070131)

November 16, 2005 In a letter (signed by Marvin Sykes), the staff provided CEG with its

inspection plan for the staff inspection of the NMPNS ALRA (ADAMS

Accession No. ML05053200262)

November 17, 2005 In a letter (signed by T. O'Connor), CEG provided new information to

supersede in its entirety the tabular clarification of information in CEG

letter dated 9/15/2005 to the previously answered RAIs from NRC

(ADAMS Accession No. ML053320201)

November 22, 2005 NRC Request for Additional Information for the Review of NMPNS,

Units land 2, Amended LRA (TAC Nos. MC3272 and MC3273)

(ADAMS Accession No. ML053290143)

B-14
November 23, 2005 NRC Audit of Aging Management Programs and Aging Management

Reviews for NMP Nuclear Power Station, Units 1 and 2 Database

(ADAMS Accession No. ML053470313) :-.

November 25, 2005 Comments (1) of Nancy Herter on Relicensing for NMPNS, Units 1 &

2 (ADAMS Accession No. ML053430114)

November 29, 2005 NRC Request for Additional Information for the Review of NMPNS,

Units 1 & 2, Amended LRA (TAC Nos. MC3272 and MC3273)

(ADAMS Accession No. ML053340117)

November 30, 2005 NMP Units 1 & 2, Amended LRA (ALRA) - Responses to NRC

Requests for Additional Information Regarding ALRA Parts 1,2, & 3

(TAC Nos. MC3272 & MC3273) (ADAMSWAccession No.

ML0534801196)

December 1, 2005 In a letter (signed by James A. Spina), CEG provided resolutions to

NRC audit items and a Table of resultant changes to the NMPNS

ALRA (ADAMS Accession No. ML053460458)

December 5, 2005 In a letter (signed by James A. Spina), CEG provided three editorial

changes and table replacement to the NMPNS ALRA (ADAMS

Accession No. ML0534801197)

December 8, 2005 Note to File - Docketing of Additional Information pertaining to LRA of

the NMPNS, Units 1 and 2 (ADAMS Accession No. ML053420477)

December 8, 2005 Email comments from Tom Gurdziel on NUREG-1437, Supplement

24, Draft, pertaining to LRA of NMPNS, Units 1 and 2 (ADAMS

Accession No. ML0603110472)

December 13, 2005 In a letter (signed by James A. Spina), CEG provided three changes

to previously submitted information in CEG letters dated December 1,

2005 and letter dated December 5, 2005 to the NMPNS ALRA

(ADAMS Accession No. ML053630052)

December 15, 2005 In a letter (signed by James A. Spina), CEG provided comments on

Draft Supplement 24 to the GElS for License Renewal of NMPNS

(ADAMS Accession No. ML053640304)

December 20 2005 In a letter (signed by Timothy O'Connor), CEG submitted its Annual

Update information as required by 10 CFR54.21(b) for License

Renewal of NMPNS (ADAMS Accession No. ML061080367)

December 21 2005 NMP, Units 1 and 2, LRA - Responses to the NRC Requests for

Additional Information Regarding LRA Section 3.4 (ADAMS

Accession No. ML050040315)

B-15
December 21 2005 In a meeting summary (signed by L. Field) the staff provided a

summary of information that was discussed to provide the public with

an opportunity to comment on the draft supplemental environmental

impact statement (DSEIS), which was issued September 29, 2005.

(ADAMS Accession No. ML053550507)

December 22, 2005 NRC Requests for Additional Information for Review of NMPNS,

Units I and 2, LRA (TAC MC3272 and MC3273) (ADAMS Accession

No. ML043650003)

December 23, 2005 NRC Request for Additional Information for the Review of NMPNS,

Units 1 and 2, Amended LRA (ADAMS Accession No. ML053570337)

January 5, 2006 Audit and Review Report for Plant Aging Management Reviews and

Programs, NMPNS, Units 1 and 2, Docket Nos: 50-220 and 50-410,

January 5, 2006 (ADAMS Accession No. ML060110119)

January 11,2006 NMP Units 1 and 2, Amended LRA - Responses to NRC Requests

for Additional Information - Sections 3.4 and 4.7 (ADAMS Accession

No. ML060130197)

January 11, 2006 In a meeting notice (signed by A Duncan White), the NRC provided

notice to the public of a proposed meeting on January 26, 2006, with

CEG, to dicuss results of the NRC regioanl inspection regarding the

NMPNS ALRA (ADAMS Accession No. ML0060100142)

January 12, 2006 NRC Request for Additional Information [Re TLAA 4.7.5 RWCU weld

overlaid fatigue flow calculation] for the Review of NMPNS, Units 1

and 2, Amended LRA (ADAMS Accession No. ML060210002)

January 13, 2006 NRC Requests for Additional Information for Review of NMPNS,

Units 1 and 2, LRA (TAC MC3272 and MC3273) (ADAMS Accession

No. ML050130283)

January 18, 2006 In a memorandum (signed by Kenneth Chang), the staff provided a

resultant report of its audit and review activities in determinating

whether the AMPs and AMRs for the NMPNS ALRA are in

compliance with 10 CFR Part 54 (ADAMS Accession No.

ML060180205)

January 18, 2006 In a meeting summary (signed by N Le) the staff provided a summary

of information that was discussed, with the applicant, concerning the

results of the staff audits and reviews of the AMPs and AMRs for the

NMPNS, Units I and 2, ALRA (ADAMS Accession No.

ML060220009)

January 19, 2006 NRC Press Release-I-06-003: NRC, Constellation To Discuss

License Renewal inspection Conducted At NMP Nuclear Power Plant

(ADAMS Accession No. ML060190560)

B-1 6
March 3, 2006 Transmittal Letter (signed by PT Kuo) regarding Safety Evaluation

Report with Open Items for the NMPNS, Units 1 and 2 LRA (ADAMS

Accession No. ML060580756)

March 3, 2006 Safety Evaluation Report with Open Items for the NMPNS, Units 1

and 2, LRA (ADAMS Accession No. ML060580758)

March 8, 2006 Docketing of email communication between the NRC staff and

Constellation Energy related to Environmental Review of NMPNS,

Units 1 and 2 LRA (ADAMS Accession No. ML060670503)

March 13, 2006 In a meeting notice (signed by N B Le), the NRC provided notice to

the public of a proposed meeting on March 27, 2006, with CEG, to

dicuss Open Item for NMP1 drywell liner regarding the SER for

NMPNS ALRA (ADAMS Accession No. ML060720396)

March 16, 2006 NRC Requests for Additional Information for the Review of NMPNS,

Units 1 and 2, ALRA (TAC MC3272 and MC3273) (ADAMS

Accession No. ML060800739)

March 23, 2006 In a letter (signed by Timothy O'Connor), CEG submitted its second

Update information per requirements of 10 CFR 54.21(b) for License

Renewal of NMPN (ADAMS Accession No. ML060950410)

March 23, 2006 In a letter (signed by Timothy O'Connor), CEG submitted its

response to Open Item 4.7B.1-1 for License Renewal of NMPN

(ADAMS Accession No. ML060950413)

March 29, 2006 Docketing of a telephone conference between the NRC staff and

Constellation Energy related to TLAA 4.7.1 and TLAA 4.7.5 of

NMPNS, Units I and 2 LRA (ADAMS Accession No. ML060890579)

March 29, 2006 Docketing of an email communication between the NRC staff and

Constellation Energy related to NMPNS, ALRA (ADAMS Accession

No. ML060940622)

April 3, 2006 Docketting of an email communication between the NRC staff and

Constellation Energy related to the bioshied letter dated April 4, 2006

for NMPNS, ALRA ADAMS Accession No. ML060940577)

April 3, 2006 In a letter (signed by Timothy O'Connor), CEG provided its

comments to the NMPNS SER (ADAMS Accession No.

MIL061020166)

April 4, 2006 In a letter (signed by Timothy O'Connor), CEG submitted its

response to Open Item 3.0.3.2.17-1 in NMPNS SER (ADAMS

Accession No. ML061020154)

April 18, 2006 Docketing of an email communication between the NRC staff and

Constellation Energy related to clarification of NMP2 Drywell

Supplemental Inspection information (ADAMS Accession No.

ML061090064)

B-17
April 18, 2006 Email communication between the NRC staff and Constellation

Energy related to clarification of NMP2 Drywell Supplemental

Inspection information (ADAMS Accession No. ML061090319)

April 19, 2006 NRC Requests for Additional Information for the Review of TLAA

4.7.5 of the NMPNS, Units 1 and 2, ALRA (TAC MC3272 and

MC3273). (ADAMS Accession No. ML061090106)

April 21, 2006 In a letter (signed by Timothy O'Connor), CEG submitted its

response to the staff RAI regarding TLAA 4.7.5 (ADAMS Accession

No. ML061220595)

August 2, 2006 In a letter (signed by Graham B. Wallis), ACRS provided a Report on

the Safety Aspect of the License Renewal Application for the Nine

Mile Point Nuclear Station, Units 1 and 2. (ADAMS Accession No.

ML061380269)

B-1 8
APPENDIX C: PRINCIPAL CONTRIBUTORS

NAME RESPONSIBILITY

H. Ashar

W. Bateman

J. Burns

M. Case

P. Chen

T. Chan

K. Chang

R. Dennig

J. Fair

E. Forrest

G. Galletti

F. Gillespie

Q. Gan

R. Goel

K. Gruss

J. Hannon

P. Hiland

R. Hsu

E. Imbro

N. Igbal

D. Jeng

R. Jenkins

S. Jones

M. Khanna

P. Kuo

N. Le

S. Lee

C. Li

Y. Li

L. Lund

J. Lyons

K. Manoly

T. Martin

D. Matthews

M. Mayfield

J. Medoff

M. Mitchel

M. Modes

J Nakoski

D. Nguyen

P. Patnaik

T. Quay

J. Rajan

S. Richard

Civil Engineering

Management Oversight

Reactor Systems

Management Oversight

Engineering Mechanics

Management Oversight

Mechanical Engineering

Management Oversight

Engineering Mechanics

Containment Systems

Quality & Vendor

Management Oversight

General Engineer

Containment Systems

Management Oversight

Management Oversight

Management Oversight

GALL Audit and Review

Management Oversight

Fire Protection

Civil Engineering

Management Oversight

Management Oversight

Vessels & Internals Integrity

Management Oversight

Lead Project Manager

Management Oversight

Balance of Plant

Engineering Mechanics

Management Oversight

Management Oversight

Management Oversight

Management Oversight

Management Oversight

Management Oversight

Flaw Evaluation & Welding

Management Oversight

Region I Inspections

Management Oversight

Electrical Engineering

Piping Integrity

Management Oversight

Engineering Mechanics

Management Oversight

C-1
B. Rogers

D. Shum

A. Stubbs

S. Subinoy

M. Sykes

D. Thatcher

L. Tran

M. Tschiltz

S. Weerakkody

P. Wen

J. Wermiel

J. Zimmerman

Quality & Vendor

Balance of Plant

Balance of Plant

Electrical Engineering

Management Oversight (Reg. I

Inpections)

Management Oversight

GALL Audit and Review

Management Oversight

Management Oversight

GALL Audit and Review

Management Oversight

Management Oversight

CONTRACTORS

CONTRACTOR

Information Systems Laboratories

Information Systems Laboratories

Legin Group, Inc.

TECHNICAL AREA

GALL Audit

Balance of Plant

SER Support

C-2
APPENDIX D: REFERENCES

This appendix contains a listing of references used in the preparation of the Safety Evaluation

Report prepared during the review of the license renewal application for Brunswick Steam

Electric Plant, Units 1 and 2, Docket Numbers 50-325 and 50-324, respectively.

(1) NUREG-1800, -Standard Review Plan for Review of License Renewal Applications for

Nuclear Power Plants," April 2001

(2) NEI 95-10, "Industry Guideline for Implementing the Requirements of 10 CFR Part 54-

The License Renewal Rule, Revision 3," August 2001

(3) NUREG-1801, 'Generic Aging Lessons Learned Report (GALL)," April 2001

(4) Letters From NRC to Mr. James A. Spina, "Request For Additional Information (RAI)

Regarding The License Renewal Application For The Nine Mile Point Nuclear Station,

Units 1 and 2"

(5) NMP Technical Report, LRPBD-IWBCD, "AMSE Section XI Inservice Inspection, Sub

Sections IWB IWC, and IWD (Units 1 and 2)," Revison 0, 9/9/2005

(6) NMP Technical Report, LR-PBD-WCHEM, "Water Chemistry (Units 1 and 2)," Revision

0, 9/14/2005

(7) NMP Technical Report, LR-PBD-HDSTUDS, "Reactor Head Closure Studs Program,"

Revision 1, 9/7/2005

(8) Letter from U.S. Nuclear Regulatory Commission to Niagara Mohawk Power

Corporation dated October 5, 2000, Subject: Nine Mile Point Nuclear Station, Unit No. 1

- Reliefs for the Third 10-Year Inservice Inspection Program Plan, Revision 1 (TAC No.

MA7129)

(9) NMP Technical Report, LR-PBD-VIDWELDS, "BWR Vessel ID Attachment Welds

Program (Units I and 2)," Revision 0, 9/15/2005

(10) NUREG-1544, "Status Report: Intergranular SCC of BWR Core Shroud and Other

Internal Components," March 1996

(11) NRC Regulatory Guide 1.65, "Materials and Inspections for Reactor Vessel Closure

Studs," October 1973

(12) NMP Technical Report, LR-PBD-FWNZL, "BWR Feedwater Nozzle," Revision 0,

9/7/2005

(13) NMP Technical Report, LR-PBD-SCC, "BWR Stress Corrosion Cracking (Units 1 and

2)," Revision 0, 9/7/2005

D-1
(14) NMP1-RI-ISI-003, "Alternative Risk-Informed Inservice Inspection Plan and Schedule,"

Revision 01, 12/4/2003. NMP2-RI-ISI-006, "Alternative Risk-Informed Inservice

Inspection Plan and Schedule," Revision 00, 12/5/2003

(15) NMP Technical Report, LR-PBD-VSSLPENS, "BWR Penetrations (Units 1 and 2),"

Revision 0, 9/15/2005

(16) NMP Technical Report, LR-PBD-RVI, "BWR Vessel Internals (Units 1 and 2),"

Revision 0, 9/15/2005

(17) ECPN-N1-HE-001, "NMP Unit 1 Erosion Corrosion Program Carbon Steel Piping

Review Program High Energy Systems," Revision 5. ECPR-N2-HE-003, "NMP Unit 2

Carbon Steel and Low Alloy Piping Systems Erosion Corrosion (E/C) Review Program,"

Revision 0

(18) NMP Technical Report, LR-PBD-U1OCCW, "Open-Cycle Cooling Water System

(Unit 1)," Revision 0, 9/14/2005. NMP Technical Report, LR-PBD-U1CCCW,

"Closed-Cycle Cooling Water System (Unit 1)," Revision 0, 9/14/2005

(19) NMP Technical Report, LR-PBD-RVI, "BWR Vessel Internals (Units 1 and 2)," Revision

0, 9/15/2005

(20) NMP-AMP BFX01, Rev 0, "NMP1 Program Plan for Spent Fuel Rack Boraflex

Degradation Monitoring Program"

(21) NMP Technical Report, LR-PBD-OHLOAD, "Inspection of Overhead Heavy Load and

Light Load (Related to Refueling) Handling Systems (Units 1 and 2)," Revision 0,

9/12/2005

(22) NMP Technical Report, LR-PBD-COMPAIR, "Compressed Air Monitoring (Unit 1 only),"

Revision 0, 9/13/2005

(23) NMP Unit 1 and 2 Reactor Water Cleanup System (GALL XI.M25) Program Attribute

Assessment, Revision 1, 8/5/2004 .

(24) NMP Technical Report, LR-PBD-FIREPRO, "Fire Protection," Revision 0, 9/12/2005

(25) NMP Technical Report, LR-PBD-FIREWATER, "Fire Water," Revision 0, 9/12/2005

(26) N2-FSP-FPW-ROO1, "Electric/Diesel Fire Pump Functional Test," Revision 6,

10/23/2003. N1-PM-C3, "Electric and Diesel Fire Pump Performance Tests,"

Revision 5, 8/29/2003

(27) NMP Technical Report, LR-PBD-U1FOCHEM, "Fuel Oil Chemistry (Unit 1)," Revision 0,

9/14/2005

(28) NMP Technical Report, LR-PBD-OTINSP, "One-Time Inspection," Revision 0, 9/9/2005

D-2
(29) NMP Technical Report, LR-PBD-IWE, "ASME Section Xl, Subsection IWE (Units 1 and

2)," Revision 2, 9/20/2005

(30) NMP Technical Report, LR-PBD-IWF, "ASME Section XI, Subsection IWF (Units I and

2)," Revision 1, 9/7/2005

(31) NMP Technical Report, LR-PBD-APPJ, "Program Attribute Assessment: Unit 1

10 CFR 50, Appendix J Program and Unit 2 10 CFR 50, Appendix J Program"

(32) NMP Technical Report, LR-PBD-STRUCMON, "Structures Monitoring Program (Units 1

and 2)," Revision 0, 9/12/2005

(33) NMP Technical Report, LR-PBP-ELECT1, "Aging Management Program for Electrical

Cables and Connections not Subject to 10 CFR 50.49 Environmental Qualification

Requirement," Revision 0, 9/14/2005

(34) NMP Technical Report, LR-PBD-ELECT2, "Electrical Cables and Connections Not

Subject to 10 CFR 50.49 Environmental Qualification Requirements Used in

Instrumentation Circuits," Revision 2, 9/16/2005

(35) NMP Technical Report, LR-PBD-ELECT3, "Inaccessible Medium-Voltage Cable not

Subject to 10 CFR 50.49 Environmental Qualification Requirements (Unit 2 Only),"

Revision 0, 10/10/2005

(36) NMP Technical Report, LR-PBD-ELECT4, "Aging Management Program for Bus Duct,"

Revision 0, 9/9/2005

(37) NMP Technical Report, LR-PBD-CRDRL, "BWR Control Rod Drive Return Line Nozzle

(Units I and 2)," Revision 1, 9/7/2005

(38) NMP Technical Report, LR-PBD-ELECTPOLE, "Wooden Power Pole Inspection

Program," Revision 0, 9/9/2005

(39) NIP-REL-06, Revision 02, "Fatigue Monitoring Program," 7/20/2004

(40) NER-1 S-035, "Report on System Review and Recommendations for a Transient and

Fatigue Monitoring System at the Nine Mile Point Nuclear Station," Revision 0,

2/10/2004

D-3

1I

NRC FORM 335 U.S. NUCLEAR REGULATORY COMMISSION 1. REPORT NUMBER

(9-2004) (Assigned by NRC, Add Vol., Supp., Rev.

NRCMD 3.7 and Addendum Numbers, IH any.)

BIBLIOGRAPHIC DATA SHEET

(See instruchions on the reverse) NUREG-1900 Vol. 2

2. TITLE AND SUBTITLE 3. DATE REPORT PUBLISHED

Safety Evaluation Report MONTH YEAR

Related to the License Renewal of Nine Mile Point Nuclear Station, Units I and 2 September 2006

4. FIN OR GRANT NUMBER

AUTHOR(S) 6. TYPE OF REPORT

Tommy Le

7. PERIOD COVERED (Inclusive Dates)

. PERFORMING ORGANIZATION - NAME AND ADDRESS (If NRC. provide Division, Office or Region, U.S. Nuclear Regulatory Commission, and maiing address; fcontractor, provide name and rnaikg address.)

Division of License Renewal

Office of Nuclear Reactor Regulation

U.S. Nuclear Regulatory Commission

Washington, DC 20555-0001

9. SPONSORING ORGANIZATION - NAME AND ADDRESS (If NRC, type Same as above; if contractor, provide NRC Division, Office or Region, U.S. Nuclear Regulatory Commission,

and mailing address.)

Same as above

10. SUPPLEMENTARY NOTES

11. ABSTRACT (200 words or less)

This safety evaluation report (SER) documents the technical review of the Nine Mile Point Nuclear Station Units, 1 and 2

(NMPNS), license renewal application (LRA) by the staff of the U.S. Nuclear Regulatory Commission (NRC) (the staff). By letter

dated May 26, 2004, Constellation Energy Group, LLC submitted the LRA for NMPNS in accordance with Title10, Part 54, of

the Code of Federal Regulations (1 OCFRPart54). Due to concerns with the adequacy of support for and documentation of the

license renewal activities in the initial submission, the applicant submitted an amended LRA (ALRA) on July14, 2005.

Constellation Energy Group, LLC is requesting renewal of the operating licenses for NMPNS (Facility Operating License

NumbersDPR-63 and NPF-69, respectively), for a period of 20 years beyond the current expiration dates of midnight August 22,

2009, for Unit 1 (NMP1) and midnight October 31, 2026, for Unit 2 (NMP2).

This SER presents the status of the staff's review of information submitted to the staff through April 21, 2006, the cutoff date for

consideration in this SER. On March 3, 2006, the staff issued a draft SER which identified two open items that had to be

resolved before the staff makes a final determination on the application. The two open items have now been resolved and SER

Section1.5 summarizes these items and their resolutions. SER Section 6 provides the staff's final conclusion on the review of

the NMPNS License Renewal Application dated May 26, 2004, as amended July 14, 2005, and all its subsequent supplemental

letters as listed in SER Appendix B.

i

12. KEY WORDS/DESCRIPTORS (List words or phrases that will assist researchers in locating the report.) 13. AVAILABILITY STATEMENT

license renewal, nuclear power unlimited

14. SECURITY CLASSIFICATION

(This Page)

unclassified

(This Report)

unclassified

IS. NUMBER OF PAGES

16. PRICE

N•FORM 335 (9-2004) PRINTED ON RECYCLED PAPER
ornreyled

paperyld

Federal Recycling Program
UNITED STATES

NUCLEAR REGULATORY COMMISSION

WASHINGTON, DC 20555-0001

OFFICIAL BUSINESS