NUREG-2191, Vol. 2

Generic Aging Lessons 

Learned for Subsequent 

License Renewal 

(GALL-SLR) Report 

Final Report

Office of Nuclear Reactor Regulation

NUREG-2191, Vol. 2

Generic Aging Lessons 

Learned for Subsequent 

License Renewal 

(GALL-SLR) Report

Final Report

Manuscript Completed: May 2017

Date Published: July 2017

Office of Nuclear Reactor Regulation

iii

ABSTRACT

This document provides guidance on the content of applications for renewal of the initial renewed 

operating license. The initial renewed operating license is the first renewed license issued under 

Title 10 of the Code of Federal Regulations (10 CFR) Part 54, “Requirements for Renewal of 

Operating Licenses for Nuclear Power Plants,” after either supersession or the expiration of the 

original operating license issued under either 10 CFR Part 50 or Part 52 following the completion 

of construction under a construction permit issued under Part 50, or a combined license issued 

under Part 52. In this guidance document, the renewal of the initial renewed operating license is 

referred to as “subsequent license renewal” (SLR). NUREG–2191, “Generic Aging Lessons 

Learned for Subsequent License Renewal (GALL-SLR) Report,” provides guidance for SLR 

applicants. The GALL-SLR Report contains the U.S. Nuclear Regulatory Commission (NRC)

staff’s generic evaluation of plant aging management programs (AMPs) and establishes the 

technical basis for their adequacy. The GALL-SLR Report contains recommendations on specific 

areas for which existing AMPs should be augmented for SLR. An applicant may reference this 

report in an SLR application to demonstrate that the AMPs at the applicant’s facility correspond to 

those described in the GALL-SLR Report. If an applicant credits an AMP in the GALL-SLR 

Report, it is incumbent on the applicant to ensure that the conditions and operating experience 

(OE) at the plant are bounded by the conditions and OE for which the GALL-SLR Report program 

was evaluated. If these bounding conditions are not met, it is incumbent on the applicant to 

address any additional aging effects and augment the AMPs for SLR. For AMPs that are based 

on the GALL-SLR Report, the NRC staff will review and verify whether the applicant’s AMPs are 

consistent with those described in the GALL-SLR Report, including applicable plant conditions 

and OE. The focus of the NRC staff’s review of an SLR application is on those AMPs that an 

applicant has enhanced to be consistent with the GALL-SLR Report, those AMPs for which the 

applicant has taken an exception to the program described in the GALL-SLR Report, and 

plant-specific AMPs not described in the GALL-SLR Report. 

This document is a companion document to NUREG–2192, “Standard Review Plan for Review of 

Subsequent License Renewal Applications for Nuclear Power Plants,” (SRP-SLR) that provides 

guidance to NRC staff on the review of SLR applications. The guidance in this document is for 

the use of future applicants for SLR. The NRC does not intend to impose the guidance in 

this document on current holders of an initial operating license. However, this document 

encompasses all of the guidance applicable to initial license renewal. Accordingly, both current 

holders of initial operating licenses as well as future applicants for initial license renewal may 

voluntarily choose to reference an AMP in the GALL-SLR Report in their applications. However, 

such applicants should inform the NRC that they plan to demonstrate consistency with the 

GALL-SLR Report. 

Both the GALL-SLR Report and the SRP-SLR were published for public comment in 

December 2015, with the comment period ending February 29, 2016. The staff received over 

300 pages of comments from interested stakeholders. These comments were reviewed and 

dispositioned by the staff. The disposition of these comments and the technical bases for the 

staffs’ agreement or disagreement with these comments will be published shortly in a NUREG. 

The staff will also publish a second NUREG that will document all the technical changes made to 

the license renewal guidance documents for first license renewal (i.e., for operation from 40 years 

to 60 years), along with the technical bases for these changes.

v

TABLE OF CONTENTS

Section Page

ABSTRACT.....................................................................................................................................iii

LIST OF TABLES ...........................................................................................................................xi

LIST OF CONTRIBUTORS............................................................................................................xv

ABBREVIATIONS......................................................................................................................... xix

INTRODUCTION.......................................................................................................................... xxv

BACKGROUND..........................................................................................................................xxvii

OVERVIEW OF THE GENERIC AGING LESSONS LEARNED FOR SUBSEQUENT 

LICENSE RENEWAL (GALL-SLR) REPORT EVALUATION PROCESS................................. xxxi

EXPLANATION OF THE USE OF MULTIPLE AGING MANAGEMENT PROGRAMS

IN AGING MANAGEMENT REVIEW ITEMS ............................................................................ xxxv

REFERENCES..........................................................................................................................xxxvii

GUIDANCE ON USE OF LATER EDITIONS/REVISIONS OF 

VARIOUS INDUSTRY DOCUMENTS .......................................................................................xxxix

APPLICATION OF THE GENERIC AGING LESSONS LEARNED FOR SUBSEQUENT 

LICENSE RENEWAL (GALL-SLR) REPORT............................................................................... xli

I APPLICATION OF THE AMERICAN SOCIETY OF MECHANICAL ENGINEERS

BOILER AND PRESSURE VESSEL CODE .................................................................... l-1

II CONTAINMENT STRUCTURES..................................................................................... II-1

II PRESSURIZED WATER REACTOR CONTAINMENTS.................................. II-3

A1 CONCRETE CONTAINMENTS 

(REINFORCED AND PRESTRESSED).......................................................II A1-1

A2 STEEL CONTAINMENTS............................................................................II A2-1

A3 COMMON COMPONENTS..........................................................................II A3-1

II BOILING WATER REACTOR CONTAINMENTS ..........................................II B-1

B1 MARK I CONTAINMENTS ...........................................................................II B1-1

B2 MARK II CONTAINMENTS ..........................................................................II B2-1

II MARK III CONTAINMENTS............................................................................ II B3

B3 MARK III CONTAINMENTS.........................................................................II B3-1

B4 COMMON COMPONENTS..........................................................................II B4-1

III STRUCTURES AND COMPONENT SUPPORTS.......................................................III-1

III SAFETY-RELATED AND OTHER STRUCTURES........................................III-3

A1 GROUP 1 STRUCTURES (BOILING WATER REACTOR

BUILDING, PRESSURIZED WATER REACTOR

SHIELD BUILDING, CONTROL ROOM/BUILDING) ............................... III A1-1

A2 GROUP 2 STRUCTURES (BOILING WATER REACTOR 

BUILDING WITH STEEL SUPERSTRUCTURE)..................................... III A2-1

A3 GROUP 3 STRUCTURES (AUXILIARY BUILDING, DIESEL

GENERATOR BUILDING, RADWASTE BUILDING, TURBINE

BUILDING, SWITCHGEAR ROOM, YARD STRUCTURES,

SUCH AS AUXILIARY FEEDWATER PUMPHOUSE, UTILITY/PIPING 

TUNNELS, SECURITY/LIGHTING POLES, MANHOLES, DUCT

BANKS; STATION BLACKOUT STRUCTURES, SUCH AS

TRANSMISSION TOWERS, STARTUP TOWERS CIRCUIT

BREAKER FOUNDATION, ELECTRICAL ENCLOSURE)....................... III A3-1
vi

A4 GROUP 4 STRUCTURES (CONTAINMENT INTERNAL

STRUCTURES, EXCLUDING REFUELING CANAL).............................. III A4-1

A5 GROUP 5 STRUCTURES (FUEL STORAGE FACILITY, 

REFUELING CANAL) ............................................................................. III A5-1

A6 GROUP 6 STRUCTURES (WATER-CONTROL STRUCTURES)........... III A6-1

A7 GROUP 7 STRUCTURES (CONCRETE TANKS AND 

MISSILE BARRIERS) ............................................................................. III A7-1

A8 GROUP 8 STRUCTURES (STEEL TANKS AND

MISSILE BARRIERS) ............................................................................. III A8-1

A9 GROUP 9 STRUCTURES (BOILING WATER REACTOR UNIT

VENT STACK) ........................................................................................ III A9-1

III COMPONENT SUPPORTS ...................................................................... III B-1

B1 SUPPORTS FOR ASME PIPING AND COMPONENTS......................... III B1-1

B2 SUPPORTS FOR CABLE TRAYS, CONDUIT, HVAC DUCTS, 

TUBETRACK®, INSTRUMENT TUBING, NON-ASME PIPING 

AND COMPONENTS.............................................................................. III B2-1

B3 ANCHORAGE OF RACKS, PANELS, CABINETS, AND 

ENCLOSURES FOR ELECTRICAL EQUIPMENT AND 

INSTRUMENTATION.............................................................................. III B3-1

B4 SUPPORTS FOR EMERGENCY DIESEL GENERATOR, HEATING 

VENTILATION, AND AIR CONDITIONING SYSTEM COMPONENTS,

AND OTHER MISCELLANEOUS MECHANICAL EQUIPMENT ............. III B4-1

B5 SUPPORTS FOR PLATFORMS, PIPE WHIP RESTRAINTS, JET 

IMPINGEMENT SHIELDS, MASONRY WALLS, AND OTHER

MISCELLANEOUS STRUCTURES ........................................................ III B5-1

IV REACTOR VESSEL, INTERNALS, AND REACTOR COOLANT SYSTEM............... IV-1

A1 REACTOR VESSEL (BOILING WATER REACTOR) .............................IV A1-1

A2 REACTOR VESSEL (PRESSURIZED WATER REACTOR) ...................IV A2-1

B1 REACTOR VESSEL INTERNALS (BOILING WATER REACTOR) .........IV B1-1

B2 REACTOR VESSEL INTERNALS (PRESSURIZED WATER 

REACTOR)—WESTINGHOUSE.............................................................IV B2-1

B3 REACTOR VESSEL INTERNALS (PRESSURIZED WATER 

REACTOR)—COMBUSTION ENGINEERING........................................IV B3-1

B4 REACTOR VESSEL INTERNALS (PRESSURIZED WATER

REACTOR)—BABCOCK AND WILCOX.................................................IV B4-1

C1 REACTOR COOLANT PRESSURE BOUNDARY 

(BOILING WATER REACTOR)...............................................................IV C1-1

C2 REACTOR COOLANT SYSTEM AND CONNECTED LINES 

(PRESSURIZED WATER REACTOR) ....................................................IV C2-1

D1 STEAM GENERATOR (RECIRCULATING)............................................IV D1-1

D2 STEAM GENERATOR (ONCE-THROUGH)............................................IV D2-1

E COMMON MISCELLANEOUS MATERIAL/

ENVIRONMENT COMBINATIONS ...........................................................IV E-1

V ENGINEERED SAFETY FEATURES..........................................................................V-1

A CONTAINMENT SPRAY SYSTEM 

(PRESSURIZED WATER REACTOR) .......................................................V A-1

B STANDBY GAS TREATMENT SYSTEM 

(BOILING WATER REACTOR) .................................................................V B-1

C CONTAINMENT ISOLATION COMPONENTS...........................................V C-1
vii

D1 EMERGENCY CORE COOLING SYSTEM 

(PRESSURIZED WATER REACTOR) .....................................................V D1-1

D2 EMERGENCY CORE COOLING SYSTEM 

(BOILING WATER REACTOR)................................................................V D2-1

E EXTERNAL SURFACES OF COMPONENTS AND 

MISCELLANEOUS BOLTING....................................................................V E-1

F COMMON MISCELLANEOUS MATERIAL/ 

ENVIRONMENT COMBINATIONS ............................................................V F-1

VI ELECTRICAL COMPONENTS ..................................................................................VI-1

A EQUIPMENT NOT SUBJECT TO 10 CFR 50.49 ENVIRONMENTAL

QUALIFICATION REQUIREMENTS.........................................................VI A-1

B EQUIPMENT SUBJECT TO 10 CFR 50.49 ENVIRONMENTAL

QUALIFICATION REQUIREMENTS.........................................................VI B-1

VII AUXILIARY SYSTEMS.............................................................................................VII-1

A1 NEW FUEL STORAGE..........................................................................VII A1-1

A2 SPENT FUEL STORAGE.......................................................................VII A2-1

A3 SPENT FUEL POOL COOLING AND CLEANUP 

(PRESSURIZED WATER REACTOR) ...................................................VII A3-1

A4 SPENT FUEL POOL COOLING AND CLEANUP 

(BOILING WATER REACTOR)..............................................................VII A4-1

A5 SUPPRESSION POOL CLEANUP SYSTEM 

(BOILING WATER REACTOR)..............................................................VII A5-1

B OVERHEAD HEAVY LOAD AND LIGHT LOAD 

(RELATED TO REFUELING) HANDLING SYSTEMS ................................VII B-1

C1 OPEN-CYCLE COOLING WATER SYSTEM 

(SERVICE WATER SYSTEM) ...............................................................VII C1-1

C2 CLOSED-CYCLE COOLING WATER SYSTEM.....................................VII C2-1

C3 ULTIMATE HEAT SINK ........................................................................VII C3-1

D COMPRESSED AIR SYSTEM .................................................................VII D-1

E1 CHEMICAL AND VOLUME CONTROL SYSTEM 

(PRESSURIZED WATER REACTOR) ...................................................VII E1-1

E2 STANDBY LIQUID CONTROL SYSTEM 

(BOILING WATER REACTOR) .............................................................VII E2-1

E3 REACTOR WATER CLEANUP SYSTEM 

(BOILING WATER REACTOR) .............................................................VII E3-1

E4 SHUTDOWN COOLING SYSTEM 

(OLDER BOILING WATER REACTOR).................................................VII E4-1

E5 WASTE WATER SYSTEMS ..................................................................VII E5-1

F1 CONTROL ROOM AREA VENTILATION SYSTEM .............................. VII F1-1

F2 AUXILIARY AND RADWASTE AREA VENTILATION SYSTEM............ VII F2-1

F3 PRIMARY CONTAINMENT HEATING AND VENTILATION SYSTEM...VII F3-1

F4 DIESEL GENERATOR BUILDING VENTILATION SYSTEM ................VII F4-1

G FIRE PROTECTION .............................................................................. VII G-1

H1 DIESEL FUEL OIL SYSTEM..................................................................VII H1-1

H2 EMERGENCY DIESEL GENERATOR SYSTEM ..................................VII H2-1

I EXTERNAL SURFACES OF COMPONENTS AND

MISCELLANEOUS BOLTING...................................................................VII I-1

J COMMON MISCELLANEOUS MATERIAL/

ENVIRONMENT COMBINATIONS .......................................................... VII J-1
viii

VIII STEAM AND POWER CONVERSION SYSTEM .........................................................VIII-1

A STEAM TURBINE SYSTEM .......................................................................VIII A-1

B1 MAIN STEAM SYSTEM (PRESSURIZED WATER REACTOR) ..............VIII B1-1

B2 MAIN STEAM SYSTEM (BOILING WATER REACTOR) .........................VIII B2-1

C EXTRACTION STEAM SYSTEM............................................................... VIII C-1

D1 FEEDWATER SYSTEM (PRESSURIZED WATER REACTOR)............. VIII D1-1

D2 FEEDWATER SYSTEM (BOILING WATER REACTOR)........................ VIII D2-1

E CONDENSATE SYSTEM............................................................................VIII E-1

F STEAM GENERATOR BLOWDOWN SYSTEM 

(PRESSURIZED WATER REACTOR)........................................................VIII F-1

G AUXILIARY FEEDWATER SYSTEM 

(PRESSURIZED WATER REACTOR).......................................................VIII G-1

H EXTERNAL SURFACES OF COMPONENTS AND 

MISCELLANEOUS BOLTING.................................................................... VIII H-1

I COMMON MISCELLANEOUS MATERIAL/

ENVIRONMENT COMBINATIONS..............................................................VIII I-1

IX USE OF TERMS FOR STRUCTURES, COMPONENTS, MATERIALS, 

ENVIRONMENTS, AGING EFFECTS, AND AGING MECHANISMS............................IX-1

A INTRODUCTION .........................................................................................IX A-1

B STRUCTURES AND COMPONENTS..........................................................IX B-1

C MATERIALS ................................................................................................IX C-1

D ENVIRONMENTS........................................................................................IX D-1

E AGING EFFECTS........................................................................................IX E-1

F SIGNIFICANT AGING MECHANISMS.........................................................IX F-1

G REFERENCES ........................................................................................... IX G-1

X AGING MANAGEMENT PROGRAMS THAT MAY BE USED TO 

DEMONSTRATE ACCEPTABILITY OF TIME-LIMITED AGING ANALYSES 

IN ACCORDANCE WITH 10 CFR 54.21(c)(1)(iii) .......................................................X-1

X.M1 FATIGUE MONITORING ..................................................................... X.M1-1

X.M2 NEUTRON FLUENCE MONITORING.................................................. X.M2-1

X.S1 CONCRETE CONTAINMENT UNBONDED 

TENDON PRESTRESS ........................................................................X.S1-1

X.E1 ENVIRONMENTAL QUALIFICATION OF 

ELECTRIC EQUIPMENT ......................................................................X.E1-1

XI AGING MANAGEMENT PROGRAMS...........................................................................XI-1

XI.M1 ASME SECTION XI INSERVICE INSPECTION, SUBSECTIONS

IWB, IWC, AND IWD...............................................................................XI.M1-1

XI.M2 WATER CHEMISTRY .............................................................................XI.M2-1

XI.M3 REACTOR HEAD CLOSURE STUD BOLTING......................................XI.M3-1

XI.M4 BWR VESSEL ID ATTACHMENT WELDS.............................................XI.M4-1

XI.M5 DELETED................................................................................................XI.M5-1

XI.M6 DELETED................................................................................................XI.M6-1

XI.M7 BWR STRESS CORROSION CRACKING.......................................... XI.M7-1

XI.M8 BWR PENETRATIONS....................................................................... XI.M8-1

XI.M9 BWR VESSEL INTERNALS................................................................ XI.M9-1

XI.M10 BORIC ACID CORROSION ..................................................................XI.M10-1
ix

XI.M11B CRACKING OF NICKEL-ALLOY COMPONENTS AND LOSS 

OF MATERIAL DUE TO BORIC ACID-INDUCED CORROSION IN 

REACTOR COOLANT PRESSURE BOUNDARY 

COMPONENTS (PWRs ONLY)......................................................... XI.M11B-1

XI.M12 THERMAL AGING EMBRITTLEMENT OF CAST AUSTENITIC 

STAINLESS STEEL (CASS).................................................................XI.M12-1

XI.M16A PWR VESSEL INTERNALS............................................................... XI.M16A-1

XI.M17 FLOW-ACCELERATED CORROSION.................................................XI.M17-1

XI.M18 BOLTING INTEGRITY ..........................................................................XI.M18-1

XI.M19 STEAM GENERATORS .......................................................................XI.M19-1

XI.M20 OPEN-CYCLE COOLING WATER SYSTEM .......................................XI.M20-1

XI.M21A CLOSED TREATED WATER SYSTEMS .......................................... XI.M21A-1

XI.M22 BORAFLEX MONITORING...................................................................XI.M22-1

XI.M23 INSPECTION OF OVERHEAD HEAVY LOAD AND LIGHT LOAD 

(RELATED TO REFUELING) HANDLING SYSTEMS..........................XI.M23-1

XI.M24 COMPRESSED AIR MONITORING .....................................................XI.M24-1

XI.M25 BWR REACTOR WATER CLEANUP SYSTEM ...................................XI.M25-1

XI.M26 FIRE PROTECTION..............................................................................XI.M26-1

XI.M27 FIRE WATER SYSTEM ........................................................................XI.M27-1

XI.M29 OUTDOOR AND LARGE ATMOSPHERIC METALLIC

STORAGE TANKS................................................................................XI.M29-1

XI.M30 FUEL OIL CHEMISTRY ........................................................................XI.M30-1

XI.M31 REACTOR VESSEL MATERIAL SURVEILLANCE ..............................XI.M31-1

XI.M32 ONE-TIME INSPECTION......................................................................XI.M32-1

XI.M33 SELECTIVE LEACHING .......................................................................XI.M33-1

XI.M35 ASME CODE CLASS 1 SMALL-BORE PIPING ...................................XI.M35-1

XI.M36 EXTERNAL SURFACES MONITORING OF 

MECHANICAL COMPONENTS............................................................XI.M36-1

XI.M37 FLUX THIMBLE TUBE INSPECTION ..................................................XI.M37-1

XI.M38 INSPECTION OF INTERNAL SURFACES IN MISCELLANEOUS 

PIPING AND DUCTING COMPONENTS .............................................XI.M38-1

XI.M39 LUBRICATING OIL ANALYSIS.............................................................XI.M39-1

XI.M40 MONITORING OF NEUTRON-ABSORBING MATERIALS 

OTHER THAN BORAFLEX...................................................................XI.M40-1

XI.M41 BURIED AND UNDERGROUND PIPING AND TANKS .......................XI.M41-1

XI.M42 INTERNAL COATINGS/LININGS FOR IN-SCOPE PIPING, 

PIPING COMPONENTS, HEAT EXCHANGERS, AND TANKS...........XI.M42-1

XI.S1 ASME SECTION XI, SUBSECTION IWE.................................................XI.S1-1

XI.S2 ASME SECTION XI, SUBSECTION IWL.................................................XI.S2-1

XI.S3 ASME SECTION XI, SUBSECTION IWF.................................................XI.S3-1

XI.S4 10 CFR PART 50, APPENDIX J ..............................................................XI.S4-1

XI.S5 MASONRY WALLS..................................................................................XI.S5-1

XI.S6 STRUCTURES MONITORING ...............................................................XI.S6-1

XI.S7 INSPECTION OF WATER-CONTROL STRUCTURES

ASSOCIATED WITH NUCLEAR POWER PLANTS ...............................XI.S7-1

XI.S8 PROTECTIVE COATING MONITORING AND MAINTENANCE ............XI.S8-1

XI.E1 ELECTRICAL INSULATION FOR ELECTRICAL CABLES AND 

CONNECTIONS NOT SUBJECT TO 10 CFR 50.49 

ENVIRONMENTAL QUALIFICATION REQUIREMENTS........................XI.E1-1
x

XI.E2 ELECTRICAL INSULATION FOR ELECTRICAL CABLES AND

CONNECTIONS NOT SUBJECT TO 10 CFR 50.49 

ENVIRONMENTAL QUALIFICATION REQUIREMENTS USED IN

INSTRUMENTATION CIRCUITS.............................................................XI.E2-1

XI.E3A ELECTRICAL INSULATION FOR INACCESSIBLE 

MEDIUM-VOLTAGE POWER CABLES NOT SUBJECT TO 

10 CFR 50.49 ENVIRONMENTAL QUALIFICATION 

REQUIREMENTS .................................................................................XI.E3A-1

XI.E3B ELECTRICAL INSULATION FOR INACCESSIBLE

INSTRUMENT AND CONTROL CABLES NOT SUBJECT TO 

10 CFR 50.49 ENVIRONMENTAL QUALIFICATION 

REQUIREMENTS .................................................................................XI.E3B-1

XI.E3C ELECTRICAL INSULATION FOR INACCESSIBLE 

LOW-VOLTAGE POWER CABLES NOT SUBJECT TO 

10 CFR 50.49 ENVIRONMENTAL QUALIFICATION 

REQUIREMENTS .................................................................................XI.E3C-1

XI.E4 METAL-ENCLOSED BUS........................................................................XI.E4-1

XI.E5 FUSE HOLDERS .....................................................................................XI.E5-1

XI.E6 ELECTRICAL CABLE CONNECTIONS NOT SUBJECT 

TO 10 CFR 50.49 ENVIRONMENTAL

QUALIFICATION REQUIREMENTS........................................................XI.E6-1

XI.E7 HIGH-VOLTAGE INSULATORS..............................................................XI.E7-1

APPENDIX A—QUALITY ASSURANCE FOR AGING MANAGEMENT PROGRAMS ..........A–1

APPENDIX B—OPERATING EXPERIENCE FOR AGING MANAGEMENT 

PROGRAMS.................................................................................................B–1
xi

LIST OF TABLES 

Table Page

OVERVIEW OF THE GENERIC AGING LESSONS LEARNED FOR SUBSEQUENT 

LICENSE RENEWAL (GALL-SLR) REPORT EVALUATION PROCESS

1 Aging Management Review Column Heading Descriptions................................xxxii

2 Aging Management Programs Element Descriptions.........................................xxxiv

APPLICATION OF THE AMERICAN SOCIETY OF MECHANICAL ENGINEERS BOILER 

AND PRESSURE VESSEL CODE

I-1 ASME Code Section XI Editions and Addenda that Are Acceptable for 

Use in AMPs.......................................................................................................... I-3

CHAPTER II CONTAINMENT STRUCTURES

A1 Concrete Containments (Reinforced and Prestressed)...................................II A1-2

A2 Steel Containments .........................................................................................II A2-2

A3 Common Components ....................................................................................II A3-2

B1.1 Mark I Steel Containments ..............................................................................II B1-2

B1.2 Mark I Concrete Containments........................................................................II B1-4

B2.1 Mark II Steel Containments .............................................................................II B2-2

B2.2 Mark II Concrete Containments.......................................................................II B2-4

B3.1 Mark III Steel Containments ............................................................................II B3-2

B3.2 Mark III Concrete Containments......................................................................II B3-5

B4 Common Components ....................................................................................II B4-2

CHAPTER III STRUCTURES AND COMPONENT SUPPORTS

A1 Group 1 Structures (BWR Reactor Bldg., PWR Shield Bldg., 

Control Room/Bldg)........................................................................................III A1-2

A2 Group 2 Structures (BWR Reactor Bldg. With Steel Superstructure).............III A2-2

A3 Group 3 Structures (Auxiliary Bldg., Diesel Generator Bldg., 

Radwaste Bldg., Turbine Bldg., Switchgear Rm., Yard Structures 

Such As AFW Pumphouse Utility/Piping Tunnels, Security/Lighting 

Poles, Manholes, Duct Banks; SBO Structures Such As Transmission 

Towers, Startup Tower Circuit Breaker Foundation, 

Electrical Enclosure).......................................................................................III A3-2

A4 Group Structures (Containment Internal Structures, Excluding 

Refueling Canal).............................................................................................III A4-2

A5 Group 5 Structures, (Fuel Storage Facility, Refueling Canal).........................III A5-2

A6 Group 6 Structures (Water-Control Structures)..............................................III A6-2

A7 Group 7 Structures (Concrete Tanks and Missile Barriers)............................III A7-2

A8 Group 8 Structures (Steel Tanks and Missile Barriers) ..................................III A8-2

A9 Group 9 Structures (BWR Unit Vent Stack)....................................................III A9-2

B1.1 Class 1............................................................................................................III B1-2

B1.2 Class 2 and 3..................................................................................................III B1-6

B1.3 Class MC......................................................................................................III B1-10

B2 Support for Cable Trays, Conduit, HVAC Ducts, Tube Track, 

Instrument Tubing, Non-ASME Piping and Components ...............................III B2-2

B3 Anchorage of Racks, Panels, Cabinets, and Enclosures for Electrical 

Equipment and Instrumentation......................................................................III B3-2
xii

B4 Supports for Emergency Diesel Generator, HVAC System 

Components, and Other Miscellaneous Mechanical Equipment....................III B4-2 

B5 Supports for Platforms, Pipe Whip Restraints, Jet Impingement 

Shields, Masonry Walls, and Other Miscellaneous Structures.......................III B5-2 

CHAPTER IV REACTOR VESSEL, INTERNALS, AND REACTOR COOLANT

SYSTEM

A1 Reactor Vessel (BWR) ...................................................................................IV A1-2 

A2 Reactor Vessel (PWR) ...................................................................................IV A2-2 

B1 Reactor Vessel Internals (BWR).....................................................................IV B1-2 

B2 Reactor Vessel Internals (PWR)—Westinghouse ..........................................IV B2-2 

B3 Reactor Vessel Internals (PWR)—Combustion Engineering .........................IV B3-2 

B4 Reactor Vessel Internals (PWR)—Babcock & Wilcox ....................................IV B4-2 

C1 Reactor Coolant, Pressure Boundary (BWR)................................................ IV C1-2 

C2 Reactor Coolant System and Connected Lines (PWR)................................. IV C2-2 

D1 Steam Generator (Recirculating) ................................................................... IV D1-2 

D2 Steam Generator (Once-Through) ................................................................ IV D2-2 

E Common Miscellaneous Material/Environment Combinations .........................IV E-2 

CHAPTER V ENGINEERED SAFETY FEATURES

A Containment Spray system (PWR) ...................................................................V A-2 

B Standby Gas Treatment System (BWR) ...........................................................V B-2 

C Containment Isolation Components ................................................................. V C-2 

D1 Emergency Core Cooling System (PWR) ...................................................... V D1-2 

D2 Emergency Core Cooling System (BWR) ...................................................... V D2-2 

E External Surfaces of Components and Miscellaneous Bolting..........................V E-2 

F Common Miscellaneous Material/Environment Combinations ..........................V F-2 

CHAPTER VI ELECTRICAL COMPONENTS

A Equipment Not Subject to 10 CFR 50.49 Environmental 

Qualification Requirements ..............................................................................VI A-2 

B Equipment Subject to 10 CFR 50.49 Environmental 

Qualification Requirements ..............................................................................VI B-2 

CHAPTER VII AUXILIARY SYSTEMS

A1 New Fuel Storage..........................................................................................VII A1-2 

A2 Spent Fuel Storage........................................................................................VII A2-2 

A3 Spent Fuel Pool Cooling and Cleanup (PWR)...............................................VII A3-2 

A4 Spent Fuel Pool Cooling and Cleanup (BWR)...............................................VII A4-2 

B Overhead Heavy Load and Light Load (Related to Refueling) 

Handling Systems............................................................................................VII B-2 

C1 Open-Cycle Cooling Water System (Service Water System)....................... VII C1-2 

C2 Closed-Cycle Cooling Water System ........................................................... VII C2-2 

C3 Ultimate Heat Sink........................................................................................ VII C3-2 

D Compressed Air System................................................................................. VII D-2 

E1 Chemical and Volume Control System (PWR)..............................................VII E1-2 

E2 Standby Liquid Control System (BWR) .........................................................VII E2-2 

E3 Reactor Water Cleanup System (BWR)........................................................VII E3-2 

E4 Shutdown Cooling System (Older BWR).......................................................VII E4-2 

E5 Waste Water Systems...................................................................................VII E5-2 

F1 Control Room Area Ventilation System.........................................................VII F1-2 
xiii

F2 Auxiliary and Radwaste Area Ventilation System..........................................VII F2-2

F3 Primary Containment Heating and Ventilation System..................................VII F3-2

F4 Diesel Generator Building Ventilation System...............................................VII F4-2

G Fire Protection ................................................................................................VII G-3

H1 Diesel Fuel Oil System ................................................................................. VII H1-2

H2 Emergency Diesel Generator System .......................................................... VII H2-2

I External Surfaces of Components and Miscellaneous Bolting.........................VII I-2

J Common Miscellaneous Material/Environment Combinations ........................VII J-2

CHAPTER VIII STEAM AND POWER CONVERSION SYSTEM

A Steam Turbine System...................................................................................VIII A-2

B1 Main Steam System (PWR) .........................................................................VIII B1-2

B2 Main Steam System (BWR) .........................................................................VIII B2-2

C Extraction Steam System .............................................................................. VIII C-2

D1 Feedwater Systems (PWR)......................................................................... VIII D1-2

D2 Feedwater Systems (BWR)......................................................................... VIII D2-2

E Condensate System .......................................................................................VIII E-2

F Steam Generator Blowdown System (PWR)..................................................VIII F-2

G Auxiliary Feedwater System (PWR)..............................................................VIII G-2

H External Surfaces of Components and Miscellaneous Bolting...................... VIII H-2

I Common Miscellaneous Material/Environment Combinations ........................VIII I-2

CHAPTER IX USE OF TERMS FOR STRUCTURES, COMPONENTS, MATERIALS, 

ENVIRONMENTS, AGING EFFECTS, AND AGING MECHANISMS

IX.B Use of Terms for Structures and Components.................................................IX B-2

IX.C Use of Terms for Materials .............................................................................. IX C-2

IX.D Use of Terms for Environments....................................................................... IX D-2

IX.E Use of Terms for Aging Effects.........................................................................IX E-2

IX.F Use of Terms for Aging Mechanisms ...............................................................IX F-2

CHAPTER X AGING MANAGEMENT PROGRAMS THAT MAY BE USED TO 

DEMONSTRATE ACCEPTABILITY OF TIME-LIMITED AGING ANALYSES IN 

ACCORDANCE WITH 10 CFR 54.21(c)(1)(III)

X-01 FSAR Supplement Summaries for GALL-SLR Report Chapter X Aging 

Management Programs...................................................................................X 01-1

CHAPTER XI AGING MANAGEMENT PROGRAMS

XI.M12-1 Thermal Embrittlement Screening Criteria ..................................................XI.M12-2

XI.M27-1 Fire Water System Inspection and Testing Recommendations...................XI.M27-4

XI.M29-1 Tank Inspection Recommendations ............................................................XI.M29-4

XI.M32-1 Examples of Parameters Monitored or Inspected and Aging Effect for 

Specific Structure or Component.................................................................XI.M32-3

XI.M35-1 Examinations...............................................................................................XI.M35-2

XI.M41-1 Preventive Actions for Buried and Underground Piping and Tanks ............XI.M41-2

XI.M41-2 Inspection of Buried and Underground Piping and Tanks...........................XI.M41-6

XI.M41-3 Cathodic Protection Acceptance Criteria...................................................XI.M41-11

XI.M42-1 Inspection Intervals for Internal Coatings/Linings for Tanks, Piping, 

Piping Components, and Heat Exchangers ................................................XI.M42-4
xiv

XI-01 FSAR Supplement Summaries for GALL-SLR Report Chapter XI Aging

Management Programs..................................................................................XI 01-1 

APPENDIX A QUALITY ASSURANCE FOR AGING MANAGEMENT PROGRAMS

A-01 FSAR Supplement Summary for Quality Assurance Programs for Aging 

Management Programs........................................................................................ A-2 

APPENDIX B OPERATING EXPERIENCE FOR AGING MANAGEMENT PROGRAMS

B-01 FSAR Supplement Summary for Operating Experience Programs for Aging 

Management Programs........................................................................................ B-6 
xv

LIST OF CONTRIBUTORS1

Division of License Renewal, Office of Nuclear Reactor Regulation

B. Holian Division Director

C. Miller Division Director

J. Lubinski Division Director

G. Wilson Division Director

R. Caldwell Deputy Division Director

M. Delligatti Deputy Division Director

J. Donoghue Deputy Division Director

M. Galloway Deputy Division Director

J. Marshall Deputy Director and Acting Division Director

B. Beasley Acting Deputy Division Director

S. Weerakkody Deputy Division Director

S. Bloom Branch Chief

Y. Diaz Branch Chief

M. Marshall Branch Chief

D. Morey Branch Chief

B. Pham Branch Chief

B. Wittick Branch Chief

A. Hiser Senior Technical Advisor

B. Brady Technical Project Manager Lead

W. Burton Regulatory Project Manager Lead

A. Billoch Lead Project Manager

H. Jones Lead Project Manager

B. Litkett Lead Project Manager

J. Mitchell Lead Project Manager

R. Plasse Lead Project Manager

B. Rogers Lead Project Manager

E. Sayoc Lead Project Manager

A. Wong Lead Project Manager

E. Gettys Public Coordination

A. Kazi Public Coordination

B. Allik Mechanical Engineering

A. Bufford Structural Engineering

D. Brittner Project Manager

C. Doutt Electrical Engineering

B. Fu Mechanical Engineering

W. Gardner Mechanical Engineering

1The titles in this List of Contributions refer to the NRC staff’s role in the development of this document, not their 

current position.
xvi

B. Grange Project Manager

K. Green Mechanical Engineering

W. Holston Mechanical Engineering

C. Hovanec Materials Engineering

R. Kalikian Mechanical Engineering

J. Medoff Mechanical Engineering

S. Min Materials Engineering

A. Prinaris Structural Engineering

M. Sadollah Electrical Engineering

G. Thomas Structural Engineering

M. Yoo Mechanical Engineering

Other Divisions in the Office of Nuclear Reactor Regulation

D. Alley Branch Chief

S. Bailey Branch Chief

R. Dennig Branch Chief

C. Jackson Branch Chief

A. Klein Branch Chief

G. Kulesa Branch Chief

T. Lupold Branch Chief

J. McHale Branch Chief

S. Rosenberg Branch Chief

J. Zimmerman Branch Chief

R. Hardies

K. Karwoski

L. Banic

Senior Level Advisor 

Senior Level Advisor 

Project Manager 

G. Cheruvenki Materials Engineering

J. Collins Materials Engineering

S. Cumblidge Materials Engineering

A. Erickson Structural Engineering

C. Fairbanks Materials Engineering

M. Hardgrove Mechanical Engineering

K. Hoffman Materials Engineering

N. Iqbal Fire Protection Engineering

A. Johnson Reactor Operations Engineering

S. Jones Reactor Systems Engineering

B. Lee Reactor Systems Engineering

B. Lehman Structural Engineering

R. Mathew Electrical Engineering

C. Ng Mechanical Engineering

D. Nguyen Electrical Engineering

J. Gavula Mechanical Engineering
xvii

A. Patel Reactor Engineering

B. Parks Reactor Engineering

J. Poehler Materials Engineering

P. Purtscher Materials Engineering

S. Ray Electrical Engineering

S. Sheng Materials Engineering

A. Tsirigotis Mechanical Engineer

P. Verdi International Assignee

O. Yee Reactor Systems Engineering

M. Yoder Chemical Engineering

Region II

P. Cooper Sr. Reactor Inspector

J. Rivera-Ortiz Reactor Inspector

Region III

N. Feliz-Adorno Sr. Reactor Inspector

M. Holmberg Sr. Reactor Inspector

C. Tilton Sr. Reactor Inspector

Region IV

S. Graves Sr. Reactor Inspector

G. Pick Sr. Reactor Inspector

M. Williams Reactor Inspector

Office of New Reactors

J. Xu Branch Chief

A. Istar Structural Engineering

Office of Nuclear Material Safety and Safeguards

A. Csontos Branch Chief

J. Wise Materials Engineering

Office of Nuclear Regulatory Research

J. Burke Branch Chief

S. Frankl Branch Chief

M. Gavrilas Branch Chief

J. Nakoski Branch Chief

W. Ott Branch Chief

D. Rudland Branch Chief

M. Salley Branch Chief

R. Sydnor Branch Chief

J. Ake Senior Technical Advisor—Geophysical Engineering

T. Nicholson Senior Technical Advisor—Radionuclide Transport

R. Tregoning Senior Technical Advisor—Materials Engineering

A. Hull Team Leader

A. Obodoako Materials Engineering
xviii

K. Arai Materials Engineering

M. Benson Materials Engineering

E. Focht Materials Engineering

M. Fuhrman Geochemistry

C. Harris Materials Engineering

M. Hiser Materials Engineering

M. Homiack Mechanical Engineering

M. Kirk Materials Engineering

B. Lin Mechanical Engineering

S. Malik Materials Engineering

K. Miller Electrical Engineering

W. Norris Materials Engineering

G. Oberson Materials Engineering

R. Perkins Reliability & Risk Engineering

I. Prokofiev Materials Engineering

J. Philip Geotechnical Engineering

A. Pulvirenti Materials Engineering

S. Rao Materials Engineering

M. Rossi Materials Engineering

M. Sircar Structural Engineering

M. Srinivasan Materials Engineering

G. Stevens Materials Engineering

D. Stroup Fire Protection Engineering

G. Wang Mechanical Engineering

Center for Nuclear Waste Regulatory Analyses, Southwest Research Institute®

G. Adams Computer/Industrial Engineering

L. Howard Project Manager/Nuclear Engineering

L. Naukam Program Support/Technical Editing

Y. Pan Materials Engineering

A. Ramos Program Support/Technical Editing

D. Speaker Nuclear Engineering
xix

ABBREVIATIONS

ACAR aluminum conductor aluminum alloy reinforced

ACSR aluminum conductor steel reinforced

ACI American Concrete Institute

ADAMS Agencywide Documents Access and Management System

AEA Atomic Energy Act

AEC Atomic Energy Commission

AFW auxiliary feedwater

AERM aging effect requiring management

AISC American Institute of Steel Construction

Al Aluminum

AMPs aging management programs

AMR aging management review

ANSI American National Standards Institute

API American Petroleum Institute

ASCE American Society of Civil Engineers

ASME American Society of Mechanical Engineers

ASME Code American Society of Mechanical Engineers Boiler and Pressure Vessel Code

ASTM ASTM International

AWG American wire gauge

B&W Babcock & Wilcox

BWR boiling water reactor

BWRVIP Boiling Water Reactor Vessel and Internals Project

CASS cast austenitic stainless steel

CB core barrel

CCCW closed-cycle cooling water

CE Combustion Engineering

CEA control element assembly

CFR Code of Federal Regulations

CFS core flood system 

CLB current licensing basis

CRD control rod drive

CRGT control rod guide tube

CSE copper/copper sulfate reference electrode

CVCS chemical and volume control system

DOE U.S. Department of Energy

DSCSS drywell and suppression chamber spray system
xx

ECT eddy current testing

EDG emergency diesel generator

EMDA Expanded Materials Degradation Assessment

EPDM ethylene propylene diene monomer

EPR ethylene-propylene rubber

EPRI Electric Power Research Institute

EQ environmental qualification

FAC flow-accelerated corrosion

FERC Federal Energy Regulatory Commission

FRN Federal Register Notice

FSAR Final Safety Analysis Report

FW feedwater

GALL Generic Aging Lessons Learned

GALL-SLR Generic Aging Lessons Learned for Subsequent License Renewal

GL generic letter

HDPE high density polyethylene

HELB high-energy line break

HP high pressure

HPCI high-pressure coolant injection

HPCS high-pressure core spray

HPSI high-pressure safety injection

HVAC heating, ventilation, and air conditioning

I&C instrumentation and control

I&E inspection and evaluation

IAEA International Atomic Energy Agency 

IASCC irradiation-assisted stress corrosion cracking

IC isolation condenser

ID inside diameter

IEB Inspection and Enforcement Bulletin

IEEE Institute of Electrical and Electronics Engineers

IGA intergranular attack

IGSCC intergranular stress corrosion cracking

IMI incore monitoring instrumentation

IN information notice

INPO Institute of Nuclear Power Operations

IRM intermediate range monitor
xxi

ISA International Society of Automation

ISG interim staff guidance

ISI inservice inspection

ISP integrated surveillance program

LERs licensee event reports

LG lower grid

LOCA loss of coolant accident

LP low pressure

LPCI low-pressure coolant injection

LPCS low-pressure core spray

LPSI low-pressure safety injection

LR-ISG license renewal interim staff guidance

LRT leak rate test

LWR light water reactor

MIC microbiologically influenced corrosion

MPa megapascal

MRP Materials Reliability Program

MS main steam

MSR moisture separator/reheater

NACE National Association of Corrosion Engineers

NDE nondestructive examination

NEA Nuclear Energy Agency

NEI Nuclear Energy Institute

NFPA National Fire Protection Association

NPP nuclear power plant

NPS nominal pipe size

NRC U.S. Nuclear Regulatory Commission

NSAC Nuclear Safety Analysis Center

NUMARC Nuclear Management and Resources Council

OCCW open-cycle cooling water

ODSCC outside diameter stress corrosion cracking

OECD Organisation for Economic Co-operation and Development

OE operating experience

PVC polyvinyl chloride

PWR pressurized water reactor

PWSCC primary water stress corrosion cracking
xxii

QA quality assurance

RCIC reactor core isolation cooling

RCP reactor coolant pump

RCPB reactor coolant pressure boundary

RCS reactor coolant system

RES Office of Nuclear Regulatory Research

RG Regulatory Guide

RHR residual heat removal

RVI reactor vessel internal

RWCU reactor water cleanup

RWT refueling water tank

SBO

SCs

station blackout

structures and components

SCC stress corrosion cracking

SDC shutdown cooling

SEI Structural Engineering Institute

SFP spent fuel pool

SG steam generator

S/G standards and guides

SIT safety injection tank

SLC standby liquid control

SLR subsequent license renewal

SLRAs subsequent license renewal applications

SOC Statements of Consideration

SOER significant operating experience report

SRM source range monitor

SRM staff requirements memorandum

SRP-SLR Standard Review Plan for Review of Subsequent License Renewal Applications 

for Nuclear Power Plants

SS stainless steel

SSCs systems, structures, and components
xxiii

TGSCC transgranular stress corrosion cracking

TLAA time-limited aging analysis

TS technical specifications

UHS ultimate heat sink

USACE U.S. Army Corps of Engineers

USE upper-shelf energy

UT ultrasonic testing

UV ultraviolet

XLPE cross-linked polyethylene

xxv

INTRODUCTION

NUREG–2191, “Generic Aging Lessons Learned for Subsequent License Renewal 

(GALL-SLR) Report,” is referenced as a technical basis document in NUREG–2192, “Standard 

Review Plan for Review of Subsequent License Renewal Applications for Nuclear Power Plants,” 

(SRP-SLR). The GALL-SLR Report lists generic aging management reviews of systems, 

structures, and components (SSCs) that may be in the scope of subsequent license renewal 

applications (SLRAs) and identifies aging management programs (AMPs) that are determined to 

be acceptable to manage aging effects of SSCs in the scope of license renewal, as required by 

Title 10 of the Code of Federal Regulations (10 CFR) Part 54, “Requirements for Renewal of 

Operating Licenses for Nuclear Power Plants.” If an applicant credits an AMP described in the 

GALL-SLR Report in the SLRA, the applicant should ensure that the conditions and operating 

experience (OE) at the plant are bounded by the conditions and OE for which the GALL-SLR 

Report program was evaluated. If these bounding conditions are not met, the applicant should 

address any additional aging effects and augment the AMPs for subsequent license renewal. If 

an SLRA references the GALL-SLR Report as the approach used to manage aging effect(s), the 

U.S. Nuclear Regulatory Commission staff will use the GALL-SLR Report as a basis for the SLRA 

assessment consistent with guidance specified in the SRP-SLR.

xxvii

BACKGROUND

The Atomic Energy Act (AEA) of 1954, as amended, allows the U.S. Nuclear Regulatory 

Commission (NRC) to issue licenses for commercial nuclear power reactors to operate for up to 

40 years. The NRC regulations permit these licenses to be renewed beyond the initial 40-year 

term for an additional period of time, limited to 20-year increments per renewal, based on the 

results of an assessment to determine if the nuclear facility can continue to operate safely during 

the proposed period of extended operation. There are no limitations in the AEA or the NRC 

regulations restricting the number of times a license may be renewed.

The focus of license renewal, as described in Title 10 of the Code of Federal Regulations 

(10 CFR) Part 54, is to identify aging effects that could impair the ability of systems, structures, 

and components (SSCs) within the scope of license renewal to perform their intended functions, 

and to demonstrate that these effects will be adequately managed during the period of extended 

operation. The regulatory requirements for both initial and subsequent license renewal (SLR) are 

established by 10 CFR Part 54. To address the unique aspects of material aging and degradation 

that would apply to SLR (e.g., to permit plants to operate to 80 years), the Office of Nuclear 

Reactor Regulation requested support from the Office of Nuclear Regulatory Research (RES) to 

develop technical information to evaluate the feasibility of SLR. RES has memoranda of 

understanding with both the U.S. Department of Energy (DOE) and the Electric Power Research 

Institute to cooperate in nuclear safety research related to long-term operations beyond 60 years. 

Under these memoranda, the NRC and the DOE held two international conferences, in 2008 and 

2011, on reactor operations beyond 60 years. In May 2012, the NRC and the DOE also 

co-sponsored the Third International Conference on Nuclear Power Plant Life Management for 

Long-Term Operations, organized by the International Atomic Energy Agency (IAEA). In 

February 2013 and February 2015, the Nuclear Energy Institute (NEI) held a forum on long-term 

operations and SLR. These conferences laid out the technical issues that would need to be 

addressed to provide assurance for safe operation beyond 60 years. 

Based on the information gathered from these conferences and forums, and from other sources 

over the past several years, the most significant technical issues identified as challenging 

operation beyond 60 years are: reactor pressure vessel embrittlement; irradiation-assisted stress 

corrosion cracking (SCC) of reactor internals; concrete structures and containment degradation; 

and electrical cable environmental qualification, condition monitoring and assessment. 

Throughout this process, the NRC staff has emphasized that it is the industry’s responsibility to

resolve these and other issues to provide the technical bases to ensure safe operation beyond

60 years.

The NRC, in cooperation with the DOE, completed the Expanded Materials Degradation 

Assessment (EMDA) in 2014 [Agencywide Documents Access and Management System 

(ADAMS) Accession Nos. ML14279A321, ML14279A331, ML14279A349, ML14279A430, and 

ML14279A461]. The EMDA uses an expert elicitation process to identify materials and 

components, which could be susceptible to significant degradation during operation beyond 

60 years. The EMDA covers the reactor vessel, primary system piping, reactor vessel internals, 

concrete, and electrical cables and qualification. The NRC staff used the results of the EMDA to 

identify gaps in the current technical knowledge or issues not being addressed by planned 

industry or DOE research, and to identify aging management programs (AMPs) that will require 

modification for SLR.
xxviii

On May 9, 2012 (ADAMS Accession No. ML12158A545) and subsequently on November 1, 

13, and 14, 2012, the NRC staff and interested stakeholders met to discuss issues and 

receive comments for consideration for SLR. The staff’s resolution to these public 

comments is available in the staff’s memo dated September 12, 2016 (ADAMS Accession 

No. ML16194A222).

In addition to working with external stakeholders, the NRC staff conducted AMP effectiveness 

audits at three units that were at least 2 years into the period of extended operation. The purpose 

of these information gathering audits was to better understand how licensees are implementing 

the license renewal AMPs, in terms of both the findings and the effectiveness of the programs, 

and to develop recommendations for updating license renewal guidance. The NRC staff used the

information gathered from these audits to update the SLR guidance based on the staff’s 

experience with the aging management activities during the first license renewals. A summary of 

the first two AMP effectiveness audits can be found in the May 2013 report, “Summary of Aging 

Management Program Effectiveness Audits to Inform Subsequent License Renewal: R.E. Ginna 

NPP and Nine Mile Point Nuclear Station, Unit 1” (ADAMS Accession No. ML13122A007). The 

summary of the third audit can be found in the August 5, 2014, report, “H.B. Robinson Steam 

Electric Plant, Unit 2, Aging Management Program Effectiveness Audit” (ADAMS Accession 

No. ML14017A289). In addition, on June 15, 2016, the staff issued the Technical Letter Report, 

“Review of Aging Management Programs: Compendium of Insight from License Renewal 

Applications and from AMP Effectiveness Audits Conducted to Inform Subsequent License 

Renewal Guidance Documents,” (ADAMS Accession No. ML16167A076), which provides the 

staff’s observations from reviewing license renewal applications and the AMP effectiveness 

audits. 

The NRC staff reviewed domestic operating experience (OE) as reported in licensee event reports 

and NRC generic communications related to failures and degradation of passive components. 

Similarly the NRC staff reviewed the following international OE databases: (i) International 

Reporting System, jointly operated by the IAEA; (ii) IAEA’s International Generic Ageing Lessons 

Learned Programme; (iii) Organisation for Economic Co-operation and Development

(OECD)/Nuclear Energy Agency (NEA) Component Operational Experience and Degradation and 

Ageing Programme database; and (iv) OECD/NEA Cable Aging Data and Knowledge database.

The NRC staff reviewed the results from AMP audits, findings from the EMDA, domestic and 

international OE, and public comments to identify technical issues that need to be considered for 

assuring the safe operation of NRC-licensed nuclear power plants (NPPs). By letter dated 

August 6, 2014 (ADAMS Accession No. ML14253A104), NEI documented the industry’s views 

and recommendations for updating NUREG–1801, Revision 2, “Generic Aging Lessons Learned 

(GALL) Report,” and NUREG–1800, Revision 2, “Standard Review Plan for Review of License 

Renewal Applications for Nuclear Power Plants,” to support SLR. Between fiscal years 2014 and 

2015, the NRC staff reviewed the comments and recommendations and drafted the Generic 

Aging Lessons Learned for Subsequent License Renewal (GALL-SLR) Report to ensure that 

sufficient guidance was in place to support review of an SLR application in 2018 or 2019. 

The staff requirements memorandum (SRM) on SECY-14-0016, “Ongoing Staff Activities to 

Assess Regulatory Considerations for Power Reactor Subsequent License Renewal,” 

(ADAMS Accession No. ML14241A578) directed the staff to continue to update the license 

renewal guidance, as needed, to provide additional clarity on the implementation of the license 

renewal regulatory framework. The SRM also directed the staff to keep the Commission informed 

on the progress in resolving the following technical issues related to SLR: (i) reactor pressure 

vessel neutron embrittlement at high fluence, (ii) irradiation-assisted SCC of reactor internals
xxix

and primary system components, (iii) concrete and containment degradation, and (iv) electrical 

cable qualification and condition assessment. In addition, the SRM directed that the staff should 

keep the Commission informed regarding the staff’s readiness for accepting an application and 

any further need for regulatory process changes, rulemaking, or research.

During the staff’s consideration of revisions to 10 CFR Part 54, changes were considered to the 

License Renewal Rule to address the provisions of 10 CFR 50.54(hh)(2) regarding guidance and 

strategies to maintain and restore core cooling, containment, and spent fuel cooling capabilities 

under the circumstances associated with the loss of large areas of the plant due to explosions or 

fires. After discussions with stakeholders and the public, it was concluded that these issues need 

not be addressed in the License Renewal Rule because emergency preparedness equipment is 

not identified in 10 CFR 54.4(a)(3). The 1995 Federal Register Notice for the final license renewal 

rule, 60 FR 22461, 22468 states: 

Regarding systems, structures, and components required to make protective 

action recommendations, the Commission thoroughly evaluated emergency 

planning considerations in the previous license renewal rulemaking. These 

evaluations and conclusions are still valid and can be found in the [Statements of 

Consideration] SOC for the previous license renewal rule (56 FR 64943 at 

64966). Therefore, the Commission concludes that systems, structures, and 

components required for emergency planning, unless they meet the scoping 

criteria in §54.4, should not be the focus of a license renewal review. 

Further, even if this equipment is within the scope of license renewal that does not necessarily 

mean that it is subject to aging management review based on the existing rule in that only 

passive, long-lived structures and components are subject to an aging management review. 

Further, this is not an issue specific to SLR and is inconsistent with the first principle of license 

renewal (i.e., “....with the exception of age-related degradation and possibly a few other issues 

related to safety only during extended operation of nuclear power plants, the existing regulatory 

process is adequate to ensure that the licensing bases of all currently operating plants provide 

and maintain an acceptable level of safety so that operation will not be inimical to public health 

and safety or common defense and security”). Therefore, there is no need to address 

10 CFR 50.54(hh) and diverse and flexible mitigation capability equipment in the License 

Renewal Rule.

The GALL-SLR report also includes the NRC staff’s resolutions of License Renewal Interim Staff 

Guidance (LR-ISGs) from 2011 through 2016. Under the LR-ISG process, the NRC staff, 

industry, or stakeholders can propose a change to certain license renewal guidance documents. 

The NRC staff evaluates the issue, develops the proposed LR-ISG, issues it for public comment, 

evaluates any comments received, and, if necessary, issues the final LR-ISG. 

The LR-ISG is then used until the NRC staff incorporates the revised guidance into a formal 

license renewal guidance document revision. The LR-ISGs addressed in the GALL-SLR 

report are:

• LR-ISG-2011-01: Aging Management of Stainless Steel Structures and Components in 

Treated Borated Water, Revision 1

• LR-ISG-2011-02: Aging Management Program for Steam Generators
xxx

• LR-ISG-2011-03: Generic Aging Lessons Learned (GALL) Report Revision 2 AMP 

XI.M41, “Buried and Underground Piping and Tanks”

• LR-ISG-2011-04: Updated Aging Management Criteria for Reactor Vessel Internal 

Components of Pressurized Water Reactors

• LR-ISG-2011-05: Ongoing Review of Operating Experience

• LR-ISG-2012-01: Wall Thinning Due to Erosion Mechanisms

• LR-ISG-2012-02: Aging Management of Internal Surfaces, Fire Water Systems, 

Atmospheric Storage Tanks, and Corrosion Under Insulation

• LR-ISG-2013-01: Aging Management of Loss of Coating or Lining Integrity for Internal 

Coatings/Linings on In-Scope Piping, Piping Components, Heat Exchangers, and Tanks

• LR-ISG-2015-01: Changes to Buried and Underground Piping and 

Tank Recommendations

• LR-ISG-2016-01: Changes to Aging Management Guidance for Various Steam 

Generator Components
xxxi

OVERVIEW OF THE GENERIC AGING LESSONS LEARNED FOR 

SUBSEQUENT LICENSE RENEWAL (GALL-SLR) REPORT 

EVALUATION PROCESS

The Generic Aging Lessons Learned for Subsequent License Renewal (GALL-SLR) Report 

contains 11 chapters and 2 appendices. The majority of the chapters contain summary 

descriptions and tabulations of evaluations of aging management programs (AMPs) for a large 

number of structures and components (SCs) in major plant systems found in light-water reactor 

nuclear power plants. The major plant systems include the containment structures (Chapter II), 

SC supports (Chapter III), reactor vessel, internals and reactor coolant system (Chapter IV), 

engineered safety features (Chapter V), electrical components (Chapter VI), auxiliary systems 

(Chapter VII), and steam and power conversion system (Chapter VIII). 

Chapter I of the GALL-SLR Report addresses the application of the American Society of 

Mechanical Engineers Boiler and Pressure Vessel Code for subsequent license renewal (SLR). 

Chapter IX contains the description of a selection of standard terms used within the GALL-SLR

Report. Chapter X contains examples of AMPs that may be used to demonstrate the acceptance 

of time-limited aging analyses (TLAAs) in accordance with Title 10 of the Code of Federal 

Regulations (10 CFR) 54.21(c)(1)(iii). Chapter XI contains the AMPs for the mechanical, 

structural and electrical components. The appendices of the GALL-SLR Report address quality 

assurance for AMPs and operating experience (OE).

The evaluation process for the AMPs and the application of the GALL-SLR Report is described in 

this document. The aging management review (AMR) items for the GALL-SLR Report are 

presented in tabular format as described in Table 1. Table 1 describes the information presented 

in each column of the tables in Chapters II through VIII contained in this report.

The staff’s evaluation of the adequacy of each generic AMP to manage certain aging effects for 

particular SCs is based on its review of the 10 program elements in each AMP, as defined in 

Table 2.

On the basis of its evaluation, if the staff determines that a program is adequate to manage 

certain aging effects for a particular SC without change, the “Further Evaluation” entry will indicate 

that no further evaluation is recommended for SLR.

Chapters X and XI of the GALL-SLR Report contain generic AMPs that the staff finds to be 

sufficient to manage aging effects in the subsequent period of extended operation, such as the 

ASME Code Section XI inservice inspection, water chemistry, or structures monitoring program.
xxxii

Table 1. Aging Management Review Column Heading Descriptions

Column Heading Description

New (N), Modified (M), Deleted (D), 

Edited (E) Item

Identifies the item as new to GALL-SLR Report, modified from 

GALL Revision 2, deleted from GALL Revision 2, edited from 

GALL Revision 2, or if blank, is unchanged from GALL 

Revision 2.

Item Identifies a unique number for the item (i.e., VII.G.A-91). The 

first part of the number indicates the chapter and AMR system 

(e.g., VII.G is in the auxiliary systems, fire protection system), 

and the second part is a unique chapter-specific identifier within 

a chapter (e.g., A–91 for auxiliary systems).

Standard Review Plan (SRP) Item 

(Table, ID)

For each row in the subsystem tables, this item identifies the 

corresponding row identifier from the SRP-SLR to provide the 

crosswalk to the SRP system table items.

Structure and/or Component Identifies the structure or components to which the row applies.

Material Identifies the material of construction. See Chapter IX.C of this 

report for further information.

Environment Identifies the environment applicable to this row. 

See Chapter IX.D of this report for further information.

Aging Effect/ Mechanism Identifies the applicable aging effect and mechanism(s). 

See Chapters IX.E and IX.F of this report for more information 

on applicable aging effects/mechanisms.

Aging Management Program

(AMP)/TLAA

Identifies an AMP/TLAA found acceptable for adequately 

managing the effects of aging. See Chapters X and XI of this 

report.

Further Evaluation Identifies whether a further evaluation is needed.

Edited (E) items, in contrast to modified (M) items, are those for which no technical aspects were 

changed. Examples of editorial changes include: 

• Line item citations that were missed in the SRP-SLR Table 3.X-1.

• Deleting whether the environment is internal or external from the description of the 

environment because based on the material, environment, aging effect, and AMP 

combination, it is obvious that the environment could only be on either the inside or 

outside of the component.

• Deletion of the term “piping element” from aging management review items that do not cite 

glass as a material. Piping elements were defined in the GALL Report as components 

constructed of glass.

• Line item changes that only involved removing detail related to a Further Evaluation 

Recommended column was removed after it was verified that the identical information was 

included in the SRP-SLR further evaluation section.

• Line item changes that only involved renumbering further evaluation sections.
xxxiii

• Aging effects changed from “and” to “or.” This could appear to be a technical change; 

however, this is not the case because the staff confirmed that is was never the intent that 

both aging effects were occurring. For example, the “and” in cracking due to stress 

corrosion cracking and cyclic loading was replaced with “or.”

• Deleting the term “environment” from the description of the environment in the 

“Environment” column when the phrase “any environment” was used because it was 

obvious and redundant.

• Descriptors for the AMPs in the “Aging Management Program/TLAA” column were 

simplified if the information was provided elsewhere.

• Minor edits to component descriptions, examples: (a) deleting “elastomer” from 

“elastomer, elastomer seals;” (b) adding “piping” or “ducting” in front of the term 

“component.”

• Adding the term “electrical” to Structure and/or Component and Aging Effect/Mechanism 

description. 
xxxiv

Table 2. Aging Management Programs Element Descriptions

AMP Element Description

1. Scope of the Program The scope of the program should include the specific structures 

and components subject to an AMR.

2. Preventive Actions Preventive actions should mitigate or prevent the applicable 

aging effects.

3. Parameters Monitored 

or Inspected

This identifies the aging effects that the program manages and 

provides a link between the parameter or parameters that will be 

monitored and how the monitoring of these parameters will 

maintain adequate aging management.

4. Detection of Aging Effects Detection of aging effects should occur before there is a loss of 

any structure and component intended function. This element 

describes 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 timely 

detection of aging effects.

5. Monitoring and Trending Monitoring and trending should provide for an estimate of the 

extent of the effects of aging and timely corrective or 

mitigative actions. 

6. Acceptance Criteria Acceptance criteria, against which the need for corrective action 

will be evaluated, should provide reasonable assurance that the 

particular structure and component’s intended functions are 

maintained under all current licensing basis conditions during the 

subsequent period of extended operation.

7. Corrective Actions Description of corrective actions that will be implemented if the 

acceptance criteria of the program are not met.

8. Confirmation Process The confirmation process should provide reasonable assurance 

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 (OE) OE applicable to 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 managed adequately so that the structureand component intended function(s) will be maintained during the 

subsequent period of extended operation. In addition, an ongoing 

review of both plant-specific and industry OE provides reasonable 

assurance that the AMP is effective in managing the aging effects 

for which it is credited. The AMP is either enhanced or new AMPs 

are developed, as appropriate, when it is determined through the 

evaluation of OE that the effects of aging may not be 

adequately managed.
xxxv

EXPLANATION OF THE USE OF MULTIPLE AGING MANAGEMENT 

PROGRAMS IN AGING MANAGEMENT REVIEW ITEMS

For aging management review (AMR) items associated with some “Further Evaluations,” the 

associated Generic Aging Lessons Learned for Subsequent License Renewal (GALL-SLR) 

Report items now include a letter suffix with the unique chapter-specific identifier. For these 

items, the staff designated the various aging management programs (AMPs) it found to be 

acceptable in lieu of specifying “plant-specific aging management program” in the Aging 

Management Program column. Depending on the GALL-SLR Report Table 2 item cited in the 

subsequent license renewal application (SLRA) for these items, applicants can either use one of 

the AMPs found to be acceptable to the staff for specific situations or, comparable to any other 

item, can propose their own plant-specific program to manage the associated aging effect. 

For example, Standard Review Plan for Review of Subsequent License Renewal Applications for 

Nuclear Power Plants (SRP-SLR) Section 3.1.2.2.16 is a further evaluation associated with 

SRP-SLR item 3.1-1, 136, for loss of material due to pitting and crevice corrosion in stainless steel 

and nickel alloy piping and piping components. The associated chapter-specific identifier has 

been expanded to include items R-452a, R-452b, R-452c, and R-452d. The further evaluation 

recommends a review of plant-specific operating experience (OE) to determine if the site’s air 

environments are sufficiently aggressive to cause pitting and crevice corrosion. The need to 

manage this aging effect will depend on the results of the OE reviews and a one-time inspection 

to demonstrate that pitting and crevice corrosion are not occurring or are occurring sufficiently 

slowly. Consequently, the acceptable AMP could be XI.M32 for performing the one-time 

inspection (if the aging effect does not need to be periodically managed), or it could be XI.M36,

XI.M38, or XI.M42, depending on whether a periodic program is needed for external surfaces, 

internal surfaces, or coatings/linings. The SLRA will specify the applicable AMP by citing the 

specific GALL-SLR item R-452a, R-452b, R-452c, or R-452d for the corresponding AMP being 

used at the site. More specifically, if the plant-specific OE review does not reveal any instances 

of loss of material for stainless steel or nickel alloy piping and piping components, R-452a 

(AMP XI.M32) would be the cited SLRA AMR Table 2 item. In contrast, if external loss of 

material has occurred, and it was sufficient to potentially affect the intended function, R-452b 

(AMP XI.M36) or R-452d (AMP XI.M42) would be cited.

xxxvii

REFERENCES

References are listed in the aging management program (AMP) following the program elements. 

References consist of documents (e.g., Codes, Standards) associated with recommended actions 

(e.g., qualification of personnel, inspection methods) cited in the program elements or documents 

containing background information associated with the AMP (e.g., Information Notices). The 

specific version (e.g., edition, addenda, revision) of a reference is cited in the list of references. It 

should be noted that in some instances, specific program elements might cite a different version 

of a reference than that cited in the reference list. In these cases, the staff has reviewed the 

provisions of the different version of the reference and has specifically cited a version based on 

the requirements or guidance contained within the document. Where a specific version is not 

cited in a program element, the version cited in the reference list is applicable. With the exception 

of the guidance on use of later editions/revisions of various industry documents cited below, an 

applicant should identify exceptions to the Generic Aging Lessons Learned for Subsequent 

License Renewal (GALL-SLR) Report and provide justification when using a different version of a 

reference cited in the program elements.

xxxix

GUIDANCE ON USE OF LATER EDITIONS/REVISIONS OF 

VARIOUS INDUSTRY DOCUMENTS

To aid applicants in the development of their subsequent license renewal applications (SLRAs), 

the staff has developed a list of aging management programs in the Generic Aging Lessons 

Learned for Subsequent License Renewal (GALL-SLR) Report that are based entirely or in 

part on specific editions/revisions of various industry codes (other than the American Society 

of Mechanical Engineers Boiler and Pressure Vessel Code), standards, and other 

industry-generated guidance documents. SLRAs may use later editions/revisions of these 

industry generated documents, subject to the following provisions:

(i) If the later edition/revision has been explicitly reviewed and approved/endorsed by the 

U.S. Nuclear Regulatory Commission (NRC) staff for license renewal via a NRC 

Regulatory Guide endorsement, a safety evaluation for generic use [such as for a Boiling 

Water Reactor Vessel and Internals Project (BWRVIP)], incorporation into Title 10 of the 

Code of Federal Regulation (10 CFR), or license renewal interim staff guidance.

(ii) If the later edition/revision has been explicitly reviewed and approved on a plant-specific 

basis by the NRC staff in its Safety Evaluation Report for another applicant’s SLRA 

(a precedent exists). Applicants may reference this and justify applicability to their facility 

via the exception process in Nuclear Energy Institute 95-10.

If either of these methods is used as justification for adopting a later edition/revision than specified 

in the GALL-SLR Report, the applicant shall reference the information pertaining to the NRC 

endorsement/approval of the later edition/revision.

xli

APPLICATION OF THE GENERIC AGING LESSONS LEARNED FOR 

SUBSEQUENT LICENSE RENEWAL (GALL-SLR) REPORT

The Generic Aging Lessons Learned for Subsequent License Renewal (GALL-SLR) Report is a 

technical basis document to the Standard Review Plan for Review of Subsequent License 

Renewal Applications for Nuclear Power Plants (SRP-SLR), which provides the staff with 

guidance in reviewing a subsequent license renewal application (SLRA). The GALL-SLR Report 

should be treated in the same manner as an approved topical report that is generically applicable. 

An applicant may reference the GALL-SLR Report in an SLRA to demonstrate that the aging 

management programs (AMPs) at the applicant’s facility correspond to those reviewed and 

approved in the GALL-SLR Report.

If an applicant takes credit for an AMP in GALL-SLR Report, it is incumbent on the applicant to 

ensure that the plant AMP contains all the elements of the referenced GALL-SLR program. In 

addition, the conditions and operating experience (OE) at the plant must be bounded by the 

conditions and OE for which the GALL-SLR Report AMP was evaluated; otherwise it is incumbent 

on the applicant to augment the GALL-SLR Report AMP as appropriate to address the impact of 

the plant-specific OE on the AMP element criteria. The documentation for the above verifications 

must be available onsite in an auditable form. 

The GALL-SLR Report contains one acceptable way to manage aging effects for subsequent 

license renewal (SLR). An applicant may propose alternatives for staff review in its plant-specific 

SLRA. The use of the GALL-SLR Report is not required, but its use should facilitate both 

preparation of an SLRA by an applicant and timely, consistent review by the U.S. Nuclear 

Regulatory Commission staff.

The GALL-SLR Report does not address scoping of structures and components (SCs) for license 

renewal; this is addressed in SRP-SLR Chapter 2. Scoping is plant-specific, and the results 

depend on the plant design and current licensing basis. The inclusion of a certain structure or 

component in the GALL-SLR Report does not imply that this particular structure or component is 

within the scope of license renewal for all plants. Conversely, the omission of a certain structure 

or component in the GALL-SLR Report does not imply that this particular structure or component 

is not within the scope of SLR for any plants.

The GALL-SLR Report contains an evaluation of a large number of SCs that may be in the scope 

of a typical SLRA. The evaluation results documented in the GALL-SLR Report indicate that 

many existing, typical generic AMPs are adequate to manage aging effects for particular 

structures or components for SLR without change. The GALL-SLR Report also contains 

recommendations on specific areas for which existing generic AMPs should be augmented 

(require further evaluation) for SLR and documents the technical basis for each such 

determination. The GALL-SLR Report identifies certain systems, structures, and components 

(SSCs) that may or may not be subject to particular aging effects, and those for which industry is

developing generic AMPs or investigating whether aging management is warranted. 

Appendix A of the GALL-SLR Report addresses quality assurance (QA) for AMPs. Those aspects 

of the aging management review (AMR) process that affect the quality of safety-related SSCs are 

subject to the QA requirements of Appendix B to Title 10 of the Code of Federal Regulations 

(10 CFR) Part 50. For nonsafety-related SCs subject to an AMR, the existing 10 CFR Part 50, 

Appendix B, QA program may be used by an applicant to address the elements of the corrective 

actions, confirmation process, and administrative controls for an AMP for SLR.
xlii

The GALL-SLR Report provides a technical basis for crediting existing plant AMPs and 

recommending areas for AMP augmentation and further evaluation. The incorporation of the 

GALL-SLR Report information into the SRP-SLR, as directed by the Commission, should improve 

the efficiency of the SLR review process and the use of staff resources.
CHAPTER IX

USE OF TERMS FOR STRUCTURES, COMPONENTS, MATERIALS, 

ENVIRONMENTS, AGING EFFECTS, AND AGING MECHANISMS

IX-1

IX USE OF TERMS FOR STRUCTURES, COMPONENTS, MATERIALS, 

ENVIRONMENTS, AGING EFFECTS, AND AGING MECHANISMS

A. INTRODUCTION

B. STRUCTURES AND COMPONENTS

C. MATERIALS

D. ENVIRONMENTS

E. AGING EFFECTS

F. SIGNIFICANT AGING MECHANISMS

G. REFERENCES

IX A-1

A. INTRODUCTION

This chapter is designed to clarify the usage of terms in the aging management review (AMR) 

tables in Chapters II–VIII of this report. The format and content of the AMR tables have been 

revised from the Generic Aging Lessons Learned (GALL) Report, Revision 2, to enhance the 

report’s applicability to future subsequent license renewal applications. The U.S. Nuclear 

Regulatory Commission has also added several new terms, and removed, or clarified some of 

those that were in the GALL Report, Revision 2. 

IX B-1

B. STRUCTURES AND COMPONENTS

The Generic Aging Lessons Learned for Subsequent License Renewal (GALL-SLR) Report does 

not address scoping of structures and components for subsequent license renewal (SLR). 

Scoping is plant-specific, and the results depend on individual plant design and its current

licensing basis. The inclusion of a certain structure or component in the GALL-SLR Report does 

not mean that this particular structure or component is within the scope of SLR for all plants. 

Conversely, the omission of a certain structure or component in the GALL-SLR Report does not 

mean that this particular structure or component is omitted from the scope of SLR for any plant.
IX B-2

IX.B Use of Terms for Structures and Components

Term Usage in this document

Bolting Bolting can refer to structural bolting, closure bolting, or all other 

bolting. Within the scope of license renewal, both Class 1 and 

nonClass 1 systems and components contain bolted closures that 

are necessary for the pressure boundary of the components 

being joined or closed. Closure bolting in high-pressure or 

high-temperature systems is defined as that in which the pressure 

exceeds 275 psi or 93 °C [200 °F]. Closure bolting is used to join 

pressure boundaries or where a mechanical seal is required.

Ducting and ducting components Ducting and ducting components include HVAC components. 

Examples include ductwork, ductwork fittings, access doors, 

equipment frames and housing, housing supports, including 

housings for valves, dampers (including louvers and gravity), and 

ventilation fans (including exhaust fans, intake fans, and purge 

fans). In some cases, this includes HVAC closure bolting or 

HVAC piping.

Electrical insulation Electrical insulation is a material used to inhibit/prevent the 

conduction of electric current. 

Electrical insulating materials in this category include bakelite, 

phenolic melamine, molded polycarbonate, organic polymers 

(e.g., EPR, SR, EPDM, and XLPE) and ceramics. 

Encapsulation components/valve 

chambers

These are airtight enclosures that function as a secondary 

containment boundary to completely enclose containment sump 

lines and isolation valves. Encapsulation components and 

features (e.g., emergency core cooling system, containment spray 

system, containment isolation system, refueling water storage 

tank, etc.) can include encapsulation vessels, piping, and valves. 

“Existing programs”

components

One of four groups of pressurized water reactor vessel internal 

(PWR RVI) components defined in EPRI Report No. 1022863 

(MRP-227-A) that is discussed in the GALL-SLR Report AMP 

XI.M16A, “PWR Vessel Internals.” Refer to Section 3.3 in the 

MRP-227-A report for EPRI’s official definition of PWR RVI 

“Existing Programs” components. 

“Expansion” components One of four groups of pressurized water reactor vessel internal 

(PWR RVI) components defined in EPRI Report No. 1022863 

(MRP-227-A) that is discussed in the GALL-SLR Report AMP 

XI.M16A, “PWR Vessel Internals.” Refer to Section 3.3 in the 

MRP-227-A report for EPRI’s official definition of PWR RVI 

“Expansion” components. 

External surfaces In the context of SCs, the term “external surfaces” is used to 

represent the external surfaces of SCs, such as tanks, that are 

not specifically listed elsewhere.

Heat exchanger components A heat exchanger is a device that transfers heat from one fluid to 

another without the fluids coming in contact with each other. This 

includes air handling units and other devices that cool or heat 

fluids. Heat exchanger components may include, but are not 

limited to, air handling unit cooling and heating coils, piping/tubing, 

shell, plates/frames, tubesheets, tubes, valves, and bolting. 

Although tubes are the primary heat transfer components, heat 

exchanger internals, including tubesheets and fins, contribute to 

heat transfer and may be affected by reduction of heat transfer 

due to fouling [Ref. 1]. The inclusion of components such as 

tubesheets is dependent on manufacturer specifications.
IX B-3

IX.B Use of Terms for Structures and Components

Term Usage in this document

High-voltage insulators An insulator is an insulating material in a configuration designed to 

physically support a conductor and separate the conductor 

electrically from other conductors or objects. The high-voltage 

insulators that are evaluated for license renewal are those used to 

support and insulate high-voltage electrical components in 

switchyards, switching stations and transmission lines.

Inaccessible areas of structural 

components for non-ASME 

structural AMPs

With regard to access for routine visual examination of steel and 

concrete structures and components within the scope of the 

Structures Monitoring program and other structural AMPs not 

based on the ASME Code, areas considered inaccessible are as 

defined below: 

• below-grade surfaces exposed to foundation soil/material, 

backfill, or groundwater 

• portions of concrete surfaces that are covered by metallic 

liners 

• portions of surfaces where visual access is obstructed by 

adjacent permanent plant structures, components, 

equipment, parts, or appurtenances 

• portions of steel components, supports, connections, 

parts, and appurtenances that are embedded or encased 

in concrete or encapsulated or otherwise made 

inaccessible during construction or as a result of 

repair/replacement activities. 

Wetted surfaces of submerged areas or areas covered or 

obstructed by insulation, protective coatings, microorganisms, 

biofoliage or vegetation are not considered inaccessible.

Metal enclosed bus (MEB) MEB is the term used in electrical and industry standards 

(IEEE and ANSI) for electrical buses installed on electricallyinsulated supports constructed with all phase conductors 

enclosed in a metal enclosure.

“No Additional Measures” 

components

One of four groups of pressurized water reactor vessel internal 

(PWR RVI) components defined in EPRI Report No. 1022863 

(MRP-227-A) that is discussed in the GALL-SLR Report AMP 

XI.M16A, “PWR Vessel Internals.” Refer to Section 3.3 in the 

MRP-227-A report for EPRI’s official definition of PWR RVI “No 

Additional Measures” components. 

Piping, piping components, and 

tanks

This general category includes features of the piping system 

within the scope of license renewal. Examples include piping, 

fittings, tubing, flow elements/indicators, demineralizers, nozzles, 

orifices, flex hoses, pump casings and bowls, safe ends, sight 

glasses, spray heads, strainers, thermowells, tanks and valve 

bodies and bonnets. For reactor coolant pressure boundary 

components in Chapter IV that are subject to cumulative fatigue 

damage, this category also can include flanges, nozzles and safe 

ends, penetrations, instrument connections, vessel heads, shells, 

welds, weld inlays and weld overlays, stub tubes, and 

miscellaneous Class 1 components (e.g., pressure housings, 

etc.). 
IX B-4

IX.B Use of Terms for Structures and Components

Term Usage in this document

Piping elements The category of “piping elements” applies only to components or 

portions of components made of glass (e.g., the glass portion of 

sight glasses and level indicators). In the GALL-SLR Report, 

Chapters V, VII, and VIII, piping elements are thus called 

out separately. 

Pressure housing The term “pressure housing” only refers to pressure housing for 

the CRD head penetration (it is only of concern in Section A2 for 

PWR reactor vessels).

“Primary” components One of four groups of pressurized water reactor vessel internal 

(PWR RVI) components defined in EPRI Report No. 1022863 

(MRP-227-A) that is discussed in the GALL-SLR Report AMP 

XI.M16A, “PWR Vessel Internals.” Refer to Section 3.3 in the 

MRP-227-A report for EPRI’s official definition of PWR RVI 

“Primary” components. 

Reactor coolant pressure boundary 

components

Reactor coolant pressure boundary components include, but are 

not limited to, piping, piping components, flanges, nozzles, safe 

ends, pressurizer vessel shell heads and welds, heater sheaths 

and sleeves, penetrations, and thermal sleeves.

Seals, gaskets, and moisture 

barriers (caulking, flashing, and 

other sealants)

This category includes elastomer and polymer components used 

as sealants or gaskets.

Steel elements: liner; liner anchors; 

integral attachments

This category includes steel liners used in suppression pools or 

spent fuel pools.

Switchyard bus Switchyard bus is the uninsulated, unenclosed, rigid electrical 

conductor or pipe used in switchyards and switching stations to 

connect two or more elements of an electrical power circuit, such 

as active disconnect switches and passive transmission 

conductors.

Tanks Tanks are large reservoirs used as hold-up volumes for liquids or 

gases. Tanks may have an internal liquid and/or vapor space and 

may be partially buried or in close proximity to soils or concrete. 

Tanks are treated separately from piping due to their potential 

need for different AMPs. One example is GALL-SLR Report AMP 

XI.M29, “Outdoor and Large Atmospheric Metallic Storage 

Tanks,” for tanks partially buried or in contact with soil or concrete 

that experience general corrosion as the aging effect at the soil or 

concrete interface.

Thermal insulation Thermal insulation is a material used to inhibit/prevent heat 

transfer across a thermal gradient. 

Thermal insulation materials include calcium silicate, fiberglass, 

Foamglas®, glass dust, cellular glass, and other materials with 

appropriate thermal conductivities. 

Transmission conductors Transmission conductors are uninsulated, stranded electrical 

cables used in switchyards, switching stations, and transmission 

lines to connect two or more elements of an electrical power 

circuit, such as active disconnect switches, power circuit breakers, 

and transformers and passive switchyard bus.

Vibration isolation elements This category includes nonsteel supports used for supporting 

components prone to vibration.
IX C-1

C. MATERIALS

The following table defines many generalized materials used in the preceding Generic Aging 

Lessons Learned for Subsequent License Renewal (GALL-SLR) Report Aging Management 

Review tables in Chapters II through VIII of the GALL-SLR Report.
IX C-2

IX.C Use of Terms for Materials

Term Usage in this document

Aluminum Aluminum (Al) alloy and heat treatment temper designations are used in 

accordance with ANSI document: ANSI H35.1/H35.1M. [Ref. 39]

Boraflex Boraflex is a material that is composed of 46% silica, 4% 

polydimethylsiloxane polymer, and 50% boron carbide, by weight. It is a 

neutron-absorbing material used in spent fuel storage racks. Degradation 

of Boraflex panels under gamma radiation can lead to a loss of their 

ability to absorb neutrons in spent fuel storage pools. The AMP for 

Boraflex is found in GALL-SLR Report AMPXI.M22, “Boraflex Monitoring.”

Boral®, boron steel Boron steel is steel with a boron content ranging from one to several 

percent. Boron steel absorbs neutrons and is often used as a control rod 

to help control the neutron flux.

Boral® is a cermet consisting of a core of Al and boron carbide powder 

sandwiched between sheets of Al. Boral refers to patented AluminumBoron master alloys; these alloys can contain up to 10% boron as AlB12 

intermetallics.

Cast austenitic stainless steel CASS alloys, such as CF-3, CF-8, CF-3M, and CF-8M, have been widely 

used in LWRs. These CASS alloys are similar to wrought grades 

Type 304L, Type 304, Type 316L, and Type 316, except CASS typically 

contains 5 to 25% ferrite. CASS is susceptible to loss of fracture 

toughness due to thermal and neutron irradiation embrittlement.

Coatings/linings Coatings/linings include inorganic (e.g., zinc-based, cementitious) or 

organic (e.g., elastomeric or polymeric) coatings, linings (e.g., rubber, 

cementitious), paints, and concrete surfacers designed to adhere to a 

component to protect its surface.

Concrete and cementitious 

material

When used generally, this category of concrete applies to concrete in 

many different configurations (block, cylindrical, etc.) and prestressed or 

reinforced concrete. Cementitious material can be defined as any 

material having cementing properties, which contributes to the formation 

of hydrated calcium silicate compounds. When mixing concrete, the 

following materials have cementitious properties: (i) Portland cement, (ii) 

blended hydraulic cement, (iii) fly ash, (iv) ground granulated blast furnace 

slag, (v) silica fume, (vi) calcined clay, (vii) metakaolin, (viii) calcined 

shale, and (ix) rice husk ash. This category may include asbestos 

cement. 

Copper alloy This category applies to those copper alloys whose critical alloying 

elements are below the thresholds that make them susceptible to SCC, 

selective leaching, and boric acid corrosion. For example, copper alloys 

with less than 15% zinc concentration are resistant to SCC, selective 

leaching, and boric acid corrosion. However, these alloys are susceptible 

to aging effects including general, pitting, and crevice corrosion in certain 

environments (e.g., closed-cycle cooling water, raw water, lubricating oil, 

treated water). [Ref. 2, 41]
IX C-3

IX.C Use of Terms for Materials

Term Usage in this document

Copper alloy (>15% Zn or 

>8% Al)

This category applies to those copper alloys whose critical alloying 

elements are above the thresholds that make them (in some cases) 

susceptible to SCC, selective leaching and boric acid corrosion. Copperzinc alloys >15% Zn (weight percent) are susceptible to SCC, selective 

leaching (dezincification), and boric acid corrosion. Copper aluminum 

bronze alloys > 8% Al (weight percent), are susceptible to SCC or 

selective leaching (dealuminification); however, not susceptible to loss of 

material due to boric acid corrosion. The percent values for zinc and 

aluminum are weight percent. [Ref. 2]. Inhibited brass components are 

resistant to dezincification as a result of the addition of alloying elements 

such as tin, arsenic, antimony, or phosphorous. [Ref. 35, 36].

Ductile iron Ductile iron, similar to gray cast iron, is an iron alloy made by adding 

larger amounts of carbon to molten iron than would be used to make 

steel. Most steel has less than about 1.2% by weight carbon, while cast 

irons typically have between 2.5 to 4%. Ductile iron contains spherical 

graphite nodules, as opposed to graphite flakes for gray cast iron, 

resulting in increased strength and ductility when compared to gray cast 

iron. Ductile iron is susceptible to selective leaching, resulting in a loss of 

iron from the microstructure, leaving a porous matrix of graphite. In some 

environments, ductile iron is categorized with the group “Steel.”

Elastomers Elastomer is an encompassing term used to refer to a variety of 

viscoelastic polymers including natural and synthetic rubbers. Elastomers 

include flexible materials such as rubber, EPT, EPDM, PTFE, ETFE, 

viton, vitril, neoprene, and silicone elastomer. 

Galvanized steel Galvanized steel is steel coated with Zn, usually by immersion or 

electrodeposition. The Zn coating protects the underlying steel because 

the corrosion rate of the Zn coating in dry, clean air is very low. In the 

presence of moisture, galvanized steel is classified under the category 

“Steel.”

Glass This category includes any glass material. Glass is a hard, amorphous, 

brittle, super-cooled liquid made by fusing together one or more of the 

oxides of silicon, boron, or phosphorous with certain basic oxides (e.g., 

Na, Mg, Ca, K), and cooling the product rapidly to prevent crystallization 

or devitrification. 

Graphitic tool steel Graphitic tool steels (such as AISI O6, which is oil-hardened, and, AISI 

A10, which is air-hardened), have excellent nonseizing properties. The 

graphite particles provide self-lubricity and hold applied lubricants.

Gray cast iron Gray cast iron is an iron alloy made by adding larger amounts of carbon 

to molten iron than would be used to make steel. Most steel has less 

than about 1.2% by weight carbon, while cast irons typically have 

between 2.5 to 4%. Gray cast iron contains flat graphite flakes that 

reduce its strength and form cracks, inducing mechanical failures. They 

also cause the metal to behave in a nearly brittle fashion, rather than 

experiencing the elastic, ductile behavior of steel. Gray cast iron is 

susceptible to selective leaching, resulting in a loss of iron from the 

microstructure, leaving a porous matrix of graphite. In some 

environments, gray cast iron is categorized with the group “Steel.”
IX C-4

IX.C Use of Terms for Materials

Term Usage in this document

High-strength steel High-strength steels are those with an actual yield strength greater than 

or equal to 150 kilo-pounds per square inch (ksi) [1,034 megapascals 

(MPa)]. These types of steels are susceptible to cracking. The materials 

are cited in GALL-SLR AMPs such as XI.M3, “Reactor Head Closure Stud 

Bolting,” XI.M18, “Bolting Integrity,” and XI.S3, “ASME Section XI, 

Subsection IWF.” AMP XI.M3 also uses a criterion of 170 ksi (1,172 

MPa) for the ultimate tensile strength of existing studs. [Ref. 40]

Lubrite® Lubrite® refers to a patented technology in which the bearing substrate 

(bronze is commonly used, but in unusual environments can range from 

SS and nodular-iron to tool-steel) is fastened to lubricant. Lubrite is often 

defined as bronze attached to ASTM B22, alloy 905, with G10 lubricant. 

Even though Lubrite bearings are characterized as maintenance-free 

because of the differences in installation, fineness of the surfaces, and 

lubricant characteristics, they can experience mechanical wear and 

fretting.

Bearings generally have not shown adverse conditions related to the use 

of Lubrite. The unique environment and precise installation tolerances 

required for installing the bearings require bearing-specific examinations. 

The vendor’s (Lubrite® Technologies) literature shows 10 lubricant types 

used in the bearings, ranging from G1 (General Duty) to AE7 

(temperature- and radiation-tested) lubricants. The type of lubricant used 

depends on the plant-specific requirements. Careful installation and 

clearing out any obstructions during installation ensures that the required 

tolerances of the bearings are met and reduces the likelihood of functional 

problems during challenging loading conditions (such as DBA or SSE). 

The associated aging effects could include malfunctioning, distortion, dirt 

accumulation, and fatigue under vibratory and cyclic thermal loads. The 

potential aging effects could be managed by incorporating its periodic 

examination in ASME Code Section XI, Subsection IWF (GALL-SLR 

Report AMP XI.S3) or in Structures Monitoring (GALL-SLR Report 

AMP XI.S6).

Malleable iron The term “Malleable iron” usually means malleable cast iron, 

characterized by exhibiting some elongation and reduction in area in a 

tensile test. Malleable iron is one of the materials in the category of 

“Porcelain, Malleable iron, Al, galvanized steel, cement.”

Nickel alloys Nickel alloys are nickel-chromium-iron (molybdenum) alloys and include 

the Alloys 600 and 690. Examples of nickel alloys include Alloy 182, 600, 

and 690, Gr. 688 (X-750), Inconel 182, Inconel 82, NiCrFe, SB-166, -167, 

and -168, and X-750. [Ref. 3]

Porcelain Hard-quality porcelain is used as an insulator for supporting high voltage 

electrical insulators. Porcelain is a hard, fine-grained ceramic that 

consists of kaolin, quartz, and feldspar fired at high temperatures. 

SA508-Cl 2 forgings clad with 

stainless steel using a highheat-input welding process

This category consists of quenched and tempered vacuum-treated carbon 

and alloy steel forgings for pressure vessels. As shown in AMR item R85, growth of intergranular separations (underclad cracks) in low-alloy 

steel forging heat affected zone under austenitic SS cladding is a TLAA to 

be evaluated for the subsequent period of extended operation for all the 

SA 508-Cl 2 forgings where the cladding was deposited with a high heat 

input welding process per ASME Code, Section XI. 
IX C-5

IX.C Use of Terms for Materials

Term Usage in this document

Stainless steel Products grouped under the term stainless steel (SS) include austenitic, 

ferritic, martensitic, PH, or duplex SS (Cr content >11%). These SSs may 

be fabricated using a wrought or cast process. These materials are 

susceptible to a variety of aging effects and mechanisms, including loss of 

material due to pitting and crevice corrosion, and cracking due to SCC. In 

some cases, when an aging effect is applicable to all of the various SS 

categories, it can be assumed that the term “stainless steel” in the 

“Material” column of an AMR item in the GALL-SLR Report encompasses 

all SS types. CASS is quite susceptible to loss of fracture toughness due 

to thermal and neutron irradiation embrittlement. In addition, MRP-227-A 

indicates that PH SSs or martensitic SSs may be susceptible to loss of 

fracture toughness by a thermal aging mechanism. Therefore, when loss 

of fracture toughness due to thermal and neutron irradiation embrittlement 

is an applicable aging effect and mechanism for a component in the 

GALL-SLR Report, the CASS, PH SS, or martensitic SS designation is 

specifically identified in an AMR item. 

Steel with SS cladding also may be considered SS when the aging effect 

is associated with the SS surface of the material, rather than the 

composite volume of the material. 

Examples of SS designations that comprise this category include A-286, 

SA193-Gr. B8, SA193-Gr. B8M, Gr. 660 (A-286), SA193-6, SA193-Gr. B8 

or B-8M, SA453, Type 416, Type 403, 410, 420, and 431 martensitic SSs, 

Type 15-5, 17-4, and 13-8-Mo PH SSs, and SA-193, Grade B8 and B8M 

bolting materials.

Examples of wrought austenitic stainless materials that comprise this 

category include Type 304, 304NG, 304L, 308, 308L, 309, 309L, 316 and 

347. Examples of CASS that comprise this category include CF3, CF3M, 

CF8 and CF8M. [Ref. 4, 5, 6].

Steel In some environments, carbon steel, alloy steel, gray cast iron, ductile 

iron, malleable iron, and high-strength low-alloy steel are vulnerable to 

general, pitting, and crevice corrosion, even though the rate of loss of 

material may vary amongst material types. Consequently, these metal 

types are generally grouped under the broad term “steel.” Note that this 

does not include SS, which has its own category. However, gray cast iron

and ductile iron are susceptible to selective leaching, and high-strength 

low-alloy steel is susceptible to SCC. Therefore, when these aging 

effects are being considered, these materials are specifically identified. 

Galvanized steel (Zn-coated carbon steel) is also included in the category 

of “steel” when exposed to moisture. Malleable iron is specifically called 

out in the phrase “Porcelain, Malleable iron, Al, galvanized steel, cement,” 

which is used to define the high-voltage insulators in GALL-SLR 

Chapter VI.

Examples of steel designations included in this category are ASTM A36, 

ASTM A285, ASTM A759, SA36, SA106-Gr. B, SA155-Gr. KCF70, 

SA193-Gr. B7, SA194 -Gr. 7, SA302-Gr B, SA320-Gr. L43 (AISI 4340), 

SA333-Gr. 6, SA336, SA508-64, class 2, SA508-Cl 2 or Cl 3, SA516-Gr. 

70, SA533-Gr. B, SA540-Gr. B23/24, and SA582. [Ref. 4, 5]
IX C-6

IX.C Use of Terms for Materials

Term Usage in this document

Superaustenitic stainless 

steel

Superaustenitic SSs have the same structure as the common austenitic 

alloys, but they have enhanced levels of elements such as chromium, 

nickel, molybdenum, copper, and nitrogen, which give them superior 

strength and corrosion resistance. Compared to conventional austenitic 

SSs, superaustenitic materials have a superior resistance to pitting and 

crevice corrosion in environments containing halides. Several nuclear 

power plants have installed superaustenitic SS (AL-6XN) buried piping. 

Titanium The category titanium includes unalloyed titanium (ASTM grades 1-4) and 

various related alloys (ASTM grades 5, 7, 9, 11, and 12). The corrosion 

resistance of titanium is a result of the formation of a continuous, stable, 

highly adherent protective oxide layer on the metal surface. 

The AMR tables in some instances, depending on the specific grade of 

titanium, state that there are no aging effects requiring management. 

However, titanium in general is susceptible to reduction of heat transfer 

due to fouling or flow blockage due to fouling depending upon the specific 

environment (e.g., E-458). 

Titanium and titanium alloys may be susceptible to crevice corrosion in 

saltwater environments at elevated temperatures >71 °C [>160 °F]. 

Titanium Grades 5 and 12 are resistant to crevice corrosion in seawater 

at temperatures as high as 500 °F. SCC of titanium and its alloys is 

considered applicable in seawater or brackish raw water systems if the 

titanium alloy contains more than 6% Al or more than 0.30% oxygen or 

any amount of tin [Ref. 7]. ASTM Grades 1, 2, 7, 9, 11, or 12 are not 

susceptible to SCC in seawater or brackish raw water [Ref. 8].

Various organic polymers Polymers used in electrical applications include EPR, SR, EPDM, and 

XLPE. XLPE is a cross-linked polyethylene thermoplastic resin, such as 

polyethylene and polyethylene copolymers. EPR and EPDM are EPRs in 

the category of thermosetting elastomers.

Various polymeric materials Polymers used in mechanical applications are either addressed as 

specific material types (e.g., PVC, HDPE, fiberglass); or generically as 

elastomers used in different components types (e.g., piping, seals, linings, 

fire barriers) with distinct aging effects, or broadly as polymeric where a 

wide range of potential aging effects are cited. Unless otherwise justified 

in the SLRA (or as follows), when the material type is cited as polymeric, 

inspections are conducted in a manner conducive to detecting all cited 

aging effects. Flow blockage due to fouling need not be considered for 

polymeric materials exposed to air (external), condensation (external), 

underground environment, and concrete environments. For the concrete 

environment, inspections consistent with GALL-SLR Report AMP XI.M41 

are acceptable. Hardening need not be detected in rigid polymers.

Wood Wood piles or sheeting exposed to flowing or standing water is subject to 

loss of material or changes in material properties due to weathering, 

chemical degradation, insect infestation, repeated wetting and drying, or 

fungal decay.

Zircaloy-4 Zry-4 is a member in the group of high-Zr alloys. Such Zircaloys are used 

in nuclear technology, as Zr has very low absorption cross-section of 

thermal neutrons. In the GALL-SLR Report, Zry-4 is referenced in AMR 

Item IV.B3.RP-357 for incore instrumentation thimble tubes. Zry-4 

consists of 98.23 weight % zirconium with 1.45% tin, 0.21% iron, 0.1% 

chromium, and 0.01% hafnium. 
IX D-1

D. ENVIRONMENTS

The following table defines many of the standardized terms for environments used in the 

preceding Generic Aging Lessons Learned for Subsequent License Renewal (GALL-SLR) Report 

Aging Management Review (AMR) tables in Chapters II through VIII of the GALL-SLR Report. 

The usage of temperature thresholds for describing aging effects are continued as in the Generic 

Aging Lessons Learned (GALL) Report, Revision 2. 

Environmental stressors for elastomeric and polymeric materials: In general, if the ambient 

temperature is less than about 35 °C (Celsius) [95 °F (Fahrenheit)], then thermal aging may be 

considered not significant for rubber, butyl rubber, neoprene, nitrile rubber, silicone elastomer, 

fluoroelastomer, ethylene-propylene rubber, and ethylene propylene diene monomer [Ref. 9]. 

Hardening or loss of strength of elastomers and polymers can be induced by thermal aging, 

exposure to ozone, oxidation, photolysis (due to ultraviolet light), and radiation. When applied to 

the elastomers used in electrical cable insulation, it should be noted that most cable insulation is 

manufactured as either 75 °

C [167 °F] or 90 °C [194 °F] rated material.

Temperature threshold of 60 °C [140 °F] for stress corrosion cracking (SCC) in stainless steel 

(SS): SCC occurs very rarely in austenitic SSs below 60 °C [140 °F]. Although SCC has been 

observed in stagnant, oxygenated borated water systems at lower temperatures than this 60 °C 

[140 °F] threshold, all of these instances have identified a significant presence of contaminants 

(halogens, specifically chlorides) in the failed components. With a harsh enough environment 

(e.g., significant contamination), SCC can occur in austenitic SS at ambient temperature. In a 

water environment where the concentration of contaminants (e.g., sulfates, chlorides, fluorides) is 

maintained consistent with a water chemistry program, these conditions are considered eventdriven, resulting from a breakdown of chemistry controls. However in environments where the 

chemistry is not controlled (e.g., air-outdoor, soil, exposure to leakage from bolted connections in 

the vicinity of the component) SCC can occur at ambient temperature. In air-outdoor 

environments, surface temperatures exposed directly to sunlight will be higher than ambient air 

conditions [Ref. 8, 10, 11]. 

Temperature threshold of 250 °C [482 °F] for thermal embrittlement in cast austenitic stainless 

steel (CASS): CASS subjected to sustained temperatures below 250 °C [482 °F] will not result in 

a reduction of room temperature Charpy impact energy below 50 foot-pound (ft-lb) for exposure 

times of approximately 300,000 hours (for CASS with ferrite content of 40 percent and 

approximately 2,500,000 hours for CASS with ferrite content of 14 percent) [Fig. 2; Ref. 12]. For a 

maximum exposure time of approximately 420,000 hours (48 EFPY), a screening temperature of 

250 °C [482 °F] is conservatively chosen because (1) the majority of nuclear grade materials is 

expected to contain a ferrite content well below 40 percent, and (2) the 50 ft-lb limit is very 

conservative when applied to cast austenitic materials. It is typically applied to ferritic materials 

(e.g., 10 CFR Part 50 Appendix G). For CASS components in the reactor coolant pressure 

boundary, this threshold is supported by the GALL-SLR Report AMP XI.M12, “Thermal Aging 

Embrittlement of Cast Austenitic Stainless Steel (CASS),” with the exception of 

niobium-containing steels, which require evaluation on a case-by-case basis.
IX D-2

IX.D Use of Terms for Environments

Term Usage in this document

Adverse localized environment An adverse localized environment is an environment limited to the 

immediate vicinity of a component that is hostile to the component 

material, thereby leading to potential aging effects. Electrical insulation 

used for electrical cables can be subjected to an adverse localized 

environment. Adverse localized environment can be due to any of the 

following: (1) exposure to significant moisture, or (2) heat, radiation, or 

moisture and are represented by specific GALL-SLR AMR items. 

Aggressive environment 

(steel in concrete)

This environment affects steel embedded in concrete with a pH <5.5 or 

a chloride concentration >500 ppm or sulfate >1,500 ppm. [Ref. 13]

Air Any indoor or outdoor air environment where the cited aging effects 

could occur regardless of the particular air environment (e.g., air-indoor 

uncontrolled, air-outdoor). For example: (a) hardening or loss of 

strength of elastomeric components occurs in many different air 

environments depending upon environmental parameters such as 

temperature, ozone, ultraviolet light, and radiation; (b) loss of preload for 

closure bolting can occur in a variety of air environments. The term “air” 

was incorporated to allow the aging management review line items to 

be more succinct in regard to citing environments. This term does not 

encompass the air environment downstream of instrument air dryers, 

air-dry, or the underground environment. The potential for leakage from 

bolted connections (e.g., flanges, packing) impacting in-scope 

components exists when citing the air environment.

Air–dry Air that has been treated to reduce its dew point well below the system 

operating temperature and treated to control lubricant content, 

particulate matter, and other corrosive contaminants. Use of this term is 

only associated with internal air environments located downstream of 

the compressed air system air dryers. 

The associated AMR items cite loss of material as an aging effect and 

GALL-SLR Report AMP XI.M24, “Compressed Air Monitoring,” as the 

recommended AMP. AMP XI.M24 recommends opportunistic 

inspections for loss of material and therefore the line items were revised 

to cite loss of material. 

Air–indoor controlled An environment where the specified internal or external surface of the 

component or structure is exposed to a humidity-controlled (i.e., air 

conditioned) environment. For electrical components and structures, 

the controlled environment must be sufficient to show that the electrical 

component(s) or structure(s) are not subjected to the cited aging 

effect(s) (e.g., reduced insulation resistance). The potential for leakage 

from bolted connections (e.g., flanges, packing) impacting in-scope 

components exists when citing the air–indoor controlled environment.

Air–indoor uncontrolled Air–indoor uncontrolled is associated with systems with temperatures 

higher than the dew point (i.e., condensation can occur, but only rarely; 

equipment surfaces are normally dry). The potential for leakage from 

bolted connections (e.g., flanges, packing) impacting in-scope 

components exists when citing the air–indoor uncontrolled environment.
IX D-3

IX.D Use of Terms for Environments

Term Usage in this document

Air–outdoor The outdoor environment consists of moist, possibly salt-laden air and 

spray, cooling tower plumes (which might contain chemical additives), 

industrial pollutants (e.g., fly ash, soot), ambient temperatures and 

humidity, and exposure to weather events, including precipitation and 

wind. The outdoor air environment also potentially includes component 

contamination due to animal infestation including by-products or 

excrement containing uric acid, ammonia, phosphates, or other 

compounds. The outdoor air environment can also result in 

submergence of components (particularly when they are in vaults) due 

to the potential for water to accumulate or due to external or internal 

buildup of condensation.

Air with borated water leakage Air and untreated borated water leakage on indoor or outdoor systems 

with temperatures either above or below the dew point. The water from 

leakage is considered to be untreated, due to the potential for water 

contamination at the surface (germane to PWRs).

Any With some exceptions, this could be any environment where the cited 

aging effects could occur regardless of the particular environment 

(e.g., air, water, lubricating oil). For example, loss of preload is an 

applicable aging effect for bolting in air as well as fluid environments. 

This term includes all fluid and air environments (with the exception of 

air-dry (internal), but excludes underground). For structural 

components (i.e., GALL-SLR Chapters II and III) the term “any” includes 

groundwater and soil environments. For mechanical components 

(i.e., GALL-SLR Chapters IV, V, VII, and VIII) the term “any” excludes 

underground, soil, and concrete environments where water could be 

present (i.e., the environments addressed in GALL-SLR Report AMP 

XI.M41, “Buried and Underground Piping and Tanks”). 

Buried Buried piping and tanks are those in direct contact with soil, or those in 

contact with concrete where water could be present (e.g., a wall 

penetration). When the soil environment is cited, the term includes 

exposure to groundwater.

Closed-cycle cooling water A subset of treated water that is subject to the closed treated water 

systems program. Systems are closed in that the rate of recirculation is 

much higher than the rate of makeup water addition. Examples include 

the closed portions of HVAC systems and diesel generator cooling 

water systems.

Closed-cycle cooling water systems above 60 °C [>140 °F] exceed the 

threshold for SS SCC.

Concrete This environment consists of components that sit on concrete or are 

embedded in concrete.
IX D-4

IX.D Use of Terms for Environments

Term Usage in this document

Condensation Condensation on the surfaces of systems at temperatures below the 

dew point facilitates loss of material in steel caused by general, pitting, 

and crevice corrosion. It also facilitates cracking in those materials 

susceptible to stress corrosion cracking due to the potential for internal 

or external surface contamination. The former term “moist air” is 

subsumed by the usage of the term “condensation.” Moisture in the air 

can result in loss of material or cracking due to hygroscopic surface 

contaminants.

Condensation can form between thermal insulation and a component 

when air intrusion occurs through minor gaps in the insulation and the 

operating temperature of the component is below the dew point of the 

penetrating air.

Containment environment 

(inert) 

A drywell environment is made inert with nitrogen to render the primary 

containment atmosphere nonflammable by maintaining the oxygen 

content below 4% by volume during normal operation.

Diesel exhaust This environment consists of gases, fluids, and particulates present in 

diesel engine exhaust.

Fuel oil Diesel oil, No. 2 oil, or other liquid hydrocarbons used to fuel diesel 

engines. Fuel oil used for combustion engines may be contaminated 

with water, which may promote additional aging effects. 

Gas Internal gas environments include inert or nonreactive gases. This 

generic term is used only with “Common Miscellaneous 

Material/Environment,” where aging effects are not expected to degrade 

the ability of the structure or component to perform its intended function 

for the subsequent period of extended operation. 

The term “gas” is not meant to comprehensively include all gases in the 

fire suppression system. The GALL-SLR Report AMP XI.M26, “Fire 

Protection,” is used for the periodic inspection and testing of the 

halon/carbon dioxide fire suppression system.

Groundwater/soil Groundwater is subsurface water that can be detected in wells, tunnels, 

or drainage galleries, or that flows naturally to the earth’s surface via 

seeps or springs. Soil is a mixture of organic and inorganic materials 

produced by the weathering of rock and clay minerals or the 

decomposition of vegetation. Voids containing air and moisture can 

occupy 30–60% of the soil volume [Ref.14]. Concrete subjected to a 

groundwater/soil environment can be vulnerable to an increase in 

porosity and permeability, cracking, loss of material (spalling, scaling), 

or aggressive chemical attack. Other materials with prolonged 

exposures to groundwater or moist soils are subject to the same aging 

effects as those systems and components exposed to raw water.
IX D-5

IX.D Use of Terms for Environments

Term Usage in this document

Lubricating oil Lubricating oils are low-to-medium viscosity hydrocarbons that can 

contain contaminants and/or moisture. This usage also functionally 

encompasses hydraulic oil (nonwater based). These oils are used for 

bearing, gear, and engine lubrication. The GALL-SLR Report AMP 

XI.M39, “Lubricating Oil Analysis,” addresses this environment. Piping

and piping components, whether copper, SS, or steel, when exposed to 

lubricating oil with some water, will have limited susceptibility to aging 

degradation due to general or localized corrosion.

Lubricating oil (waste oil) and lubricating oil are two different 

environments. Lubricating oil (waste oil) is oil that has been collected 

as it leaks from a component (e.g., reactor coolant pumps) and as such, 

contains potential contaminants such as water and dirt. Lubricating oil 

is unlikely to contain contaminants due to the testing of the oil and 

corrective actions when contaminants are detected. As a result, 

one-time inspections for components exposed to these environments 

are treated as two separate populations.

Raw water Raw water consists of untreated surface or groundwater, whether fresh, 

brackish, or saline in nature. This includes water for use in OCCW 

systems and may include potable water, water that is used for drinking 

or other personal use. See also “condensation.”

Reactor coolant Reactor coolant is treated water in the reactor coolant system and 

connected systems at or near full operating temperature, including 

steam associated with BWRs. 

Reactor coolant >250 °C 

[>482°F]

Treated water above the thermal embrittlement threshold for CASS. 

Reactor coolant >250 °C 

[>482°F] and neutron flux

Treated water in the reactor coolant system and connected systems 

above the thermal embrittlement threshold for CASS. 

Reactor coolant and high 

fluence (>1 × 1021 n/cm2 E 

>0.1 MeV)

Reactor coolant subjected to a high fluence (>1 × 1021 n/cm2 E 

>0.1 MeV). 

Reactor coolant and neutron 

flux

The reactor core environment that will result in a neutron fluence 

exceeding 1017 n/cm2 (E >1 MeV) at the end of the license renewal 

term. 

Reactor coolant and 

secondary feedwater/steam

Water in the reactor coolant system and connected systems at or near 

full operating temperature and the PWR feedwater or steam at or near 

full operating temperature, subject to the secondary water chemistry 

program (GALL-SLR Report AMP XI.M2). 

Secondary feedwater Within the context of the recirculating steam generator, components 

such as steam generator feedwater impingement plate and support may 

be subjected to loss of material due to erosion in a secondary feedwater 

environment. More generally, the environment of concern is a 

secondary feedwater/steam combination.

Secondary feedwater/steam PWR feedwater or steam at or near full operating temperature, subject 

to the secondary water chemistry program (GALL-SLR Report AMP 

XI.M2). 

Sodium pentaborate solution Treated water that contains a mixture of borax and boric acid.
IX D-6

IX.D Use of Terms for Environments

Term Usage in this document

Soil Soil is a mixture of inorganic materials produced by the weathering of 

rock and clay minerals, and organic material produced by the 

decomposition of vegetation. Voids containing air and moisture occupy 

30–60% of the soil volume [Ref.14]. Properties of soil that can affect 

degradation kinetics include moisture content, pH, ion exchange 

capacity, density, and hydraulic conductivity. External environments 

included in the soil category consist of components at the air/soil 

interface, buried in the soil, or exposed to groundwater in the soil. See 

also “groundwater/soil.”

Steam The steam environment is managed by the BWR water chemistry 

program or PWR secondary plant water chemistry program. Defining 

the temperature of the steam is not considered necessary for analysis.

System temperature up to 

288 °C [550 °F]

This environment consists of a metal temperature of BWR components 

<288 °C [550 °F].

System temperature up to 

340 °C [644 °F]

This environment consists of a maximum metal temperature <340 °C 

[644 °F].

Treated borated water Borated (PWR) water is a controlled water system. The CVCS 

maintains the proper water chemistry in the reactor coolant system 

while adjusting the boron concentration during operation to match 

long-term reactivity changes in the core.

Treated borated water >250 

°C [>482 °F]

Treated water with boric acid above the 250 °C [>482 °F] thermal 

embrittlement threshold for CASS.

Treated borated water >60 °C 

[>140 °F]

Treated water with boric acid in PWR systems above the 60 °C [>140 

°F] SCC threshold for SS.

Treated water Treated water is water whose chemistry has been altered and is 

maintained (as evidenced by testing) in a state which differs from 

naturally-occurring sources so as to meet a desired set of chemical 

specifications. 

Treated water generally falls into one of two categories. 

(1) The first category is based on demineralized water and, with the 

possible exception of boric acid (for PWRs only), generally contains 

minimal amounts of any additions. This water is generally 

characterized by high purity, low conductivity, and very low oxygen 

content. This category of treated water is generally used as BWR 

coolant and PWR primary and secondary water.

(2) The second category may be but need not be based on 

demineralized water. It contains corrosion inhibitors and also may 

contain biocides or other additives. This water will generally be 

comparatively higher in conductivity and oxygen content than the 

first category of treated water. This category of treated water is 

generally used in HVAC systems, auxiliary boilers, and diesel 

engine cooling systems. CCCW is a subset of this category of 

treated water.

Treated water >60 °C [>140 

°F]

Treated water above the 60 °C [140 °F] SCC threshold for SS.
IX D-7

IX.D Use of Terms for Environments

Term Usage in this document

Underground Underground piping and tanks are below grade, but are contained 

within a tunnel or vault such that they are in contact with air and are 

located where access for inspection is limited (e.g., special lifting 

equipment is required to gain access to the vault). When the 

underground environment is cited, the term includes exposure to 

air-outdoor, air-indoor uncontrolled, air, raw water, groundwater, and

condensation.

Waste water Radioactive, potentially radioactive or nonradioactive waters that are 

collected from equipment and floor drains. Waste waters may contain 

contaminants, including oil and boric acid, depending on location, as 

well as originally treated water that is not monitored by a 

chemistry program.

Water-flowing Water that is refreshed; thus, it has a greater impact on leaching and 

can include rainwater, raw water, groundwater, or water flowing under a 

foundation.

Water-standing Water that is stagnant and unrefreshed, thus possibly resulting in 

increased ionic strength up to saturation.

IX E-1

E. AGING EFFECTS

The following table explains the selected usage of many of the standardized aging effects due to 

associated aging mechanisms used in the preceding Generic Aging Lessons Learned for 

Subsequent License Renewal (GALL-SLR) Report aging management review tables in 

Chapters II through VIII of the GALL-SLR Report.
IX E-2

IX.E Use of Terms for Aging Effects

Term Usage in this document

Changes in dimensions Changes in dimension can result from various phenomena, such as 

void swelling, and on a macroscopic level, denting. 

Concrete cracking and spalling Cracking and exfoliation of concrete as the result of freeze-thaw, 

aggressive chemical attack, and reaction with aggregates.

Corrosion of connector 

contact surfaces

Corrosion of exposed connector contact surfaces when caused by 

borated water intrusion.

Crack growth Increase in crack size attributable to cyclic loading.

Cracking This term is synonymous with the phrase “crack initiation and growth” in 

metallic substrates. Cracking in concrete when caused by restraint 

shrinkage, creep, settlement, and aggressive environment.

Cracks; distortion; increase in 

component stress level

Within concrete structures, cracks, distortion, and increase in 

component stress level when caused by settlement. Although 

settlement can occur in a soil environment, the symptoms can be 

manifested in any environment.

Cumulative fatigue damage Cumulative fatigue damage is due to fatigue, as defined by ASME 

Code.

Denting Denting in steam generators can result from corrosion of carbon steel 

tube support plates.

Expansion and cracking Within concrete structures, expansion and cracking can result from 

reaction with aggregates. 

Fatigue Fatigue in metallic fuse holder clamps can result from ohmic heating, 

thermal cycling, electrical transients, frequent manipulation, and 

vibration. [Ref. 15]

Flow blockage Flow blockage is the reduction of flow and/or pressure in a component 

due to fouling, which can occur from accumulations of particulate 

fouling, biofouling, or macro fouling. In addition to affecting the 

“pressure boundary” intended function (as it relates to sufficient flow at 

adequate pressure), flow blockage can also affect the “heat transfer,” 

“spray,” and “throttle” intended functions.

Hardening or loss of strength Hardening (loss of flexibility) and loss of strength (loss of ability to 

withstand tensile or compressive stress) can result from elastomer or 

polymer degradation of seals and other components. Degraded 

elastomers or polymers can experience increased hardness, shrinkage, 

loss of sealing, cracking, and loss of strength. Hardening or loss of 

strength of elastomers or polymers can be induced by elevated 

temperature [over about 35 °C (95 °F)], and additional aging factors 

(e.g., exposure to ozone, oxidation, photolysis (due to ultraviolet light), 

and radiation). [Ref. 9]

Increase in porosity and 

permeability, cracking, loss of 

material (spalling, scaling), 

loss of strength

Porosity and permeability, cracking, and loss of material (spalling, 

scaling) in concrete can increase due to aggressive chemical attack. In 

concrete, the loss of material (spalling, scaling) and cracking can result 

from the freeze-thaw processes. Loss of strength can result from 

leaching of calcium hydroxide in the concrete.
IX E-3

IX.E Use of Terms for Aging Effects

Term Usage in this document

Increased resistance of 

connection

Increased resistance of connection is an aging effect that can be 

caused by the loosening of bolts resulting from thermal cycling and 

ohmic heating. [Ref. 17, 18]

In the GALL-SLR Report Chapter VI AMR items, increased resistance 

to connection is also said to be caused by the following aging 

mechanisms:

• Chemical contamination, corrosion, and oxidation (in an air-indoor 

controlled environment, increased resistance of connection due to 

chemical contamination, corrosion and oxidation do not apply) 

• Thermal cycling, ohmic heating, electrical transients, vibration, 

chemical contamination, corrosion, or oxidation

• Fatigue caused by frequent manipulation or vibration 

• Corrosion of connector contact surfaces caused by intrusion of 

borated water 

• Oxidation or loss of preload.

Ligament cracking Steel tube support plates can experience ligament cracking due to 

corrosion. As previously noted in IN 96-09, tube support plate signal 

anomalies found during eddy current testing of SG tubes may be 

indicative of support plate damage or ligament cracking. 

Long-term loss of material The term “long-term loss of material” was incorporated into the 

GALL-SLR Report to differentiate it from the term “loss of material.” 

Original plant designs should have included at least a 40-year corrosion 

allowance for steel systems. For steel systems exposed to water 

environments without corrosion inhibitors, it is appropriate to confirm 

that the rate of loss of material will not challenge the structural integrity 

of these systems throughout an 80-year span of operation. Long-term 

loss of material is addressed once prior to entering the subsequent 

period of extended operation, as long as the results of volumetric 

examinations establish that the structural integrity intended function(s)

of the in-scope components will be met until the end of 80 years of 

operation. In contrast, loss of material is addressed in periodic or 

opportunistic inspections conducted throughout the subsequent period 

of extended operation.

Loss of coating or lining 

integrity

Loss of coating or lining integrity is the disbondment of a coating/lining 

from its substrate. Loss of coating or lining integrity can be due to a 

variety of aging mechanisms such as blistering, cracking, flaking, 

peeling, delamination, rusting, or physical damage, and spalling for

cementitious coatings/linings.

Where the aging mechanism results in exposure of the base material, 

loss of material of the base material can occur.

Where the aging mechanism results in the coating/lining not remaining 

adhered to the substrate, the coating/lining can become debris that 

could prevent an in-scope component from satisfactorily accomplishing 

any of its functions identified under 10 CFR 54.4(a)(1) or (a)(3) 

(e.g., reduction in flow, drop in pressure, reduction of heat transfer).

Loss of conductor strength Transmission conductors can experience loss of conductor strength 

due to corrosion.
IX E-4

IX.E Use of Terms for Aging Effects

Term Usage in this document

Loss of fracture toughness Loss of fracture toughness can result from various aging mechanisms, 

including thermal aging embrittlement and neutron irradiation 

embrittlement. 

Loss of leak tightness Steel airlocks can experience loss of leak tightness in the closed 

position resulting from mechanical wear of locks, hinges, and closure 

mechanisms.

Loss of material Loss of material in mechanical components may be due to general 

corrosion, boric acid corrosion, pitting corrosion, galvanic corrosion, 

crevice corrosion, erosion, fretting, flow-accelerated corrosion, 

microbiologically influenced corrosion, fouling, selective leaching, 

wastage, and wear. 

In concrete structures, loss of material can also be caused by 

aggressive chemical attack, abrasion, cavitation or corrosion of

embedded steel. 

For high voltage insulators, loss of material can be attributed to 

mechanical wear or wind-induced abrasion. [Ref. 17]

Loss of material, loss of form In earthen water-control structures, the loss of material and loss of form 

can result from erosion, settlement, sedimentation, frost action, waves, 

currents, surface runoff, and seepage.

Loss of mechanical function Loss of mechanical function in Class 1 piping and components (such as 

constant and variable load spring hangers, guides, stops, sliding 

surfaces, and vibration isolators) fabricated from steel or other 

materials, such as Lubrite®, can occur through the combined influence 

of a number of aging mechanisms. Such aging mechanisms can 

include corrosion, distortion, dirt accumulation, overload, fatigue due to 

vibratory and cyclic thermal loads, or elastomer or polymer hardening. 

Clearances being less than the design requirements can also contribute 

to loss of mechanical function.

Loss of preload Loss of preload can be due to gasket creep, thermal or irradiation 

effects (including differential expansion and creep or stress relaxation), 

and self-loosening (which includes vibration, joint flexing, cyclic shear 

loads, thermal cycles). [Ref. 19]

Loss of prestress Loss of prestress in structural steel anchorage components can result 

from relaxation, shrinkage, creep, or elevated temperatures.

Loss of sealing; leakage 

through containment

Loss of sealing and leakage through containment in such materials as 

seals, elastomers, rubber, and other similar materials can result from 

deterioration of seals, gaskets, and moisture barriers (caulking, 

flashing, and other sealants). Loss of sealing in elastomeric phase bus 

enclosure assemblies can result from moisture intrusion.

None Certain material/environment combinations may not be subject to 

significant aging mechanisms; thus, there are no relevant aging effects 

that require management.
IX E-5

IX.E Use of Terms for Aging Effects

Term Usage in this document

Reduced electrical insulation 

resistance

Reduced electrical insulation resistance is the decrease in the 

effectiveness of the electrical insulation to inhibit/prevent the conduction 

of an electric current. 

Reduced electrical insulation resistance is an aging effect associated 

with the following aging mechanisms: 

• Thermal/thermoxidative degradation of organics/thermoplastics, 

radiation-induced oxidation, moisture/debris intrusion, and ohmic 

heating 

• Presence of salt deposits or surface contamination 

• Thermal/thermoxidative degradation of organics, radiolysis, 

and photolysis (UV sensitive materials only) of organics; 

radiation-induced oxidation; moisture intrusion moisture

• Moisture

Reduced thermal insulation 

resistance 

Reduced thermal insulation resistance is a decrease in the 

effectiveness of the thermal insulation to inhibit/prevent heat transfer 

across a thermal gradient. 

Reduced thermal insulation resistance can be the result of moisture 

intrusion and/or the exposure to moisture.

Reduction in concrete anchor 

capacity due to local concrete 

degradation

Reduction in concrete anchor capacity due to local concrete 

degradation can result from a service-induced cracking or other 

concrete aging mechanisms.

Reduction in foundation 

strength, cracking, differential 

settlement

Reduction in foundation strength, cracking, and differential settlement 

can result from erosion of porous concrete subfoundation.

Reduction in impact strength Exposure of PVC piping and piping components to sunlight for 2 years 

or longer can result in a reduction in impact strength. Other polymeric 

materials are subject to embrittlement due to environmental conditions 

such as sunlight, ozone, chemical vapors, or loss of plasticizers due to 

evaporation. [Ref. 16]

Reduction of heat transfer Reduction of heat transfer can result from fouling on the heat transfer 

surface. Although in heat exchangers the tubes are the primary heat 

transfer component, heat exchanger internals, including tubesheets and 

fins, contribute to heat transfer and may be affected by the reduction of 

heat transfer due to fouling. Although the GALL-SLR Report does not 

include reduction of heat transfer for any heat exchanger surfaces other 

than tubes, reduction of heat transfer is of concern for other heat 

exchanger surfaces.

Reduction of neutronabsorbing capacityReduction of neutron-absorbing capacity can result from Boraflex 

degradation.

Reduction of strength and 

modulus

In concrete, reduction of strength and modulus can be attributed to 

elevated temperatures {>66 °C [>150 °F] general; >93 °C [>200 °F]

local}.

Reduction or loss of isolation 

function 

Reduction or loss of isolation function in polymeric vibration isolation 

elements can result from elastomers exposed to radiation hardening, 

temperature, humidity, sustained vibratory loading.

Wall thinning Wall thinning is a specific type of loss of material attributed in the AMR 

items to general corrosion, flow-accelerated corrosion, and erosion 

mechanisms including cavitation, flashing, droplet impingement, or solid 

particle impingement.

IX F-1

F. SIGNIFICANT AGING MECHANISMS

An aging mechanism is considered to be significant when it may result in aging effects that 

produce a loss of functionality of a component or structure during the current or license renewal 

period if allowed to continue without mitigation. 

The following table defines many of the standardized aging mechanisms used in the preceding 

Generic Aging Lessons Learned for Subsequent License Renewal (GALL-SLR) Report aging 

management review line item tables in Chapters II through VIII of GALL-SLR Report.
IX F-2

IX.F Use of Terms for Aging Mechanisms

Term Usage in this document

Abrasion As used in the context of the GALL-SLR Report, Chapter III, “Structures 

and Component Supports,” as water migrates over a concrete surface, it 

may transport material that can abrade the concrete. The passage of 

water also may create a negative pressure at the water/air-to-concrete 

interface that can result in abrasion and cavitation degradation of the 

concrete. This may result in pitting or aggregate exposure due to loss of 

cement paste. [Ref. 20]

Aggressive chemical attack Concrete, being highly alkaline (pH >12.5), is degraded by strong acids. 

Chlorides and sulfates of potassium, sodium, and magnesium may attack 

concrete, depending on their concentrations in soil/groundwater that 

comes into contact with the concrete. Exposed surfaces of Class 1 

structures may be subject to sulfur-based acid-rain degradation. The 

minimum thresholds causing concrete degradation are 500 ppm chlorides 

and 1,500 ppm sulfates. [Ref. 20]

Boraflex degradation Boraflex degradation may involve gamma radiation-induced shrinkage of 

Boraflex and the potential to develop tears or gaps in the material. A 

more significant potential degradation is the gradual release of silica and 

the depletion of boron carbide from Boraflex, following gamma irradiation 

and long-term exposure to the wet pool environment. The loss of boron 

carbide from Boraflex is characterized by slow dissolution of the Boraflex 

matrix from the surface of the Boraflex and a gradual thinning of 

the material.

The boron carbide loss can result in a significant increase in the reactivity 

within the storage racks. An additional consideration is the potential for 

silica transfer through the fuel transfer canal into the reactor core during 

refueling operations and its effect on the fuel-clad heat transfer capability. 

[Ref. 21] 

Boric acid corrosion Corrosion by boric acid, which can occur where there is borated water 

leakage in an environment described as air with borated water leakage 

(see Corrosion).

Cavitation Formation and instantaneous collapse of innumerable tiny voids or 

cavities within a liquid subjected to rapid and intense pressure changes. 

Cavitation caused by severe turbulent flow can potentially lead to 

cavitation damage.

Chemical contamination Presence of chemicals that do not occur under normal conditions at 

concentrations that could result in the degradation of the component.

Cladding degradation This refers to the degradation of the SS cladding via any applicable 

degradation process and is a precursor to cladding breach. 

It is only used to describe the loss of material due to pitting and crevice 

corrosion (only for steel after cladding degradation) of piping, piping 

components, and fabricated from steel, with SS cladding.

Corrosion Chemical or electrochemical reaction between a material, usually a metal, 

and the environment or between two dissimilar metals that produces a 

deterioration of the material and its properties.

Corrosion of carbon steel 

tube support plate

Corrosion can occur on the carbon steel tube support plates, which are 

plate-type components providing tube-to-tube mechanical support for the 

tubes in the tube bundle of the steam generator (recirculating) system of a 

PWR. The tubes pass through drilled holes in the plate. The secondary 

coolant flows through the tube supports via flow holes between the tubes. 

[Ref. 22, 23] 
IX F-3

IX.F Use of Terms for Aging Mechanisms

Term Usage in this document

Corrosion of embedded steel If the pH of concrete in which steel is embedded is reduced below 11.5 by 

intrusion of aggressive ions (e.g., chlorides > 500 ppm) in the presence of 

oxygen, embedded steel may corrode. A reduction in pH may be caused 

by the leaching of alkaline products through cracks, entry of acidic 

materials, or carbonation. Chlorides may be present in the constituents of 

the original concrete mix. The severity of the corrosion is affected by the 

properties and types of cement, aggregates, and moisture content. 

[Ref. 24]

Cracking due to chemical 

reaction, weathering, 

settlement, or corrosion of 

reinforcement (reinforced 

concrete only); loss of 

material due to delamination, 

exfoliation, spalling, popout, 

scaling, or cavitation

This term applies to concrete, concrete cylinder pipe, reinforced concrete, 

asbestos cement, and cementitious components in GALL-SLR Report 

Chapter VII. Aging mechanisms associated with cracking are described 

in ACI 224.1R-07, “Causes, Evaluation, and Repair of Cracks in Concrete 

Structures.” For example, chemical reaction includes: (a) reaction with 

aggregates, (b) effects of sulfates in the soil, and (c) effects of deicing 

salts. Increased porosity and permeability of cementitious materials can 

also result in cracking. Aging mechanisms associated with loss of 

material are described in ACI 201.1R-08, “Guide for Conducting a Visual 

Inspection of Concrete in Service.” [Ref. 37, 38]

Creep Creep, for a metallic material, refers to a time-dependent continuous 

deformation process under constant stress. It is an elevated temperature 

process and is not a concern for low-alloy steel below 371 °C [700 °F], for 

austenitic alloys below 538 °C [1,000 °F], or for Ni-based alloys below 

982 °C [1,800 °F]. [Ref. 25, 26] 

Creep, in concrete, is related to the loss of absorbed water from the 

hydrated cement paste. It is a function of the modulus of elasticity of the 

aggregate. It may result in loss of prestress in the tendons used in 

prestressed concrete containment. [Ref. 22] 

Crevice corrosion Crevice corrosion occurs in a wetted or buried environment when a 

crevice or area of stagnant or low flow exists that allows a corrosive 

environment to develop in a component. It occurs most frequently in 

joints and connections, or points of contact between metals and 

nonmetals, such as gasket surfaces, lap joints, and under bolt heads. 

Carbon steel, cast iron, low alloy steels, SS, copper, and nickel base 

alloys are all susceptible to crevice corrosion. Steel can be subject to 

crevice corrosion in some cases after lining/cladding degradation. 

Localized corrosion of a metal surface at, or immediately adjacent to, an 

area that is shielded from full exposure to the environment because of the 

close proximity of the metal to the surface of another dissimilar material.

Cyclic loading Cyclic loading can cause cracking by periodic application of mechanical 

and thermal loads on a component. Examples of cyclic loading are 

pressure and thermally-induced loads due to thermal-hydraulic transients 

of piping components. Fatigue cracking is a typical result of cyclic 

loadings on metal components.

Distortion The aging mechanism of distortion (as associated with component 

supports in the GALL-SLR Report, Chapter III.B2) can be caused by 

time-dependent strain or by gradual elastic and plastic deformation of 

metal that is under constant stress at a value lower than its normal yield 

strength.
IX F-4

IX.F Use of Terms for Aging Mechanisms

Term Usage in this document

Elastomer or polymer 

degradation

Elastomer or polymer degradation is an encompassing term related to 

various aging mechanisms that result in hardening or loss of strength of 

elastomers or polymers. Degradation can occur due to thermal aging 

{elevated temperature over about 35 °C [95 °F]}, exposure to ozone, 

oxidation, photolysis (due to ultraviolet light), and radiation. [Ref. 9] 

Degradation may include mechanisms such as cracking, crazing, fatigue 

breakdown, abrasion, chemical attacks, and change in material 

properties. [Ref. 27, 28] 

Electrical transients An electrical transient is a stressor caused by a voltage spike that can 

contribute to aging degradation. Certain types of high-energy electrical 

transients can contribute to electromechanical forces, ultimately resulting 

in fatigue or loosening of bolted connections. Transient voltage surges 

are a major contributor to the early failure of sensitive 

electrical components.

Elevated temperature Elevated temperature is referenced as an aging mechanism only in the 

context of LWR containments (GALL-SLR Chapter II). In concrete, 

reduction of strength and modulus can be attributed to elevated 

temperatures {>66 °C [>150 °F] general; >93 °C [>200 °F] local}.

Erosion Erosion is the progressive loss of material due to the mechanical 

interaction between a surface and a moving fluid. Different forms of 

erosion include cavitation, flashing, droplet impingement, and solid 

particle impingement.

Erosion settlement Erosion settlement is the subsidence of a containment structure that may 

occur due to changes in the site conditions, (e.g., erosion or changes in 

the water table). The amount of settlement depends on the foundation 

material. [Ref. 24]

Another synonymous term is “erosion of the porous concrete 

subfoundation.”

Erosion, settlement, 

sedimentation, frost action, 

waves, currents, surface 

runoff, seepage

In earthen water-control structures, the loss of material and loss of form 

can result from erosion, settlement, sedimentation, frost action, waves, 

currents, surface runoff, and seepage.

Fatigue Fatigue is a phenomenon leading to fracture under repeated or fluctuating 

stresses having a maximum value less than the tensile strength of the 

material. Fatigue fractures are progressive, and grow under the action of 

the fluctuating stress. Fatigue due to vibratory and cyclic thermal loads is 

defined as the structural degradation that can occur from repeated 

stress/strain cycles caused by fluctuating loads (e.g., from vibratory loads) 

and temperatures, giving rise to thermal loads. After repeated cyclic 

loading of sufficient magnitude, microstructural damage may accumulate, 

leading to macroscopic crack initiation at the most vulnerable regions. 

Subsequent mechanical or thermal cyclic loading may lead to growth of 

the initiated crack. Vibration may result in component cyclic fatigue, as 

well as in cutting, wear, and abrasion, if left unabated. Vibration is 

generally induced by external equipment operation. It may also result 

from flow resonance or movement of pumps or valves in fluid systems.

Crack initiation and growth resistance is governed by factors including 

stress range, mean stress, loading frequency, surface condition, and the 

presence of deleterious chemical species. [Ref. 29]
IX F-5

IX.F Use of Terms for Aging Mechanisms

Term Usage in this document

Flow-accelerated corrosion FAC is a corrosion mechanism, which results in wall thinning of carbon 

steel components exposed to moving, high temperature, low-oxygen 

water, such as PWR primary and secondary water, and BWR reactor 

coolant. FAC is the result of dissolution of the surface film of the steel, 

which is transported away from the site of dissolution by the movement of 

water. [Ref. 30]

Fouling Fouling is an accumulation of deposits on the surface of a component or 

structure. This term includes accumulation and growth of aquatic 

organisms on submerged surfaces or the accumulation of deposits 

(usually inorganic). Fouling can be categorized as particulate fouling 

(e.g., sediment, silt, dust, eroded coatings, and corrosion products), 

biofouling, or macro fouling (e.g., delaminated coatings, debris).

Biofouling can be caused by either macro organisms (e.g., barnacles, 

Asian clams, zebra mussels, or others found in fresh and salt water) or

microorganisms (e.g., algae, bacteria, fungi). Fouling from tuberculation 

can be due to either inorganic (localized electrochemical corrosion) or 

organic (microbiological) causes. Fouling can result in a reduction of heat 

transfer, loss of material, or flow blockage and can occur in air, 

condensation, lubricating oil, or various water environments.

Freeze-thaw, frost action Repeated freezing and thawing can cause severe degradation of 

concrete, characterized by scaling, cracking, and spalling. The cause is 

water freezing within the pores of the concrete, creating hydraulic 

pressure. If unrelieved, this pressure will lead to freeze-thaw degradation.

If the temperature cannot be controlled, other factors that enhance the 

resistance of concrete to freeze-thaw degradation are (a) adequate air 

content (i.e., within ranges specified in ACI 301-84), (b) low permeability, 

(c) protection until adequate strength has developed, and (d) surface 

coating applied to frequently wet-dry surfaces. [Ref. 24, 31] 

Fretting Fretting is a wear process that occurs at the interface between contacting 

surfaces that experience a slight, differential oscillatory movement. 

Fretting can lead to loss of material.
IX F-6

IX.F Use of Terms for Aging Mechanisms

Term Usage in this document

Galvanic corrosion Galvanic corrosion is accelerated corrosion of a metal because of an 

electrical contact with a more noble metal or nonmetallic conductor in a 

corrosive electrolyte. It is also called bimetallic corrosion, contact 

corrosion, dissimilar metal corrosion, or two-metal corrosion. For 

example, galvanic corrosion is an applicable aging mechanism for steel 

materials coupled to more noble metals in heat exchangers; galvanic 

corrosion of copper is of concern when coupled with the nobler SS.

Galvanic corrosion was removed from the AMR item tables as a specific 

aging mechanism. The most effective means of mitigating or preventing 

galvanic corrosion involve design and maintenance activities. For 

example: (a) selecting dissimilar metals that are as close to each other in 

the galvanic series; (b) avoiding localized small anodes and large 

cathodes; (c) instituting means to insulate the dissimilar metals from each 

other; (d) coatings and (e) sacrificial anodes.

Although galvanic corrosion has been removed from the AMR item tables 

as a specific aging mechanism, several AMPs support the mitigation or 

prevention of galvanic corrosion. For example: GALL-SLR Report

AMP XI.M42, “Internal Coatings/Linings for In-Scope Piping, Piping 

Components, Heat Exchangers, and Tanks,” manages loss of coating 

integrity. A licensee experienced accelerated galvanic corrosion when 

loss of coating integrity occurred in the vicinity of carbon steel 

components attached to AL6XN components. [Ref. 32] GALL-SLR 

Report AMP XI.M10, “Boric Acid Corrosion,” inspections can detect boric 

acid residue spanning dissimilar metals, which can result in a galvanic 

corrosion cell. A licensee experienced galvanic corrosion of a steel 

nozzle when boric acid residue spanned the steel nozzle and attached SS 

piping. The galvanic corrosion resulted in corrosion rates 1.5 times higher 

than expected. [Ref. 33] Cracking or pitting of SS or nickel alloy cladding 

can lead to localized galvanic attack. AMPs XI.M32, “One-Time 

Inspection,” and XI.M21A, “Closed Treated Water Systems,” are used to 

detect cracking due to SCC and loss of material due to pitting and crevice 

corrosion for clad steel components.

Any of the AMPs used to detect loss of material due to general, pitting, or 

crevice corrosion can also detect loss of material due to galvanic 

corrosion.

General corrosion General corrosion, also known as uniform corrosion, proceeds at 

approximately the same rate over a metal surface. 

Intergranular attack In austenitic SSs, the precipitation of chromium carbides, usually at grain 

boundaries, on exposure to temperatures of about 550–850 °C [1,022–

1,562 °F], leaves the grain boundaries depleted of Cr and, therefore, 

susceptible to preferential attack (IGA) by a corroding (oxidizing) medium.

Intergranular stress 

corrosion cracking

IGSCC is SCC in which the cracking occurs along grain boundaries.

Irradiation-assisted stress 

corrosion cracking

Failure by intergranular cracking in aqueous environments of stressed 

materials exposed to ionizing radiation has been termed IASCC. 

Irradiation by high-energy neutrons can promote SCC by affecting 

material microchemistry (e.g., radiation-induced segregation of elements 

such as P, S, Si, and Ni to the grain boundaries), material composition 

and microstructure (e.g., radiation hardening), as well as water chemistry 

(e.g., radiolysis of the reactor water to make it more aggressive).
IX F-7

IX.F Use of Terms for Aging Mechanisms

Term Usage in this document

Leaching of calcium 

hydroxide and carbonation

Water passing through cracks, inadequately prepared construction joints, 

or areas that are not sufficiently consolidated during placing may dissolve 

some calcium-containing products (of which calcium hydroxide is the 

most-readily soluble, depending on the solution pH) in concrete. Once 

the calcium hydroxide has been leached away, other cementitious 

constituents become vulnerable to chemical decomposition, finally leaving 

only the silica and alumina gels behind with little strength. The water's 

aggressiveness in the leaching of calcium hydroxide depends on its salt 

content, pH, and temperature. This leaching action is effective only if the 

water passes through the concrete. [Ref. 24]

Low-temperature crack 

propagation

LTCP is IGSCC at low temperatures ~54–77 °C [~130–170 °F].

Mechanical loading Applied loads of mechanical origins rather than from other sources, such 

as thermal. 

Mechanical wear See “Wear.”

Microbiologically influenced

corrosion

Any of the various forms of corrosion induced by the presence and 

activities of such microorganisms as bacteria, fungi, and algae, and/or the 

byproducts of their metabolism. Degradation of material that is 

accelerated due to conditions under a biofilm or tubercle, for example, 

anaerobic bacteria that can set up an electrochemical galvanic reaction or 

inactivate a passive protective film, or acid-producing bacterial that might 

produce corrosive metabolites.

Moisture intrusion Influx of moisture through any viable process.

Neutron irradiation 

embrittlement

Irradiation by neutrons results in embrittlement of carbon and low-alloy 

steels. It may produce changes in mechanical properties by increasing 

tensile and yield strengths with a corresponding decrease in fracture 

toughness and ductility. The extent of embrittlement depends on neutron 

fluence, temperature, and trace material chemistry. [Ref. 26]

Ohmic heating Ohmic heating is induced by current flow through a conductor and can be 

calculated using first principles of electricity and heat transfer. Ohmic 

heating is a thermal stressor and can be induced by conductors passing 

through electrical penetrations, for example. Ohmic heating is especially 

significant for power circuit penetrations. [Ref. 17] 

Outside diameter stress 

corrosion cracking

ODSCC is SCC initiating in the outer diameter (secondary side) surface 

of steam generator tubes. The secondary side is part of the secondary 

system consisting of the shell side of the steam generator, high- and 

low-pressure turbines, moisture/separator reheaters, main electrical 

stages and interconnecting piping.

This differs from PWSCC, which describes inner diameter (SG primary 

side) initiated cracking. [Ref. 23]. The primary loop basically consists of 

the reactor vessel, reactor coolant pumps, pressurizer steam generator 

tubes, and interconnecting piping. 

Overload Overload is one of the aging mechanisms that can cause loss of 

mechanical function in Class 1 piping and components, such as constant 

and variable load spring hangers, guides, stops, sliding surfaces, and 

vibration isolators, fabricated from steel or other materials, such as 

Lubrite®.

Oxidation Oxidation involves two types of reactions: (a) an increase in valence 

resulting from a loss of electrons, or (b) a corrosion reaction in which the 

corroded metal forms an oxide. [Ref. 27]

Photolysis Chemical reactions induced or assisted by light.
IX F-8

IX.F Use of Terms for Aging Mechanisms

Term Usage in this document

Pitting corrosion Localized corrosion of a metal surface, confined to a point or small area, 

which takes the form of cavities called pits.

Presence of any salt 

deposits

The surface contamination (and increased electrical conductivity) 

resulting from the aggressive environment associated with the presence 

of salt deposits can degrade high-voltage insulator quality. Although this 

aging mechanism may be due to temporary, transient environmental 

conditions, the net result may be long-lasting and cumulative for plants 

located in the vicinity of saltwater bodies.

Primary water stress 

corrosion cracking

PWSCC is an intergranular cracking mechanism that requires the 

presence of high applied and/or residual stress, susceptible 

microstructure (few intergranular carbides), and also high temperatures. 

This aging mechanism is most likely a factor for nickel alloys in the PWR 

environment. [Ref. 22]

Radiation hardening, 

temperature, humidity, 

sustained vibratory loading

Reduction or loss of isolation function in polymeric vibration isolation 

elements can result from a combination of radiation hardening, 

temperature, humidity, and sustained vibratory loading.

Radiation-induced oxidation Two types of reactions that are affected by radiation are (a) an increase in 

valence resulting from a loss of electrons, or (b) a corrosion reaction in 

which the corroded metal forms an oxide. This is a very limited form of 

oxidation and is referenced in GALL-SLR Chapter VI for MEB insulation. 

[Ref. 27]

Radiolysis Radiolysis is a chemical reaction induced or assisted by radiation. 

Radiolysis and photolysis aging mechanisms can occur in UV-sensitive 

organic materials.

Reaction with aggregate The presence of reactive alkalis in concrete can lead to subsequent 

reactions with aggregates that may be present. These alkalis are 

introduced mainly by cement, but also may come from admixtures, 

salt-contamination, seawater penetration, or solutions of deicing salts. 

These reactions include alkali-silica reactions, cement-aggregate 

reactions, and aggregate-carbonate reactions. These reactions may lead 

to expansion and cracking. [Ref. 14, 34]

Recurring internal corrosion Recurring internal corrosion is identified by both the number of 

occurrences of internal aging effects with the same aging mechanism and 

the extent of degradation at each localized site. In regard to the number 

of occurrences, aging effects are considered recurring if the search of 

plant-specific OE reveals repetitive occurrences (e.g., one per refueling 

outage cycle that has occurred over three or more sequential or 

nonsequential cycles for a 10-year OE search, or two or more sequential 

or nonsequential cycles for a 5-year OE search) of aging effects with the 

same aging mechanism. In regard to the extent of degradation, aging 

effects are considered recurring if the aging effect resulted in the 

component not meeting either plant-specific acceptance criteria or 

experiencing a reduction in wall thickness of greater than 50% (regardless 

of the minimum wall thickness). Recurring internal corrosion is evaluated 

based on the aging mechanisms observed. For example, multiple 

occurrences of loss of material due to microbiologically influenced

corrosion, pitting, or galvanic corrosion would be considered three 

separate occurrences of aging mechanisms that could be grouped as 

recurring internal corrosion but that would be evaluated separately. 

Restraint shrinkage Restraint shrinkage can cause cracking in concrete transverse to the 

longitudinal construction joint.
IX F-9

IX.F Use of Terms for Aging Mechanisms

Term Usage in this document

Selective leaching Selective leaching is a type of corrosion in which one or more elements 

are preferentially removed from an alloy or metallic phase. Selective 

leaching is also called dealloying but it might be referred to by material 

specific names (e.g., dezincification, dealuminification, graphitic 

corrosion). A dealloyed component often retains its shape and may 

visually appear to be unaffected; however, the effective cross-section of 

the component has been reduced. The dealloyed volume is often 

comprised of various amounts of unaffected phases, corrosion products, 

redeposited material, and a network of interconnected voids. The 

dealloyed volume does not have mechanical properties that can be 

credited for structural integrity.

Service-induced cracking or 

other concrete aging 

mechanisms

Cracking of concrete under load over time of service (e.g., from shrinkage 

or creep, or other concrete aging mechanisms) that may include 

freeze-thaw, leaching, aggressive chemicals, reaction with aggregates, 

corrosion of embedded steels, elevated temperatures, irradiation, 

abrasion, and cavitation. [Ref. 20] 

Settlement This term is referenced as an aging mechanism in GALL-SLR Chapter II,

Containment Structures. Settlement of a containment structure may 

occur due to changes in the site conditions (e.g., water table, etc.). The 

amount of settlement depends on the foundation material. [Ref. 23] 

Stress corrosion cracking SCC is the cracking of a metal produced by the combined action of 

corrosion and tensile stress (applied or residual), especially at elevated 

temperature. SCC is highly chemically specific in that certain alloys are 

likely to undergo SCC only when exposed to a small number of chemical 

environments. For PWR internal components, in Chapters IV.B2, IV.B3 

and IV.B4, SCC includes intergranular SCC, transgranular SCC, primary 

water SCC, and low temperature crack propagation as aging 

mechanisms.

Stress relaxation Many of the bolts in reactor internals are stressed to a cold initial preload. 

When subject to high operating temperatures, over time these bolts may 

loosen and the preload may be lost. Radiation can also cause stress 

relaxation in highly stressed members such as bolts. [Ref. 15]. 

Relaxation in structural steel anchorage components can be an aging 

mechanism contributing to the aging effect of loss of prestress.

Surface contamination Contamination of the surfaces by corrosive constituents or fouling.

Sustained vibratory loading Vibratory loading over time.

Thermal aging embrittlement Also termed “thermal aging” or “thermal embrittlement.” At operating 

temperatures of 260 to 343 °C [500 to 650 °F], CASS exhibit a spinoidal 

decomposition of the ferrite phase into ferrite-rich and chromium-rich 

phases. This may give rise to significant embrittlement (reduction in 

fracture toughness), depending on the amount, morphology, and 

distribution of the ferrite phase and the composition of the steel.

Thermal aging of materials other than CASS is a time- and temperaturedependent degradation mechanism that decreases material toughness. It 

includes temper embrittlement and strain aging embrittlement. Ferritic 

and low-alloy steels are subject to both of these types of embrittlement, 

but wrought SS is not affected by either of these processes. [Ref. 26] 

Thermal effects, gasket 

creep, and self-loosening

Loss of preload due to gasket creep, thermal effects (including differential 

expansion and creep or stress relaxation), and self-loosening (which 

includes vibration, joint flexing, cyclic shear loads, thermal cycles). 

[Ref. 18, 19] 
IX F-10

IX.F Use of Terms for Aging Mechanisms

Term Usage in this document

Thermal and mechanical 

loading

Loads (stress) due to mechanical or thermal (temperature) sources.

Thermal degradation of 

organic materials

Organic materials, in this case, are polymers. This category includes both 

short-term thermal degradation and long-term thermal degradation. 

Thermal energy absorbed by polymers can result in crosslinking and 

chain scission. Crosslinking will generally result in such aging effects as 

increased tensile strength and hardening of material, with some loss of 

flexibility and eventual decrease in elongation-at-break and increased 

compression set. Scission generally reduces tensile strength. Other 

reactions that may occur include crystallization and chain 

depolymerization. 

Thermal fatigue Fatigue is the progressive and localized structural damage that occurs 

when a material is subjected to cyclic loading. The maximum stress 

values are less than the ultimate tensile stress limit, and may be below 

the yield stress limit of the material. Higher temperatures generally 

decrease fatigue strength. Thermal fatigue can result from phenomena 

such as thermal loading, thermal cycling, where there is cycling of the 

thermal loads, and thermal stratification and turbulent penetration. 

Thermal stratification is a thermo-hydraulic condition with a definitive hot 

and cold water boundary inducing thermal fatigue of the piping. Turbulent 

penetration is a thermo-hydraulic condition where hot and cold water mix 

as a result of turbulent flow conditions, leading to thermal fatigue of the 

piping. The GALL-SLR Report AMP XI.M32, “One-Time Inspection,” 

inspects for cracking induced by thermal stratification, and for turbulent 

penetration via volumetric (RT or UT) techniques.

Thermoxidative degradation 

of organics/thermoplastics

Degradation of organics/thermoplastics via oxidation reactions (loss of 

electrons by a constituent of a chemical reaction) and thermal means 

(see Thermal degradation of organic materials). [Ref. 25]

Transgranular stress 

corrosion cracking

TGSCC is SCC in which cracking occurs across the grains.

Void swelling Vacancies created in reactor (metallic) materials as a result of irradiation 

may accumulate into voids that may, in turn, lead to changes in 

dimensions (swelling) of the material. Void swelling may occur after an 

extended incubation period.

Water trees Water trees occur when the insulating materials are exposed to long-term 

electrical stress and moisture; these trees eventually result in breakdown 

of the dielectric and ultimate failure. The growth and propagation of water 

trees is somewhat unpredictable. Water treeing is a degradation and 

long-term failure phenomenon. 

Wear Wear is defined as the removal of surface layers due to relative motion 

between two surfaces or under the influence of hard, abrasive particles. 

Wear occurs in parts that experience intermittent relative motion, frequent 

manipulation, or in clamped joints where relative motion is not intended, 

but may occur due to a loss of the clamping force. [Ref. 26]. Loss of 

material due to wear can also occur in polymeric components buried in 

soil containing deleterious materials that move over time due to seasonal 

change effects on the soil. 

Weathering Weathering is the mechanical or chemical degradation of external 

surfaces of materials when exposed to an outside environment.

Wind-induced abrasion (See Abrasion) The fluid carrier of abrading particles is wind rather than 

water/liquids.
IX G-1

G. REFERENCES

1. SNL. SAND 93–7070, “Aging Management Guideline for Commercial Nuclear Power 

Plants-Heat Exchangers.” Albuquerque, New Mexico: Sandia National Laboratories. 

June 1994.

2. ASTM International. “Corrosion: Materials, Corrosion of Copper and Copper Alloys.” 

Volume 13B. pp 129–133. Materials Park, Ohio: American Society for Testing Materials 

International. 2006.

3. ASME. American Society of Mechanical Engineers Boiler and Pressure Vessel Code 

(ASME Code), Section II, Part B, “Nonferrous Material Specifications.” New York, 

New York: American Society of Mechanical Engineers. 2008. 

4. ASME. ASME Code, Section II, Part A, “Ferrous Material Specification.” New York, 

New York: American Society of Mechanical Engineers. 2008. 

5. NRC. NUREG–1950, “Disposition of Public Comments and Technical Bases for Changes 

in the License Renewal Guidance Documents NUREG–1801 and NUREG–1800.” 

Washington, DC: U.S. Nuclear Regulatory Commission. April 2011.

6. Welding Handbook. “Metals and Their Weldability.” Seventh Edition. Volume 4. 

American Welding Society. p. 76–145. 1984. 

7. Metals Handbook. “Failure Analysis.” Ninth Edition. Volume 11. ASM International. 

p. 415. 1980.

8. Fink, F.W. and W.K. Boyd. “The Corrosion of Metals in Marine Environments.” 

DMIC Report 245. May 1970.

9. Gillen, K.T. and R.L. Clough. “Occurrence and Implications of Radiation Dose-Rate 

Effects for Material Aging Studies.” Radiation Physics and Chemistry. Vol. 18. p. 679. 

1981.

10. Peckner, D. and I.M. Bernstein, eds. Handbook of Stainless Steels. 

New York, New York: McGraw-Hill. p. 16-85. 1977. 

11. EPRI. EPRI 1010639, “Non-Class 1 Mechanical Implementation Guideline and 

Mechanical Tools.” Palo Alto, California: Electric Power Research Institute. Appendix A, 

“Treated Water,” p. 2-13. January 2006.

12. Chopra, O.K. and A. Sather. ANL-89/17, “Initial Assessment of the Mechanisms and 

Significance of Low-Temperature Embrittlement of Cast Stainless Steels in LWR 

Systems.” Argonne, Illinois: Argonne National Laboratory. August 1990.

13. NRC. NUREG–1557, “Summary of Technical Information and Agreements from Nuclear 

Management and Resources Council Industry Reports Addressing License Renewal.” 

Washington, DC: U.S. Nuclear Regulatory Commission. October 1996.

14. Freeze, R.A. and J.A Cherry. Groundwater. Englewood Cliffs, New Jersey. 

Prentice-Hall. 1979.
IX G-2

15. NRC. NUREG–1760, “Aging Assessment of Safety-Related Fuses Used in Low- and 

Medium-Voltage Applications in Nuclear Power Plants.” Washington, DC: U.S. Nuclear 

Regulatory Commission. May 2002.

16. JM EagleTM Technical Bulletin. “The Effects of Sunlight Exposure on PVC Pipe and 

Conduit.” Ft. Recovery, Ohio: JM Manufacturing Company Inc. January 2009.

17. SNL. SAND96–0344, “Aging Management Guideline for Commercial Nuclear Power 

Plants-Electrical Cable and Terminations.” Albuquerque, New Mexico: Sandia National 

Laboratories. September 1996.

18. EPRI. EPRI TR–104213, “Bolted Joint Maintenance & Application Guide.” 

Palo Alto, California: Electric Power Research Institute. December 1995.

19. EPRI. EPRI NP-5067, “Good Bolting Practices, A Reference Manual for Nuclear Power 

Plant Maintenance Personnel.” Volume 1: “Large Bolt Manual.” 1987 and Volume 2: 

“Small Bolts and Threaded Fasteners.” Palo Alto, California: Electric Power Research 

Institute. 1990. 

20. NEI. NUMARC Report 90-06, “Class 1 Structures License Renewal Industry Report.” 

Revision 1. Washington, DC: Nuclear Energy Institute. December 1991.

21. NRC. GL 96-04, “Boraflex Degradation in Spent Fuel Pool Storage Racks.” 

Washington, DC: U.S. Nuclear Regulatory Commission. 1996.

22. Shah, V.N. and D. E. Macdonald, eds. “Aging and Life Extension of Major Light Water 

Reactor Components.” Amsterdam, Netherlands: Elsevier. 1993.

23. Gavrilas, M., P. Hejzlar, N.E. Todreas, and Y. Shatilla. “Safety Features of Operating 

Light Water Reactors of Western Designs.” Cambridge, Massachusetts. CANES, MIT. 

2000.

24. NEI. NUMARC Report 90-01, “Pressurized Water Reactors Containment Structures 

License Renewal Industry Report.” Revision 1. Washington, DC: Nuclear Energy 

Institute. 1991. 

25. ASTM. “1976 Annual Book of ASTM Standards, Part 10.” Philadelphia, Pennsylvania: 

ASTM. 1976.

26. NEI. NUMARC Report 90-07, “PWR Reactor Coolant System License Renewal Industry 

Report.” Washington, DC: Nuclear Energy Institute. May 1992.

27. Davis, J.R., Ed. “Corrosion.” Materials Park, Ohio: ASM International. 2000.

28. ASTM. “2004 Annual Book of ASTM Standards.” Volume 09.01. Philadelphia, 

Pennsylvania: ASTM International. 2004.

29. NEI. NUMARC Report 90-05, “PWR Reactor Pressure Vessel Internals License Renewal 

Industry Report.” Revision 1. Washington, DC: Nuclear Energy Institute. 

December 1992.
IX G-3

30. EPRI. EPRI NSAC-202L-R4, “Recommendations for an Effective Flow-Accelerated 

Corrosion Program.” Palo Alto, California: Electric Power Research Institute. 

November 2013.

31. ACI. ACI Standard 301-84, “Specification for Structural Concrete for Buildings.” 

(Field Reference Manual). Farmington Hills, Michigan: American Concrete Institute. 

Revised 1988.

32. DNC. “Relief Request RR-04-13 for the Temporary Non-Code Compliant Condition of the 

Class 3 Service Water System 10-Inch Emergency Diesel Generator Supply Piping 

Flange.” Agencywide Documents Access and Management System (ADAMS) Accession 

No. ML12297A333. Glen Allen, Virginia: Dominion Nuclear Connecticut, Inc. 

October 18, 2012. 

33. EPRI. EPRI 1000975, “Boric Acid Corrosion Guidebook, Revision 1: Managing Boric Acid 

Corrosion Issues at PWR Power Stations.” Palo Alto, California: Electric Power Research 

Institute. 2001.

34. ACI. ACI Standard 201.2R-08, “Guide to Durable Concrete.” Farmington Hills, Michigan: 

American Concrete Institute. 2008.

35. ASM International. ASM International Handbook, Volume 11, “Failure Analysis and 

Prevention.” pg. 786. Materials Park, Ohio: ASM International. 2002.

36. Jones, D.A. “Principles and Prevention of Corrosion.” Second Edition. pp. 326-327.

37. ACI. ACI Standard 224.1R-07, “Causes, Evaluation, and Repair of Cracks in Concrete 

Structures.” Farmington Hills, Michigan: American Concrete Institute. 2007.

38. ACI. ACI Standard 201.1R-08, “Guide for Conducting a Visual Inspection of Concrete in 

Service.” Farmington Hills, Michigan: American Concrete Institute. 2008. 

39. ANSI. ANSI Standard H35.1/H35.1M, “Alloy and Temper Designation Systems for 

Aluminum.” New York, New York: American National Standards Institute, Inc. 2013.

40. EPRI. EPRI 1010639, “Non-Class 1 Mechanical Implementation Guideline and 

Mechanical Tools, Revision 4.” Appendix F, Section 3.2, “Cracking of Bolting Materials,”

“Stress Corrosion Cracking.” Palo Alto, California: Electric Power Research Institute. 

2006.

41. ASM International. ASM International Handbook, Volume 13B, “Corrosion: Materials, 

Corrosion of Copper and Copper Alloys.” pp. 129–133. Materials Park, Ohio: ASM 

International. 2006.

42. EPRI. EPRI Technical Report No.1022863, “Materials Reliability Program: Pressurized

Water Reactor Internals Inspection and Evaluation Guidelines (MRP-227-A).” ADAMS 

Accession No. ML12017A193 (Transmittal letter from the EPRI-MRP) and ADAMS

Accession Nos. ML12017A194, ML12017A196, ML12017A197, ML12017A191,

ML12017A192, ML12017A195 and ML12017A199, (Final Report). Palo Alto, California: 

Electric Power Research Institute. December 2011.

CHAPTER X

AGING MANAGEMENT PROGRAMS THAT MAY BE USED TO 

DEMONSTRATE ACCEPTABILITY OF TIME-LIMITED AGING 

ANALYSES IN ACCORDANCE WITH 10 CFR 54.21(C)(1)(III)

X-1

X AGING MANAGEMENT PROGRAMS THAT MAY BE USED TO 

DEMONSTRATE ACCEPTABILITY OF TIME-LIMITED AGING 

ANALYSES IN ACCORDANCE WITH 10 CFR 54.21(c)(1)(iii)

This chapter of the Generic Aging Lessons Learned for Subsequent License Renewal 

(GALL-SLR) Report provides the following aging management programs that are used to 

demonstrate acceptance of specific types of generic time-limited aging analyses in accordance 

with the requirements in Title 10 of the Code of Federal Regulations (10 CFR) 54.21(c)(1)(iii) and 

to demonstrate that the impacts of the effects of aging on the intended functions of the 

components in the analyses will be adequately managed during the subsequent license 

renewal period:

X.M1 FATIGUE MONITORING

X.M2 NEUTRON FLUENCE MONITORING

X.S1 CONCRETE CONTAINMENT UNBONDED TENDON PRESTRESS

X.E1 ENVIRONMENTAL QUALIFICATION (EQ) OF ELECTRIC COMPONENTS

TABLE X-01 FSAR SUPPLEMENT SUMMARIES FOR GALL-SLR REPORT 

CHAPTER X AGING MANAGEMENT PROGRAMS

X.M1-1

X.M1 FATIGUE MONITORING

Program Description

This aging management program (AMP) provides an acceptable basis for managing structures 

and components (SCs) that are the subject of fatigue or cycle-based time-limited aging analyses 

(TLAAs) or other analyses that assess fatigue or cyclical loading, in accordance with the 

requirements in Title 10 of the Code of Federal Regulations (10 CFR) 54.21(c)(1)(iii). Examples 

of cycle-based fatigue analyses for which this AMP may be used include, but are not limited to: 

(a) cumulative usage factor (CUF) analyses or their equivalent (e.g., lt-based fatigue analyses, as 

defined in specific design codes) that are performed in accordance with American Society of 

Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code) requirements for specific 

mechanical or structural components; (b) fatigue analysis calculations for assessing 

environmentally-assisted fatigue; (c) implicit fatigue analyses, as defined in the United States of 

America Standards (USAS) B31.1 design code or ASME Code Section III rules for Class 2 and 

Class 3 components; (d) fatigue flaw growth analyses that are based on cyclical loading 

assumptions; (e) fracture mechanics analyses that are based on cycle-based loading 

assumptions; and (f) fatigue waiver or exemption analyses that are based on cycle-based loading 

assumptions. This program may be used for fatigue analyses that apply to mechanical or 

structural components.

Fatigue of components is managed by monitoring one or more relevant fatigue parameters, which 

include, but are not limited to, the CUF factors, the environmentally-adjusted (CUFen), transient 

cycle limits, and the predicted flaw size (for a fatigue crack growth analysis). The limit of the 

fatigue parameter is established by the applicable fatigue analysis and may be a design limit, for 

example, from an ASME Code fatigue evaluation; an analysis-specific value, for example, based 

on the number of cyclic load occurrences assumed in a fatigue exemption evaluation; or the 

acceptable size of a flaw identified during an inservice inspection.

This program has two aspects, one that verifies the continued acceptability of existing analyses 

through cycle counting and the other that provides periodically updated evaluations of the fatigue 

analyses to demonstrate that they continue to meet the appropriate limits. In the former, the 

program assures that the number of occurrences and severity of each transient remains within the 

limits of the fatigue analyses, which in turn ensure that the analyses remain valid. For the latter, 

actual plant operating conditions monitored by this program can be used to inform updated 

evaluations of the fatigue analyses to ensure they continue to meet the design or analysis-specific 

limit. The program may include stress-based fatigue monitoring, in which operating temperatures,

pressures, and other parameters are monitored and used to determine the effects of actual

operating transients on the cumulative CUF and CUFen for the analyzed components. Technical 

specification requirements may apply to these activities.

CUF is a computed parameter used to assess the likelihood of fatigue damage in components 

subjected to cyclic stresses. Crack initiation is assumed to begin in a mechanical or structural 

component when the CUF at a point on or in the component reaches the value of 1.0, which is the 

ASME Code Section III design limit on CUF values. (Note that other values may be used as CUF 

design limits, for example, values used for high energy line break considerations.) In order not to 

exceed the design limit on CUF, the AMP may be used to directly monitor the number of transient 

occurrences (i.e., transient cycles) or else to monitor applicable design transient parameters

(e.g., temperatures, pressures, displacements, strains, flow rates, etc.) for components with 

stress-based fatigue calculations, such that the actual severity of each event is evaluated and 

used to compute the resulting fatigue usage factors for the impacted component locations.
X.M1-2

CUFen is CUF adjusted to account for the effects of the reactor water environment on component 

fatigue life. For a plant, the effects of reactor water environment on fatigue are evaluated by 

assessing a set of sample critical components for the plant. Examples of critical components are 

identified in NUREG/CR–6260; however, plant-specific component locations in the reactor coolant 

pressure boundary may be more limiting than those considered in NUREG/CR–6260, and thus 

should also be considered. Environmental effects on fatigue for these critical components may be 

evaluated using the guidance in Regulatory Guide (RG) 1.207, Revision 11

; alternatively, the 

bases in NUREG/CR–6909, Revision 0 (with “average temperature” used consistent with the 

clarification that was added to NUREG/CR–6909, Revision 1); or other subsequent U.S. Nuclear 

Regulatory Commission (NRC)-endorsed alternatives. Similar to monitoring of CUF limits, the 

AMP monitors and tracks the number of occurrences and severity of each of the critical thermal 

and pressure transients for the selected components in order to maintain the CUFen below the 

design limit of 1.0. This program also relies on the Generic Aging Lessons Learned for 

Subsequent License Renewal Report (GALL-SLR) Report AMP XI.M2, “Water Chemistry,” to 

provide monitoring of appropriate environmental parameters for calculating environmental fatigue 

multipliers (Fen values).

Some of the design fatigue analyses are implicit evaluations or fatigue waivers. Both of these 

analyses provide the basis for not requiring detailed fatigue analyses (e.g., CUF, CUFen). Implicit 

evaluations specify allowable stress levels based on the number of anticipated full thermal range 

transient cycles. As an example, piping components designed to USAS American National 

Standards Institute (ANSI) B31.1 requirements and ASME Code Class 2 and 3 components 

designed to ASME Code Section III design requirements include implicit cycle-based maximum 

allowable stress range calculations. Fatigue waivers are based on transient cycle limits. Fatigue 

waivers may have been permitted such that a detailed fatigue calculation was not required if a 

component conformed to certain criteria, such as those established in ASME Code, Section III, 

NB-3222.4(d). The AMP monitors and tracks the number of critical thermal and pressure transient 

occurrences for the selected components and verifies that the severity of the monitored transients 

is bounded by the design transient definitions in order to ensure these implicit fatigue evaluations 

or fatigue waivers remain valid.

In some cases, flaw tolerance evaluations are used to establish inspection frequencies for 

components that, for example, exceed CUF or CUFen fatigue limits. As an example, ASME Code, 

Section XI, Nonmandatory Appendix L provides guidance on the performance of fatigue flaw 

tolerance evaluations to determine acceptability for continued service of reactor coolant system 

and primary pressure boundary components and piping subjected to cyclic loadings. In flaw 

tolerance evaluations, the predicted size of a postulated fatigue flaw, whose initial size is typically 

based on the resolution of the inspection method, is a computed parameter that is used to 

determine the appropriate inspection frequency. The AMP monitors and tracks the number of 

occurrences and severity of critical thermal and pressure transients for the selected components 

that are used in the fatigue flaw tolerance evaluations to verify that the inspection frequencies 

remain appropriate.

When a flaw is identified by inservice inspection, ASME Code, Section XI, Nonmandatory 

Appendices A and C provide guidance on the performance of fatigue flaw crack growth 

evaluations to determine acceptability for continued service of reactor coolant system pressure 

boundary components and piping subjected to cyclic loadings. In such a case, the predicted size 

of an identified flaw is a computed parameter suitable for determining the appropriate inspection 

 

1 If and when published as RG 1.207, Revision 1 Final.
X.M1-3

frequency through a fatigue crack growth evaluation. The AMP monitors and tracks the number 

of occurrences and severity of each of the critical thermal and pressure transients for the selected 

components that are used in the crack growth evaluations to verify that the inspection frequencies 

remain appropriate.

Evaluation and Technical Basis

1. Scope of Program: The scope includes those mechanical or structural components with 

a fatigue TLAA or other analysis that depends on the number of occurrences and severity 

of transient cycles. The program monitors and tracks the number of occurrences and 

severity of thermal and pressure transients for the selected components, to ensure that 

they remain within the plant-specific limits. The program ensures that the fatigue analyses 

remain within their allowable limits, thus minimizing the likelihood of failures from 

fatigue-induced cracking of the components caused by cyclic strains in the component’s 

material. In addition, the program can be used to monitor actual plant operating conditions 

for component locations with stress-based fatigue calculations (i.e., stress-based CUF 

calculations) to perform updated evaluations of the fatigue analyses to ensure they 

continue to meet the design limits.

For the purposes of ascertaining the effects of the reactor water environment on fatigue, 

applicants include CUFen calculations for a set of sample reactor coolant system 

components. This sample set includes the locations identified in NUREG/CR–6260 and 

additional plant-specific component locations in the reactor coolant pressure boundary if 

they may be more limiting than those considered in NUREG/CR–6260. Plant-specific 

justification can be provided to demonstrate that calculations for the NUREG/CR–6260 

locations do not need to be included. Environmental effects on fatigue for these critical 

components may be evaluated using the guidance in RG 1.207, Revision 12

;

NUREG/CR–6909, Revision 0 (with “average temperature” used consistent with the 

clarification that was added to NUREG/CR–6909, Revision 1); or other subsequent 

NRC-endorsed alternatives. Component locations within the scope of this program are

updated based on operating experience (OE), plant modifications, and inspection findings.

2. Preventive Actions: This program does not involve preventive actions.

3. Parameters Monitored or Inspected: The program monitors all applicable plant 

transients that cause cyclic strains and contribute to fatigue, as specified in the fatigue 

analyses, and monitors or validates appropriate environmental parameters that contribute 

to Fen values. The number of occurrences and the severity of the plant transients 

that contribute to the fatigue analyses for each component are monitored. For 

environmentally-assisted fatigue calculations, chemistry parameters that provide inputs to 

Fen factors used in CUFen calculations are monitored and tracked in accordance with this 

program or alternatively through implementation of the applicant’s water chemistry 

program. More detailed monitoring of pressure, thermal, and water chemistry conditions 

at the component location may be performed to allow the fatigue analyses to be assessed 

for the specified critical locations.

4. Detection of Aging Effects: The program uses applicant defined activities or methods to 

track the number of occurrences and severity of design basis transient conditions, and any

 

2 If and when published as RG 1.207, Revision 1 Final.
X.M1-4

applicable plant operating conditions used to inform updated evaluations of the fatigue

analyses. Monitoring of water chemistry parameters that are inputs to environmentallyassisted fatigue calculations may be performed in accordance with the implementation of 

this AMP or an applicant’s Water Chemistry Program. Technical specification 

requirements may apply to these activities.

5. Monitoring and Trending: Monitoring and trending of the number of occurrences of each 

of the transient cycles and their severity is used to track the occurrences of all transients 

needed to ensure the continued acceptability of the fatigue analyses, or to update the 

analyses. Monitoring of plant operating conditions or water chemistry parameter 

conditions (i.e., as inputs for components with stress-based fatigue calculations or 

environmental fatigue calculations) is used to either verify the validity of the evaluations 

against their applicable design limits or else to update the evaluations, when necessary, of 

the fatigue analyses to ensure they continue to meet the design or analysis-specific limit. 

Trending is performed to ensure that the fatigue analyses are managed and that the

fatigue parameter limits will not be exceeded during the subsequent period of extended 

operation, thus minimizing the possibility of fatigue crack initiation of metal components 

caused by cyclic strains or water chemistry conditions. The program provides for revisions 

to the fatigue analyses or other corrective actions (e.g., revising augmented inspection 

frequencies) on an as-needed basis, if the values assumed for fatigue parameters are 

approached, transient severities exceed the design or assumed severities, transient 

counts exceed the design or assumed quantities, transient definitions have changed, 

unanticipated new fatigue loading events are discovered, or the geometries of 

components are modified.

6. Acceptance Criteria: The acceptance criterion is maintaining the value of all relevant 

fatigue parameters to values less than or equal to the limits established in the fatigue 

analyses, with consideration of reactor water environmental effects, where appropriate, as 

described in the program description and scope of program.

7. Corrective Actions: Results that do not meet the acceptance criteria are addressed in 

the applicant’s corrective action program under those specific portions of the quality 

assurance (QA) program that are used to meet Criterion XVI, “Corrective Action,” of 

10 CFR Part 50, Appendix B. Appendix A of the GALL-SLR Report describes how an 

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the corrective 

actions element of this AMP for both safety-related and nonsafety-related SCs within the 

scope of this program.

The program also provides for corrective actions to prevent the appropriate limits of the 

fatigue analyses from being exceeded during the subsequent period of extended 

operation. Acceptable corrective actions include repair of the component, replacement of 

the component, and a more rigorous analysis of the component to demonstrate that the 

design limit will not be exceeded during the subsequent period of extended operation. In 

addition, a flaw tolerance analysis with appropriate (e.g., inclusion of environmental 

effects) crack growth rate curves and associated inspections performed in accordance 

with Appendix L of ASME Code Section XI is an acceptable correction action. For CUFen

analyses, scope expansion includes consideration of other locations with the highest 

expected CUFen values.

8. Confirmation Process: The confirmation process is addressed through those specific 

portions of the QA program that are used to meet Criterion XVI, “Corrective Action,” of 
X.M1-5

10 CFR Part 50, Appendix B. Appendix A of the GALL-SLR Report describes how an 

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the confirmation 

process element of this AMP for both safety-related and nonsafety-related SCs within the 

scope of this program. 

9. Administrative Controls: Administrative controls are addressed through the QA program 

that is used to meet the requirements of 10 CFR Part 50, Appendix B, associated with 

managing the effects of aging. Appendix A of the GALL-SLR Report describes how an 

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the 

administrative controls element of this AMP for both safety-related and nonsafety-related 

SCs within the scope of this program.

10. Operating Experience: The program reviews industry experience relevant to fatigue 

cracking. Applicable OE relevant to fatigue cracking is to be considered in selecting 

the locations for monitoring. As discussed in the NRC Regulatory Issue Summary 

(RIS) 2008-30, the use of certain simplified analysis methodology to demonstrate 

compliance with the ASME Code fatigue acceptance criteria could be nonconservative; 

therefore, a confirmatory analysis is recommended, if such a methodology is used. 

Furthermore, as discussed in NRC RIS 2011–14, the staff has identified concerns 

regarding the implementation of computer software packages used to calculate fatigue 

usage associated with plant transient operations.

The program is informed and enhanced when necessary through the systematic and 

ongoing review of both plant-specific and industry OE including research and development 

such that the effectiveness of the AMP is evaluated consistent with the discussion in 

Appendix B of the GALL-SLR Report.

References

10 CFR Part 50, Appendix B, “Quality Assurance Criteria for Nuclear Power Plants and Fuel 

Reprocessing Plants.” Washington, DC: U.S. Nuclear Regulatory Commission. 2016.

ANSI. ANSI/ASME B31.1, “Power Piping.” New York, New York: American National Standards 

Institute. 2014.

ASME. ASME Code, Section III, “Rules for Construction of Nuclear Power Plant Components.” 

New York, New York: American Society of Mechanical Engineers. 2015.

_____. ASME Code, Section XI, Nonmandatory Appendix A, Analysis of Flaws, “Rules for 

Construction of Nuclear Power Plant Components.” New York, New York: American Society of 

Mechanical Engineers. 2015.

_____. ASME Code, Section XI, Appendix C, Evaluation of Flaws in Austenitic Piping, “Rules for 

Inservice Inspection of Nuclear Power Plant Components.” New York, New York: American 

Society of Mechanical Engineers. 2015.

_____. ASME Code, Section XI, Nonmandatory Appendix L, Operating Plant Fatigue 

Assessment. “Rules for Inservice Inspection of Nuclear Power Plant Components.” New York, 

New York: American Society of Mechanical Engineers. 2013.
X.M1-6

NRC. NUREG/CR–6260, “Application of NUREG/CR-5999 Interim Fatigue Curves to Selected 

Nuclear Power Plant Components.” Washington, DC: U.S. Nuclear Regulatory Commission. 

March 1995.

_____. NUREG/CR–6909, “Effect of LWR Coolant Environments on the Fatigue Life of Reactor 

Materials.” Revision 1. Washington, DC: U.S. Nuclear Regulatory Commission. March 2014.

_____. Regulatory Guide 1.207, “Guidelines for Evaluating the Effects of Light Water Reactor 

Coolant Environments in Fatigue Analyses of Metal Components.” Revision 13

. Washington, DC: 

U.S. Nuclear Regulatory Commission. 

_____. Regulatory Issue Summary 2008-30, “Fatigue Analysis of Nuclear Power Plant 

Components.” Washington, DC: U.S. Nuclear Regulatory Commission. December 16, 2008.

_____. Regulatory Issue Summary 2011-14, “Metal Fatigue Analysis Performance by Computer 

Software.” Washington, DC: U.S. Nuclear Regulatory Commission. December 29, 2011.

 

3 If and when published as RG 1.207, Revision 1 Final.
X.M2-1

X.M2 NEUTRON FLUENCE MONITORING

Program Description

This aging management program (AMP) provides a means to ensure the validity of the neutron 

fluence analysis and related neutron fluence-based, time-limited aging analyses (TLAAs). In so 

doing, this AMP also provides an acceptable basis for managing aging effects attributable to 

neutron fluence in accordance with requirements in Title 10 of the Code of Federal Regulations

(10 CFR) 54.21(c)(1)(iii). This program monitors neutron fluence for reactor pressure vessel 

(RPV) components and reactor vessel internal (RVI) components and is used in conjunction with 

the Generic Aging Lessons Learned for Subsequent License Renewal (GALL-SLR) Report 

AMP XI.M31, “Reactor Vessel Material Surveillance.” Neutron fluence is a time-dependent input 

parameter for evaluating the loss of fracture toughness due to neutron irradiation embrittlement. 

Accurate neutron fluence values are also necessary to identify the RPV beltline region, for which 

neutron fluence is projected to exceed 1 × 1017 n/cm2 (E > 1 MeV) during the subsequent period 

of extended operation.

Neutron fluence is an input to a number of RPV irradiation embrittlement analyses that are 

required by specific regulations in 10 CFR Part 50. These analyses are TLAAs for subsequent 

license renewal applications (SLRAs) and are the topic of the acceptance criteria and review 

procedures in Standard Review Plan for Review of Subsequent License Renewal Applications for 

Nuclear Power Plants (SRP-SLR) Section 4.2, “Reactor Vessel Neutron Embrittlement Analyses.” 

The neutron irradiation embrittlement TLAAs that are within the scope of this AMP include, but are 

not limited to: (a) neutron fluence, (b) pressurized thermal shock analyses for pressurized water 

reactors, as required by 10 CFR 50.61 or alternatively [if applicable for the current licensing basis 

(CLB)] by 10 CFR 50.61a; (c) RPV upper-shelf energy analyses, as required by Section IV.A.1 of 

10 CFR Part 50, Appendix G, and (d) pressure-temperature (P-T) limit analyses that are required

by Section IV.A.2 of 10 CFR Part 50, Appendix G and controlled by plant technical specifications 

(TS) update and reporting requirements (i.e., the 10 CFR 50.90 license amendment process for 

updates of P-T limit curves located in the TS limiting conditions of operation, or TS administrative 

control section requirements for updates of P-T limit curves that have been relocated into a 

pressure-temperature limits report). 

The calculations of neutron fluence also factor into other analyses or technical report 

methodologies that assess irradiation-related aging effects. Examples include, but are not limited 

to: (a) determination of the RPV beltline as defined in Regulatory Issue Summary 2014-11, 

“Information On Licensing Applications For Fracture Toughness Requirements For Ferritic 

Reactor Coolant Pressure Boundary Components,” (b) evaluation of the susceptibility of RVI 

components to neutron radiation damage mechanisms, including irradiation embrittlement (IE), 

irradiation-assisted stress corrosion cracking (IASCC), irradiation-enhanced stress relaxation or 

creep (IESRC) and void swelling or neutron induced component distortion; and (c) evaluating the 

dosimetry data obtained from an RPV surveillance program.

Guidance on acceptable methods and assumptions for determining reactor vessel neutron fluence 

is described in the U.S. Nuclear Regulatory Commission (NRC) Regulatory Guide (RG) 1.190, 

“Calculational and Dosimetry Methods for Determining Pressure Vessel Neutron Fluence.” The 

methods developed and approved using the guidance contained in RG 1.190 are specifically 

intended for determining neutron fluence in the region of the RPV close to the active fuel region of 

the core and are not intended to apply to vessel regions significantly above and below the active 

fuel region of the core, nor to RVI components. Therefore, the use of RG 1.190-adherent 

methods to estimate neutron fluence for the RPV regions significantly above and below the active 
X.M2-2

fuel region of the core and RVI components may require additional justification, even if those 

methods were approved by the NRC for RPV neutron fluence calculations. This program 

monitors in-vessel or ex-vessel dosimetry capsules and evaluates the dosimetry data, as needed. 

Such dosimetry capsules may be needed when the reactor surveillance program has exhausted 

the available capsules for in-vessel exposure.

Evaluation and Technical Basis

1. Scope of Program: The scope of the program includes RPV and RVI components that 

are subject to a neutron embrittlement TLAA or other analysis involving time-dependent 

neutron irradiation. The program monitors neutron fluence throughout the subsequent 

period of extended operation for determining the susceptibility of the components to IE, 

IASCC, IESRC, and void swelling or distortion. The use of this program also continues to 

ensure the adequacy of the neutron fluence estimates by: (a) monitoring plant and core 

operating conditions relative to the assumptions used in the neutron fluence calculations, 

and (b) continuously updating the qualification database associated with the neutron 

fluence method as new calculational and measurement data become available for 

benchmarking. This program is used in conjunction with GALL-SLR Report AMP XI.M31, 

“Reactor Vessel Material Surveillance.”

Updated neutron fluence calculations, plant modifications, and RPV surveillance program 

data are used to identify component locations within the scope of this program, including 

the beltline region of the RPV. Applicable requirements in 10 CFR Part 50, and if 

appropriate, plant TS, related to calculating neutron fluence estimates and incorporating 

those calculations into neutron irradiation analyses for the RPVs and RVIs must be met.

2. Preventive Actions: This program is a condition monitoring program through calculation 

of neutron fluence values, and continuous monitoring of their validity; thus, there are no 

specific preventive actions. Because this program can be used to verify that the inputs 

and assumptions associated with neutron fluence in the irradiation embrittlement TLAAs 

(described in SRP-SLR Section 4.2) remain within their respective limits, this program can 

prevent those TLAAs from being outside of the acceptance criteria that are set as 

regulatory or design limits in the analyses. Since the program is used to determine that 

the inputs and assumptions associated with neutron fluence in irradiation embrittlement 

TLAAs will remain within their respective limits, this program does have some preventative 

aspects to it.

3. Parameters Monitored or Inspected: The program monitors component neutron fluence 

as determined by the neutron fluence analyses, and appropriate plant and core operating 

parameters that affect the calculated neutron fluence. The calculational methods, 

benchmarking, qualification, and surveillance data are monitored to maintain the adequacy 

of neutron fluence calculations. Neutron fluence levels in specific components are 

monitored to verify component locations within the scope of this program are identified.

Neutron fluence is estimated using a computational method that incorporates the following 

major elements: (1) determination of the geometrical and material input data for the 

reactor core, vessel and internals, and cavity; (2) determination of the characteristics of the 

neutron flux emitting from the core; (3) transport of the neutrons from the core to the 

vessel, and into the cavity; and (4) qualification of the calculational procedure.
X.M2-3

Guidance on acceptable methods and assumptions for determining RPV neutron fluence 

is described in NRC RG 1.190. The use of RG 1.190-adherent methods to estimate 

neutron fluence for the RPV beltline regions significantly above and below the active fuel

region of the core, and RVI components may require additional justification, even if those 

methods were approved by the NRC for RPV neutron fluence calculations.

4. Detection of Aging Effects: The program uses applicant-defined activities or methods to 

track the RPV and RVI component neutron fluence levels. The neutron fluence levels 

estimated in this program are used as input to the evaluation for determining applicable 

aging effects for RPV and RVI components, including evaluation of TLAAs as described in 

SRP-SLR Section 4.2. 

5. Monitoring and Trending: Monitoring and trending of neutron fluence are needed to 

ensure the continued adequacy of various neutron fluence analyses as identified as 

TLAAs for the SLRA. When applied to RVI components and to components significantly 

above and below the active fuel region of the core, the program also assesses and 

justifies whether the current neutron fluence methodology for the CLB is acceptable for 

monitoring and projecting the neutron fluence values for these components during the 

subsequent period of extended operation, or else appropriately enhances (with

justification) the program’s monitoring and trending element activities accordingly on an 

as-needed basis. Trending is performed to ensure that plant and core operating 

conditions remain consistent with the assumptions used in the neutron fluence analyses 

and that the analyses are updated as necessary.

Neutron fluence estimates are typically determined using a combination of plant and core 

operating history data that address past plant operating conditions, and projections that 

are intended to address future operation. Although projections for future operation may 

conservatively over-estimate the core neutron flux to cover potential variations in plant and 

core operation and increases in neutron flux at any given time, there is no explicit 

requirement to do so. Therefore, projections for future plant and core operation should be 

periodically verified to ensure that any projections used in the neutron fluence calculations 

remain bounding with respect to actual plant operating conditions.

This program monitors in-vessel or ex-vessel dosimetry capsules and evaluates the 

dosimetry data, as needed. Additional dosimetry capsules may be needed when 

the reactor surveillance program has exhausted the available capsules for 

in-vessel exposure.

6. Acceptance Criteria: There are no specified acceptance values for neutron fluence; the 

acceptance criteria relate to the different parameters that are evaluated using neutron 

fluence, as described in SRP-SLR Section 4.2.

NRC RG 1.190 provides guidance for acceptable methods to determine neutron 

fluence for the RPV beltline region. It should be noted, however, that applying 

RG 1.190-adherent methods to determine neutron fluence in locations other than those 

close to the active fuel region of the core may require additional justification regarding, for 

example, the level of detail used to represent the core neutron source, the methods to 

synthesize the three-dimensional flux field, and the order of angular quadrature used in the 

neutron transport calculations. The applicability of existing qualification data may also 

require additional justification.
X.M2-4

7. Corrective Actions: Results that do not meet the acceptance criteria are addressed in 

the applicant’s corrective action program under those specific portions of the quality 

assurance (QA) program that are used to meet Criterion XVI, “Corrective Action,” of 

10 CFR Part 50, Appendix B. Appendix A of the GALL-SLR Report describes how an 

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the corrective 

actions element of this AMP for both safety-related and nonsafety-related structures and 

components (SCs) within the scope of this program.

The program provides for corrective actions by updating the analyses for the RPV 

components, or assessing the need for revising the augmented inspection bases for RVI 

components, if the neutron fluence assumptions in RPV analyses or augmented 

inspection bases for RVI components are projected to be exceeded during the subsequent 

period of extended operation. Acceptable corrective actions include revisions to the 

neutron fluence calculations to incorporate additional operating history data, as such data 

become available; use of improved modeling approaches to obtain more accurate neutron 

fluence estimates; and rescreening of RPV and RVI components when the estimated 

neutron fluence exceeds threshold values for specific aging mechanisms.

When the fluence monitoring activities are used to confirm the validity of existing RPV 

neutron irradiation embrittlement analyses and result in the need for an update of an 

analysis that is required by a specific 10 CFR Part 50 regulation, the corrective actions to 

be taken follow those prescribed in the applicable regulation.

8. Confirmation Process: The confirmation process is addressed through those specific 

portions of the QA program that are used to meet Criterion XVI, “Corrective Action,” of 

10 CFR Part 50, Appendix B. Appendix A of the GALL-SLR Report describes how an 

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the confirmation 

process element of this AMP for both safety-related and nonsafety-related SCs within the 

scope of this program.

9. Administrative Controls: Administrative controls are addressed through the QA program 

that is used to meet the requirements of 10 CFR Part 50, Appendix B, associated with 

managing the effects of aging. Appendix A of the GALL-SLR Report describes how an 

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the 

administrative controls element of this AMP for both safety-related and nonsafety-related 

SCs within the scope of this program. 

10. Operating Experience: The program reviews industry and plant operating experience

(OE) relevant to neutron fluence. Applicable OE affecting the neutron fluence estimate is 

to be considered in selecting the components for monitoring. RG 1.190 provides 

expectations for updating the qualification database for the neutron fluence methods via 

the operational experience gathered from RPV material surveillance program data. This 

operational experience is in accordance with the requirements of 10 CFR Part 50 

Appendix H.

The program is informed and enhanced when necessary through the systematic and 

ongoing review of both plant-specific and industry OE including research and development 

such that the effectiveness of the AMP is evaluated consistent with the discussion in 

Appendix B of the GALL-SLR Report.
X.M2-5

References

10 CFR Part 50, Appendix B, “Quality Assurance Criteria for Nuclear Power Plants and Fuel 

Reprocessing Plants.” Washington, DC: U.S. Nuclear Regulatory Commission. 2016.

10 CFR Part 50, Appendix G, “Fracture Toughness Requirements.” Washington, DC: 

U.S. Nuclear Regulatory Commission. 2016.

10 CFR Part 50, Appendix H, “Reactor Vessel Material Surveillance Program Requirements.” 

Washington, DC: U.S. Nuclear Regulatory Commission. 2016.

10 CFR 50.55a, “Codes and Standards.” Washington, DC: U.S. Nuclear Regulatory 

Commission. 2016.

10 CFR 50.60, “Acceptance Criteria for Fracture Prevention Measures for Lightwater Nuclear 

Power Reactor for Normal Operation.” Washington, DC: U.S. Nuclear Regulatory Commission. 

2016.

10 CFR 50.61, “Fracture Toughness Requirements for Protection Against Pressurized Thermal 

Shock Events.” Washington, DC: U.S. Nuclear Regulatory Commission. 2016.

10 CFR 50.61a, “Alternate Fracture Toughness Requirements for Protection Against Pressurized 

Thermal Shock Events.” Washington, DC: U.S. Nuclear Regulatory Commission. 2016.

NRC. Regulatory Guide 1.190, “Calculational and Dosimetry Methods for Determining Pressure 

Vessel Neutron Fluence.” Agencywide Documents Access and Management System (ADAMS) 

Accession No. ML010890301. Washington, DC: U.S. Nuclear Regulatory Commission. 

March 2001.

X.S1-1

X.S1 CONCRETE CONTAINMENT UNBONDED TENDON PRESTRESS

Program Description

This time-limited aging analysis (TLAA) aging management program (AMP) provides reasonable

assurance of the adequacy of prestressing forces in unbonded tendons of prestressed concrete

containments, during the subsequent period of extended operation, under Title 10 of the Code of 

Federal Regulations (10 CFR) 54.21(c)(1)(iii). The program consists of an assessment of

measured tendon prestress forces from required examinations performed in accordance with

Subsection IWL of the American Society of Mechanical Engineers Boiler and Pressure Vessel 

Code (ASME Code), Section XI, as incorporated by reference in 10 CFR 50.55a, and as further 

supplemented herein. The assessment related to the adequacy of the prestressing force for each 

tendon group based on type (i.e., hoop, vertical, dome, inverted-U, helical) and other 

considerations (e.g., geometric dimensions, whether affected by repair/replacement, etc.) 

establishes (a) acceptance criteria in accordance with ASME Code Section XI, Subsection IWL 

and (b) trend lines constructed based on the guidance provided in the U.S. Nuclear Regulatory 

Commission (NRC) Information Notice (IN) 99-10, “Degradation of Prestressing Tendon Systems 

in Prestressed Concrete Containments.” The NRC Regulatory Guide 1.35.1, “Determining 

Prestressing Forces for Inspection of Prestressed Concrete Containments,” may be used for 

guidance related to calculation of prestressing losses and predicted forces.

Evaluation and Technical Basis

1. Scope of Program: The program addresses the assessment of unbonded tendon 

prestressing forces measured in accordance with ASME Code Section XI, Subsection IWL, 

when an applicant performs the concrete containment prestressing force TLAA using 

10 CFR 54.21(c)(1)(iii).

2. Preventive Actions: This is primarily a condition monitoring program, which periodically 

measures and evaluates tendon forces such that corrective action can be taken, if 

required, prior to tendon forces falling below minimum required values established in the 

design. Maintaining the prestressing above the minimum required value (MRV) 

[prestressing force], as described under the acceptance criteria below, provides 

reasonable assurance that the structural and functional adequacy of the concrete 

containment is maintained.

3. Parameters Monitored: The parameters monitored are the concrete containment tendon 

prestressing forces in accordance with ASME Code Section XI, Subsection IWL. The 

prestressing forces are measured on common (control) tendons and tendons selected by 

random sampling of each tendon group using lift-off or equivalent method.

4. Detection of Aging Effects: The loss of concrete containment tendon prestressing

forces is detected by measuring tendon forces, and analyzing (predicting) tendon 

forces and trending the data obtained as part of ASME Code Section XI, 

Subsection IWL examinations.

5. Monitoring and Trending: In addition to Subsection IWL examination requirements, the 

estimated and all measured prestressing forces up to the current examination are plotted 

against time. The predicted lower limit (PLL) line, MRV, and trend line are developed for 

each tendon group examined for the subsequent period of extended operation. The trend 

line represents the general variation of prestressing forces with time based on the actual 
X.S1-2

measured forces in individual tendons of the specific tendon group. The trend line for 

each tendon group is constructed by regression analysis of all measured prestressing 

forces in individual tendons of that group obtained from all previous examinations. The 

PLL line, MRV, and trend line for each tendon group are projected to the end of the 

subsequent period of extended operation. The trend lines are updated at each scheduled 

examination. 

6. Acceptance Criteria: The prestressing force trend line (constructed as indicated in the 

Monitoring and Trending program element) for each tendon group must indicate that 

existing prestressing forces in the concrete containment tendon would not fall below the 

appropriate MRV prior to the next scheduled examination. If the trend line crosses the 

PLL line, its cause should be determined, evaluated and corrected. The trend line 

crossing the PLL line is an indication that the existing prestressing forces in concrete 

containment could fall below the MRV. Any indication in the trend line that the overall 

prestressing force in any tendon group(s) could potentially fall below the MRV during the 

subsequent period of extended operation is evaluated, the cause(s) is/are documented, 

and corrective action(s) is/are performed in a timely manner.

7. Corrective Actions: Results that do not meet the acceptance criteria are addressed in 

the applicant’s corrective action program under those specific portions of the quality 

assurance (QA) program that are used to meet Criterion XVI, “Corrective Action,” of 

10 CFR Part 50, Appendix B. Appendix A of the Generic Aging Lessons Learned for 

Subsequent License Renewal (GALL-SLR) Report describes how an applicant may apply 

its 10 CFR Part 50, Appendix B, QA program to fulfill the corrective actions element of this 

AMP for both safety-related and nonsafety-related structures and components (SCs) 

within the scope of this program.

If acceptance criteria are not met then either systematic retensioning of tendons or a

reanalysis of the concrete containment is warranted so that the design adequacy of 

the containment is demonstrated.

8. Confirmation Process: The confirmation process is addressed through those specific 

portions of the QA program that are used to meet Criterion XVI, “Corrective Action,” of 

10 CFR Part 50, Appendix B. Appendix A of the GALL-SLR Report describes how an 

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the confirmation 

process element of this AMP for both safety-related and nonsafety-related SCs within the 

scope of this program.

9. Administrative Controls: Administrative controls are addressed through the QA program 

that is used to meet the requirements of 10 CFR Part 50, Appendix B, associated with 

managing the effects of aging. Appendix A of the GALL-SLR Report describes how an 

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the 

administrative controls element of this AMP for both safety-related and nonsafety-related 

SCs within the scope of this program.

10. Operating Experience: The program incorporates a review of the relevant operating 

experience (OE) that has occurred at the applicant’s plant as well as at other plants. 

NUREG/CR–7111, “A Summary of Aging Effects and their Management in Reactor Spent 

Fuel Pools, Refueling Cavities, Tori, and Safety-Related Concrete Structures,” 

summarizes observations on low prestress forces recorded in some plants. However, 

tendon OE may vary at different plants with prestressed concrete containments. The 
X.S1-3

difference could be due to the prestressing system design (e.g., button- headed, wedge, or 

swaged anchorages), environment, and type of reactor (i.e., pressurized water reactor and 

boiling water reactor) and possible concrete containment modifications. Thus, the 

applicant’s plant-specific OE is reviewed and evaluated in detail for the subsequent period 

of extended operation. Applicable portions of the experience with prestressing systems 

described in NRC IN 99-10 could be useful.

If plant-specific OE indicates degradation and/or losses that may fall below minimum 

required values established in the design, additional examinations may be required to 

determine the condition of an expanded tendon group. Upward trending group prestress 

forces or tendon measurements shall be further assessed as part of the OE.

The program is informed and enhanced when necessary through the systematic and 

ongoing review of both plant-specific and industry OE including research and development 

such that the effectiveness of the AMP is evaluated consistent with the discussion in 

Appendix B of the GALL-SLR Report.

References

10 CFR Part 50, Appendix B, “Quality Assurance Criteria for Nuclear Power Plants and Fuel 

Reprocessing Plants.” Washington, DC: U.S. Nuclear Regulatory Commission. 2016.

10 CFR 50.55a, “Codes and Standards.” Washington, DC: U.S. Nuclear Regulatory 

Commission. 2016.

10 CFR 54.21, “Contents of Application-Technical Information.” Washington, DC: U.S. Nuclear 

Regulatory Commission. 2016.

ASME. ASME Code Section XI, Subsection IWL, “Requirements for Class CC Concrete 

Components of Light-Water Cooled Plants.” New York, New York: American Society of 

Mechanical Engineers. 2008.

NRC. Information Notice 99-10, “Degradation of Prestressing Tendon Systems in Prestressed 

Concrete Containments.” Agencywide Documents Access and Management System (ADAMS) 

Accession No. ML031500244. Washington, DC: U.S. Nuclear Regulatory Commission. 

April 1999.

_____. NUREG/CR–7111, “A Summary of Aging Effects and their Management in Reactor Spent 

Fuel Pools, Refueling Cavities, Tori, and Safety-Related Concrete Structures.” ADAMS 

Accession No. ML12047A184. Washington, DC: U.S. Nuclear Regulatory Commission. 

January 2012.

_____. Regulatory Guide 1.35.1, “Determining Prestressing Forces for Inspection of Prestressed 

Concrete Containments.” ADAMS Accession No. ML003740040. Washington, DC: U.S. Nuclear 

Regulatory Commission. July 1990.

X.E1-1

X.E1 ENVIRONMENTAL QUALIFICATION OF ELECTRIC EQUIPMENT

Program Description

The U.S. Nuclear Regulatory Commission (NRC) has established nuclear station environmental 

qualification (EQ) requirements in Title 10 of the Code of Federal Regulations (10 CFR) Part 50, 

Appendix A, Criterion 4, and 10 CFR 50.49. 10 CFR 50.49 specifically requires that an EQ 

program be established to demonstrate that certain electrical equipment located in harsh plant 

environments [that is, those areas of the plant that could be subject to the harsh environmental 

effects of a loss of coolant accident (LOCA), high energy line break and post-LOCA environment]

are qualified to perform their safety function in those harsh environments after the effects of 

inservice (operational) aging. 10 CFR 50.49 requires that the effects of significant aging 

mechanisms be addressed as part of EQ.

For equipment located in a harsh environment, the objective of EQ is to demonstrate with 

reasonable assurance that electric equipment important to safety, for which a qualified life has 

been established, can perform its safety function(s) without experiencing common cause failures 

before, during or after applicable design basis events. 

For equipment located in a mild environment (an environment that at no time would be 

significantly more severe than the environment occurring during normal operation, including 

anticipated operational occurrences as defined in 10 CFR 50.49), the demonstration that the 

equipment meets its functional requirements during normal environmental conditions and 

anticipated operational occurrences is in accordance with the plant design and licensing basis. 

Equipment important to safety located in a mild environment is not part of an EQ program per 

10 CFR 50.49(c). Documents that demonstrate that a component is qualified or designed for a 

mild environment include design/purchase specifications, seismic test qualification reports, an 

evaluation, or certificate of conformance.

Operating plants requesting subsequent license renewal shall meet the qualification requirements 

of 10 CFR 50.49 and license renewal aging management provisions of 10 CFR Part 54 for certain 

electrical equipment important to safety. 10 CFR 50.49 defines the scope of equipment to be 

included in an EQ program, requires the preparation and maintenance of a list of in-scope 

equipment, and requires the preparation and maintenance of a qualification file that contains the 

qualification report, with applicable equipment performance specifications, electrical 

characteristics, and the environmental conditions to which the equipment could be subjected. 

Licensees are required to maintain a record of qualification in auditable form [10 CFR 50.49(j)] for 

the entire period during which each covered item installed in the nuclear power plant or is stored 

for future use.

Additionally, 10 CFR 50.49(e) states that electric equipment qualification programs must include 

and be based on temperature, pressure, humidity, chemical effects, radiation, aging, 

submergence, and consideration of synergistic effects. The requirements of 10 CFR 50.49(e) 

also includes the application of margins to account for unquantified uncertainties, including 

production variations, and inaccuracies in test instruments. These margins are in addition to any 

conservatism applied during the derivation of local environmental conditions of the equipment 

unless these conservatisms can be quantified and shown to contain the appropriate margins. The 

aging provisions contained in 10 CFR 50.49(e)(5) require, in part, consideration of all significant 

types of aging degradation (e.g., plant-specific operational aging that includes thermal, radiation, 

vibration, and cyclic aging) which can have an effect on the functional capability of the equipment.
X.E1-2

EQ programs manage equipment thermal, radiation, and cyclic aging through the use of aging 

evaluations based on 10 CFR 50.49(f) qualification methods. Four methods are established by 

10 CFR 50.49(f) to demonstrate qualification for aging and accident conditions, as shown below:

 Testing an identical item of equipment under identical conditions or under similar 

conditions with a supporting analysis to show that the equipment to be qualified 

is acceptable.

 Testing a similar item of equipment with a supporting analysis to show that the equipment 

to be qualified is acceptable.

 Experience with identical or similar equipment under similar conditions with a supporting 

analysis to show that the equipment to be qualified is acceptable.

 Analysis in combination with partial type-test data that supports the analytical assumptions 

and conclusions [is acceptable.]

Additionally, 10 CFR 50.49(k) and (i) permit different qualification criteria to apply based on plant 

and electrical equipment vintage.

Supplemental EQ regulatory guidance for compliance with these different qualification criteria are

provided in the Division of Operating Reactors (DOR) Guidelines; “Guidelines for Evaluating 

Environmental Qualification of Class 1E Electrical Equipment in Operating Reactors,” 

NUREG–0588, “Interim Staff Position on Environmental Qualification of Safety-Related Electrical 

Equipment (Category 1 and Category 2 requirements),” and Regulatory Guide (RG) 1.89, 

Revision 1, “Environmental Qualification of Certain Electric Equipment Important to Safety for 

Nuclear Power Plants,” as applicable. Compliance with 10 CFR 50.49 provides reasonable 

assurance that the equipment can perform its intended function during accident conditions after 

experiencing the effects of inservice aging.

For equipment preconditioned and tested to less than an end-of-installed life condition 

(i.e., preconditioned to a shorter designated life) 10 CFR 50.49(e)(5) requires the equipment to be 

replaced or refurbished at the end of its designated life unless additional life is established through 

ongoing qualification.

Electrical equipment important to safety to be included in a 10 CFR 50.49 EQ program are 

specified under 10 CFR 50.49(b). A list of environmentally qualified electrical equipment 

important to safety is required under 10 CFR 50.49(d). Plant systems, structures, and 

components within the scope of license renewal established under 10 CFR 50.49 that are within 

scope of license renewal per 10 CFR 54.4(a)(3) and are considered a time-limited aging analysis

(TLAA) under 10 CFR 54.3(a) require an evaluation to demonstrate that the TLAA analysis 

satisfies 10 CFR 54.21(c)(1)iii.

Along with Generic Aging Lessons Learned for Subsequent License Renewal (GALL-SLR) Report 

AMP X.E1, plant EQ programs which implement the requirements of 10 CFR 50.49 (as further 

defined and clarified by the DOR Guidelines, NUREG–0588, and RG 1.89) demonstrate the 

acceptability of the TLAA analysis under 10 CFR 54.21(c)(1) and are considered an acceptable 

aging management program (AMP) for the subsequent period of extended operation.
X.E1-3

Environmental Qualification – Reanalysis

Reanalysis evaluates the original attributes, assumptions and conservatisms for environmental 

conditions and other factors of an aging evaluation to demonstrate that equipment qualified life 

can be extended. Reanalysis of equipment qualified under the program requirements of 

10 CFR 50.49(e) is performed as part of an EQ program. Important attributes for the reanalysis of 

an aging evaluation include analytical methods, data collection and reduction methods, underlying 

assumptions, acceptance criteria, and corrective actions. These attributes are discussed in the 

“Environmental Qualification Equipment Reanalysis Attributes” section below.

Environmental Qualification Equipment Reanalysis Attributes

The reanalysis of an existing aging evaluation is normally performed to extend the qualification by 

reevaluating original attributes, assumptions and conservatisms in environmental conditions and 

other factors to identify excess conservatisms incorporated in the prior evaluation. Reanalysis of 

an aging evaluation to extend the qualification of electrical equipment is performed pursuant to 

10 CFR 50.49(e) as part of an EQ program. While an electrical equipment life limiting condition 

may be due to thermal, radiation, or cyclical aging, the majority of electrical equipment aging limits 

are based on thermal conditions. Conservatism may exist in aging evaluation parameters, such 

as the assumed service conditions or unrealistically low activation energy. The reanalysis of an 

aging evaluation is performed according to the station's quality assurance (QA) program 

requirements, which requires the verification of assumptions and conclusions including the 

maintenance of required margins. 

As already noted, important attributes of a reanalysis include analytical methods, data collection 

and reduction methods, underlying assumptions, acceptance criteria, and corrective actions. 

These attributes are discussed below.

Analytical Methods: The analytical models used in the reanalysis of an aging evaluation are the 

same as those previously applied during the prior evaluation. The Arrhenius methodology is an 

acceptable thermal model for performing a thermal aging evaluation. The analytical method used 

for a radiation aging evaluation is to demonstrate qualification for the total integrated dose that 

includes normal radiation dose for the projected installed life plus accident radiation dose. For 

subsequent license renewal, one acceptable method of establishing the 80-year normal radiation 

dose is to multiply the initial 40-year normal radiation dose by two. The result is added to the 

accident radiation dose to obtain the total integrated dose for the component. For cyclical aging, a 

similar approach may be used. Other models may be justified on a case-by-case basis.

Data Collection and Reduction Methods: The identification of excess conservatism in electrical 

equipment service conditions used in the prior aging evaluation is the chief method used for a 

reanalysis. For example, temperature data, associated margins, and uncertainties used in an 

equipment EQ evaluation may be based on anticipated plant design temperatures found to be 

conservative when compared to actual plant temperature data. When used, plant environmental

data may be obtained from monitors used for technical specification compliance; other installed 

monitors, measurements made by plant operators during rounds, dedicated monitors for EQ

equipment or combinations of the above. The environmental data gathering and analysis method 

can be used to identify conservatism in the original qualification and justify additional qualified life 

for the EQ equipment. Any changes to material activation energy values included as part of a 

reanalysis are justified by the applicant on a component-specific basis.
X.E1-4

Underlying Assumptions: EQ equipment aging evaluations account for environmental changes 

occurring due to plant modifications, seasonal changes, and events. A reanalysis demonstrates 

that adequate margin is maintained consistent with the original analysis in accordance with 

10 CFR 50.49. 10 CFR 50.49 requires further consideration of certain margins and accounting for 

unquantified uncertainties such as diffusion limited oxidation, activation energy, synergistic effects, 

inverse temperature, and dose rate effects. Reanalysis that utilizes initial qualification 

conservatisms and/or inservice environmental conditions (e.g., actual temperature and radiation 

conditions) are part of an EQ program.

Adverse Localized Environment

In most areas within a nuclear power plant, the actual operating environment (e.g., temperature, 

or radiation), is less severe than the plant design basis environment. However, in a limited 

number of localized areas, the actual environment may be more severe than the anticipated plant 

design basis environment. These localized areas are characterized as “adverse localized 

environments” that represent a limited plant area where the operating environment is significantly 

more severe than the plant design environment considered in the qualification for EQ equipment.

An adverse localized environment may increase the rate of aging or have an adverse effect on the 

basis for equipment qualification. An adverse localized environment is an environment that 

exceeds the most limiting qualified condition for temperature or radiation for the component 

material. EQ electrical equipment may degrade more rapidly than expected when exposed to an 

adverse localized environment.

Adverse localized environments are identified through the use of an integrated approach. This 

approach includes, but is not limited to: (a) the review of EQ program radiation levels and 

temperatures, (b) recorded information from equipment or plant instrumentation, (c) as-built and 

field walk down data (e.g., cable routing data base), (d) a plant spaces scoping and screening 

methodology, (e) plant modifications (e.g., power uprate), and (f) the review of relevant 

plant-specific and industry operating experience (OE). This OE includes, but is not limited to:

 Identification of work practices that have the potential to subject in-scope EQ equipment to 

an adverse localized environment (e.g., influence of maintenance activity that removes 

thermal insulation and restoration from hot pipes).

 Corrective actions for in-scope EQ equipment involving end-of-installed life, designated 

life, or qualified life (current operating term).

 Observations from previous walk-downs including visual inspection.

 Environmental monitoring (e.g., long term periodic environmental monitoring of EQ 

equipment – temperature or radiation).

 Inspection of accessible passive EQ equipment and the evaluation of the equipment 

environment to identify electrical equipment subjected to an adverse localized 

environment. The aging impact on accessible EQ equipment located in an adverse 

localized environment is evaluated and represents, with reasonable assurance, both 

accessible and inaccessible EQ equipment age degradation.

The inspection portion of the EQ of Electric Components program is considered a visual 

inspection performed from the floor, with the use of scaffolding as available, without the opening 
X.E1-5

of junction boxes, pull boxes, or terminal boxes. The purpose of the visual inspection is to identify 

adverse localized environments (employing diagnostic tools such as thermography as applicable). 

The accessible, passive EQ components located in these adverse localized environments are 

then visually inspected which depending on the visual inspection results, may require further 

inspection using scaffolding or other means (e.g., opening of junction boxes, pull boxes, 

accessible pull points, panels, terminal boxes, and junction boxes) to assess EQ electrical 

equipment aging degradation. Passive EQ equipment subject to an adverse localized 

environment may result in surface abnormalities that are visually observable, such as cable jacket 

surface embrittlement, discoloration, cracking, melting, swelling, or surface contamination. Visual 

inspection can be used as an indicator of age degradation.

Adverse conditions identified during periodic inspections or by operational or maintenance 

activities that affect the operating environment of EQ equipment are evaluated and appropriate 

corrective actions are taken, which may include changes to qualification bases and conclusions 

(e.g., changes to qualified life).

In-scope accessible passive EQ electrical equipment is inspected at least once every 10 years to 

identify EQ electrical equipment subjected to an adverse localized environment. The first periodic 

inspection is to be performed prior to the subsequent period of extended operation.

Acceptance Criteria and Corrective Actions: Reanalysis of an aging evaluation is used to 

extend the qualification of the component. If the qualification cannot be extended by reanalysis, 

the equipment is refurbished, replaced, or requalified prior to exceeding the current qualified life. 

A reanalysis is performed in a timely manner to ensure sufficient time is available to refurbish, 

replace, or requalify the equipment if the result is unfavorable.

A modification to qualified life by reanalysis must demonstrate that adequate margin is maintained 

consistent with the original analysis including unquantified uncertainties established in the original 

EQ equipment aging evaluation.

Environmental Qualification – Ongoing Qualification

Ongoing qualification, for the purposes of this document is defined as the process of requalifying a 

component through activities similar to the original qualification which may include testing, type 

testing, or a monitoring program. When assessed, if margins, conservatisms, or assumptions do 

not support extending qualified life, the following methods may be used:

 The retention and continued aging of a test sample from the original EQ test program with 

demonstration that the qualified life is bounding for the subsequent period of extended 

operation, 

 Removal and type testing of additional EQ equipment installed in identical service 

conditions with a greater period of operational aging, 

 Monitoring Program – Requires that EQ equipment characteristics subject to aging 

degradation be monitored at specific intervals and compared to specified acceptance 

criteria. The acceptance criteria are based on the capability of post aging characteristics 

for the EQ equipment to retain functional properties during and after enduring design 

bases environment, as applicable. Condition monitoring intervals are established to 

prevent age degradation beyond the acceptance criteria prior to corrective action.
X.E1-6

The above methods are considered ongoing qualification. Other methods or approaches may 

be acceptable. A modification to extend qualified life must be justified including program 

documentation and auditable evidence that adequate margin is maintained consistent with the 

original analysis including unquantified uncertainties established in the original EQ equipment 

aging evaluation.

Evaluation and Technical Basis

1. Scope of Program: EQ programs apply to certain electrical equipment that are important 

to safety and could be exposed to harsh environment accident conditions, as defined in 

10 CFR 50.49 and RG 1.89, Revision 1. Plant EQ programs along with GALL-SLR Report 

AMP X.E1 demonstrate acceptability of the EQ electrical equipment TLAA analysis under 

10 CFR 54.21(c)(1).

2. Preventive Actions: 10 CFR 50.49 does not require actions that prevent aging effects. 

EQ program actions that could be viewed as preventive actions include (a) establishing 

the equipment service condition tolerance and aging limits (e.g., qualified life or condition 

limit) and (b) where applicable, requiring specific installation, inspection, monitoring, or 

periodic maintenance actions to maintain electrical equipment aging within the bounds of 

the qualification basis (e.g., identification of adverse localized environments or shielding 

for temperature and/or radiation).

3. Parameters Monitored or Inspected: Qualified life is not based on condition or 

performance monitoring. However, pursuant to RG 1.211 and RG 1.89, Revision 1, such 

monitoring programs are an acceptable basis to modify a qualified life to establish a 

revised qualified condition. Monitoring or inspection of certain environmental conditions, 

including adverse localized environments, or equipment parameters may be used to verify

that the equipment is within the bounds of its qualification basis, or as a means to modify 

the qualified life.

4. Detection of Aging Effects: 10 CFR 50.49 does not require the detection of aging 

effects for inservice EQ equipment. EQ program actions that could be viewed as detection 

of aging effects include (a) inspecting EQ equipment periodically with particular emphasis 

on monitoring or condition assessment and (b) monitoring of plant environmental 

conditions or component parameters used to verify that the equipment is within the 

bounds of its EQ basis including attributes, assumptions, and conservatisms for 

equipment/environmental conditions and other factors. Monitoring or inspection of certain 

environmental conditions or component parameters may provide a means to maintain

equipment qualified life.

Visual inspection of accessible, passive EQ equipment is performed at least once every 

10 years. The purpose of the visual inspection is to identify adverse localized 

environments that may impact qualified life. Potential adverse localized environments are 

evaluated through the applicant’s corrective action program. The first periodic visual 

inspection is to be performed prior to the subsequent period of extended operation.
X.E1-7

5. Monitoring and Trending: 10 CFR 50.49 does not require monitoring and trending of 

component condition or performance parameters of inservice equipment to manage the 

effects of aging. Monitoring, trending, or inspection of certain environmental, condition, or 

component parameters may be used to verify that EQ equipment is within the bounds of 

its qualification basis, or as a means to modify the qualification.

6. Acceptance Criteria: An unacceptable indication is defined as a noted condition or 

situation, if left unmanaged, could potentially lead to a loss of intended function.

10 CFR 50.49 acceptance criteria are that inservice EQ equipment is maintained within 

the bounds of its qualification basis, including its established qualified life and continued 

qualification for the projected accident conditions. 10 CFR 50.49 requires refurbishment, 

replacement, or requalification prior to exceeding the qualified life of each installed 

component. When monitoring is used to modify equipment qualified life, plant-specific 

acceptance criteria are established based on applicable 10 CFR 50.49(f) qualification 

methods.

Visual inspection results show that accessible passive EQ equipment is free from 

unacceptable surface abnormalities that may indicate age degradation.

7. Corrective Actions: Results that do not meet the acceptance criteria are addressed in 

the applicant’s corrective action program under those specific portions of the QA program 

that are used to meet Criterion XVI, “Corrective Action,” of 10 CFR Part 50, Appendix B. 

Appendix A of the GALL-SLR Report describes how an applicant may apply its 

10 CFR Part 50, Appendix B, QA program to fulfill the corrective actions element of this 

AMP for both safety-related and nonsafety-related structures and components (SCs) 

within the scope of this program.

If an EQ component is found to be outside the bounds of its qualification basis, corrective 

actions are implemented in accordance with the station’s corrective action program. When 

an unexpected adverse localized environment or condition is identified during operational 

or maintenance activities that affect the qualification of electrical equipment, the affected 

EQ equipment is evaluated and appropriate corrective actions are taken, which may 

include changes to qualified life.

8. Confirmation Process: The confirmation process is addressed through those specific 

portions of the QA program that are used to meet Criterion XVI, “Corrective Action,” of 

10 CFR Part 50, Appendix B. Appendix A of the GALL-SLR Report describes how an 

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the confirmation 

process element of this AMP for both safety-related and nonsafety-related SCs within the 

scope of this program.

9. Administrative Controls: Administrative controls are addressed through the QA program 

that is used to meet the requirements of 10 CFR Part 50, Appendix B, associated with 

managing the effects of aging. Appendix A of the GALL-SLR Report describes how an 

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the 

administrative controls element of this AMP for both safety-related and nonsafety-related 

SCs within the scope of this program. 
X.E1-8

10. Operating Experience: EQ programs include consideration of OE to modify qualification 

bases and conclusions, including qualified life such that the impact on the EQ program is 

evaluated and any necessary actions or modifications to the program are performed. 

Compliance with 10 CFR 50.49 provides reasonable assurance that EQ equipment can 

perform their intended functions during accident conditions after experiencing the effects 

of operational aging.

The program is informed and enhanced when necessary through the systematic and 

ongoing review of both plant-specific and industry OE including research and development 

such that the effectiveness of the AMP is evaluated consistent with the discussion in 

Appendix B of the GALL-SLR Report.

References

10 CFR Part 50, Appendix B, “Quality Assurance Criteria for Nuclear Power Plants and Fuel 

Reprocessing Plants.” Washington, DC: U.S. Nuclear Regulatory Commission. 2016.

10 CFR 50.49, “Environmental Qualification of Electrical Equipment Important to Safety for 

Nuclear Power Plants.” Washington, DC: U.S. Nuclear Regulatory Commission. 2016.

10 CFR 54.21, “Contents of Application—Technical Information.” Washington, DC: U.S. Nuclear 

Regulatory Commission. 2015. 

EPRI. EPRI 1003057, Revision 1, “Plant Support Engineering: License Renewal Electrical 

Handbook.” Palo Alto, California: Electric Power Research Institute February 2007.

IEEE. IEEE Standard 1205-2014, “IEEE Guide for Assessing, Monitoring and Mitigating Aging 

Effects on Class 1E Equipment Used in Nuclear Power Generating Stations.” New York, 

New York: Institute of Electrical and Electronics Engineers. 2014.

NRC. Denton, H.R., U.S. Nuclear Regulatory Commission, letter to V. Stello, Office of Inspection 

and Enforcement. Agencywide Documents Access and Management System (ADAMS) 

Accession No. ML032541214. Washington, DC: U.S. Nuclear Regulatory Commission. 

November 13, 1979.

_____. Generic Letter 2007-01, “Inaccessible or Underground Power Cable Failures that Disable 

Accident Mitigation Systems or Cause Plant Transients.” ADAMS Accession No. ML070360665. 

Washington, DC: U.S. Nuclear Regulatory Commission. February 7, 2007.

_____. NUREG–0588, “Interim Staff Position on Environmental Qualification of Safety-Related 

Electrical Equipment.” Revision 1. ADAMS Accession No. ML031480402. Washington, DC: 

U.S. Nuclear Regulatory Commission. July 31, 1981.

_____. NUREG/CR–7000, “Essential Elements of an Electric Cable Condition Monitoring 

Program.” ADAMS Accession No. ML100540050. Washington, DC: U.S. Nuclear Regulatory 

Commission. January 31, 2010.

_____. Regulatory Guide 1.100, “Seismic Qualification of Electrical and Active Mechanical 

Equipment and Functional Qualification of Active Mechanical Equipment for Nuclear Power 

Plants.” Revision 3. ADAMS Accession No. ML091320468. Washington, DC: U.S. Nuclear 

Regulatory Commission. September 30, 2009.
X.E1-9

_____. Regulatory Guide 1.211, “Qualification of Safety-Related Cables and Field Splices for 

Nuclear Power Plants.” ADAMS Accession No. ML082530205. Washington, DC: U.S. Nuclear 

Regulatory Commission. April 1, 2009.

_____. Regulatory Guide 1.218, “Condition-Monitoring Techniques for Electric Cables Used in 

Nuclear Power Plants.” ADAMS Accession No. ML103510458. Washington, DC: U.S. Nuclear 

Regulatory Commission. April 30, 2012.

_____. Regulatory Guide 1.89, “Environmental Qualification of Certain Electric Equipment

Important to Safety for Nuclear Power Plants.” Revision 1. ADAMS Accession No. 

ML14070A119. Washington, DC: U.S. Nuclear Regulatory Commission. May 20, 1984.

_____. Regulatory Issue Summary 2003-09, “Environmental Qualification of Low-Voltage 

Instrumentation and Control Cables.” ADAMS Accession No. ML03120078. Washington, DC: 

U.S. Nuclear Regulatory Commission. May 2, 2003.

X 01-1

Table X-01 FSAR Supplement Summaries for GALL-SLR Report Chapter X Aging Management 

Programs That May Be Used to Demonstrate Acceptability of Time-Limited 

Aging Analyses in Accordance with 10 CFR 54.21(c)(1)(iii)

GALL- SLR 

AMP

GALL-SLR 

Program Description of Program

Implementation 

Schedule*

X.M1 Fatigue

Monitoring

This program is used to accept fatigue or other types 

of cyclical loading TLAAs in accordance with the 

acceptance criterion in 10 CFR 54.21(c)(1)(iii). The 

aging management program monitors and tracks the 

number of occurrences and severity of design basis 

transients assessed in the applicable fatigue or 

cyclical loading analyses, including those in 

applicable CUF analyses, environmental-assisted 

fatigue analyses (CUFen analyses), maximum 

allowable stress range reduction/expansion stress 

analyses for ANSI B31.1 and ASME Code Class 2 

and 3 components, ASME III fatigue waiver analyses, 

and cycle-based flaw growth, flaw tolerance, or 

fracture mechanics analyses. The program also 

monitors applicable design transient parameters 

(e.g., temperatures, pressures, displacements, 

strains, flow rates, etc.) for components with stressbased fatigue calculations.

The program manages cumulative fatigue damage or 

cracking induced by fatigue or cyclic loading in the 

applicable structures and components through 

performance of activities that monitor one or more 

relevant analysis parameters, such as CUF values, 

CUFen values, design transient cycle limit values, 

predicted flaw size values, or plant-specific parameter 

values used in stress- based fatigue analysis 

methodologies. The program also sets applicable 

acceptance criteria (limits) on these parameters.

Therefore, the program has two aspects, one to verify 

the continued acceptability of existing analyses through 

cycle counting or parameter monitoring and the other 

to provide periodically updated evaluations of the 

analyses to demonstrate that they continue to meet the 

appropriate limits.

The program also implements appropriate corrective 

actions (e.g., reanalysis, component or structure 

inspections, or component or structure repair or 

replacement activities) when acceptance limits are 

approached. Plant technical specification 

requirements may apply to the scope of this program.

Program and SLR 

enhancements, 

when applicable, 

are implemented 

6 months prior to 

the subsequent 

period of extended 

operation.

X.M2

Neutron 

Fluence 

Monitoring

This program monitors and tracks increasing neutron 

fluence (integrated, time-dependent neutron flux 

exposures) to reactor pressure vessel and reactor 

internal components to ensure that applicable reactor 

pressure vessel neutron irradiation embrittlement 

analyses (i.e., TLAAs) and radiation-induced aging 

effect assessment for reactor internal components will 

remain within their applicable limits.

Program is 

implemented 

6 months prior to the 

subsequent period of 

extended operation.
X 01-2

Table X-01 FSAR Supplement Summaries for GALL-SLR Report Chapter X Aging Management 

Programs That May Be Used to Demonstrate Acceptability of Time-Limited 

Aging Analyses in Accordance with 10 CFR 54.21(c)(1)(iii)

GALL- SLR 

AMP

GALL-SLR 

Program Description of Program

Implementation 

Schedule*

This program has two aspects, one to verify the 

continued acceptability of existing analyses through 

neutron fluence monitoring and the other to provide 

periodically updated evaluations of the analyses 

involving neutron fluence inputs to demonstrate that 

they continue to meet the appropriate limits defined in 

the CLB.

Monitoring is performed to verify the adequacy of 

neutron fluence projections, which are defined for the 

CLB in NRC approved reports. For fluence monitoring 

activities that apply to the beltline region of the reactor 

pressure vessel(s), the calculational methods are 

generally performed in a manner that is consistent with 

RG 1.190, “Calculational and Dosimetry Methods for 

Determining Pressure Vessel Neutron Fluence,” 

March 2001. Additional justifications may be 

necessary for neutron fluence monitoring, regarding

methods that are applied to reactor pressure vessel 

locations outside of the beltline region of the vessels or 

to reactor internal components.

This program’s results are compared to the neutron 

fluence parameter inputs used in the neutron 

embrittlement analyses for reactor pressure vessel 

components. This includes but is not limited to the 

neutron fluence inputs for the reactor pressure vessel

upper shelf energy analyses (or equivalent margin 

analyses, as applicable to the CLB), 

pressure-temperature limits analyses, and low 

temperature overpressure protection (LTOP, PWRs 

only) that are required to be performed in accordance 

in 10 CFR Part 50, Appendix G requirements, and for 

PWRs, those safety analyses that are performed to 

demonstrate adequate protection of the reactor 

pressure vessels against the consequences of PTS 

events, as required by 10 CFR 50.61 or 10 CFR 

50.61a and applicable to the CLB. Comparisons to the 

neutron fluence inputs for other analyses (as applicable 

to the CLB) may include those for mean RTNDT and 

probability of failure analyses for BWR reactor pressure 

vessel circumferential and axial shell welds, BWR core 

reflood design analyses, and aging effect assessments 

for PWR and BWR reactor internals that are induced 

by neutron irradiation exposure mechanisms.

Reactor vessel surveillance capsule dosimetry data 

obtained in accordance with 10 CFR Part 50, 

Appendix H requirements and through implementation 

of the applicant’s Reactor Vessel Surveillance 

Program (Refer to GALL-SLR Report AMP XI.M31) 
X 01-3

Table X-01 FSAR Supplement Summaries for GALL-SLR Report Chapter X Aging Management 

Programs That May Be Used to Demonstrate Acceptability of Time-Limited 

Aging Analyses in Accordance with 10 CFR 54.21(c)(1)(iii)

GALL- SLR 

AMP

GALL-SLR 

Program Description of Program

Implementation 

Schedule*

may provide inputs to and have impacts on the neutron 

fluence monitoring results that are tracked by this 

program. In addition, regulatory requirements in the 

plant technical specifications or in specific regulations 

of 10 CFR Part 50 may apply, including those in 

10 CFR Part 50, Appendix G; 10 CFR 50.55a; and for 

PWRs, the PTS requirements in 10 CFR 50.61 or 

10 CFR 50.61a, as applicable for the CLB.

X.S1

Concrete 

Containment 

Tendon 

Prestress

The program monitors and assesses the adequacy of 

the prestressing force for each tendon group based on 

type (i.e., hoop, vertical, dome, inverted-U, helical) and 

other considerations (e.g., geometric dimensions, 

whether affected by repair/replacement, etc.). The 

program ensures, during each inspection, that the 

trend lines of the measured prestressing forces remain 

above the minimum required value before the next 

scheduled inspections. Otherwise, corrective actions 

are taken to ensure containment prestress adequacy. 

Acceptance criteria follow 10 CFR 50.55a, ASME Code 

Section XI (Subsection IWL) and include construction 

of trend lines consistent with NRC Information Notice 

(IN) 99-10, “Degradation of Prestressing Tendon 

Systems in Prestressed Concrete Containments.” 

The NRC RG 1.35.1, “Determining Prestressing Forces 

for Inspection of Prestressed Concrete Containments,”

provides guidance for calculating prestressing losses 

and predicted forces. The program incorporates 

plant-specific and industry operating experience.

Program and SLR 

enhancements, 

when applicable, 

are implemented 

6 months prior to the 

subsequent period of 

extended operation.
X 01-4

Table X-01 FSAR Supplement Summaries for GALL-SLR Report Chapter X Aging Management 

Programs That May Be Used to Demonstrate Acceptability of Time-Limited 

Aging Analyses in Accordance with 10 CFR 54.21(c)(1)(iii)

GALL- SLR 

AMP

GALL-SLR 

Program Description of Program

Implementation 

Schedule*

X.E1

Environmental 

Qualification 

(EQ) of Electric 

Components

This program implements the EQ requirements in 

10 CFR Part 50, Appendix A, Criterion 4, and 

10 CFR 50.49. 10 CFR 50.49 specifically requires that 

an EQ program be established to demonstrate that 

certain electrical equipment located in harsh plant 

environments will perform their safety function in those 

harsh environments after the effects of inservice aging. 

10 CFR 50.49 requires that the effects of significant 

aging mechanisms be addressed as part of 

environmental qualification.

As required by 10 CFR 50.49, EQ equipment not 

qualified for the current license term is refurbished, 

replaced, or have their qualification extended prior to 

reaching the designated life aging limits established in 

the evaluation. Aging evaluations for EQ equipment 

that specify a qualification of at least 60 years are 

TLAAs for SLR.

This program is implemented in accordance 

10 CFR 50.49 and 10 CFR 54.21(c)(1)(iii). Along with 

GALL-SLR Report AMP X.E1 the EQ program 

demonstrates the acceptability of the TLAA analysis 

under 10 CFR 54.21(c)(1) and is considered an AMPs 

for the subsequent period of extended operation.

Program and SLR 

enhancements, 

when applicable, 

are implemented 

6 months prior to the 

subsequent period of 

extended operation.
CHAPTER XI

AGING MANAGEMENT PROGRAMS

XI-1

XI: AGING MANAGEMENT PROGRAMS

GUIDANCE ON USE OF LATER EDITIONS/REVISIONS OF VARIOUS INDUSTRY 

DOCUMENTS

XI.M1 ASME SECTION XI INSERVICE INSPECTION, SUBSECTIONS IWB, 

IWC, AND IWD

XI.M2 WATER CHEMISTRY

XI.M3 REACTOR HEAD CLOSURE STUD BOLTING

XI.M4 BWR VESSEL ID ATTACHMENT WELDS

XI.M5 DELETED

XI.M6 DELETED

XI.M7 BWR STRESS CORROSION CRACKING

XI.M8 BWR PENETRATIONS

XI.M9 BWR VESSEL INTERNALS

XI.M10 BORIC ACID CORROSION

XI.M11B CRACKING OF NICKEL-ALLOY COMPONENTS AND LOSS OF MATERIAL 

DUE TO BORIC ACID-INDUCED CORROSION IN REACTOR COOLANT

PRESSURE BOUNDARY COMPONENTS (PWRs ONLY)

XI.M12 THERMAL AGING EMBRITTLEMENT OF CAST AUSTENITIC STAINLESS

STEEL (CASS)

XI.M16A PWR VESSEL INTERNALS

XI.M17 FLOW-ACCELERATED CORROSION

XI.M18 BOLTING INTEGRITY

XI.M19 STEAM GENERATORS 

XI.M20 OPEN-CYCLE COOLING WATER SYSTEM

XI.M21A CLOSED TREATED WATER SYSTEMS

XI.M22 BORAFLEX MONITORING

XI.M23 INSPECTION OF OVERHEAD HEAVY LOAD AND LIGHT LOAD (RELATED TO

REFUELING) HANDLING SYSTEMS

XI.M24 COMPRESSED AIR MONITORING
XI-2

XI: AGING MANAGEMENT PROGRAMS (Continued)

XI.M25 BWR REACTOR WATER CLEANUP SYSTEM

XI.M26 FIRE PROTECTION

XI.M27 FIRE WATER SYSTEM

XI.M29 OUTDOOR AND LARGE ATMOSPHERIC METALLIC STORAGE TANKS

XI.M30 FUEL OIL CHEMISTRY

XI.M31 REACTOR VESSEL MATERIAL SURVEILLANCE

XI.M32 ONE-TIME INSPECTION

XI.M33 SELECTIVE LEACHING

XI.M35 ASME CODE CLASS 1 SMALL-BORE PIPING

XI.M36 EXTERNAL SURFACES MONITORING OF MECHANICAL COMPONENTS

XI.M37 FLUX THIMBLE TUBE INSPECTION 

XI.M38 INSPECTION OF INTERNAL SURFACES IN MISCELLANEOUS PIPING 

AND DUCTING COMPONENTS

XI.M39 LUBRICATING OIL ANALYSIS

XI.M40 MONITORING OF NEUTRON-ABSORBING MATERIALS OTHER 

THAN BORAFLEX

XI.M41 BURIED AND UNDERGROUND PIPING AND TANKS

XI.M42 INTERNAL COATINGS/LININGS FOR IN-SCOPE PIPING, PIPING 

COMPONENTS, HEAT EXCHANGERS, AND TANKS

XI.S1 ASME SECTION XI, SUBSECTION IWE

XI.S2 ASME SECTION XI, SUBSECTION IWL

XI.S3 ASME SECTION XI, SUBSECTION IWF

XI.S4 10 CFR 50, APPENDIX J

XI.S5 MASONRY WALLS

XI.S6 STRUCTURES MONITORING 

XI.S7 INSPECTION OF WATER-CONTROL STRUCTURES ASSOCIATED WITH

NUCLEAR POWER PLANTS 
XI-3

XI: AGING MANAGEMENT PROGRAMS (Continued)

XI.S8 PROTECTIVE COATING MONITORING AND MAINTENANCE 

XI.E1 ELECTRICAL INSULATION FOR ELECTRICAL CABLES AND CONNECTIONS 

NOT SUBJECT TO 10 CFR 50.49 ENVIRONMENTAL QUALIFICATION 

REQUIREMENTS

XI.E2 ELECTRICAL INSULATION FOR ELECTRICAL CABLES AND CONNECTIONS 

NOT SUBJECT TO 10 CFR 50.49 ENVIRONMENTAL QUALIFICATION 

REQUIREMENTS USED IN INSTRUMENTATION CIRCUITS

XI.E3A ELECTRICAL INSULATION FOR INACCESSIBLE MEDIUM-VOLTAGE POWER

CABLES NOT SUBJECT TO 10 CFR 50.49 ENVIRONMENTAL QUALIFICATION 

REQUIREMENTS

XI.E3B ELECTRICAL INSULATION FOR INACCESSIBLE INSTRUMENT AND 

CONTROL CABLES NOT SUBJECT TO 10 CFR 50.49 ENVIRONMENTAL 

QUALIFICATION REQUIREMENTS

XI.E3C ELECTRICAL INSULATION FOR INACCESSIBLE LOW-VOLTAGE POWER

CABLES NOT SUBJECT TO 10 CFR 50.49 ENVIRONMENTAL QUALIFICATION 

REQUIREMENTS

XI.E4 METAL-ENCLOSED BUS

XI.E5 FUSE HOLDERS

XI.E6 ELECTRICAL CABLE CONNECTIONS NOT SUBJECT TO 10 CFR 50.49 

ENVIRONMENTAL QUALIFICATION REQUIREMENTS

XI.E7 HIGH-VOLTAGE INSULATORS

TABLE XI-01 FSAR SUPPLEMENT SUMMARIES FOR GALL-SLR CHAPTER XI AGING 

MANAGEMENT PROGRAMS

XI.M1-1

XI.M1 ASME SECTION XI INSERVICE INSPECTION, SUBSECTIONS IWB, IWC, 

AND IWD

Program Description

Title 10 of the Code of Federal Regulations (10 CFR) 50.55a, imposes the inservice inspection 

(ISI) requirements of the American Society of Mechanical Engineers Boiler and Pressure Vessel 

Code (ASME Code), Section XI, Rules for ISI of Nuclear Power Plant Components for Class 1, 2, 

and 3 pressure-retaining components and their integral attachments in light-water cooled power 

plants. The rules of Section XI require a mandatory program of examinations, testing and 

inspections to demonstrate adequate safety and to manage deterioration and aging effects. 

Inspection of these components is covered in Subsections IWB, IWC, and IWD, respectively, in 

accordance with the applicable plant ASME Code Section XI edition(s) and addenda as required 

by 10 CFR 50.55a(g)(4).1

 The program generally includes periodic visual, surface, and/or 

volumetric examination and leakage test of Class 1, 2, and 3 pressure-retaining components and 

their integral attachments. Repair/replacement activities for these components are covered in 

Subsection IWA of the ASME Code.

The ASME Code Section XI ISI program, in accordance with Subsections IWA, IWB, IWC, and 

IWD, has been shown to be generally effective in managing aging effects in Class 1, 2, and 3 

components and their integral attachments in light-water cooled power plants. 10 CFR 50.55a 

imposes additional conditions and augmentations of ISI requirements specified in the ASME 

Code, Section XI, and those conditions or augmentations described in 10 CFR 50.55a are 

included as part of this program. In certain cases, the ASME Code Section XI ISI program is 

augmented to manage effects of aging for license renewal and is so identified in the Generic 

Aging Lessons Learned for Subsequent License Renewal (GALL-SLR) Report. 

Evaluation and Technical Basis

1. Scope of Program: The ASME Code Section XI program provides the requirements for 

ISI, repair, and replacement of Class 1, 2, and 3 pressure-retaining components and their 

integral attachments in light-water cooled nuclear power plants. The components within 

the scope of the program are specified in ASME Code, Section XI, Subsections IWB-1100, 

IWC-1100, and IWD-1100 for Class 1, 2, and 3 components, respectively. The 

components described in Subsections IWB-1220, IWC-1220, and IWD-1220 are exempt 

from the volumetric and surface examination requirements, but not exempt from VT-2 

visual examination and pressure testing requirements of Subsections IWB-2500, 

IWC-2500, and IWD-2500.

2. Preventive Actions: This is a condition monitoring program; therefore, this program does 

not implement preventive actions.

3. Parameters Monitored or Inspected: The ASME Code, Section XI ISI program detects 

degradation of components by using the examination and inspection requirements 

specified in ASME Code, Section XI Tables IWB-2500-1, IWC-2500-1, and IWD-2500-1 

for Class 1, 2, and 3 components, respectively.

 

1 GALL-SLR Report, Chapter I, Table 1, identifies the ASME Code Section XI editions and addenda that are 

acceptable to use for this AMP.
XI.M1-2

The program uses three types of examination—visual, surface, and volumetric—in 

accordance with the requirements of Subsection IWA-2000. Visual VT-1 examination 

detects discontinuities and imperfections, such as cracks, corrosion, wear, or erosion, on 

the surface of components. Visual VT-2 examination detects evidence of leakage from 

pressure-retaining components, as required during the system pressure test. Visual VT-3 

examination (a) determines the general mechanical and structural condition of 

components and their supports by verifying parameters such as clearances, settings, and 

physical displacements; (b) detects discontinuities and imperfections, such as loss of 

integrity at bolted or welded connections, loose or missing parts, debris, corrosion, wear, 

or erosion; and (c) observes conditions that could affect operability or functional adequacy 

of constant-load and spring-type components and supports.

Surface examination uses magnetic particle, liquid penetrant, or eddy current 

examinations to indicate the presence of surface discontinuities and flaws. Volumetric 

examination uses radiographic, ultrasonic, or eddy current examinations to indicate the 

presence of discontinuities or flaws throughout the volume of material included in the 

inspection program.

4. Detection of Aging Effects: The extent and schedule of the inspection and test 

techniques prescribed by the program are designed to maintain structural integrity and to 

detect and repair or replace components before the loss of intended function of the 

component. Inspection can reveal cracking, loss of material due to corrosion, leakage of 

coolant, and indications of degradation due to wear or stress relaxation (such as changes 

in clearances, settings, physical displacements, loose or missing parts, debris, wear, 

erosion, or loss of integrity at bolted or welded connections).

Class 1, 2, and 3 components are examined and tested as specified in Tables IWB-2500-1, 

IWC-2500-1, and IWD-2500-1, respectively. The tables specify the extent and schedule of 

the inspection and examination methods for the components of the pressure-retaining 

boundaries.

5. Monitoring and Trending: For Class 1, 2, and 3 components, the inspection schedule of 

IWB-2400, IWC-2400, and IWD-2400, and the extent and frequency of IWB-2500-1, 

IWC-2500-1, and IWD-2500-1, respectively, provides for timely detection of degradation. 

The sequence of component examinations established during the first inspection interval is 

repeated during each successive inspection interval, to the extent practical. Volumetric 

and surface examination results are compared with recorded preservice examination and 

prior inservice examinations. Flaw conditions or relevant conditions of degradation are 

evaluated in accordance with IWB-3100, IWC-3100, or IWD-3100.

Examinations that reveal indications that exceed the acceptance standards described 

below are extended to include additional examinations in accordance with IWB-2430, 

IWC-2430, and IWD-2430 for Class 1, 2, and 3 components, respectively. Examination 

results that exceed the acceptance standards below are repaired/replaced or accepted by 

analytical evaluation in accordance with IWB-3600, IWC-3600 or IWD-3600, as applicable. 

Those items accepted by analytical evaluation are reexamined during the next three 

inspection periods of IWB-2410 for Class 1 components, IWC-2410 for Class 2 

components, and IWD-2410 for Class 3 components.
XI.M1-3

6. Acceptance Criteria: Any indication or relevant conditions of degradation are evaluated 

in accordance with IWB-3000, IWC-3000, and IWD-3000 for Class 1, 2, and 3 

components, respectively. Examination results are evaluated in accordance with 

IWB-3100, IWC-3100, or IWD-3100 by comparing the results with the acceptance 

standards of IWB-3400 and IWB-3500 for Class 1, IWC-3400 and IWC-3500 for Class 2, 

and IWD-3400 and IWD-3500 for Class 3 components. Flaws that exceed the size of 

allowable flaws, as defined in IWB-3500, IWC-3500 and IWD-3500 may be evaluated by 

using the analytical procedures of IWB-3600, IWC-3600 and IWD-3600 for Class 1, 2 and 

3 components, respectively. 

7. Corrective Actions: Results that do not meet the acceptance criteria are addressed in 

the applicant’s corrective action program under those specific portions of the quality 

assurance (QA) program that are used to meet Criterion XVI, “Corrective Action,” of 

10 CFR Part 50, Appendix B. Appendix A of the GALL-SLR Report describes how an 

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the corrective 

actions element of this aging management program (AMP) for both safety-related and 

nonsafety-related structures and components (SCs) within the scope of this program.

Repair and replacement activities are performed in conformance with IWA-4000.

8. Confirmation Process: The confirmation process is addressed through those specific 

portions of the QA program that are used to meet Criterion XVI, “Corrective Action,” of 

10 CFR Part 50, Appendix B. Appendix A of the GALL-SLR Report describes how an 

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the confirmation 

process element of this AMP for both safety-related and nonsafety-related SCs within the 

scope of this program.

9. Administrative Controls: Administrative controls are addressed through the QA program 

that is used to meet the requirements of 10 CFR Part 50, Appendix B, associated with 

managing the effects of aging. Appendix A of the GALL-SLR Report describes how an 

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the 

administrative controls element of this AMP for both safety-related and nonsafety-related 

SCs within the scope of this program.

10. Operating Experience: Because the ASME Code is a consensus document that has 

been widely used over a long period, it has been shown to be generally effective in 

managing aging effects in Class 1, 2, and 3 components and their integral attachments in 

light-water cooled power plants (see Chapter I of the GALL-SLR Report).

Some specific examples of operating experience (OE) of component degradation are 

as follows:

Boiling Water Reactor (BWR): Cracking due to intergranular stress corrosion cracking

(IGSCC) has occurred in small- and large-diameter BWR piping made of austenitic 

stainless steel (SS) and nickel alloys. IGSCC has also occurred in a number of vessel 

internal components, such as core shrouds, access hole covers, top guides, and core 

spray spargers [U.S. Nuclear Regulatory Commission (NRC) Inspection and Enforcement 

Bulletin (IEB) 80-13, NRC Information Notice (IN) 95-17, NRC Generic Letter (GL) 94-03, 

and NUREG–1544]. Cracking due to thermal and mechanical loading has occurred in 

high-pressure coolant injection piping (NRC IN 89-80) and instrument lines [Licensee

Event Report (LER) 249/99-003-01]. BWR jet pumps are designed with access holes in 
XI.M1-4

the shroud support plate at the bottom of the annulus between the core shroud and the 

reactor vessel wall. These holes are used for access during construction and are 

subsequently closed by welding a plate over the hole. Both circumferential (NRC 

IN 88-03) and radial cracking (NRC IN 92-57) have been observed in access hole 

covers. Failure of the isolation condenser tube bundles due to thermal fatigue and 

transgranular stress corrosion cracking caused by leaky valves has also occurred 

(NRC LER 219/98-014-00).

Pressurized Water Reactor (PWR) Primary System: Although the primary pressure 

boundary piping of PWRs has generally not been found to be affected by stress corrosion 

cracking (SCC) because of low dissolved oxygen levels and control of primary water 

chemistry, SCC has occurred in safety injection lines (NRC IN 97-19 and 84-18), charging 

pump casing cladding (NRC IN 80-38 and 94-63), instrument nozzles in safety 

injection tanks (NRC IN 91-05), control rod drive seal housing (NRC Inspection 

Report 50-255/99012), and safety-related SS piping systems that contain oxygenated, 

stagnant, or essentially stagnant borated coolant (NRC IN 97-19). Cracking has occurred 

in SS baffle former bolts in a number of foreign plants (NRC IN 98-11) and has been 

observed in plants in the United States. Cracking due to thermal and mechanical loading 

has occurred in high-pressure injection and safety injection piping (NRC IN 97-46 and 

NRC Bulletin 88-08). Through-wall circumferential cracking has been found in reactor 

pressure vessel head control rod drive penetration nozzles (NRC IN 2001-05). Evidence 

of reactor coolant leakage, together with crack-like indications, has been found in 

bottom-mounted instrumentation nozzles (NRC IN 2003-11 and IN 2003-11, 

Supplement 1). Cracking in pressurizer safety and relief line nozzles and in surge line 

nozzles has been detected (NRC IN 2004-11), and circumferential cracking in SS 

pressurizer heater sleeves has also been found (NRC IN 2006-27). Also, primary water 

stress corrosion cracking has been observed in steam generator drain bowl welds 

inspected as part of a licensee’s Alloy 600/82/182 program (NRC IN 2005-02).

PWR Secondary System: Steam generator tubes have experienced outside diameter 

stress corrosion cracking, intergranular attack, wastage, and pitting (NRC IN 97-88). 

Carbon steel support plates in steam generators have experienced general corrosion. 

Steam generator shells have experienced pitting and SCC (NRC INs 82-37, 85-65, 

and 90-04).

The program is informed and enhanced when necessary through the systematic and 

ongoing review of both plant-specific and industry OE including research and development 

such that the effectiveness of the AMP is evaluated consistent with the discussion in 

Appendix B of the GALL-SLR Report.

References

10 CFR Part 50, Appendix B, “Quality Assurance Criteria for Nuclear Power Plants and Fuel 

Reprocessing Plants.” Washington, DC: U.S. Nuclear Regulatory Commission. 2016.

10 CFR 50.55a, “Codes and Standards.” Washington, DC: U.S. Nuclear Regulatory 

Commission. 2016.
XI.M1-5

ASME. ASME Code Section XI, “Rules for Inservice Inspection of Nuclear Power Plant 

Components.” New York, New York: The American Society of Mechanical Engineers. 2008.

2

EPRI. BWRVIP-03, Revision 6 (EPRI 105696-R6), “BWR Vessel and Internals Project, Reactor 

Pressure Vessel and Internals Examination Guidelines.” Palo Alto, California: Electric Power 

Research Institute. December 2003.

Licensee Event Report 219/98-014-00, “Failure of the Isolation Condenser Tube Bundles due to 

Thermal Stresses/Transgranular Stress Corrosion Cracking Caused by Leaky Valve.” 

https://lersearch.inl.gov/LERSearchCriteria.aspx. October 1998.

Licensee Event Report 249/99-003-01, “Supplement to Reactor Recirculation B Loop, High 

Pressure Flow Element Venturi Instrument Line Steam Leakage Results in Unit 3 Shutdown Due 

to Fatigue Failure of Socket Welded Pipe Joint.” https://lersearch.inl.gov/LERSearchCriteria.aspx. 

August 1999.

NRC. Bulletin 88-08, “Thermal Stresses in Piping Connected to Reactor Coolant System.”

Washington, DC: U.S. Nuclear Regulatory Commission. June 1988. Supplement 1, June 1988. 

Supplement 2, September 1988. Supplement 3, April 1989.

_____. Generic Letter 94-03, “Intergranular Stress Corrosion Cracking of Core Shrouds in Boiling 

Water Reactors.” Agencywide Documents Access and Management System (ADAMS) 

Accession No. ML070600206. Washington, DC: U.S. Nuclear Regulatory Commission. 

July 1994.

NRC. IE Bulletin 80-13, “Cracking in Core Spray Spargers.” Washington, DC: U.S. Nuclear 

Regulatory Commission. May 1980.

_____. Information Notice 80-38, “Cracking in Charging Pump Casing Cladding.” ADAMS 

Accession No. ML073550834. Washington, DC: U.S. Nuclear Regulatory Commission. 

October 1980.

_____. Information Notice 82-37, “Cracking in the Upper Shell to Transition Cone Girth Weld of a 

Steam Generator at an Operating PWR.” ADAMS Accession No. ML082970942. 

Washington, DC: U.S. Nuclear Regulatory Commission. September 1982.

_____. Information Notice 84-18, “Stress Corrosion Cracking in PWR Systems.” 

Washington, DC: U.S. Nuclear Regulatory Commission. March 1984.

_____. Information Notice 85-65, “Crack Growth in Steam Generator Girth Welds.” 

Washington, DC: U.S. Nuclear Regulatory Commission. July 1985.

_____. Information Notice 88-03, “Cracks in Shroud Support Access Hole Cover Welds.” 

Washington, DC: U.S. Nuclear Regulatory Commission. February 1988.

 

2GALL-SLR Report Chapter I, Table 1, identifies the ASME Code Section XI editions and addenda that are 

acceptable to use for this AMP.
XI.M1-6

_____. Information Notice 89-80, “Potential for Water Hammer, Thermal Stratification, and Steam 

Binding in High-Pressure Coolant Injection Piping.” Washington, DC: U.S. Nuclear Regulatory 

Commission. December 1989.

_____. Information Notice 90-04, “Cracking of the Upper Shell-to-Transition Cone Girth Welds in 

Steam Generators.” Washington, DC: U.S. Nuclear Regulatory Commission. January 1990.

_____. Information Notice 91-05, “Intergranular Stress Corrosion Cracking in Pressurized Water 

Reactor Safety Injection Accumulator Nozzles.” Washington, DC: U.S. Nuclear Regulatory 

Commission. January 1991.

_____. Information Notice 92-57, “Radial Cracking of Shroud Support Access Hole Cover Welds.” 

Washington, DC: U.S. Nuclear Regulatory Commission. August 1992.

_____. Information Notice 94-63, “Boric Acid Corrosion of Charging Pump Casing Caused by 

Cladding Cracks.” Washington, DC: U.S. Nuclear Regulatory Commission. August 1994.

_____. Information Notice 95-17, “Reactor Vessel Top Guide and Core Plate Cracking.” 

Washington, DC: U.S. Nuclear Regulatory Commission. March 1995.

_____. Information Notice 97-19, “Safety Injection System Weld Flaw at Sequoyah Nuclear 

Power Plant, Unit 2.” Washington, DC: U.S. Nuclear Regulatory Commission. April 18, 1997.

_____. Information Notice 97-46, “Unisolable Crack in High-Pressure Injection Piping.” 

Washington, DC: U.S. Nuclear Regulatory Commission. July 1997.

_____. Information Notice 97-88, “Experiences During Recent Steam Generator Inspections.” 

Washington, DC: U.S. Nuclear Regulatory Commission. December 1997.

_____. Information Notice 98-11, “Cracking of Reactor Vessel Internal Baffle Former Bolts in 

Foreign Plants.” Washington, DC: U.S. Nuclear Regulatory Commission. March 1998.

_____. Information Notice 2001-05, “Through-Wall Circumferential Cracking of Reactor Pressure 

Vessel Head Control Rod Drive Mechanism Penetration Nozzles at Oconee Nuclear Station, 

Unit 3.” Washington, DC: U.S. Nuclear Regulatory Commission. April 2001.

_____. Information Notice 2003-11, “Leakage Found on Bottom-Mounted Instrumentation 

Nozzles.” Washington, DC: U.S. Nuclear Regulatory Commission. August 2003.

_____. Information Notice 2003-11, Supplement 1, “Leakage Found on Bottom-Mounted 

Instrumentation Nozzles.” Washington, DC: U.S. Nuclear Regulatory Commission. 

January 2004.

_____. Information Notice 2004-11, “Cracking in Pressurizer Safety and Relief Nozzles and in 

Surge Line Nozzles.” Washington, DC: U.S. Nuclear Regulatory Commission. May 2004.

_____. Information Notice 2005-02, “Pressure Boundary Leakage Identified on Steam Generator 

Drain Bowl Welds.” Washington, DC: U.S. Nuclear Regulatory Commission. February 2005.
XI.M1-7

_____. Information Notice 2006-27, “Circumferential Cracking in the Stainless Steel Pressurizer 

Heater Sleeves of Pressurized Water Reactors.” Washington, DC: U.S. Nuclear Regulatory 

Commission. December 2006.

_____. Inspection Report 50-255/99012, “Palisades Inspection Report.” Item E8.2, Licensee 

Event Report 255/99-004, “Control Rod Drive Seal Housing Leaks and Crack Indications.” 

Washington, DC: U.S. Nuclear Regulatory Commission. January 2000.

_____. NUREG–1544, “Status Report: Intergranular Stress Corrosion Cracking of BWR Core 

Shrouds and Other Internal Components.” Washington, DC: U.S. Nuclear Regulatory 

Commission. March 1996.

XI.M2-1

XI.M2 WATER CHEMISTRY

Program Description

The main objective of this program is to mitigate loss of material due to corrosion, cracking due to 

stress corrosion cracking (SCC) and related mechanisms, and reduction of heat transfer due to 

fouling in components exposed to a treated water environment. The program includes periodic 

monitoring of the treated water in order to minimize loss of material or cracking.

The water chemistry program for boiling water reactors (BWRs) relies on monitoring and control of 

reactor water chemistry based on industry guidelines contained in the Boiling Water Reactor 

Vessel and Internals Project (BWRVIP)-190 (Electric Power Research Institute (EPRI) 1016579). 

The BWRVIP-190 has three sets of guidelines: (i) one for reactor water, (ii) one for condensate 

and feedwater, and (iii) one for control rod drive mechanism cooling water. The water chemistry 

program for pressurized water reactors (PWRs) relies on monitoring and control of reactor water 

chemistry based on industry guidelines contained in EPRI 1014986, “PWR Primary Water 

Chemistry Guidelines,” Revision 7 and EPRI 1016555, “PWR Secondary Water Chemistry 

Guidelines,” Revision 7. 

The water chemistry programs are generally effective in removing impurities from intermediate 

and high flow areas. The Generic Aging Lessons Learned for Subsequent License Renewal 

(GALL-SLR) Report identifies those circumstances in which the water chemistry program is to be 

augmented to manage the effects of aging for license renewal. For example, the water chemistry 

program may not be effective in low flow or stagnant flow areas. Accordingly, in certain cases as 

identified in the GALL-SLR Report, verification of the effectiveness of the chemistry control 

program is undertaken to provide reasonable assurance that significant degradation is not 

occurring and the component’s intended function is maintained during the subsequent period of 

extended operation. For these specific cases, an acceptable verification program is a one-time 

inspection of selected components at susceptible locations in the system.

Evaluation and Technical Basis

1. Scope of Program: The program includes components in the reactor coolant system, the 

engineered safety features, the auxiliary systems, and the steam and power conversion 

system. This program addresses the metallic components subject to aging management 

review that are exposed to a treated water environment controlled by the water chemistry 

program.

2. Preventive Actions: The program includes specifications for chemical species, impurities 

and additives, sampling and analysis frequencies, and corrective actions for control of 

reactor water chemistry. System water chemistry is controlled to minimize contaminant 

concentration and mitigate loss of material due to general, crevice, and pitting corrosion 

and cracking caused by SCC. For BWRs, maintaining high water purity reduces 

susceptibility to SCC, and chemical additive programs such as hydrogen water chemistry 

or noble metal chemical application also may be used. For PWRs, additives are used for 

reactivity control, to control pH and dose rates, and inhibit corrosion.

3. Parameters Monitored or Inspected: The concentrations of corrosive impurities listed in 

the EPRI water chemistry guidelines are monitored to mitigate loss of material, cracking, 

and reduction of heat transfer. Water quality also is maintained in accordance with the 

guidance. Chemical species and water quality are monitored by in-process methods or 
XI.M2-2

through sampling. The chemical integrity of the samples is maintained and verified to 

provide reasonable assurance that the method of sampling and storage will not cause a 

change in the concentration of the chemical species in the samples.

4. Detection of Aging Effects: This is a mitigation program and does not provide for 

detection of any aging effects of concern for the components within its scope. The 

monitoring methods and frequency of water chemistry sampling and testing is performed 

in accordance with the EPRI water chemistry guidelines and based on plant operating 

conditions. The main objective of this program is to mitigate loss of material due to 

corrosion and cracking due to SCC in components exposed to a treated 

water environment.

5. Monitoring and Trending: Chemistry parameter data are recorded, evaluated, and 

trended in accordance with the EPRI water chemistry guidelines.

6. Acceptance Criteria: Maximum levels for various chemical parameters are maintained 

within the system-specific limits as indicated by the limits specified in the corresponding 

EPRI water chemistry guidelines. 

7. Corrective Actions: Results that do not meet the acceptance criteria are addressed in 

the applicant’s corrective action program under those specific portions of the quality 

assurance (QA) program that are used to meet Criterion XVI, “Corrective Action,” of 

Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B. Appendix A of 

the GALL-SLR Report describes how an applicant may apply its 10 CFR Part 50, 

Appendix B, QA program to fulfill the corrective actions element of this aging management 

program (AMP) for both safety-related and nonsafety-related structures and components 

(SCs) within the scope of this program.

Any evidence of aging effects or unacceptable water chemistry results are evaluated, the 

cause identified, and the condition corrected. When measured water chemistry 

parameters are outside the specified range, corrective actions are taken to bring the 

parameter back within the acceptable range (or to change the operational mode of the 

plant) within the time period specified in the EPRI water chemistry guidelines. Whenever 

corrective actions are taken to address an abnormal chemistry condition, increased 

sampling or other appropriate actions are taken and analyzed to verify that the corrective 

actions were effective in returning the concentrations of contaminants, such as chlorides, 

fluorides, sulfates, and dissolved oxygen, to within the acceptable ranges. 

8. Confirmation Process: The confirmation process is addressed through those specific 

portions of the QA program that are used to meet Criterion XVI, “Corrective Action,” of 

10 CFR Part 50, Appendix B. Appendix A of the GALL-SLR Report describes how an 

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the confirmation 

process element of this AMP for both safety-related and nonsafety-related SCs within the 

scope of this program.

9. Administrative Controls: Administrative controls are addressed through the QA program 

that is used to meet the requirements of 10 CFR Part 50, Appendix B, associated with 

managing the effects of aging. Appendix A of the GALL-SLR Report describes how an 

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the 

administrative controls element of this AMP for both safety-related and nonsafety-related 

SCs within the scope of this program.
XI.M2-3

10. Operating Experience: The EPRI guideline documents have been developed based on 

plant experience and have been shown to be effective over time with their widespread 

use. The specific examples of operating experience (OE) are as follows:

BWR: Intergranular stress corrosion cracking (IGSCC) has occurred in small- and 

large-diameter BWR piping made of austenitic stainless steels (SSs) and nickel-base 

alloys. Significant cracking has occurred in recirculation, core spray, residual heat 

removal systems, and reactor water cleanup system piping welds. IGSCC has also 

occurred in a number of vessel internal components, including core shroud, access hole 

cover, top guide, and core spray spargers [U.S. Nuclear Regulatory Commission (NRC)

Inspection and Enforcement Bulletin (IEB) 80-13, NRC Information Notice (IN) 95-17, NRC 

Generic Letter (GL) 94-03, and NUREG–1544]. No occurrence of SCC in piping and other 

components in standby liquid control systems exposed to sodium pentaborate solution has 

ever been reported (NUREG/CR–6001).

PWR Primary System: The potential for SCC-type mechanisms might normally occur 

because of inadvertent introduction of contaminants into the primary coolant system, 

including contaminants introduced from the free surface of the spent fuel pool (which can 

be a natural collector of airborne contaminants) or the introduction of oxygen during plant 

cooldowns (NRC IN 84–18). Ingress of demineralizer resins into the primary system has 

caused IGSCC of Alloy 600 vessel head penetrations (NRC IN 96-11, NRC GL 97-01). 

Inadvertent introduction of sodium thiosulfate into the primary system has caused IGSCC 

of steam generator tubes. SCC has occurred in safety injection lines (NRC INs 97-19 and 

84-18), charging pump casing cladding (NRC INs 80-38 and 94-63), instrument nozzles in 

safety injection tanks (NRC IN 91-05), and safety-related SS piping systems that contain 

oxygenated, stagnant, or essentially stagnant borated coolant (NRC IN 97-19). Steam 

generator tubes and plugs and Alloy 600 penetrations have experienced primary water 

SCC (NRC INs 89-33, 94-87, 97-88, 90-10, and 96-11; NRC Bulletin 89-01 and its two 

supplements). IGSCC-induced circumferential cracking has occurred in PWR pressurizer 

heater sleeves (NRC IN 2006-27).

PWR Secondary System: Steam generator tubes have experienced outside diameter 

stress corrosion cracking, intergranular attack, wastage, and pitting (NRC IN 97-88, NRC 

GL 95-05). Carbon steel support plates in steam generators have experienced general 

corrosion. The steam generator shell has experienced pitting and SCC (NRC INs 82-37, 

85-65, and 90-04). Extensive buildup of deposits at steam generator tube support holes 

can result in flow-induced vibrations and tube cracking (NRC IN 2007-37).

Such OE has provided feedback to revisions of the EPRI water chemistry guideline 

documents. 

The program is informed and enhanced when necessary through the systematic and 

ongoing review of both plant-specific and industry OE including research and development 

such that the effectiveness of the AMP is evaluated consistent with the discussion in 

Appendix B of the GALL-SLR Report.
XI.M2-4

References

10 CFR Part 50, Appendix B, “Quality Assurance Criteria for Nuclear Power Plants and Fuel 

Reprocessing Plants.” Washington, DC: U.S. Nuclear Regulatory Commission. 2016.

EPRI. BWRVIP-190 (EPRI 1016579), “BWR Vessel and Internals Project: BWR Water Chemistry 

Guidelines-2008 Revision.” Palo Alto, California: Electric Power Research Institute. 

October 2008.

_____. EPRI 1014986, “PWR Primary Water Chemistry Guidelines.” Revision 7, Volumes 1 and 

2. Palo Alto, California: Electric Power Research Institute. April 2014.

_____. EPRI 1016555, “PWR Secondary Water Chemistry Guidelines.” Revision 7. Palo Alto, 

California: Electric Power Research Institute. February 2009.

NRC. Bulletin 89-01, “Failure of Westinghouse Steam Generator Tube Mechanical Plugs.”

Washington, DC: U.S. Nuclear Regulatory Commission. May 1989.

_____. Bulletin 89-01, “Supplement 1, “Failure of Westinghouse Steam Generator Tube 

Mechanical Plugs.” Washington, DC: U.S. Nuclear Regulatory Commission. November 1989.

_____. Bulletin 89-01, Supplement 2, “Failure of Westinghouse Steam Generator Tube 

Mechanical Plugs.” Washington, DC: U.S. Nuclear Regulatory Commission. June 1991.

_____. Generic Letter 94-03, “Intergranular Stress Corrosion Cracking of Core Shrouds in Boiling 

Water Reactors.” Washington, DC: U.S. Nuclear Regulatory Commission. July 1994.

_____. Generic Letter 95-05, “Voltage-Based Repair Criteria for Westinghouse Steam Generator 

Tubes Affected by Outside Diameter Stress Corrosion Cracking.” Washington, DC: U.S. Nuclear 

Regulatory Commission. August 1995.

_____. Generic Letter 97-01, “Degradation of Control Rod Drive Mechanism Nozzle and Other 

Vessel Closure Head Penetrations.” Washington, DC: U.S. Nuclear Regulatory Commission. 

April 1997.

_____. IE Bulletin 80-13, “Cracking in Core Spray Piping.” Washington, DC: U.S. Nuclear 

Regulatory Commission. May 1980.

_____. Information Notice 80-38, “Cracking In Charging Pump Casing Cladding.” 

Washington, DC: U.S. Nuclear Regulatory Commission. October 1980.

_____. Information Notice 82-37, “Cracking in the Upper Shell to Transition Cone Girth Weld of a 

Steam Generator at an Operating PWR.” Washington, DC: U.S. Nuclear Regulatory 

Commission. September 1982.

_____. Information Notice 84-18, “Stress Corrosion Cracking in Pressurized Water Reactor 

Systems.” Washington, DC: U.S. Nuclear Regulatory Commission. March 1984.

_____. Information Notice 85-65, “Crack Growth in Steam Generator Girth Welds.” 

Washington, DC: U.S. Nuclear Regulatory Commission. July 1985.
XI.M2-5

_____. Information Notice 89-33, “Potential Failure of Westinghouse Steam Generator Tube 

Mechanical Plugs.” Washington, DC: U.S. Nuclear Regulatory Commission. March 1989.

_____. Information Notice 90-04, “Cracking of the Upper Shell-to-Transition Cone Girth Welds in 

Steam Generators.” Washington, DC: U.S. Nuclear Regulatory Commission. January 1990.

_____. Information Notice 90-10, “Primary Water Stress Corrosion Cracking (PWSCC) of 

Inconel 600.” Washington, DC: U.S. Nuclear Regulatory Commission. February 1990.

_____. Information Notice 91-05, “Intergranular Stress Corrosion Cracking In Pressurized Water 

Reactor Safety Injection Accumulator Nozzles.” Washington, DC: U.S. Nuclear Regulatory 

Commission. January 1991.

_____. Information Notice 94-63, “Boric Acid Corrosion of Charging Pump Casing Caused by 

Cladding Cracks.” Washington, DC: U.S. Nuclear Regulatory Commission. August 1994.

_____. Information Notice 94-87, “Unanticipated Crack in a Particular Heat of Alloy 600 Used for 

Westinghouse Mechanical Plugs for Steam Generator Tubes.” Washington, DC: U.S. Nuclear 

Regulatory Commission. December 1994.

_____. Information Notice 95-17, “Reactor Vessel Top Guide and Core Plate Cracking.” 

Washington, DC: U.S. Nuclear Regulatory Commission. March 1995.

_____. Information Notice 96-11, “Ingress of Demineralizer Resins Increase Potential for Stress

Corrosion Cracking of Control Rod Drive Mechanism Penetrations.” Washington, DC: 

U.S. Nuclear Regulatory Commission. February 1996.

_____. Information Notice 97-19, “Safety Injection System Weld Flaw at Sequoyah Nuclear 

Power Plant, Unit 2.” Washington, DC: U.S. Nuclear Regulatory Commission. April 1997.

_____. Information Notice 97-88, “Experiences During Recent Steam Generator Inspections.” 

Washington, DC: U.S. Nuclear Regulatory Commission. December 1997.

_____. Information Notice 2006-27, “Circumferential Cracking in the Stainless Steel Pressurizer 

Heater Sleeves of Pressurized Water Reactors.” Washington, DC: U.S. Nuclear Regulatory 

Commission. December 2006.

_____. Information Notice 2007-37, “Buildup of Deposits in Steam Generators.” 

Washington, DC: U.S. Nuclear Regulatory Commission. November 2007.

_____. NUREG–1544, “Status Report: Intergranular Stress Corrosion Cracking of BWR Core 

Shrouds and Other Internal Components.” Washington, DC: U.S. Nuclear Regulatory 

Commission. March 1996.

_____. NUREG/CR–6001, “Aging Assessment of BWR Standby Liquid Control Systems.”

G.D. Buckley, R.D. Orton, A.B. Johnson Jr., and L.L. Larson. Washington, DC: U.S. Nuclear 

Regulatory Commission. 1992.

XI.M3-1

XI.M3 REACTOR HEAD CLOSURE STUD BOLTING 

Program Description

This program includes (a) inservice inspection (ISI) in accordance with the requirements of the 

American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code)1 , 

Section XI, Subsection IWB, Table IWB 2500-1; and (b) preventive measures to mitigate cracking. 

The program also relies on recommendations delineated in the U.S. Nuclear Regulatory 

Commission (NRC) Regulatory Guide (RG) 1.65, Revision 1.

Evaluation and Technical Basis

1. Scope of Program: The program manages the aging effects of cracking due to stress 

corrosion cracking (SCC) or intergranular stress corrosion cracking (IGSCC) and loss of 

material due to wear or corrosion for reactor vessel closure stud bolting (studs, washers, 

bushings, nuts, and threads in flange) for both boiling water reactors (BWRs) and 

pressurized water reactors.

2. Preventive Actions: Preventive measures may include: 

(a) Avoiding the use of metal-plated stud bolting to prevent degradation due to 

corrosion or hydrogen embrittlement;

(b) Using manganese phosphate or other acceptable surface treatments; 

(c) Using stable lubricants. Of particular note, use of molybdenum disulfide (MoS2) as 

a lubricant has been shown to be a potential contributor to SCC and should not 

be used;

(d) Using bolting material for closure studs that has an actual measured yield strength 

less than 150 kilo-pounds per square inch (ksi) [1,034 megapascals (MPa)] for 

newly installed studs, or 170 ksi (1,172 MPa) ultimate tensile strength for 

existing studs.

Implementation of these mitigation measures can reduce potential for SCC or IGSCC, 

thus making this program effective.

3. Parameters Monitored or Inspected: The ASME Code Section XI ISI program detects 

and sizes cracks, detects loss of material, and detects coolant leakage by following the 

examination and inspection requirements specified in Table IWB-2500-1. 

4. Detection of Aging Effects: The extent and schedule of the inspection and test 

techniques prescribed by the program are designed to maintain structural integrity, to 

detect aging effects and to repair or replace components before the loss of intended 

function of the component. Inspection can reveal cracking, loss of material due to 

corrosion or wear, and leakage of coolant.

 

1GALL-SLR Report Chapter I, Table 1, identifies the ASME Code Section XI editions and addenda that are 

acceptable to use for this AMP.
XI.M3-2

The program uses visual, surface, and volumetric examinations in accordance with the 

general requirements of Subsection IWA-2000. Surface examination uses magnetic 

particle or liquid penetrant examinations to indicate the presence of surface discontinuities 

and flaws. Volumetric examination uses radiographic or ultrasonic examinations to 

indicate the presence of discontinuities or flaws throughout the volume of material. Visual 

VT-2 examination detects evidence of leakage from pressure-retaining components, as 

required during the system pressure test.

Components are examined and tested in accordance with ASME Code, Section XI, 

Table IWB-2500-1, Examination Category B-G-1, for pressure-retaining bolting greater 

than 2 inches in diameter. Examination Category B-P for all pressure-retaining 

components specifies visual VT-2 examination of all pressure-retaining boundary 

components during the system leakage test. Table IWB-2500-1 specifies the extent and 

frequency of the inspection and examination methods, and IWB-2400 specifies the 

schedule of the inspection.

5. Monitoring and Trending: The Inspection schedule of IWB-2400 and the extent 

and frequency of IWB-2500-1 provide timely detection of cracks, loss of material, 

and leakage.

6. Acceptance Criteria: Any indication or relevant condition of degradation in closure stud 

bolting is evaluated in accordance with IWB-3100 by comparing ISI results with the 

acceptance standards of IWB-3400 and IWB-3500.

7. Corrective Actions: Results that do not meet the acceptance criteria are addressed in 

the applicant’s corrective action program under those specific portions of the quality 

assurance (QA) program that are used to meet Criterion XVI, “Corrective Action,” of 

Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B. Appendix A of 

the Generic Aging Lessons Learned for Subsequent License Renewal (GALL-SLR) Report 

describes how an applicant may apply its 10 CFR Part 50, Appendix B, QA program to 

fulfill the corrective actions element of this aging management programs (AMP) for both 

safety-related and nonsafety-related structures and components (SCs) within the scope of 

this program.

Repair and replacement are performed in accordance with the requirements of IWA-4000 

and the material and inspection guidance of RG 1.65. The maximum yield strength of 

replacement material should be limited as recommended in RG 1.65

8. Confirmation Process: The confirmation process is addressed through those specific 

portions of the QA program that are used to meet Criterion XVI, “Corrective Action,” of 

10 CFR Part 50, Appendix B. Appendix A of the GALL-SLR Report describes how an 

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the confirmation 

process element of this AMP for both safety-related and nonsafety-related SCs within the 

scope of this program.

9. Administrative Controls: Administrative controls are addressed through the QA program 

that is used to meet the requirements of 10 CFR Part 50, Appendix B, associated with 

managing the effects of aging. Appendix A of the GALL-SLR Report describes how 

an applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the 

administrative controls element of this AMP for both safety-related and nonsafety-related 

SCs within the scope of this program.
XI.M3-3

10. Operating Experience: SCC has occurred in BWR pressure vessel head studs 

(Stoller, 1991). The AMP has provisions regarding inspection techniques and evaluation, 

material specifications, corrosion prevention, and other aspects of reactor pressure vessel 

head stud cracking. Implementation of the program provides reasonable assurance that 

the effects of cracking due to SCC or IGSCC and loss of material due to wear are 

adequately managed so that the intended functions of the reactor head closure studs and 

bolts are maintained consistent with the current licensing basis for the subsequent period 

of extended operation. Degradation of threaded bolting and fasteners in closures for the 

reactor coolant pressure boundary has occurred from boric acid corrosion, SCC, and 

fatigue loading (NRC Inspection and Enforcement Bulletin (IEB) 82-02, NRC Generic 

Letter 91-17).

The program is informed and enhanced when necessary through the systematic and 

ongoing review of both plant-specific and industry operating experience including research 

and development such that the effectiveness of the AMP is evaluated consistent with the 

discussion in Appendix B of the GALL-SLR Report.

References

10 CFR Part 50, Appendix B, “Quality Assurance Criteria for Nuclear Power Plants and Fuel 

Reprocessing Plants.” Washington, DC: U.S. Nuclear Regulatory Commission. 2016.

10 CFR 50.55a, “Codes and Standards.” Washington, DC: U.S. Nuclear Regulatory 

Commission. 2016.

ASME. ASME Code Section XI, “Rules for Inservice Inspection of Nuclear Power Plant 

Components.” New York, New York: The American Society of Mechanical Engineers. 2008.

2

NRC. Generic Letter 91-17, “Generic Safety Issue 29: Bolting Degradation or Failure in Nuclear 

Power Plants.” Washington, DC: U.S. Nuclear Regulatory Commission. October 1991.

_____. IE Bulletin 82-02, “Degradation of Threaded Fasteners in the Reactor Coolant Pressure 

Boundary of PWR Plants.” Washington, DC: U.S. Nuclear Regulatory Commission. June 1982.

_____. Regulatory Guide 1.65, “Material and Inspection for Reactor Vessel Closure Studs.” 

Revision 1. Washington, DC: U.S. Nuclear Regulatory Commission. April 2010.

Stoller, S.M. “Reactor Head Closure Stud Cracking, Material Toughness Outside FSAR–SCC in 

Thread Roots.” BWR-2, Ill, 58. Nuclear Power Experience. 1991.

 

2GALL-SLR Report Chapter I, Table 1, identifies the ASME Code Section XI editions and addenda that are 

acceptable to use for this AMP.

XI.M4-1

XI.M4 BWR VESSEL ID ATTACHMENT WELDS

Program Description

This program is a condition monitoring program for detecting cracking due to stress corrosion 

cracking (SCC), intergranular stress corrosion cracking (IGSCC), and cyclical loading 

mechanisms in the reactor vessel inside diameter (ID) attachment welds of boiling water reactors 

(BWRs). The program includes inspection and flaw evaluation in accordance with the 

requirements of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code 

(ASME Code), Section XI, and the guidance in “BWR Vessel and Internals Project, Vessel ID 

Attachment Weld Inspection and Flaw Evaluation Guidelines” [Boiling Water Reactor Vessel and 

Internals Project (BWRVIP)-48-A] to provide reasonable assurance of the long-term integrity and 

safe operation of BWR vessel ID attachment welds.

The guidance in BWRVIP-48-A includes inspection recommendations and evaluation 

methodologies for certain attachment welds between the vessel wall and the brackets that attach 

components to the vessel. In some cases, the attachment is a weld attached directly to the vessel 

wall; in other cases, the attachment includes a weld build-up pad on the vessel wall. The 

BWRVIP-48-A report includes information on the geometry of the vessel ID attachments; 

evaluates susceptible locations and the safety consequence of failure; provides recommendations 

regarding the method, extent, and frequency of augmented examinations; and discusses 

acceptable methods for evaluating the structural integrity significance of indications detected 

during examinations.

Evaluation and Technical Basis

1. Scope of Program: This program manages the effects of cracking caused by SCC, 

IGSCC, or cyclical loading mechanisms for those BWR vessel ID attachment welds that 

are covered by BWRVIP-48-A. The program is an augmented inservice inspection 

(ISI) program that uses the inspection and flaw evaluation criteria in BWRVIP-48-A 

to detect cracking and monitor the effects of cracking on the intended functions of 

these components.

2. Preventive Actions: This program is a condition monitoring program and has no 

preventive actions. To mitigate SCC and IGSCC, reactor coolant water chemistry is 

monitored and controlled in accordance with activities that meet the guidelines in Generic 

Aging Lessons Learned for Subsequent License Renewal (GALL-SLR) Report aging 

management program (AMP) XI.M2, “Water Chemistry.”

3. Parameters Monitored or Inspected: The program monitors for cracks caused by SCC, 

IGSCC, and cyclical loading mechanisms. Inspections performed in accordance with the 

guidance in BWRVIP-48-A and the requirements of the ASME Code, Section XI, 

Table IWB-2500-1 are used to interrogate the components for discontinuities that may 

indicate the presence of cracking. 

4. Detection of Aging Effects: The extent and schedule of the inspections prescribed by 

BWRVIP-48-A and ASME Code, Section XI, are designed to maintain structural integrity, 

to discover aging effects, and to repair or replace the component before a loss of intended 

function. The vessel ID attachment welds are visually examined in accordance with 

the requirements of ASME Code, Section XI, Table IWB-2500-1, Examination 

Category B-N-2. The inspection and evaluation guidelines of BWRVIP-48-A recommend 
XI.M4-2

more stringent inspections for certain attachment welds. The nondestructive examination 

techniques that are appropriate for the augmented examinations, including the 

uncertainties inherent in delivering and executing these techniques and applicable for 

inclusion in flaw evaluations, are included in BWRVIP-03.

5. Monitoring and Trending: Inspections scheduled in accordance with ASME Code, 

Section XI, Subarticle IWB-2400, and BWRVIP-48-A provide for the timely detection of 

cracking. If indications are detected, the scope of examination is expanded. Any 

indications are evaluated in accordance with ASME Code, Section XI, and the guidance in

BWRVIP-48-A. Guidance for the evaluation of crack growth in stainless steels, nickel 

alloys, and low-alloy steels is provided in BWRVIP-14-A, BWRVIP-59-A, and 

BWRVIP-60-A, respectively.

6. Acceptance Criteria: The relevant acceptance criteria are provided in BWRVIP-48-A and 

ASME Code, Section XI, Subarticle IWB-3520.

7. Corrective Actions: Results that do not meet the acceptance criteria are addressed in 

the applicant’s corrective action program under those specific portions of the quality 

assurance (QA) program that are used to meet Criterion XVI, “Corrective Action,” of 

Title 10 of the Code of Federal Regulation (10 CFR) Part 50, Appendix B. Appendix A of 

the GALL-SLR Report describes how an applicant may apply its 10 CFR Part 50, 

Appendix B, QA program to fulfill the corrective actions element of this AMP for both 

safety-related and nonsafety-related structures and components (SCs) within the scope of 

this program.

Repair and replacement activities are conducted in accordance with the guidance 

in BWRVIP-52-A.

8. Confirmation Process: The confirmation process is addressed through those specific 

portions of the QA program that are used to meet Criterion XVI, “Corrective Action,” of 

10 CFR Part 50, Appendix B. Appendix A of the GALL-SLR Report describes how an 

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the confirmation 

process element of this AMP for both safety-related and nonsafety-related SCs within the

scope of this program.

9. Administrative Controls: Administrative controls are addressed through the QA program 

that is used to meet the requirements of 10 CFR Part 50, Appendix B, associated with 

managing the effects of aging. Appendix A of the GALL-SLR Report describes how an 

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the 

administrative controls element of this AMP for both safety-related and nonsafety-related 

SCs within the scope of this program.

10. Operating Experience: Cracking due to SCC, IGSCC, and cyclical loading has occurred 

in BWR components. The program guidelines are based on an evaluation of available 

information, including BWR inspection data and information on the causes of SCC, 

IGSCC, and cracking due to cyclical loading, to determine which attachment welds may be 

susceptible to cracking from any of these mechanisms. Implementation of this program 

provides reasonable assurance that cracking will be adequately managed and that the 

intended functions of the vessel ID attachments will be maintained consistent with the 

current licensing basis for the subsequent period of extended operation.
XI.M4-3

The program is informed and enhanced when necessary through the systematic and 

ongoing review of both plant-specific and industry operating experience including research 

and development such that the effectiveness of the AMP is evaluated consistent with the 

discussion in Appendix B of the GALL-SLR Report.

References

10 CFR Part 50, Appendix B, “Quality Assurance Criteria for Nuclear Power Plants and Fuel 

Reprocessing Plants.” Washington, DC: U.S. Nuclear Regulatory Commission. 2016.

10 CFR 50.55a, “Codes and Standards.” Washington, DC: U.S. Nuclear Regulatory 

Commission. 2016.

ASME. ASME Code Section XI, “Rules for Inservice Inspection of Nuclear Power Plant 

Components.” New York, New York: The American Society of Mechanical Engineers. 2008.

1

EPRI. BWRVIP-03, Revision 6 (EPRI 105696-R6), “BWR Vessel and Internals Project, Reactor 

Pressure Vessel and Internals Examination Guidelines.” Palo Alto, California: Electric Power 

Research Institute. December 2003.

_____. BWRVIP-14-A (EPRI 1016569), “Evaluation of Crack Growth in BWR Stainless Steel 

RPV Internals.” Palo Alto, California: Electric Power Research Institute. September 2008. 

_____. BWRVIP-48-A (EPRI 1009948), “BWR Vessel and Internals Project, Vessel ID 

Attachment Weld Inspection and Flaw Evaluation Guidelines.” Palo Alto, California: Electric 

Power Research Institute. November 2004. 

_____. BWRVIP-52-A (EPRI 1012119), “BWR Vessel and Internals Project, Shroud Support and 

Vessel Bracket Repair Design Criteria.” Palo Alto, California: Electric Power Research Institute. 

September 2005.

_____. BWRVIP-59-A (EPRI 1014874), “Evaluation of Crack Growth in BWR Nickel-Base 

Austenitic Alloys in RPV Internals.” Palo Alto, California: Electric Power Research Institute.

May 2007.

_____. BWRVIP-60-A (EPRI 1008871), “BWR Vessel and Internals Project, Evaluation of Crack 

Growth in BWR Low Alloy Steel RPV Internals.” Palo Alto, California: Electric Power Research 

Institute. June 2003.

 

1GALL-SLR Report Chapter I, Table 1, identifies the ASME Code Section XI editions and addenda that are 

acceptable to use for this AMP.

XI.M5-1

XI.M5 DELETED

XI.M6-1

XI.M6 DELETED

XI.M7-1

XI.M7 BWR STRESS CORROSION CRACKING

Program Description

The program to manage intergranular stress corrosion cracking (IGSCC) in boiling water reactor 

(BWR) coolant pressure boundary piping made of stainless steel (SS) and nickel-based alloy 

components is delineated in NUREG–0313, Revision 2, and the U.S. Nuclear Regulatory 

Commission (NRC) Generic Letter (GL) 88-01 and its Supplement 1. The material includes base 

metal and welds. The comprehensive program outlined in NUREG–0313, Revision 2 and NRC 

GL 88-01 describes improvements that, in combination, will reduce the susceptibility to IGSCC. 

The elements to cause IGSCC consist of a susceptible–material, a significant tensile stress, and 

an aggressive environment. Sensitization of nonstabilized austenitic SSs containing greater than 

0.035 weight percent carbon involves precipitation of chromium carbides at the grain boundaries 

during certain fabrication or welding processes. The formation of carbides creates a chromiumdepleted region that, in certain environments, is susceptible to stress corrosion cracking (SCC). 

Residual tensile stresses are introduced from fabrication processes, such as welding, cold work, 

surface grinding, and forming. High levels of dissolved oxygen or aggressive contaminants, such 

as sulfates or chlorides, accelerate the SCC processes. The program includes (a) preventive 

measures to mitigate IGSCC and (b) inspection and flaw evaluation to monitor IGSCC and its 

effects. The staff-approved Boiling Water Reactor Vessel and Internals Project (BWRVIP)-75-A 

report allows for modifications to the inspection extent and schedule described in the NRC 

GL 88-01 program.

Evaluation and Technical Basis

1. Scope of Program: The program focuses on (a) managing and implementing 

countermeasures to mitigate IGSCC and (b) performing ISI to monitor IGSCC and its 

effects on the intended function of BWR piping components within the scope of license 

renewal. The program is applicable to all BWR piping and piping welds made of 

austenitic–SS and nickel alloy that are 4 inches or larger in nominal diameter containing 

reactor coolant at a temperature above 93 °C (Celsius) [200 °F (Fahrenheit)] during power 

operation, regardless of code classification. The program also applies to pump casings, 

valve bodies, and reactor vessel attachments and appurtenances, such as head spray and 

vent components. Control rod drive return line nozzle caps and associated welds 

(previously addressed in Generic Aging Lessons Learned (GALL) Report, Revision 2, 

AMP XI.M6, “BWR Control Rod Drive Return Line Nozzle”) may be included in the scope 

of the program. NUREG–0313, Revision 2 and NRC GL 88-01, respectively, describe the 

technical basis and staff guidance regarding mitigation of IGSCC in BWRs. Attachment A 

of NRC GL 88-01 delineates the staff-approved positions regarding materials, processes, 

water chemistry, weld overlay reinforcement, partial replacement, stress improvement of 

cracked welds, clamping devices, crack characterization and repair criteria, inspection 

methods and personnel, inspection schedules, sample expansion, leakage detection, and 

reporting requirements.

2. Preventive Actions: The BWR SCC program is primarily a condition monitoring program

which also relies on countermeasures. Maintaining high water purity reduces susceptibility 

to SCC or IGSCC. Reactor coolant water chemistry is monitored and maintained in 

accordance with the Water Chemistry program. The program description, evaluation and 

technical basis of water chemistry are addressed through implementation of the Generic 

Aging Lessons Learned for Subsequent License Renewal (GALL-SLR) Report 

AMP XI.M2, “Water Chemistry.” In addition, NUREG–0313, Revision 2 and GL 88-01 
XI.M7-2

delineate the guidance for selection of resistant materials and processes that provide 

resistance to IGSCC such as solution heat treatment and stress improvement processes.

3. Parameters Monitored or Inspected: The program detects and sizes cracks and 

detects leakage by using the examination and inspection guidelines delineated in 

NUREG–0313, Revision 2, and NRC GL 88-01. 

4. Detection of Aging Effects: The extent, method, and schedule of the inspection and test 

techniques delineated in NRC GL 88-01 are designed to maintain structural integrity, to 

detect and mitigate degradation, and to repair or replace components before the loss of 

intended function of the component. Modifications to the extent and schedule of 

inspection in NRC GL 88-01 are allowed in accordance with the inspection guidance in 

approved BWRVIP-75-A. The potential for stagnant flow conditions such as dead legs is 

considered when selecting inspection locations. The program identifies these locations. 

Prior to crediting hydrogen water chemistry to modify extent and frequency of inspections 

in accordance with BWRVIP-75-A, the applicant should meet conditions described in the 

staff’s safety evaluations regarding BWRVIP-62-A. The program uses volumetric 

examinations to detect IGSCC. Inspection can reveal cracking and leakage of coolant. 

The extent and frequency of inspection recommended by the program are based on the 

condition of each weld (e.g., whether the weldments were made from IGSCC-resistant 

material, whether a stress improvement process was applied to a weldment to reduce 

residual stresses, and how the weld was repaired, if it had been cracked).

5. Monitoring and Trending: The extent and schedule for inspection, in accordance with 

the recommendations of NRC GL 88-01 or approved BWRVIP-75-A guidelines, provide 

timely detection of cracks and leakage of coolant. Indications of cracking are evaluated 

and trended in accordance with the American Society of Mechanical Engineers Boiler and 

Pressure Vessel Code (ASME Code), Section XI, IWA-3000. 

Applicable and approved BWRVIP-14-A, BWRVIP-59-A, BWRVIP-60-A, and 

BWRVIP-62-A reports provide guidelines for evaluation of crack growth in SSs, nickel 

alloys, and low-alloy steels. An applicant may use BWRVIP-61 guidelines for BWR vessel 

and internals induction heating stress improvement effectiveness on crack growth in 

operating plants.

6. Acceptance Criteria: Any cracking is evaluated in accordance with ASME Code, 

Section XI, IWA-3000 by comparing inspection results with the acceptance standards of 

ASME Code, Section XI, IWB-3000, IWC-3000 and IWD-3000 for Class 1, 2 and 3 

components, respectively.

7. Corrective Actions: Results that do not meet the acceptance criteria are addressed in 

the applicant’s corrective action program under those specific portions of the quality

assurance (QA) program that are used to meet Criterion XVI, “Corrective Action,” of 

Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B. Appendix A of 

the GALL-SLR Report describes how an applicant may apply its 10 CFR Part 50, 

Appendix B, QA program to fulfill the corrective actions element of this aging management 

program (AMP) for both safety-related and nonsafety-related structures and components 

(SCs) within the scope of this program.

The guidance for weld overlay repair and stress improvement or replacement is provided 

in NRC GL 88-01. Corrective action is performed in accordance with IWA-4000.
XI.M7-3

8. Confirmation Process: The confirmation process is addressed through those specific 

portions of the QA program that are used to meet Criterion XVI, “Corrective Action,” of 

10 CFR Part 50, Appendix B. Appendix A of the GALL-SLR Report describes how an 

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the confirmation 

process element of this AMP for both safety-related and nonsafety-related SCs within the 

scope of this program.

9. Administrative Controls: Administrative controls are addressed through the QA program 

that is used to meet the requirements of 10 CFR Part 50, Appendix B, associated with 

managing the effects of aging. Appendix A of the GALL-SLR Report describes how 

an applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the 

administrative controls element of this AMP for both safety-related and nonsafety-related 

SCs within the scope of this program.

10. Operating Experience: Intergranular SCC has occurred in small- and large-diameter 

BWR piping made of austenitic–SS and nickel-base alloys. Cracking has occurred in 

recirculation, core spray, residual heat removal, control rod drive return line penetrations, 

and reactor water cleanup system piping welds (NRC GL 88-01 and NRC Information 

Notices 82-39, 84-41, and 2004-08). The comprehensive program outlined in NRC 

GL 88-01, NUREG–0313, Revision 2, and in the staff-approved BWRVIP-75-A report 

addresses mitigating measures for SCC or IGSCC (e.g., susceptible material, significant 

tensile stress, and an aggressive environment). The GL 88-01 program, with or without 

the modifications allowed by the staff-approved BWRVIP-75-A report, has been effective 

in managing IGSCC in BWR reactor coolant pressure-retaining components and will 

adequately manage IGSCC degradation.

The program is informed and enhanced when necessary through the systematic and 

ongoing review of both plant-specific and industry operating experience including research

and development such that the effectiveness of the AMP is evaluated consistent with the 

discussion in Appendix B of the GALL-SLR Report.

References

10 CFR Part 50, Appendix B, “Quality Assurance Criteria for Nuclear Power Plants and Fuel 

Reprocessing Plants.” Washington, DC: U.S. Nuclear Regulatory Commission. 2016.

10 CFR 50.55a, “Codes and Standards.” Washington, DC: U.S. Nuclear Regulatory 

Commission. 2016.

ASME. ASME Code Section XI, “Rules for Inservice Inspection of Nuclear Power Plant 

Components.” New York, New York: The American Society of Mechanical Engineers. 2008. 1

_____. ASME Code Case N-504-4, “Alternative Rules for Repair of Class 1, 2, and 3 Austenitic 

Stainless Steel Piping.” Section XI, Division 1. New York, New York: American Society of 

Mechanical Engineers. July 2006.

 

1GALL-SLR Report Chapter I, Table 1, identifies the ASME Code Section XI editions and addenda that are 

acceptable to use for this AMP.
XI.M7-4

EPRI. BWRVIP-14-A (EPRI 1016569), “BWR Vessel and Internals Project, Evaluation of 

Crack Growth in BWR Stainless Steel RPV Internals.” Palo Alto, California: Electric Power 

Research Institute. September 2008. 

_____. BWRVIP-59-A, (EPRI 1014874), “BWR Vessel and Internals Project, Evaluation of Crack 

Growth in BWR Nickel-Base Austenitic Alloys in RPV Internals.” Palo Alto, California: Electric 

Power Research Institute. May 2007.

_____. BWRVIP-60-A (EPRI 108871), “BWR Vessel and Internals Project, Evaluation of Stress 

Corrosion Crack Growth in Low Alloy Steel Vessel Materials in the BWR Environment.” Palo Alto, 

California: Electric Power Research Institute. June 2003.

_____. BWRVIP-61 (EPRI 112076), “BWR Vessel and Internals Induction Heating Stress 

Improvement Effectiveness on Crack Growth in Operating Reactors.” Palo Alto, California: 

Electric Power Research Institute. January 1999.

_____. BWRVIP-62-A (EPRI-1021006), “BWR Vessel and Internals Project, Technical Basis for 

Inspection Relief for BWR Internal Components with Hydrogen Injection.” Palo Alto, California: 

Electric Power Research Institute. November 2010.

_____. BWRVIP-75-A (EPRI 1012621), “BWR Vessel and Internals Project, Technical Basis for 

Revisions to Generic Letter 88-01 Inspection Schedules (NUREG–0313).” Palo Alto, California: 

Electric Power Research Institute. October 2005.

NRC. Generic Letter 88-01, “NRC Position on IGSCC in BWR Austenitic Stainless Steel Piping.” 

Washington, DC: U.S. Nuclear Regulatory Commission. January 25, 1988; Supplement 1, 

February 1992.

_____. Information Notice 04-08, “Reactor Coolant Pressure Boundary Leakage Attributable to 

Propagation of Cracking in Reactor Vessel Nozzle Welds.” Washington, DC: U.S. Nuclear 

Regulatory Commission. April 2004.

_____. Information Notice 82-39, “Service Degradation of Thick Wall Stainless Steel 

Recirculation System Piping at a BWR Plant.” Washington, DC: U.S. Nuclear Regulatory 

Commission. September 1982.

_____. Information Notice 84-41, “IGSCC in BWR Plants.” Washington, DC: U.S. Nuclear 

Regulatory Commission. June 1984.

_____. NUREG–0313, “Technical Report on Material Selection and Processing Guidelines for 

BWR Coolant Pressure Boundary Piping.” Revision 2. Washington DC: U.S. Nuclear Regulatory 

Commission. 1988.
XI.M8-1

XI.M8 BWR PENETRATIONS

Program Description

The program for boiling water reactor (BWR) vessel instrumentation penetrations, control rod 

drive (CRD) housing and incore-monitoring housing (ICMH) penetrations and standby liquid 

control (SLC) nozzles/Core ΔP nozzles includes inspection and flaw evaluation in conformance 

with the guidelines of staff-approved Boiling Water Reactor Vessel and Internals Project 

(BWRVIP) Topical Reports BWRVIP-49-A, BWRVIP-47-A and BWRVIP-27-A. The program 

manages cracking due to cyclic loading, stress corrosion cracking (SCC) and intergranular stress 

corrosion cracking (IGSCC) for these BWR vessel penetrations and nozzles. The inspection and 

evaluation guidelines of BWRVIP-49-A, BWRVIP-47-A, and BWRVIP-27-A contain generic 

guidelines intended to present appropriate inspection recommendations to assure safety function 

integrity. The guidelines of BWRVIP-49-A provide information on the type of instrument 

penetration, evaluate their susceptibility and consequences of failure, and define the inspection 

strategy to assure safe operation. The guidelines of BWRVIP-47-A provide information on 

components located in the lower plenum region of BWRs, evaluate their susceptibility and 

consequences of failure, and define the inspection strategy to assure safe operation. The 

guidelines of BWRVIP-27-A are applicable to plants in which the SLC system injects sodium 

pentaborate into the bottom head region of the vessel (in most plants, as a pipe within a pipe of 

the core plate ∆P monitoring system). The BWRVIP-27-A guidelines address the region where 

the ∆P and SLC nozzle or housing penetrates the vessel bottom head and include the safe 

ends welded to the nozzle or housing. Guidelines for repair design criteria are provided in 

BWRVIP-57-A for instrumentation penetrations, BWRVIP-55-A for CRD housing and ICMH

penetrations and BWRVIP-53-A for SLC line.

Although this is a condition monitoring program, control of water chemistry helps prevent SCC and 

IGSCC. The water chemistry program for BWRs relies on monitoring and control of reactor water 

chemistry based on industry guidelines, such as BWRVIP-190 (EPRI 1016579) or later revisions. 

BWRVIP-190 has three sets of guidelines: (i) one for primary water, (ii) one for condensate and 

feedwater, and (iii) one for CRD mechanism cooling water. Adequate aging management 

activities for these components provide reasonable assurance of the long-term integrity and safe 

operation of BWR vessel instrumentation nozzles, CRD housing and ICMH penetrations and SLC 

nozzles/Core ΔP nozzles.

Evaluation and Technical Basis

1. Scope of Program: The scope of this program is applicable to BWR instrumentation 

penetrations, CRD housing and ICMH penetrations and BWR SLC nozzles/Core ΔP 

nozzles. The program manages cracking due to cyclic loading or SCC and IGSCC using 

inspection and flaw evaluation in accordance with the guidelines of staff-approved 

BWRVIP-49-A, BWRVIP-47-A and BWRVIP-27-A.

2. Preventive Actions: This program is a condition monitoring program and has no 

preventive actions. However, maintaining high water purity reduces susceptibility to SCC 

or IGSCC. The program description, evaluation, and technical basis of water chemistry 

are presented in the Generic Aging Lessons Learned for Subsequent License Renewal 

(GALL-SLR) Report aging management program (AMP) XI.M2, “Water Chemistry.”
XI.M8-2

3. Parameters Monitored or Inspected: The program manages the effects of cracking due 

to SCC/IGSCC on the intended function of the BWR instrumentation nozzles, CRD 

housing and ICMH penetrations, and BWR SLC nozzles/Core ΔP nozzles. The program 

monitors for evidence of surface-breaking linear discontinuities if a visual inspection 

technique is used or for relevant flaw signals if a volumetric ultrasonic testing (UT) method 

is used. In addition, the program includes visual examination to confirm the absence 

of leakage.

4. Detection of Aging Effects: The inspection guidelines of BWRVIP-49-A, BWRVIP-47-A,

and BWRVIP-27-A, along with the existing inspection requirements in American Society of 

Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code), Section XI, 

Table IWB-2500-1, are sufficient to monitor for indications of cracking in BWR 

instrumentation nozzles, CRD housing and ICMH penetrations and BWR SLC 

nozzles/Core ΔP nozzles, and should continue to be followed for the subsequent period of 

extended operation. The extent and schedule of the inspection and test techniques 

prescribed by the staff-approved BWRVIP inspection guidelines and the ASME Code, 

Section XI program are designed to maintain structural integrity, to detect aging effects, 

and to perform repair or replacement before the loss of intended function of the 

component. 

Instrument penetrations, CRD housing and ICMH penetrations and SLC system nozzles or 

housings are inspected in accordance with the staff-approved BWRVIP inspection 

guidelines and the requirements in the ASME Code, Section XI. These examination 

categories include volumetric examination methods (UT or radiography testing), surface 

examination methods (liquid penetrant testing or magnetic particle testing), and VT-2 

visual examination methods. 

5. Monitoring and Trending: Inspections scheduled in accordance with ASME Code, 

Section XI, IWB-2400 and approved BWRVIP-49-A, BWRVIP-47-A, or BWRVIP-27-A 

provides timely detection of cracks. The scope of examination and reinspection is 

expanded beyond the baseline inspection if flaws are detected. Any indication detected is 

evaluated in accordance with ASME Code, Section XI or other acceptable flaw evaluation 

criteria, such as the staff-approved BWRVIP-49-A, BWRVIP-47-A, or BWRVIP-27-A 

guidelines. Applicable and approved BWRVIP-14-A, BWRVIP-59-A, and BWRVIP-60-A 

documents provide additional guidelines for the evaluation of crack growth in stainless 

steels (SSs), nickel alloys, and low-alloy steels, respectively.

6. Acceptance Criteria: Acceptance criteria are given in BWRVIP-49-A for instrumentation 

nozzles, BWRVIP-47-A for CRD housing and ICMH penetrations, and BWRVIP-27-A for 

BWR SLC nozzles/Core ΔP nozzles.

7. Corrective Actions: Results that do not meet the acceptance criteria are addressed in 

the applicant’s corrective action program under those specific portions of the quality 

assurance (QA) program that are used to meet Criterion XVI, “Corrective Action,” of 

10 CFR Part 50, Appendix B. Appendix A of the GALL-SLR Report describes how an 

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the corrective 

actions element of this AMP for both safety-related and nonsafety-related structures and 

components (SCs) within the scope of this program.
XI.M8-3

Corrective actions include repair and replacement procedures in staff-approved 

BWRVIP-57-A, BWRVIP-55-A, BWRVIP-58-A and BWRVIP-53-A that are equivalent to 

those required in ASME Code, Section XI. Guidelines for repair design criteria are 

provided in BWRVIP-57-A for instrumentation penetrations, BWRVIP-55-A for CRD 

housing and ICMH penetrations, and BWRVIP-53-A for SLC line. BWRVIP-58-A provides 

guidelines for internal access weld repair for CRD penetrations.

8. Confirmation Process: The confirmation process is addressed through those specific 

portions of the QA program that are used to meet Criterion XVI, “Corrective Action,” of 

10 CFR Part 50, Appendix B. Appendix A of the GALL-SLR Report describes how an 

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the confirmation 

process element of this AMP for both safety-related and nonsafety-related SCs within the 

scope of this program.

The staff finds that licensee implementation of the guidelines in BWRVIP-49-A, 

BWRVIP-47-A, and BWRVIP-27-A, as modified, provides an acceptable level of quality for 

inspection and flaw evaluation of the safety-related components addressed in accordance 

with the 10 CFR Part 50, Appendix B confirmation process and administrative controls.

9. Administrative Controls: Administrative controls are addressed through the QA program 

that is used to meet the requirements of 10 CFR Part 50, Appendix B, associated with 

managing the effects of aging. Appendix A of the GALL-SLR Report describes how an 

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the 

administrative controls element of this AMP for both safety-related and nonsafety-related 

SCs within the scope of this program.

10. Operating Experience: Cracking due to SCC or IGSCC has occurred in BWR 

components made of austenitic SSs and nickel alloys. The program guidelines are based 

on an evaluation of available information, including BWR inspection data and information 

about the elements that cause IGSCC, to determine which locations may be susceptible to 

cracking. Implementation of the program provides reasonable assurance that cracking will 

be adequately managed so the intended functions of the instrument penetrations and SLC 

system nozzles or housings will be maintained consistent with the CLB for the subsequent 

period of extended operation.

The program is informed and enhanced when necessary through the systematic and 

ongoing review of both plant-specific and industry operating experience including research

and development such that the effectiveness of the AMP is evaluated consistent with the 

discussion in Appendix B of the GALL-SLR Report.

References

10 CFR Part 50, Appendix B, “Quality Assurance Criteria for Nuclear Power Plants and Fuel 

Reprocessing Plants.” Washington, DC: U.S. Nuclear Regulatory Commission. 2016.

10 CFR 50.55a, “Codes and Standards.” Washington, DC: U.S. Nuclear Regulatory 

Commission. 2016.
XI.M8-4

ASME. ASME Code Section XI, “Rules for Inservice Inspection of Nuclear Power Plant 

Components.” New York, New York: The American Society of Mechanical Engineers. 2008.

1

EPRI. BWRVIP-14-A (EPRI 1016569), “BWR Vessel and Internals Project, Evaluation of Crack 

Growth in BWR Stainless Steel RPV Internals.” Palo Alto, California: Electric Power Research 

Institute. September 2008. 

_____. BWRVIP-27-A (EPRI 1007279), “BWR Vessel and Internals Project, BWR Standby Liquid 

Control System/Core Plate ∆P Inspection and Flaw Evaluation Guidelines.” Palo Alto, California: 

Electric Power Research Institute. August 2003.

_____. BWRVIP-47-A (EPRI 1009947), “BWR Vessel and Internals Project, BWR Lower Plenum 

Inspection and Flaw Evaluation Guidelines.” Palo Alto, California: Electric Power Research 

Institute. November 2004.

_____. BWRVIP-49-A (EPRI 1006602), “BWR Vessel and Internals Project, Instrument 

Penetration Inspection and Flaw Evaluation Guidelines.” Palo Alto, California: Electric Power 

Research Institute. 2002.

_____. BWRVIP-53-A (EPRI 1012120), “BWR Vessel and Internals Project, Standby Liquid 

Control Line Repair Design Criteria.” Palo Alto, California: Electric Power Research Institute. 

September 2005.

_____. BWRVIP-55-A (EPRI 1012117), “BWR Vessel and Internals Project, Lower Plenum 

Repair Design Criteria.” Palo Alto, California: Electric Power Research Institute. 

September 2005.

_____. BWRVIP-57-A (EPRI 1012111), “BWR Vessel and Internals Project, Instrument 

Penetration Repair Design Criteria.” Palo Alto, California: Electric Power Research Institute. 

September 2005.

_____. BWRVIP-58-A (EPRI 1012618), “BWR Vessel and Internals Project, CRD Internal Access 

Weld Repair.” Palo Alto, California: Electric Power Research Institute. October 2005.

_____. BWRVIP-59-A (EPRI 1014874), “BWR Vessel and Internals Project, Evaluation of Crack 

Growth in BWR Nickel-Base Austenitic Alloys in RPV Internals.” Palo Alto, California: Electric 

Power Research Institute. May 2007.

_____. BWRVIP-60-A (EPRI 1008871), “BWR Vessel and Internals Project, Evaluation of Stress 

Corrosion Crack Growth in Low Alloy Steel Vessel Materials in the BWR Environment.” Palo Alto, 

California: Electric Power Research Institute. June 2003.

_____. BWRVIP-190 (EPRI 1016579), “BWR Vessel and Internals Project, BWR Water 

Chemistry Guidelines-2008.” Palo Alto, California: Electric Power Research Institute. 

October 2008.

 

1GALL-SLR Report Chapter I, Table 1, identifies the ASME Code Section XI editions and addenda that are 

acceptable to use for this AMP.
XI.M9-1

XI.M9 BWR VESSEL INTERNALS

Program Description

The program includes inspection and flaw evaluations in conformance with the guidelines of 

applicable and staff-approved Boiling Water Reactor Vessel and Internals Project (BWRVIP) 

documents to provide reasonable assurance of the long-term integrity and safe operation of 

boiling water reactor (BWR) vessel internal components. The program manages the effects of 

cracking due to stress corrosion cracking (SCC), intergranular stress corrosion cracking (IGSCC), 

or irradiation-assisted stress corrosion cracking (IASCC), cracking due to cyclic loading (including 

flow-induced vibration), loss of material due to wear, loss of fracture toughness due to neutron or 

thermal embrittlement, and loss of preload due to thermal or irradiation-enhanced stress 

relaxation.

The BWRVIP documents provide generic guidelines intended to present the applicable inspection 

recommendations to assure safety function integrity of the subject safety-related reactor pressure 

vessel internal components. The guidelines provide information on component description 

and function; evaluate susceptible locations and safety consequences of failure; provide 

recommendations for methods, extent, and frequency of inspection; discuss acceptable methods 

for evaluating the structural integrity significance of flaws detected during these examinations; and 

recommend repair and replacement procedures.

In addition, this program provides screening criteria to determine the susceptibility of cast 

austenitic stainless steel (CASS) components to thermal aging on the basis of casting method, 

molybdenum content, and percent ferrite, in accordance with the criteria set forth in the 

May 19, 2000 letter from Christopher Grimes, U.S. Nuclear Regulatory Commission (NRC), to 

Mr. Douglas Walters, Nuclear Energy Institute (NEI). The susceptibility to thermal aging 

embrittlement of CASS components is determined in terms of casting method, molybdenum 

content, and ferrite content. For low-molybdenum content steels (SA-351 Grades CF3, CF3A, 

CF8, CF8A, or other steels with ≤0.5 percent molybdenum), only static-cast steels with 

>20 percent ferrite are potentially susceptible to thermal embrittlement. Static-cast 

low-molybdenum steels with ≤20 percent ferrite and all centrifugal-cast low-molybdenum steels 

are not susceptible. For high-molybdenum content steels (SA-351 Grades CF3M, CF3MA, CF8M 

or other steels with 2.0 to 3.0 percent molybdenum), static-cast steels with >14 percent ferrite and 

centrifugal-cast steels with >20 percent ferrite are potentially susceptible to thermal embrittlement. 

Static-cast high-molybdenum steels with ≤14 percent ferrite and centrifugal-cast highmolybdenum steels with ≤20 percent ferrite are not susceptible. In the susceptibility screening 

method, ferrite content is calculated by using the Hull’s equivalent factors (described in 

NUREG/CR–4513, Revision 1) or a staff-approved method for calculating delta ferrite in CASS 

materials. A subsequent license renewal (SLR) applicant may use alternative staff-approved 

screening criteria in determining susceptibility of CASS to neutron and thermal embrittlement

(e.g., screening criteria approved in the June 22, 2016, safety evaluation regarding BWRVIP-234).

The screening criteria are applicable to all cast stainless steel (SS) primary pressure boundary 

and reactor vessel internal components with service conditions above 250 °C (Celsius) [482 °F

(Fahrenheit)]. The screening criteria for susceptibility to thermal aging embrittlement are not 

applicable to niobium-containing steels; such steels require evaluation on a case-by-case basis. 

For “potentially susceptible” components, the program considers loss of fracture toughness due to 

neutron embrittlement or thermal aging embrittlement.
XI.M9-2

This aging management program (AMP) addresses aging degradation of nickel alloy and SS that 

are used in BWR vessel internal components. When exposed to the BWR vessel environment, 

these materials can experience neutron embrittlement and a decrease in fracture toughness. 

CASS, PH martensitic SS (e.g., 15-5 and 17-4 PH steel) and martensitic SS (e.g., 403, 410, 431 

steel) are also susceptible to thermal embrittlement. Effects of thermal or neutron embrittlement 

can cause failure of these materials in vessel internal components. In addition, nickel alloy in a 

BWR environment is susceptible to IGSCC.

Evaluation and Technical Basis

1. Scope of Program: The program is focused on managing the effects of cracking due to 

SCC, IGSCC, or IASCC, cracking due to cyclic loading (including flow-induced vibration)

and loss of material due to wear. This program also manages loss of fracture toughness 

due to neutron or thermal embrittlement and loss of preload due to thermal or irradiationenhanced stress relaxation. The program applies to wrought and cast reactor vessel 

internal components. The program contains inservice inspection (ISI) to monitor the 

effects of cracking on the intended function of the components, uses staff-approved 

BWRVIP reports as the basis for inspection, evaluation, repair and/or replacement, as 

needed, and evaluates the susceptibility of nickel alloy, CASS, PH martensitic SS 

(e.g., 15-5 and 17-4 PH steel), martensitic SS (e.g., 403, 410, 431 steel) and other SS 

(e.g., 304 steel) components to neutron or thermal embrittlement.

The scope of the program includes the following BWR reactor vessel (RV) and RV internal 

components as subject to the following staff-approved applicable BWRVIP guidelines:

Core shroud: BWRVIP-76-A provides guidelines for inspection and evaluation; 

BWRVIP-02-A, Revision 2, provides guidelines for repair design criteria.

Core plate: BWRVIP-25 provides guidelines for inspection and evaluation; BWRVIP-50-A 

provides guidelines for repair design criteria.

Core spray: BWRVIP-18, Revision 1-A provides guidelines for inspection and evaluation; 

BWRVIP-16-A and BWRVIP-19-A provide guidelines for replacement and repair design 

criteria, respectively.

Shroud support: BWRVIP-38 provides guidelines for inspection and evaluation; 

BWRVIP-52-A provides guidelines for repair design criteria.

Jet pump assembly: BWRVIP-41 and BWRVIP-138, Revision 1-A, provide guidelines for 

inspection and evaluation; BWRVIP-51-A provides guidelines for repair design criteria.

Low-pressure coolant injection coupling: BWRVIP-42-A provides guidelines for inspection 

and evaluation; BWRVIP-56-A provides guidelines for repair design criteria.

Top guide: BWRVIP-26-A and BWRVIP-183 provide guidelines for inspection and 

evaluation; BWRVIP-50-A provides guidelines for repair design criteria. The program 

includes inspection of 10 percent of the top guide locations using enhanced visual 

technique (EVT-1) or ultrasonic testing every 12 years with at least 5 percent inspected 

within the first 6 years of each 12-year interval.
XI.M9-3

Reinspection Criteria:

BWR/2-5–Inspect 10 percent of the grid beam cells containing control rod drives/blades 

every 12 years with at least 5 percent to be performed within 6 years.

BWR/6–Inspect the rim areas containing the weld and heat affected zone from the top 

surface of the top guide and two cells in the same plane/axis as the weld every 6 years.

The top guide inspection locations are those that have high neutron fluence exceeding the 

IASCC threshold. The extent of the examination and its frequency will be based on a 

10 percent sample of the total population, which includes all grid beam and beam-to-beam 

crevice slots.

Control rod drive housing and lower plenum components (reactor vessel internal 

components): BWRVIP-47-A provides guidelines for inspection and evaluation; 

BWRVIP-55-A provides guidelines for repair design criteria. 

Steam dryer: BWRVIP-139-A provides guidelines for inspection and evaluation for the 

steam dryer components; BWRVIP-18, Revision 1-A provides guidelines for repair 

design criteria.

In addition, BWRVIP-180 provides guidelines for inspection and flaw evaluation of access 

hole covers and BWRVIP-217 provides guidelines for repair design criteria for these 

components.

2. Preventive Actions: The BWRVIP is a condition monitoring program and has no 

preventive actions. Maintaining high water purity reduces susceptibility to SCC or IGSCC. 

Reactor coolant water chemistry is monitored and maintained in accordance with the 

Water Chemistry program. The program description, evaluation and technical basis of 

water chemistry are presented in Generic Aging Lessons Learned for Subsequent License 

Renewal (GALL-SLR) Report AMP XI.M2, “Water Chemistry.” 

3. Parameters Monitored or Inspected: The program manages the effects of aging on the 

intended function of the component by inspecting for cracking and loss of material in 

accordance with the guidelines of applicable and staff-approved BWRVIP documents and 

the requirements of the American Society of Mechanical Engineers Boiler and Pressure 

Vessel Code (ASME Code), Section XI, Table IWB 2500-1.

Loss of fracture toughness due to neutron embrittlement in CASS materials can occur with 

a neutron fluence greater than 1 × 1017 n/cm2 [E>1 MeV]. Loss fracture toughness of 

CASS material due to thermal embrittlement is dependent on the material’s casting 

method, molybdenum content, and ferrite content in accordance with the criteria set forth 

in the May 19, 2000, letter from Christopher Grimes, U.S. Nuclear Regulatory Commission 

(NRC), to Mr. Douglas Walters, Nuclear Energy Institute (NEI). A subsequent license 

renewal applicant may use alternative staff-approved screening criteria in determining 

susceptibility of CASS to neutron and thermal embrittlement (e.g., screening criteria 

approved in the June 22, 2016, safety evaluation regarding BWRVIP-234). This program 

does not directly monitor for loss of fracture toughness that is induced by thermal aging or 

neutron irradiation embrittlement. The impact of loss of fracture toughness on component 

integrity is indirectly managed by using visual or volumetric examination techniques to 

monitor for cracking in the components. 
XI.M9-4

Loss of fracture toughness due to neutron or thermal embrittlement cannot be identified 

by typical ISI activities. However, by performing visual or other inspections, applicants 

can identify cracks that could lead to failure of a potentially embrittled component 

prior to component failure. Applicants can thus indirectly manage the effects of 

embrittlement in the nickel alloy and SS components by identifying aging degradation 

(i.e., cracks), implementing early corrective actions, and monitoring and trending 

age-related degradation.

This program also manages loss of preload due to thermal or irradiation-enhanced stress 

relaxation for core plate rim holddown bolts and jet pump assembly holddown beam bolts 

by performing visual inspections or stress analyses for adequate structural integrity.

4. Detection of Aging Effects: The extent and schedule of the inspection and test 

techniques prescribed by the applicable and staff-approved BWRVIP guidelines are 

designed to maintain structural integrity, to detect aging effects, and to perform repair or 

replacement before the loss of intended function of BWR vessel internals. Vessel internal 

components are inspected in accordance with the requirements of ASME Code 

Section XI, Subsection IWB, Table IWB-2500-1, Examination Category B-N-2 for core 

support structures, and Examination Category B-N-1 for reactor vessel internal 

components. This inspection specifies visual VT-3 examination to determine the general 

mechanical and structural condition of the component supports by (a) verifying 

parameters, such as clearances, settings, and physical displacements and (b) detecting 

discontinuities and imperfections, such as loss of integrity at bolted or welded connections, 

loose or missing parts, debris, corrosion, wear, or erosion. BWRVIP program 

requirements provide for inspection of BWR internals to manage loss of material and 

cracking using appropriate examination techniques such as visual examinations 

(e.g., EVT-1, VT-1) and volumetric examinations (e.g., ultrasonic testing).

The applicable and staff-approved BWRVIP guidelines recommend more stringent 

inspections, such as EVT-1 examinations or ultrasonic methods of volumetric inspection, 

for certain selected components and locations. The nondestructive examination (NDE) 

techniques appropriate for inspection of BWR vessel internals, including the uncertainties 

inherent in delivering and executing NDE techniques in a BWR are included in 

BWRVIP-03.

Loss of fracture toughness due to neutron or thermal embrittlement is indirectly managed 

by performing periodic visual inspections capable of detecting cracks in the components. 

This program also determines whether supplemental inspections are necessary in addition 

to the existing BWRVIP examination guidelines to manage loss of fracture toughness for 

nickel alloy and SS internals, including welds. If supplemental inspections are determined 

necessary for BWR vessel internals, the program identifies the components to be 

inspected and performs supplemental inspections to adequately manage loss of fracture 

toughness due to neutron or thermal embrittlement. This evaluation for supplemental 

inspections is based on neutron fluence, thermal aging susceptibility, fracture toughness, 

and cracking susceptibility (i.e., applied stress, operating temperature, and environmental 

conditions). This program further determines whether supplemental inspections are 

necessary to manage cracking due to IASCC for nickel alloy and SS internals, including 

welds. This evaluation is based on neutron fluence and cracking susceptibility. If 

determined necessary, the program performs the supplemental inspections on the internal 

components identified in the evaluation.
XI.M9-5

The inspection technique is capable of detecting the critical flaw size with adequate 

margin. The critical flaw size is determined based on the service loading condition and 

service-degraded material properties. One example of a supplemental examination is 

VT-1 examination of ASME Code, Section XI, IWA-2210. The initial inspection is 

performed either prior to or within 5 years after entering the subsequent period of 

extended operation. 

If cracking is detected after the initial inspection, the frequency of reinspection should be 

justified by the applicant based on fracture toughness properties appropriate for the 

condition of the component. The sample size is 100 percent of the accessible component 

population, excluding components that may be in compression during normal operations.

5. Monitoring and Trending: Inspections are scheduled in accordance with the applicable 

and staff-approved BWRVIP guidelines provide timely detection of cracks. Each BWRVIP 

guideline recommends baseline inspections that are used as part of data collection 

towards trending. The BWRVIP guidelines provide recommendations for expanding the 

sample scope and reinspecting the components if flaws are detected. Any indication 

detected is evaluated in accordance with ASME Code, Section XI or the applicable 

BWRVIP guidelines. BWRVIP-14-A, BWRVIP-59-A, BWRVIP-60-A, BWRVIP-80-A and 

BWRVIP-99-A documents provide additional guidelines for evaluation of crack growth in 

SSs, nickel alloys, and low-alloy steels. BWRVIP-100-A describes flaw evaluation 

methodologies and fracture toughness data for SS core shroud exposed to neutron 

irradiation.

Inspections scheduled in accordance with ASME Code, Section XI, IWB-2400 and reliable 

examination methods provide timely detection of cracks. The fracture toughness of 

precipitation-hardened (PH)-martensitic steels, martensitic SSs, and nickel alloys 

susceptible to thermal or neutron embrittlement need to be assessed on a case-by-case 

basis.

6. Acceptance Criteria: Acceptance criteria are given in the applicable staff-approved 

BWRVIP documents and ASME Code, Section XI. Flaws detected in the reactor vessel 

internals are evaluated in accordance with the procedures in the applicable staff-approved 

BWRVIP documents and ASME Code, Section XI.

7. Corrective Actions: Results that do not meet the acceptance criteria are addressed in 

the applicant’s corrective action program under those specific portions of the quality 

assurance (QA) program that are used to meet Criterion XVI, “Corrective Action,” of 

Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B. Appendix A of 

the GALL-SLR Report describes how an applicant may apply its 10 CFR Part 50, 

Appendix B, QA program to fulfill the corrective actions element of this AMP for both 

safety-related and nonsafety-related structures and components (SCs) within the scope of 

this program.

Repair and replacement procedures are equivalent to those requirements in ASME Code 

Section XI. Repair and replacement is performed in conformance with applicable 

staff-approved BWRVIP guidelines. Guidelines for performing weld repairs to irradiated 

internals are described in BWRVIP-97-A. In addition, for core shroud repairs or other 

IGSCC repairs, the program maintains operating tensile stresses below a threshold limit 

that mitigates IGSCC of X-750 material in accordance with the guidelines in BWRVIP-84, 
XI.M9-6

Revision 2. For top guides where cracking is observed, sample size and inspection 

frequencies are increased in accordance with the BWRVIP guidelines.

8. Confirmation Process: The confirmation process is addressed through those specific 

portions of the QA program that are used to meet Criterion XVI, “Corrective Action,” of 

10 CFR Part 50, Appendix B. Appendix A of the GALL-SLR Report describes how 

an applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the 

confirmation process element of this AMP for both safety-related and nonsafety-related 

SCs within the scope of this program.

9. Administrative Controls: Administrative controls are addressed through the QA program 

that is used to meet the requirements of 10 CFR Part 50, Appendix B, associated with 

managing the effects of aging. Appendix A of the GALL-SLR Report describes how an 

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the 

administrative controls element of this AMP for both safety-related and nonsafety-related 

SCs within the scope of this program.

10. Operating Experience: There is documentation of cracking in both the circumferential 

and axial core shroud welds, and in shroud supports. Extensive cracking of 

circumferential core shroud welds has been documented in NRC Generic Letter 

(GL) 94-03 and extensive cracking in vertical core shroud welds has been documented in 

NRC Information Notice (IN) 97-17. It has affected shrouds fabricated from Type 304 and 

Type 304L SS, which is generally considered to be more resistant to SCC. Weld regions 

are most susceptible to SCC, although it is not clear whether this is due to sensitization 

and/or impurities associated with the welds or the high residual stresses in the weld 

regions. This experience is reviewed in NRC GL 94-03 and NUREG–1544; some 

experiences with visual inspections are discussed in NRC IN 94-42. In addition, IASCC 

was observed in the core shroud beltline region and IGSCC was observed in core shroud 

tie rod upper supports made of X-750 alloy (BWRVIP-76-A).

Both circumferential (NRC IN 88-03) and radial cracking (NRC IN 92-57) have been 

observed in the shroud support access hole covers that are made from Alloy 600. 

Instances of cracking in core spray spargers have been reviewed in NRC Inspection and 

Enforcement Bulletin (IEB) 80-13, and cracking in core spray pipe has been reviewed in 

BWRVIP-18, Revision 1-A.

Cracking of the core plate has not been reported, but the creviced regions beneath the 

plate are difficult to inspect. BWRVIP-06, Revision 1-A and BWRVIP-25 address the 

safety significance and inspection requirements for the core plate assembly. Only

inspection of core plate bolts (for plants without retaining wedges) or inspection of the 

retaining wedges is required. NRC IN 95-17 discusses cracking in top guides of 

United States and overseas BWRs. Related experience in other components is reviewed 

in NRC GL 94-03 and NUREG–1544. Cracking has also been observed in the top guide 

of a Swedish BWR.

Instances of cracking have occurred in the jet pump assembly (NRC IEB 80-07), 

hold-down beam (NRC IN 93-101), and jet pump riser pipe elbows (NRC IN 97-02). 

Cracking of dry tubes has been observed at 14 or more BWRs. The cracking is 

intergranular and has been observed in dry tubes without apparent sensitization, 

suggesting that IASCC may also play a role in the cracking.
XI.M9-7

Two control rod drive mechanism lead screw male couplings were fractured in a 

pressurized water reactor (PWR), designed by Babcock & Wilcox, at Oconee 

Nuclear Station, Unit 3. The fracture was due to thermal embrittlement of 

17-4 precipitation-hardened (PH) material (NRC IN 2007-02). While this occurred at a 

PWR, it also needs to be considered for BWRs.

IGSCC in the X-750 materials of a tie rod coupling and jet pump hold-down beam was 

observed in a domestic plant.

The program guidelines outlined in applicable staff-approved BWRVIP documents are 

based on an evaluation of available information, including BWR inspection data and 

information on the elements that cause SCC, IGSCC, or IASCC, to determine which 

components may be susceptible to cracking. Implementation of the program provides 

reasonable assurance that cracking will be adequately managed so the intended functions 

of the vessel internal components will be maintained consistent with the current licensing 

basis for the subsequent period of extended operation.

The program is informed and enhanced when necessary through the systematic and 

ongoing review of both plant-specific and industry operating experience including research

and development such that the effectiveness of the AMP is evaluated consistent with the 

discussion in Appendix B of the GALL-SLR Report.

References

10 CFR Part 50, Appendix B, “Quality Assurance Criteria for Nuclear Power Plants and Fuel 

Reprocessing Plants.” Washington, DC: U.S. Nuclear Regulatory Commission. 2016.

10 CFR 50.55a, “Codes and Standards.” Washington, DC: U.S. Nuclear Regulatory 

Commission. 2016.

ASME. ASME Code Section XI, “Rules for Inservice Inspection of Nuclear Power Plant 

Components.” New York, New York: The American Society of Mechanical Engineers. 2008.

1

EPRI. BWRVIP-02-A, Revision 2 (EPRI 1012837), “BWR Vessel and Internals Project, BWR 

Core Shroud Repair Design Criteria.” Palo Alto, California: Electric Power Research Institute. 

October 2005.

_____. BWRVIP-03, Revision 1 (EPRI 105696-R1), “BWR Vessel and Internals Project, Reactor 

Pressure Vessel and Internals Examination Guidelines.” Palo Alto, California: Electric Power 

Research Institute. July 1999.

_____. BWRVIP-06, Revision 1-A (EPRI 1019058), “Safety Assessment of BWR Reactor 

Internals.” Palo Alto, California: Electric Power Research Institute. December 2009.

_____. BWRVIP-14-A (EPRI 1016569), “BWR Vessel and Internals Project, Evaluation of Crack 

Growth in BWR Stainless Steel RPV Internals.” Palo Alto, California: Electric Power Research 

Institute. September 2008.

 

1GALL-SLR Report Chapter I, Table 1, identifies the ASME Code Section XI editions and addenda that are 

acceptable to use for this AMP.
XI.M9-8

_____. BWRVIP-16-A (EPRI 1012113), “BWR Vessel and Internals Project, Internal Core Spray 

Piping and Sparger Replacement Design Criteria.” Palo Alto, California: Electric Power Research 

Institute. September 2005.

_____. BWRVIP-18-A, Revision 1-A (EPRI 1025060), “BWR Vessel and Internals Project, BWR 

Core Spray Internals Inspection and Flaw Evaluation Guidelines.” Palo Alto, California: Electric 

Power Research Institute. April 2012.

_____. BWRVIP-19-A (EPRI 1012114), “BWR Vessel and Internals Project, Internal Core Spray 

Piping and Sparger Repair Design Criteria.” Palo Alto, California: Electric Power Research 

Institute. September 2005.

_____. BWRVIP-25 (EPRI 107284), “BWR Vessel and Internals Project, BWR Core Plate 

Inspection and Flaw Evaluation Guidelines.” Palo Alto, California: Electric Power Research 

Institute. December 2000.

_____. BWRVIP-26-A (EPRI 1009946), “BWR Vessel and Internals Project, BWR Top Guide 

Inspection and Flaw Evaluation Guidelines.” Palo Alto, California: Electric Power Research 

Institute. November 2004.

_____. BWRVIP-38 (EPRI 108823), “BWR Vessel and Internals Project, BWR Shroud Support 

Inspection and Flaw Evaluation Guidelines.” Palo Alto, California: Electric Power Research 

Institute. September 1997.

_____. BWRVIP-41 (EPRI 108728), “BWR Vessel and Internals Project, BWR Jet Pump 

Assembly Inspection and Flaw Evaluation Guidelines.” Palo Alto, California: Electric Power 

Research Institute. October 1997.

_____. BWRVIP-42-A (EPRI 1011470), “BWR Vessel and Internals Project, BWR LPCI Coupling 

Inspection and Flaw Evaluation Guidelines.” Palo Alto, California: Electric Power Research 

Institute. February 2005.

_____. BWRVIP-44-A (EPRI 1014352), “BWR Vessel and Internals Project, Underwater Weld 

Repair of Nickel Alloy Reactor Vessel Internals.” Palo Alto, California: Electric Power Research 

Institute. August 2006.

_____. BWRVIP-45 (EPRI 108707), “BWR Vessel and Internals Project, Weldability of Irradiated 

LWR Structural Components.” Palo Alto, California: Electric Power Research Institute. 

June 2000.

_____. BWRVIP-47-A (EPRI 1009947), “BWR Vessel and Internals Project, BWR Lower Plenum 

Inspection and Flaw Evaluation Guidelines.” Palo Alto, California: Electric Power Research 

Institute. November 2004.

_____. BWRVIP-50-A (EPRI 1012110), “BWR Vessel and Internals Project, Top Guide/Core 

Plate Repair Design Criteria.” Palo Alto, California: Electric Power Research Institute. 

September 2005.

_____. BWRVIP-51-A (EPRI 1012116), “BWR Vessel and Internals Project, Jet Pump Repair 

Design Criteria.” Palo Alto, California: Electric Power Research Institute. September 2005.
XI.M9-9

_____. BWRVIP-52-A (EPRI 1012119), “BWR Vessel and Internals Project, Shroud Support and 

Vessel Bracket Repair Design Criteria.” Palo Alto, California: Electric Power Research Institute. 

September 2005.

_____. BWRVIP-55-A (EPRI 1012117), “BWR Vessel and Internals Project, Lower Plenum 

Repair Design Criteria.” Palo Alto, California: Electric Power Research Institute. 

September 2005.

_____. BWRVIP-56-A (EPRI 1012118), “BWR Vessel and Internals Project, LPCI Coupling 

Repair Design Criteria.” Palo Alto, California: Electric Power Research Institute. 

September 2005.

_____. BWRVIP-59-A (EPRI 1014874), “BWR Vessel and Internals Project, Evaluation of Crack 

Growth in BWR Nickel-Base Austenitic Alloys in RPV Internals.” Palo Alto, California: Electric 

Power Research Institute. May 2007.

_____. BWRVIP-60-A (EPRI 1008871), “BWR Vessel and Internals Project, Evaluation of Stress 

Corrosion Crack Growth in Low Alloy Steel Vessel Materials in the BWR Environment.” Palo Alto, 

California: Electric Power Research Institute. June 2003.

_____. BWRVIP-62-A (EPRI 1021006), “BWR Vessel and Internals Project, Technical Basis for 

Inspection Relief for BWR Internal Components with Hydrogen Injection.” Palo Alto, California: 

Electric Power Research Institute. November 2010.

_____. BWRVIP-76-A (EPRI 1019057), “BWR Vessel and Internals Project, BWR Core Shroud 

Inspection and Flaw Evaluation Guidelines.” Palo Alto, California: Electric Power Research 

Institute. October 2009.

_____. BWRVIP-80-A (EPRI 1015457), “BWR Vessel and Internals Project, Evaluation of Crack 

Growth in BWR Shroud Vertical Welds.” Palo Alto, California: Electric Power Research Institute. 

October 2007.

_____. BWRVIP-84 (EPRI 1026603), “BWR Vessel and Internals Project, Guidelines for 

Selection and Use of Materials for Repairs to BWR Internal Components.” Revision 2. Palo Alto, 

California: Electric Power Research Institute. September 2012.

_____. BWRVIP-97-A (EPRI 1019054), “BWR Vessel and Internals Project, Guidelines for 

Performing Weld Repairs to Irradiated BWR Internals.” Palo Alto, California: Electric Power 

Research Institute. June 2009.

_____. BWRVIP-99-A (EPRI 1016566), “BWR Vessel and Internals Project, Crack Growth Rates 

in Irradiated Stainless Steels in BWR Internal Components.” Palo Alto, California: Electric Power 

Research Institute. October 2008.

_____. BWRVIP-100-A (EPRI 1013396), “BWR Vessel and Internals Project, Updated 

Assessment of the Fracture Toughness of Irradiated Stainless Steel for BWR Core Shrouds.” 

Palo Alto, California: Electric Power Research Institute. August 2006.

_____. BWRVIP-138, Revision 1-A (EPRI 1025139), “BWR Vessel and Internals Project, 

Updated Jet Pump Beam Inspection and Flaw Evaluation Guidelines.” Palo Alto, California: 

Electric Power Research Institute. October 2012.
XI.M9-10

_____. BWRVIP-139-A (EPRI 1018794), “BWR Vessel and Internals Project, Steam Dryer 

Inspection and Flaw Evaluation Guidelines.” Palo Alto, California: Electric Power Research 

Institute. July 2009.

_____. BWRVIP-167NP (EPRI 3002000690) “BWR Vessel and Internals Project Boiling Water 

Reactor Issue Management Tables.” Revision 1. Palo Alto, California: Electric Power Research 

Institute. August 2013.

_____. BWRVIP-180 (EPRI 1013402), “BWR Vessel and Internals Project, Access Hole Cover 

Inspection and Flaw Evaluation Guidelines.” Palo Alto, California: Electric Power Research 

Institute. November 2007.

_____. BWRVIP-181-A (EPRI 1020997), “BWR Vessel and Internals Project, Steam Dryer Repair 

Design Criteria.” Palo Alto, California: Electric Power Research Institute. July 2010.

_____. BWRVIP-183 (EPRI 1013401), “BWR Vessel and Internals Project, Top Guide Beam 

Inspection and Flaw Evaluation Guidelines.” Palo Alto, California: Electric Power Research 

Institute. December 2007.

_____. BWRVIP-190 (EPRI 1016579), “BWR Vessel and Internals Project: BWR Water 

Chemistry Guidelines—2008 Revision.” Palo Alto, California: Electric Power Research Institute. 

October 2008.

_____. BWRVIP-217 (EPRI 1019067), “BWR Vessel and Internals Project, Access Hole Cover 

Repair Design Criteria.” Palo Alto, California: Electric Power Research Institute. July 2009.

_____. EPRI 3002000628, “Materials Degradation Matrix.” Revision 1. Palo Alto, California: 

Electric Power Research Institute. May 2013. 

Lee, S., P.T. Kuo, K. Wichman, and O. Chopra. “Flaw Evaluation of Thermally Aged Cast 

Stainless Steel in Light-Water Reactor Applications.” International Journal of Pressure Vessels 

and Piping. pp. 37–44. 1997.

NRC. “Final Safety Evaluation of the BWRVIP-234: Thermal Aging and Neutron Embrittlement 

Evaluation of Cast Austenitic Stainless Steel for BWR Internals.” Agencywide Documents Access 

and Management System (ADAMS) Accession No. ML16096A002. Washington, DC: 

U.S. Nuclear Regulatory Commission. June 22, 2016.

_____. Generic Letter 94-03, “Intergranular Stress Corrosion Cracking of Core Shrouds in Boiling 

Water Reactors.” Washington, DC: U.S. Nuclear Regulatory Commission. July 1994.

_____. IE Bulletin 80-07, “BWR Jet Pump Assembly Failure.” Washington, DC: U.S. Nuclear 

Regulatory Commission. April 1980.

_____. IE Bulletin 80-07, Supplement 1, “BWR Jet Pump Assembly Failure.” Washington, DC: 

U.S. Nuclear Regulatory Commission. May 1980.

_____. IE Bulletin 80-13, “Cracking in Core Spray Spargers.” Washington, DC: U.S. Nuclear 

Regulatory Commission. May 1980.
XI.M9-11

_____. Information Notice 88-03, “Cracks in Shroud Support Access Hole Cover Welds.” 

Washington, DC: U.S. Nuclear Regulatory Commission. February 1988.

_____. Information Notice 92-57, “Radial Cracking of Shroud Support Access Hole Cover Welds.” 

Washington, DC: U.S. Nuclear Regulatory Commission. August 1992.

_____. Information Notice 93-101, “Jet Pump Hold-Down Beam Failure.” Washington, DC: 

U.S. Nuclear Regulatory Commission. December 1993.

_____. Information Notice 94-42, “Cracking in the Lower Region of the Core Shroud in Boiling 

Water Reactors.” Washington, DC: U.S. Nuclear Regulatory Commission. June 1994.

_____. Information Notice 95-17, “Reactor Vessel Top Guide and Core Plate Cracking.” 

Washington, DC: U.S. Nuclear Regulatory Commission. March 1995.

_____. Information Notice 97-02, “Cracks Found in Jet Pump Riser Assembly Elbows at Boiling 

Water Reactors.” Washington, DC: U.S. Nuclear Regulatory Commission. February 1997.

_____. Information Notice 97-17, “Cracking of Vertical Welds in the Core Shroud and Degraded 

Repair.” Washington, DC: U.S. Nuclear Regulatory Commission. April 1997.

_____. Information Notice 2007-02, “Failure of Control Rod Drive Mechanism Lead Screw Male 

Coupling at Babcock and Wilcox-Designed Facility.” Washington, DC: U.S. Nuclear Regulatory 

Commission. March 2007.

_____. Letter from Christopher I. Grimes, U.S. Nuclear Regulatory Commission, License 

Renewal and Standardization Branch, to Douglas J. Walters, Nuclear Energy Institute, License 

Renewal Issue No. 98-0030, “Thermal Aging Embrittlement of Cast Stainless Steel Components.” 

ADAMS Accession No. ML003717179. May 19, 2000. 

_____. NUREG–1544, “Status Report: Intergranular Stress Corrosion Cracking of BWR Core 

Shrouds and Other Internal Components.” Washington, DC: U.S. Nuclear Regulatory 

Commission. March 1996.

_____. NUREG/CR–4513, “Estimation of Fracture Toughness of Cast Stainless Steels during 

Thermal Aging in LWR Systems.” Revision 1. Washington, DC: U.S. Nuclear Regulatory 

Commission. August 1994.

_____. NUREG/CR–6923, “Expert Panel Report on Proactive Materials Degradation 

Assessment.” Washington, DC: U.S. Nuclear Regulatory Commission. March 2007.

Xu, H. and S. Fyfitch. “Fracture of Type 17-4 PH CRDM Lead Screw Male Coupling Tangs.” 

11th International Conference on Environmental Degradation of Materials in Nuclear Power 

Systems-Water Reactors. Stevenson, Washington. American Nuclear Society. 2003.

XI.M10-1

XI.M10 BORIC ACID CORROSION

Program Description

The program relies, in part, on implementation of recommendations in the U.S. Nuclear 

Regulatory Commission (NRC) Generic Letter (GL) 88-05 to identify, evaluate, and correct 

borated water leaks that could cause corrosion damage to reactor coolant pressure boundary 

components in pressurized water reactors. Potential improvements to boric acid corrosion 

programs have been identified because of operating experience (OE) with cracking of certain 

nickel alloy pressure boundary components (NRC Regulatory Issue Summary 2003-013 and 

NUREG–1823). 

Borated water leakage from piping and components that are outside the scope of the program 

established in response to NRC GL 88-05 may affect structures and components (SCs) that are 

subject to aging management review (AMR). Therefore, the scope of the monitoring and 

inspections of this program includes all components subject to an AMR that may be adversely 

affected by some form of borated water leakage. The scope of the evaluations, assessments, 

and corrective actions include all observed leakage sources and the affected SCs.

Borated water leakage may be discovered through activities other than those established 

specifically to detect such leakage. Therefore, the program includes provisions for triggering 

evaluations and assessments when leakage is discovered by other activities. The effects of boric 

acid corrosion on reactor coolant pressure boundary materials in the vicinity of nickel alloy 

components are managed by Generic Aging Lessons Learned for Subsequent License Renewal 

(GALL-SLR) aging management program (AMP) XI.M11B, “Cracking of Nickel-Alloy Components 

and Loss of Material Due to Boric Acid-Induced Corrosion in Reactor Coolant Pressure Boundary 

Components (PWRs Only).”

The recommended approaches described in Section 7 of WCAP-15988-NP, Revision 2, “Generic 

Guidance for an Effective Boric Acid Inspection Program for Pressurized Water Reactors,” provide 

an acceptable means of fulfilling the activities of this program.

Evaluation and Technical Basis

1. Scope of Program: The program covers any SCs on which boric acid corrosion may 

occur (e.g., steel and copper alloy) and electrical components onto which borated reactor 

water may leak. The program includes provisions in response to the recommendations of 

NRC GL 88-05. NRC GL 88-05 elicits a program consisting of systematic measures to 

provide reasonable assurance that corrosion caused by leaking borated water does not 

lead to degradation of the leakage source or adjacent SCs, to provide assurance that the 

reactor coolant pressure boundary will have an extremely low probability of abnormal 

leakage, rapidly propagating failure, or gross rupture. Such a program provides for 

(a) determination of the principal location of leakage, (b) examinations and procedures for 

locating small leaks, and (c) engineering evaluations and corrective actions to provide 

reasonable assurance that boric acid corrosion does not lead to degradation of the 

leakage source or adjacent structures or components. Although NRC GL 88-05 

addresses boric acid corrosion of reactor coolant pressure boundary components, the 

recommendations in NRC GL 88-05 are also effective in managing the aging of other 

in-scope components.
XI.M10-2

2. Preventive Actions: Minimizing borated water leakage by frequent monitoring of the 

locations where potential leakage could occur and timely cleaning and repair if leakage is 

detected prevents or mitigates boric acid corrosion. In addition, the use of 

corrosion-resistant materials and coatings minimizes the effects of boric acid exposure.

3. Parameters Monitored or Inspected: The AMP monitors the aging effects of loss of 

material due to boric acid corrosion on the intended function of an affected SC by 

detection of borated water leakage. Borated water leakage results in deposits of white 

boric acid crystals and the presence of moisture. Discolored boric acid crystals are an 

indication of corrosion. Boric acid deposits, borated water leakage, or the presence of 

moisture that could lead to the identification of loss of material can be monitored through 

visual examination.

In order to identify potential borated water leaks inside containment that have not been

detected during walkdowns and maintenance, the program tracks airborne radioactivity 

monitors, humidity monitors, temperature monitors, reactor coolant system water inventory 

balancing, and containment air cooler thermal performance. The program also looks for 

evidence of boric acid deposits on control rod drive mechanism shroud fans, containment 

air recirculation fan coils, containment fan cooler units, and airborne filters.

4. Detection of Aging Effects: Degradation of the component due to boric acid corrosion 

cannot occur without leakage of borated water. Conditions leading to boric acid corrosion, 

such as crystal buildup and evidence of moisture, are readily detectable by visual 

inspection, though removal of insulation may be required in some cases. Obstructions to 

visual inspections are removed unless a technical justification is documented by the 

program owner. Criteria for removing insulation for bare-metal inspections include the 

safety significance of the location, evidence of leakage from under the insulation, bulging 

of the insulation, and OE. Discoloration, staining, boric acid residue, and other evidence 

of leakage on insulation surfaces and the surrounding area are given particular 

consideration as evidence of component leakage. The program delineated in NRC 

GL 88-05 includes guidelines for locating small leaks, conducting examinations, and 

performing engineering evaluations. In addition, the program includes appropriate 

interfaces with other site programs and activities, such that borated water leakage that is 

encountered by means other than the monitoring and trending established by this program 

is evaluated and corrected.

5. Monitoring and Trending: The program provides monitoring and trending activities as 

delineated in NRC GL 88-05, timely evaluation of evidence of borated water leakage 

identified by other means, and timely detection of leakage by observing boric acid crystals 

during normal plant walkdowns and maintenance. The program maintains a list of all

active borated water leaks, excessive boric acid deposits, discoloration caused by 

corrosion, and affected targets susceptible to corrosion to track the condition of 

components in the vicinity of leaks and to identify locations with repeat leakage.

6. Acceptance Criteria: All indications of boric acid leakage are screened to determine if 

more detailed evaluations of the leaking component or associated targets are warranted. 

Any detected borated water leakage not meeting screening criteria (i.e., essentially zero 

potential for adverse effects on SCs), including white or discolored boric acid crystal 

buildup, or rust-colored deposits are evaluated to confirm the intended functions of 

affected SCs consistent with the design basis prior to continued service.
XI.M10-3

7. Corrective Actions: Results that do not meet the acceptance criteria are addressed in 

the applicant’s corrective action program under those specific portions of the quality 

assurance (QA) program that are used to meet Criterion XVI, “Corrective Action,” of 

Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B. Appendix A of 

the GALL-SLR Report describes how an applicant may apply its 10 CFR Part 50, 

Appendix B, QA program to fulfill the corrective actions element of this AMP for both 

safety-related and nonsafety-related SCs within the scope of this program. 

Borated water leakage and areas of resulting boric acid corrosion are evaluated and 

corrected in accordance with the applicable provisions of NRC GL 88-05 and the 

corrective action program. Any detected boric acid crystal buildup or deposits should be 

cleaned. NRC GL 88-05 recommends that corrective actions to prevent recurrences 

of degradation caused by borated water leakage be included in the program 

implementation. These corrective actions include any modifications to be introduced in the 

present design or operating procedures of the plant that (a) reduce the probability of 

reactor coolant leaks at locations where they may cause corrosion damage and (b) entail 

the use of suitable corrosion resistant materials or the application of protective coatings or 

claddings. When corrective actions include the use of enclosures to contain borated water 

leakage, the impact of the leakage environment on the potential degradation mechanisms 

of enclosed components is evaluated [NRC Information Notice (IN) 2012-15]. Such 

modifications should allow for periodic inspections.

8. Confirmation Process: The confirmation process is addressed through those specific 

portions of the QA program that are used to meet Criterion XVI, “Corrective Action,” of 

10 CFR Part 50, Appendix B. Appendix A of the GALL-SLR Report describes how an 

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the confirmation 

process element of this AMP for both safety-related and nonsafety-related SCs within the 

scope of this program.

9. Administrative Controls: Administrative controls are addressed through the QA program 

that is used to meet the requirements of 10 CFR Part 50, Appendix B, associated with 

managing the effects of aging. Appendix A of the GALL-SLR Report describes how an 

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the 

administrative controls element of this AMP for both safety-related and nonsafety-related 

SCs within the scope of this program.

10. Operating Experience: Boric acid corrosion has been observed in nuclear power plants 

[NRC IN 86-108 (and Supplements 1 through 3), IN 2002-11, IN 2002-13, and IN 2003-02]

and has resulted in significant impairment of component-intended functions in areas that 

are difficult to access/observe (NRC Bulletin 2002-01). Boric acid leakage can become 

airborne and can cause corrosion in locations other than in the vicinity of the leak 

[Licensee Event Reports (LER) 250/2010-005, LER 346/2002-008]. Corrosion rates may 

be inaccurately predicted due to the installation of a different type of material than 

indicated on the design documents (LER 346/1998-009) or galvanic corrosion caused by 

wet boric acid crystals bridging between dissimilar metals [Electric Power Research 

Institute (EPRI) 1000975].

The program is informed and enhanced when necessary through the systematic and 

ongoing review of both plant-specific and industry OE including research and development 

such that the effectiveness of the AMP is evaluated consistent with the discussion in 

Appendix B of the GALL-SLR Report.
XI.M10-4

References

10 CFR Part 50, Appendix B, “Quality Assurance Criteria for Nuclear Power Plants and Fuel 

Reprocessing Plants.” Washington, DC: U.S. Nuclear Regulatory Commission. 2016.

EPRI. EPRI 1000975, “Boric Acid Corrosion Guidebook.” Revision 1. Palo Alto, California: 

Electric Power Research Institute. November 2001.

Licensee Event Report 250/2010-005, “Containment Liner Through Wall Defect Due to 

Corrosion.” Agencywide Documents Access and Management System (ADAMS) Accession 

No. ML103620112. https://lersearch.inl.gov/LERSearchCriteria.aspx. December 2010.

Licensee Event Report 346/2002-008, “Containment Air Coolers Collective Significance of 

Degraded Conditions.” ADAMS Accession No. ML031330192. 

https://lersearch.inl.gov/LERSearchCriteria.aspx. May 2003.

Licensee Event Report 346/1998-009, “Reactor Coolant System Pressurizer Spray Valve 

Degraded with Two of Eight Body-to-Bonnet Nuts Missing.” 

https://lersearch.inl.gov/LERSearchCriteria.aspx. August 1999.

NRC. Bulletin 2002-01, “Reactor Pressure Vessel Head Degradation and Reactor Coolant 

Pressure Boundary Integrity.” ADAMS Accession No. ML020770497. Washington, DC: 

U.S. Nuclear Regulatory Commission. March 2002.

_____. Generic Letter 88-05, “Boric Acid Corrosion of Carbon Steel Reactor Pressure Boundary 

Components in PWR Plants.” ADAMS Accession No. ML031130424. Washington, DC: 

U.S. Nuclear Regulatory Commission. March 1988.

_____. Information Notice 86-108, “Degradation of Reactor Coolant System Pressure Boundary 

Resulting from Boric Acid Corrosion.” ADAMS Accession Nos. ML031250360, ML031250366, 

ML053070387, ML053070388. December 1986. Washington, DC: U.S. Nuclear Regulatory 

Commission. Supplement 1, April 1987; Supplement 2, November 1987; Supplement 3, 

January 1995.

_____. Information Notice 2002-11, “Recent Experience with Degradation of Reactor Pressure 

Vessel Head.” ADAMS Accession No. ML020700556. Washington, DC: U.S. Nuclear 

Regulatory Commission. March 2002.

_____. Information Notice 2002-13, “Possible Indicators of Ongoing Reactor Pressure Vessel 

Head Degradation.” ADAMS Accession No. ML020930617. Washington, DC: U.S. Nuclear 

Regulatory Commission. April 2002.

_____. Information Notice 2003-02, “Recent Experience with Reactor Coolant System Leakage 

and Boric Acid Corrosion.” ADAMS Accession No. ML030160004. Washington, DC: 

U.S. Nuclear Regulatory Commission. January 2003.

_____. Information Notice 2012-15, “Use of Seal Cap Enclosures to Mitigate Leakage from Joints 

that Use A-286 Bolts.” ADAMS Accession No. ML121740012. Washington, DC: U.S. Nuclear 

Regulatory Commission. August 2012.
XI.M10-5

_____. NUREG–1823, “U.S. Plant Experience with Alloy 600 Cracking and Boric Acid Corrosion 

of Light-Water Reactor Pressure Vessel Materials.” Washington, DC: U.S. Nuclear Regulatory 

Commission. April 2005.

_____. Regulatory Issue Summary 2003-13, “NRC Review of Responses to Bulletin 2002-01, 

Reactor Pressure Vessel Head Degradation and Reactor Coolant Pressure Boundary Integrity.” 

ADAMS Accession No. ML032100653. Washington, DC: U.S. Nuclear Regulatory Commission. 

July 2003.

Westinghouse Non-Proprietary Class 3 Report No. WCAP-15988-NP, Revision 2, “Generic 

Guidance for an Effective Boric Acid Inspection Program for Pressurized Water Reactors.” 

Pittsburgh, Pennsylvania: Westinghouse Electric Company. June 2012.

XI.M11B-1

XI.M11B CRACKING OF NICKEL-ALLOY COMPONENTS AND LOSS OF 

MATERIAL DUE TO BORIC ACID-INDUCED CORROSION IN REACTOR 

COOLANT PRESSURE BOUNDARY COMPONENTS (PWRS ONLY)

Program Description

This program addresses operating experience (OE) of degradation due to primary water stress 

corrosion cracking (PWSCC) of components or welds constructed from certain nickel alloys 

(e.g., Alloy 600/82/182) and exposed to pressurized water reactor (PWR) primary coolant at 

elevated temperature. The initiation and growth of PWSCC cracks have been shown to be 

a function of several variables, including but not limited to: (i) temperature, (ii) stress, 

(iii) microstructure, (iv) time, and (v) water chemistry. As a result, this program is informed by 

Generic Aging Lessons Learned for Subsequent License Renewal (GALL-SLR) Report aging 

management program (AMP) XI.M2, “Water Chemistry.”

In addition to inspections designed to identify cracking of nickel alloy components, this program 

also contains inspections designed to potentially identify the presence of boric acid residues, 

which has been demonstrated by OE to lead to loss of material in susceptible carbon and low 

alloy steel components. Thus, this program is used in conjunction with GALL-SLR Report 

AMP XI.M10, “Boric Acid Corrosion.” Except as required in Title 10 of the Code of Federal 

Regulations (10 CFR) 50.55a, it is not the general intent of this program to manage the 

aging of components and welds constructed from PWSCC-resistant nickel alloys 

(e.g., Alloy 690/52/152).

Plants have implemented and maintained existing programs to manage cracking due to PWSCC 

for nickel alloy components and welds, consistent with Electric Power Research Institute (EPRI)

Materials Reliability Program (MRP)-126. The scope of subsequent license renewal may identify 

additional nickel alloy components or welds to be included in the applicant’s aging management 

program.

Evaluation and Technical Basis

1. Scope of Program: The scope of this program includes three basic groups of 

components and materials: (i) all nickel alloy components and welds which are identified 

at the plant in accordance with the guidelines of EPRI MRP-126; (ii) nickel alloy 

components and welds identified in American Society of Mechanical Engineers Boiler and 

Pressure Vessel Code (ASME Code)1 Cases N-770, N-729 and N-722, as incorporated by 

reference in 10 CFR 50.55a; and (iii) components that are susceptible to corrosion by 

boric acid and may be impacted by leakage of boric acid from nearby or adjacent nickel 

alloy components previously described. This program manages cracking due to PWSCC 

and loss of material due to boric acid corrosion.

 

1GALL-SLR Report Chapter I, Table 1, identifies the ASME Code Section XI editions and addenda that are 

acceptable to use for this AMP.
XI.M11B-2

2. Preventive Actions: This program is primarily a condition monitoring program. Since the 

cracking of nickel alloys is affected by water quality this program is used in conjunction 

with GALL-SLR Report AMP XI.M2, “Water Chemistry.” Additionally, in accordance with 

10 CFR 50.55a, an applicant may choose to mitigate component degradation in lieu of 

performing required inspections.

3. Parameters Monitored or Inspected: Components and welds within the scope of this 

program are inspected for evidence of PWSCC by volumetric, surface, or visual testing. In 

the event boric acid residues or corrosion products are discovered during these 

inspections, the potential for, or extent of, loss of material is evaluated by visual and 

quantitative methods.

4. Detection of Aging Effects: For nickel alloy components and welds addressed 

by regulatory requirements contained in 10 CFR 50.55a, inspections are conducted in 

accordance with 10 CFR 50.55a. Other nickel alloy components and welds within the 

scope of this program are inspected in accordance with the guidance in the EPRI 

MRP-126 report.

The program also performs a baseline volumetric or inner-diameter surface inspection of 

all susceptible nickel alloy branch line connections and associated welds as identified in 

Table 4-1 of EPRI MRP-126 if such components or welds are of a sufficient size to create

a loss of coolant accident through a complete failure (guillotine break) or ejection of the

component and the normal operating temperature of the components is 274 °C (Celsius)

[525 °F (Fahrenheit)] or greater. The baseline inspection is performed prior to the 

subsequent period of extended operation using a qualified method in accordance with 

Appendix IV or VIII of ASME Code Section XI as incorporated by reference in 

10 CFR 50.55a, or equivalent. Existing periodic inspections using volumetric or surface 

examination methods may be credited for the baseline inspection. If the baseline 

inspection indicates the occurrence of PWSCC, periodic volumetric or inner-diameter 

surface inspections are performed with adequate periodicity.

5. Monitoring and Trending: Reactor coolant leakage is calculated and trended on a 

routine basis in accordance with technical specifications to detect changes in the leakage 

rates [Regulatory Guide (RG) 1.45]. Flaw evaluation through 10 CFR 50.55a is a means 

to monitor cracking. Detected flaws are monitored and trended by performing periodic and 

successive inspections in accordance with ASME Code Cases N-770, N-729 and N-722, 

as incorporated by reference in 10 CFR 50.55a, and the guidelines in EPRI MRP-126.

6. Acceptance Criteria: Acceptance criteria are in accordance with applicable sections of 

Section XI of the ASME Code, as incorporated by reference in 10 CFR 50.55a. If any 

boric acid residue or corrosion product is detected, additional actions are performed to 

determine the source of leakage and the impact of boric acid corrosion on adjacent 

components.

7. Corrective Actions: Results that do not meet the acceptance criteria are addressed in 

the applicant’s corrective action program under those specific portions of the quality 

assurance (QA) program that are used to meet Criterion XVI, “Corrective Action,” of 

10 CFR Part 50, Appendix B. Appendix A of the GALL-SLR Report describes how an 

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the corrective 

actions element of this AMP for both safety-related and nonsafety-related structures and 

components (SCs) within the scope of this program.
XI.M11B-3

Components with relevant unacceptable flaw indications are corrected for further services 

through an implementation of appropriate repair or replacement as dictated by 

10 CFR 50.55a and industry guidelines (e.g., EPRI MRP-126). In addition, detection of 

leakage or evidence of cracking in susceptible components within the scope of this 

program require a scope expansion of current inspection and increased inspection 

frequencies for some components, as required by 10 CFR 50.55a and industry guidelines 

(e.g., EPRI MRP-126).

Repair and replacement procedures and activities must either comply with ASME Code 

Section XI, as incorporated in 10 CFR 50.55a or conform to applicable ASME Code Cases 

that have been endorsed in 10 CFR 50.55a by referencing the latest version of RG 1.147.

8. Confirmation Process: The confirmation process is addressed through those specific 

portions of the QA program that are used to meet Criterion XVI, “Corrective Action,” of 

10 CFR Part 50, Appendix B. Appendix A of the GALL-SLR Report describes how an 

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the confirmation 

process element of this AMP for both safety-related and nonsafety-related SCs within the 

scope of this program.

9. Administrative Controls: Administrative controls are addressed through the QA program 

that is used to meet the requirements of 10 CFR Part 50, Appendix B, associated with 

managing the effects of aging. Appendix A of the GALL-SLR Report describes how an 

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the 

administrative controls element of this AMP for both safety-related and nonsafety-related 

SCs within the scope of this program.

10. Operating Experience: This program addresses review of related OE, including 

plant-specific information, generic industry findings, and international data. Within the 

current regulatory requirements, as necessary, the applicant maintains a record of OE

through the required update of the facility’s inservice inspection program in accordance 

with 10 CFR 50.55a. Additionally, the applicant follows mandated industry guidelines 

developed to address OE in accordance with Nuclear Energy Institute (NEI)-03-08, 

“Guideline for the Management of Materials Issues.”

PWSCC of Alloy 600 components has been observed in domestic and foreign PWRs 

[NRC Information Notice (IN) 90-10]. The ingress of demineralizer resins also has 

occurred in operating plants (NRC IN 96-11). The Water Chemistry program, GALL-SLR 

Report AMP XI.M2, manages the effects of such excursions through monitoring and 

control of primary water chemistry. NRC Generic Letter 97-01 is effective in managing the 

effect of PWSCC. PWSCC has occurred in the vessel head penetration nozzles of 

U.S. PWRs as described in NRC Bulletins 2001-01, 2002-01 and 2002-02. In addition, 

PWSCC was observed in reactor vessel bottom mounted instrument nozzles (NRC 

IN 2003-11, Supplement 1, and Licensee Event Report 530/2013-001-00).

The program is informed and enhanced when necessary through the systematic and 

ongoing review of both plant-specific and industry OE including research and development 

such that the effectiveness of the AMP is evaluated consistent with the discussion in 

Appendix B of the GALL-SLR Report.
XI.M11B-4

References

10 CFR Part 50, Appendix B, “Quality Assurance Criteria for Nuclear Power Plants and Fuel 

Reprocessing Plants.” Washington, DC: U.S. Nuclear Regulatory Commission. 2016.

10 CFR 50.55a, “Codes and Standards.” Washington, DC: U.S. Nuclear Regulatory 

Commission. 2016.

ASME. ASME Code Case N-722-1, “Additional Examinations for PWR Pressure Retaining Welds 

in Class 1 Components Fabricated with Alloy 600/82/182 Materials. New York, New York: The 

American Society of Mechanical Engineers. January 2009.

_____. ASME Code Case N-729-1, “Alternative Examination Requirements for PWR Reactor 

Vessel Upper Heads with Nozzles Having Pressure-Retaining Partial-Penetration Welds.” 

New York, New York: The American Society of Mechanical Engineers. March 2006.

_____. ASME Code Case N-770, “Alternative Examination Requirements and Acceptance 

Standards for Class 1 PWR Piping and Vessel Nozzle Butt Welds Fabricated with UNS N06082 or 

UNS W86182 Weld Filler Material With or Without Application of Listed Mitigation Activities.” 

New York, New York: The American Society of Mechanical Engineers. January 2009.

EPRI. MRP-126, “Generic Guidance for Alloy 600 Management.” Palo Alto, California: Electric 

Power Research Institute. November 2004.

Licensee Event Report 530/2013-001-00, “Leakage on Reactor Vessel Bottom-Mounted 

Instrumentation Nozzle 3.” https://lersearch.inl.gov/LERSearchCriteria.aspx. December 2013.

NEI. NEI 03-08, “Guideline for the Management of Materials Issues.” Revision 2. 

Washington, DC: Nuclear Energy Institute. January 2010.

NRC. Bulletin 2001-01, “Circumferential Cracking of Reactor Pressure Vessel Head Penetration 

Nozzles.” Washington, DC: U.S. Nuclear Regulatory Commission. August 2001. 

_____. Bulletin 2002-01, “Reactor Pressure Vessel Head Degradation and Reactor Coolant 

Pressure Boundary Integrity.” Agencywide Documents Access and Management System 

(ADAMS) Accession No. ML020770497. Washington, DC: U.S. Nuclear Regulatory 

Commission. March 2002.

_____. Bulletin 2002-02, “Reactor Pressure Vessel Head and Vessel Head Penetration Nozzle 

Inspection Programs.” Washington, DC: U.S. Nuclear Regulatory Commission. August 2002.

_____. Generic Letter 97-01, “Degradation of Control Rod Drive Mechanism Nozzle and Other 

Vessel Closure Head Penetrations.” Washington, DC: U.S. Nuclear Regulatory Commission. 

April 1997.

_____. Information Notice 90-10, “Primary Water Stress Corrosion Cracking (PWSCC) of 

Inconel 600.” Washington, DC: U.S. Nuclear Regulatory Commission. February 1990.

_____. Information Notice 96-11, “Ingress of Demineralizer Resins Increases Potential for Stress 

Corrosion Cracking of Control Rod Drive Mechanism Penetrations.” Washington, DC: 

U.S. Nuclear Regulatory Commission. February 1996.
XI.M11B-5

_____. Information Notice 2003-11, “Leakage Found on Bottom-Mounted Instrumentation 

Nozzles.” Washington, DC: U.S. Nuclear Regulatory Commission. August 2003.

_____. Information Notice 2003-11, “Leakage Found on Bottom-Mounted Instrumentation 

Nozzles.” Supplement 1. Washington, DC: U.S. Nuclear Regulatory Commission. 

January 2004.

_____. Inspection Manual, Inspection Procedure 71111.08, “Inservice Inspection Activities.” 

Washington, DC: U.S. Nuclear Regulatory Commission. January 2015.

_____. NUREG–1823, “U.S. Plant Experience with Alloy 600 Cracking and Boric Acid Corrosion 

of Light-Water Reactor Pressure Vessel Materials.” Washington, DC: U.S. Nuclear Regulatory 

Commission. April 2005.

_____. Regulatory Guide 1.45, Revision 1, “Guidance on Monitoring and Responding to Reactor 

Coolant System Leakage.” Washington, DC: U.S. Nuclear Regulatory Commission. May 2008.

_____. Regulatory Guide 1.147, Revision 17, “Inservice Inspection Code Case Acceptability.” 

Washington, DC: U.S. Nuclear Regulatory Commission. August 2014.

_____. Regulatory Information Summary 2008-25, “Regulatory Approach for Primary Water 

Stress Corrosion Cracking of Dissimilar Metal Butt Welds in Pressurized Water Reactor Primary 

Coolant System Piping.” Washington, DC: U.S. Nuclear Regulatory Commission. 

October 2008.

XI.M12-1

XI.M12 THERMAL AGING EMBRITTLEMENT OF CAST AUSTENITIC STAINLESS 

STEEL (CASS)

Program Description

The reactor coolant system components are inspected in accordance with the American Society 

of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code), Section XI1

. This 

inspection is augmented to detect the effects of loss of fracture toughness due to thermal aging 

embrittlement of cast austenitic stainless steel (CASS) piping components except for valve 

bodies. This aging management program (AMP) includes determination of the potential 

significance of thermal aging embrittlement of CASS components based on casting method, 

molybdenum content, and percent ferrite. For components for which thermal aging embrittlement 

is “potentially significant” as defined below, aging management is accomplished through either 

(a) qualified visual inspections, such as enhanced visual examination (EVT-1); (b) a qualified 

ultrasonic testing (UT) methodology; or (c) a component-specific flaw tolerance evaluation in 

accordance with the ASME Code, Section XI. Additional inspection or evaluations to demonstrate 

that the material has adequate fracture toughness are not required for components for which 

thermal aging embrittlement in not significant. The scope of the program includes all primary 

pressure boundary components constructed from CASS with service conditions above 

250 °

C (Celsius) [482 °F (Fahrenheit)]. (see comment previous section on this)

For pump casings, as an alternative to the screening and other actions described above, no 

further actions are needed if applicants demonstrate that the original flaw tolerance evaluation 

performed as part of Code Case N-481 implementation remains bounding and applicable for the 

subsequent license renewal (SLR) period or the evaluation is revised to be applicable for 

80 years. For valve bodies, based on the results of the assessment documented in the letter 

dated May 19, 2000, from Christopher Grimes, U.S. Nuclear Regulatory Commission (NRC), to 

Douglas Walters, Nuclear Energy Institute (May 19, 2000 NRC letter), screening for significance 

of thermal aging embrittlement is not required. The existing ASME Code, Section XI inspection 

requirements are adequate for valve bodies.

Reactor vessel internal (RVI) fabricated from CASS are not within the scope of this AMP. 

GALL-SLR Report AMP XI.M9, “BWR Vessel Internals” contains aging management guidance for 

CASS RVI components of boiling water reactors (BWRs). GALL-SLR Report AMP XI.M16A,

“PWR Vessel Internals” contains aging management guidance for CASS RVI components of 

pressurized water reactors (PWRs).

Evaluation and Technical Basis

1. Scope of Program: This program manages loss of fracture toughness in ASME Code 

Class 1 piping components made from CASS. The program includes screening criteria to 

determine which CASS components have the potential for significant loss of fracture 

toughness due to thermal aging embrittlement and require augmented inspection. The 

screening criteria are applicable to all primary pressure boundary components constructed 

from CASS with service conditions above 250 °

C [482 °F]. The screening criteria for the 

 

1 GALL-SLR Report. Chapter 1, Table 1, identifies the ASME Code Section XI editions and addenda that are 

acceptable to use for this AMP.
XI.M12-2

significance of thermal aging embrittlement are not applicable to niobium-containing 

steels; such steels require evaluation on a case-by-case basis.

Based on the criteria set forth in the May 19, 2000, NRC letter, the potential significance of 

thermal aging embrittlement of CASS materials is determined in terms of casting method, 

molybdenum content, and ferrite content. For low-molybdenum content steels {SA-351 

Grades CF3, CF3A, CF8, CF8A or other steels with ≤ 0.5 weight percent [wt.%] Mo}, only 

static-cast steels with >20 percent ferrite are potentially susceptible to thermal 

embrittlement. Static-cast low-molybdenum steels with ≤20 percent ferrite and all 

centrifugal-cast low-molybdenum steels are not susceptible. For high-molybdenum 

content steels (SA-351 Grades CF3M, CF3MA, and CF8M or other steels with 2.0 to 

3.0 wt.% Mo), static-cast steels with >14 percent ferrite and centrifugal-cast steels with 

>20 percent ferrite thermal embrittlement can be potentially significant, (i.e., screens in). 

For static-cast high-molybdenum steels with ≤14 percent ferrite and centrifugal-cast 

high-molybdenum steels with ≤20 percent ferrite, thermal aging embrittlement is not 

significant, (i.e., screens out). The thermal embrittlement screening criteria of CASS with 

different molybdenum and ferrite contents are summarized in Table XI.M12-1, “Thermal 

Embrittlement Screening Criteria.”

In the significance screening method, ferrite content is calculated by using the Hull’s

equivalent factors (described in NUREG/CR–4513, Revision 1) or a staff-approved 

method for calculating delta ferrite in CASS materials. A fracture toughness value of 

255 kilo-joules per square meter (kJ/m2

) [1,450 inch-pounds per square inch] at a crack 

extension of 2.5 millimeters [0.1 inch] is used to differentiate between CASS materials for 

which thermal aging embrittlement is not significant and those for which thermal aging 

embrittlement is potentially significant. Extensive research data indicate that for CASS 

materials without the potential for significant thermal aging embrittlement, the saturated 

lower-bound fracture toughness is greater than 255 kJ/m2 (NUREG/CR–4513, Revision 1).

Table XI.M12-1. Thermal Embrittlement Screening Criteria

Molybdenum (Mo) 

Content

Fe 

Content

Casting 

Method

Potentially 

Significant

(Screens In)

Not 

Significant

(Screens Out)

Low or ≤ 0.5 wt.% >20% 

ferrite Static X —

Low or ≤ 0.5 wt.% ≤20% 

ferrite Static — X

Low or ≤ 0.5 wt.% Any Centrifugal — X

High or 2.0-3.0 wt.% >14% 

ferrite Static X —

High or 2.0-3.0 wt.% >20% 

ferrite Centrifugal X —

High or 2.0-3.0 wt.% ≤14% 

ferrite Static — X

High or 2.0-3.0 wt.% ≤20% 

ferrite Centrifugal — X
XI.M12-3

For valve bodies, screening for significance of thermal aging embrittlement is not needed 

(and thus there are no AMR items). For valve bodies greater than 4 inches nominal pipe 

size (NPS), the existing ASME Code, Section XI inspection requirements are adequate. 

ASME Code, Section XI, Subsection IWB requires only surface examination of valve 

bodies less than 4 inches NPS. For these valve bodies less than 4 inches NPS, the 

adequacy of inservice inspection (ISI) according to ASME Code, Section XI has been 

demonstrated by an NRC-performed bounding integrity analysis (May 19, 2000 letter). 

For pump casings, as an alternative to screening for significance of thermal aging, no 

further actions are needed if applicants demonstrate that the original flaw tolerance

evaluation performed as part of Code Case N-481 implementation remains bounding and 

applicable for the SLR period, or the evaluation is revised to be applicable to 80 years.

2. Preventive Actions: This program is a condition monitoring program and does not 

mitigate thermal aging embrittlement.

3. Parameters Monitored or Inspected: The program monitors the effects of loss of 

fracture toughness on the intended function of the component by identifying the CASS 

materials that are susceptible to thermal aging embrittlement. 

The program does not directly monitor for loss of fracture toughness that is induced by 

thermal aging; instead, the impact of loss of fracture toughness on component integrity is 

indirectly managed by using visual or volumetric examination techniques to monitor for 

cracking in the components.

4. Detection of Aging Effects: For valve bodies, and other “not susceptible” CASS piping 

components, no additional inspection or evaluations are needed to demonstrate that the 

material has adequate fracture toughness.

For piping components for which thermal aging embrittlement is “potentially significant,” 

the AMP provides for qualified inspections of the base metal, such as EVT-1 or a qualified 

UT methodology, with the scope of the inspection covering the portions determined to 

be limiting from the standpoint of applied stress, operating time, and environmental 

considerations. Examination methods that meet the criteria of the ASME Code, 

Section XI, Appendix VIII are acceptable. Alternatively, a plant-specific or 

component-specific flaw tolerance evaluation, using specific geometry, stress information, 

material properties, and ASME Code, Section XI can be used to demonstrate that the 

thermally-embrittled material has adequate toughness. For CASS piping, UT may be 

performed in accordance with the methodology of Code Case N-824, as conditioned by 

Title 10 of the Code of Federal Regulations (10 CFR) 50.55a.

5. Monitoring and Trending: Inspection schedules in accordance with ASME Code, 

Section XI, IWB-2400 or IWC-2400, reliable examination methods, and qualified 

inspection personnel provide timely and reliable detection of cracks. If flaws are detected, 

the period of acceptability is determined from analysis of the flaw, depending on the crack 

growth rate and mechanism.

6. Acceptance Criteria: Flaws detected in CASS components are evaluated in accordance 

with the applicable procedures of ASME Code, Section XI. The most recent version of the 

ASME Code, Section XI incorporated by reference in 10 CFR 50.55a (2007 edition 

through 2008 addenda), does not contain any evaluation procedures applicable to CASS 

with ferrite content ≥ 20 percent. (Nonmandatory Appendix C to the ASME Code, 
XI.M12-4

Section XI states that flaw evaluation methods for CASS with ≥ 20 percent ferrite are 

currently in the course of preparation.) Therefore, methods used for evaluations of flaws 

detected in CASS piping or components containing ≥ 20 percent ferrite, and methods used 

for flaw tolerance evaluations of such components, must be approved by the NRC staff on 

a case-by-case basis until such methods are incorporated into editions of the ASME Code, 

Section XI or code cases that are incorporated by reference in 10 CFR 50.55a, or in 

NRC-approved code cases, as documented in the latest revision to Regulatory Guide 

(RG) 1.147. NUREG/CR–4513, Revision 1 provides methods for predicting the fracture 

toughness of thermally aged CASS materials with delta ferrite content up to 25 percent.

7. Corrective Actions: Results that do not meet the acceptance criteria are addressed in 

the applicant’s corrective action program under those specific portions of the quality 

assurance (QA) program that are used to meet Criterion XVI, “Corrective Action,” of 

10 CFR Part 50, Appendix B. Appendix A of the Generic Aging Lessons Learned for 

Subsequent License Renewal (GALL-SLR) Report describes how an applicant may apply 

its 10 CFR Part 50, Appendix B, QA program to fulfill the corrective actions element of this 

AMP for both safety-related and nonsafety-related structures and components (SCs) 

within the scope of this program.

Repair and replacement are performed in accordance with ASME Code, Section XI, 

IWA-4000.

8. Confirmation Process: The confirmation process is addressed through those specific 

portions of the QA program that are used to meet Criterion XVI, “Corrective Action,” of 

10 CFR Part 50, Appendix B. Appendix A of the GALL-SLR Report describes how an 

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the confirmation 

process element of this AMP for both safety-related and nonsafety-related SCs within the 

scope of this program.

9. Administrative Controls: Administrative controls are addressed through the QA program 

that is used to meet the requirements of 10 CFR Part 50, Appendix B, associated with 

managing the effects of aging. Appendix A of the GALL-SLR Report describes how 

an applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the 

administrative controls element of this AMP for both safety-related and nonsafety-related 

SCs within the scope of this program.

10. Operating Experience: The AMP was developed by using research data obtained on 

both laboratory-aged and service-aged materials. Based on this information, the effects of 

thermal aging embrittlement on the intended function of CASS components will be 

effectively managed.

The program is informed and enhanced when necessary through the systematic and 

ongoing review of both plant-specific and industry operating experience including research

and development such that the effectiveness of the AMP is evaluated consistent with the 

discussion in Appendix B of the GALL-SLR Report.
XI.M12-5

References

10 CFR Part 50, Appendix B, “Quality Assurance Criteria for Nuclear Power Plants and Fuel 

Reprocessing Plants.” Washington, DC: U.S. Nuclear Regulatory Commission. 2016.

10 CFR 50.55a, “Codes and Standards.” Washington, DC: U.S. Nuclear Regulatory 

Commission. 2016.

ASME. ASME Code Section XI, “Rules for Inservice Inspection of Nuclear Power Plant 

Components.” New York, New York: The American Society of Mechanical Engineers. 2008.

2

_____. ASME Code Section XI, Division 1, Code Case N-824, “Ultrasonic Examination of Cast 

Austenitic Piping Welds From the Outside Surface.” New York, New York: The American Society 

of Mechanical Engineers. 2012.

_____. ASME Code Section XI, Division 1, Code Case N-481, “Alternative Examination 

Requirements for Cast Austenitic Pump Casings.” New York, New York: The American Society 

of Mechanical Engineers. Approval Date March 5, 1990.

EPRI. BWRVIP-03, Revision 6 (EPRI 105696-R6), “BWR Vessel and Internals Project, Reactor 

Pressure Vessel and Internals Examination Guidelines.” Palo Alto, California: Electric Power 

Research Institute. December 2003.

_____. MRP-228, “The Materials Reliability Program: Inspection Standard for PWR Internals.” 

Palo Alto, California: Electric Power Research Institute. 2009.

Grimes, Christopher I., U.S. Nuclear Regulatory Commission, License Renewal and 

Standardization Branch, letter to Douglas J. Walters, Nuclear Energy Institute, License Renewal 

Issue No. 98-0030, “Thermal Aging Embrittlement of Cast Stainless Steel Components.”

Agencywide Documents Access and Management System (ADAMS) Accession No.

ML003717179. Washington, DC: U.S. Nuclear Regulatory Commission. May 19, 2000.

Lee, S., P.T. Kuo, K. Wichman, and O. Chopra. “Flaw Evaluation of Thermally-Aged Cast 

Stainless Steel in Light-Water Reactor Applications.” International Journal of Pressure Vessel and 

Piping. pp 37–44. 1997.

Maxin, Mark J., letter to Rick Libra (BWRVIP Chairman), Safety Evaluation for Electric Power 

Research Institute (EPRI) Boiling Water Reactor Vessel and Internals project (BWRVIP) Report 

TR-105696-R6 (BWRVIP-03), Revision 6, “BWR Vessel and Internals Examination Guidelines 

(TAC No MC2293).” June 2008. ADAMS Accession No. ML081500814.

NRC. NUREG/CR–4513, “Estimation of Fracture Toughness of Cast Stainless Steels During 

Thermal Aging in LWR Systems.” Revision 1. Washington, DC: U.S. Nuclear Regulatory 

Commission. August 1994.

_____. Regulatory Guide 1.147, Revision 17, “Inservice Inspection Code Case Acceptability.” 

Washington, DC: U.S. Nuclear Regulatory Commission. August 2014.

 

2GALL-SLR Report Chapter I, Table 1, identifies the ASME Code Section XI editions and addenda that are 

acceptable to use for this AMP.

XI.M16A-1

XI.M16A PWR VESSEL INTERNALS

Program Description

This program is used to manage the effects of age-related degradation mechanisms that are

applicable to the pressurized water reactor (PWR) reactor vessel internal (RVI) components.

These aging effects include: (a) cracking, including stress corrosion cracking (SCC), primary

water stress corrosion cracking (PWSCC), irradiation-assisted stress corrosion cracking (IASCC), 

and cracking due to fatigue/cyclic loading; (b) loss of material induced by wear; (c) loss of fracture 

toughness due to thermal aging and neutron irradiation embrittlement; (d) changes in dimensions

due to void swelling or distortion; and (e) loss of preload due to thermal and irradiation-enhanced 

stress relaxation or creep.

In the absence of an acceptable generic methodology such as an approved revision of Materials 

Reliability Program (MRP)-227 that considers an operating period of 80 years, this program may 

be based on an existing plant program that is consistent with Electric Power Research Institute 

(EPRI) Technical Report No. 1022863, “Materials Reliability Program: Pressurized Water Reactor 

(PWR) Internals Inspection and Evaluation Guidelines,” (MRP-227-A), which is implemented in 

accordance with Nuclear Energy Institute (NEI) 03-08, “Guideline for the Management of Materials 

Issues.” The staff approved the augmented inspection and evaluation (I&E) criteria for PWR RVI 

components in NRC Safety Evaluation (SE), Revision 1, on MRP-227 by letter dated 

December 16, 2011.

Because the guidelines of MRP-227-A are based on an analysis of the RVI that considers the 

operating conditions up to a 60-year operating period, these guidelines are supplemented through 

a gap analysis that identifies enhancements to the program that are needed to address an 

80-year operating period. In this program, the term “MRP-227-A (as supplemented)” is used to 

describe either MRP-227-A as supplemented by this gap analysis, or an acceptable generic 

methodology such as an approved revision of MRP-227 that considers an operating period of 

80 years.

The program applies the guidance in MRP-227-A (as supplemented) for inspecting, evaluating, 

and, if applicable, dispositioning non-conforming RVI components at the facility. These 

examinations provide reasonable assurance that the effects of age-related degradation 

mechanisms will be managed during the period of extended operation. The program includes 

expanding periodic examinations and other inspections, if the extent of the degradation identified 

exceeds the expected levels.

MRP-227-A guidance for selecting RVI components for inclusion in the inspection sample is 

based on a four-step ranking process. Through this process, the RVIs for all three PWR designs 

were assigned to one of the following four groups: “Primary,” “Expansion,” “Existing Programs,” 

and “No Additional Measures.” Definitions of each group are provided in MRP-227-A. 

In the absence of an acceptable generic methodology such as an approved revision of MRP-227 

that considers an operating period of 80 years, the gap analysis described below is used to 

provide reasonable assurance that the aging management for the RVI components identified in 

the four groups is appropriate for 80 years of operation.

The result of this four-step sample selection process is a set of “Primary” internals component 

locations for each of the three plant designs that are inspected because they are expected to 

show the leading indications of the degradation effects, with another set of “Expansion” internals 
XI.M16A-2

component locations that are specified to expand the sample should the indications be more 

severe than anticipated.

The degradation effects in a third set of internals locations are deemed to be adequately managed 

by “Existing Programs,” such as American Society of Mechanical Engineers Boiler and Pressure 

Vessel Code (ASME Code), Section XI,1 Examination Category B-N-3, examinations of core 

support structures. A fourth set of internals locations are deemed to require “No Additional 

Measures.”

If the program is based on MRP-227-A with a gap analysis, the inspection categories, inspection 

criteria, and other program characteristics required by MRP-227-A are identified and justified for 

each component in the applicable program elements. The justification should focus on the aging 

management of the additional aging considerations (i.e., new aging effect/mechanism) during the 

subsequent period of extended operation. The acceptance criteria in the Standard Review Plan 

for Review of Subsequent License Renewal Applications for Nuclear Power Plants (SRP-SLR), 

Section 3.1.2.2.9 and the review procedures in Section 3.1.3.2.9 provide additional information.

Evaluation and Technical Basis

1. Scope of Program: The scope of the program includes all RVI components based on the 

plant’s applicable nuclear steam supply system design. The scope of the program applies 

the methodology and guidance in MRP-227-A (as supplemented), which provides an 

augmented inspection and flaw evaluation methodology for assuring the functional 

integrity of safety-related internals in commercial operating U.S. PWR nuclear power 

plants designed by Babcock & Wilcox (B&W), Combustion Engineering (CE), and 

Westinghouse. The scope of components includes core support structures, those RVI 

components that serve an intended license renewal safety function pursuant to criteria 

in Title 10 of the Code of Federal Regulations (10 CFR) 54.4(a)(1), and other RVI 

components whose failure could prevent satisfactory accomplishment of any of the 

functions identified in 10 CFR 54.4(a)(1)(i), (ii), or (iii). In addition, ASME Code, Section XI 

includes inspection requirements for PWR removable core support structures in 

Table IWB-2500-1, Examination Category B-N-3, which are in addition to any inspections 

that are implemented in accordance with MRP-227-A (as supplemented).

The scope of the program does not include consumable items, such as fuel assemblies, 

reactivity control assemblies, and nuclear instrumentation. The scope of the program also 

does not include welded attachments to the internal surface of the reactor vessel because 

these components are considered to be ASME Code Class 1 appurtenances to the reactor 

vessel and are managed in accordance with an applicant’s AMP that corresponds to 

GALL-SLR Report AMP XI.M1, “ASME Code, Section XI Inservice Inspection, 

Subsections IWB, IWC, and IWD.”

This program element specifies if the program is based on an existing program that is 

consistent with MRP-227-A with a gap analysis or if it is based on an acceptable generic 

methodology such as an approved revision of MRP-227 that considers an operating period 

 

1GALL-SLR Report Chapter I, Table 1, identifies the ASME Code Section XI editions and addenda that are 

acceptable to use for this AMP.
XI.M16A-3

of 80 years. If based on MRP-227-A with a gap analysis, the scope of the program 

focuses on identification and justification of the following:

a. Components that screen in for additional aging effects or mechanisms when 

assessed for the 60-80 year operating period.

b. Components that previously screened in for an aging effect or mechanism and the 

severity of that aging effect or mechanism could significantly increase for the 

60-80 year operating period.

c. Changes to the existing MRP-227-A program characteristics or criteria, including 

but not limited to changes in inspection categories, inspection criteria, or 

primary-to-expansion component criteria and relationships.

2. Preventive Actions: The program relies on PWR water chemistry control to prevent or 

mitigate aging effects that can be induced by corrosive aging mechanisms [e.g., loss of 

material induced by general, pitting corrosion, crevice corrosion, or stress corrosion 

cracking or any of its forms (SCC, PWSCC, or IASCC)]. Reactor coolant water chemistry 

is monitored and maintained in accordance with the Water Chemistry Program, as 

described in GALL-SLR Report AMP XI.M2, “Water Chemistry.”

3. Parameters Monitored or Inspected: The program manages the following age-related 

degradation effects and mechanisms that are applicable in general to RVI components at 

the facility: (a) cracking induced by SCC, PWSCC, IASCC, or fatigue/cyclic loading; 

(b) loss of material induced by wear; (c) loss of fracture toughness induced by thermal 

aging and neutron irradiation embrittlement; (d) changes in dimensions due to void 

swelling or distortion; and (e) loss of preload due to thermal and irradiation-enhanced 

stress relaxation or creep.

For the management of cracking, the program monitors for evidence of surface-breaking 

linear discontinuities if a visual inspection technique is used as the non-destructive 

examination (NDE) method or for relevant flaw presentation signals if a volumetric 

ultrasonic testing (UT) method is used as the NDE method. For the management of loss 

of material, the program monitors for gross or abnormal surface conditions that may be

indicative of loss of material occurring in the components. For the management of loss of 

preload, the program monitors for gross surface conditions that may be indicative of 

loosening in applicable bolted, fastened, keyed, or pinned connections. The program does 

not directly monitor for loss of fracture toughness that is induced by thermal aging or 

neutron irradiation embrittlement. Instead, the impact of loss of fracture toughness on 

component integrity is indirectly managed by: (1) using visual or volumetric examination 

techniques to monitor for cracking in the components, and (2) applying applicable reduced 

fracture toughness properties in the flaw evaluations, in cases where cracking is detected 

in the components and is extensive enough to necessitate a supplemental flaw growth or 

flaw tolerance evaluation. The program uses physical measurements to monitor for any 

dimensional changes due to void swelling or distortion.

Specifically, the program implements the parameters monitored/inspected criteria 

consistent with the applicable tables in Section 4, “Aging Management Requirements,” in 

MRP-227-A (as supplemented).
XI.M16A-4

4. Detection of Aging Effects: The inspection methods are defined and established in 

Section 4 of MRP-227-A (as supplemented). Standards for implementing the inspection 

methods are defined and established in MRP-228. In all cases, well-established 

inspection methods are selected. These methods include volumetric UT examination 

methods for detecting flaws in bolting and various visual (VT-3, VT-1, and EVT-1) 

examinations for detecting effects ranging from general conditions to detection and sizing 

of surface-breaking discontinuities. Surface examinations may also be used as 

an alternative to visual examinations for detection and sizing of surface-breaking 

discontinuities.

Cracking caused by SCC, IASCC, and fatigue is monitored/inspected by either VT-1 or 

EVT-1 examination (for internals other than bolting) or by volumetric UT examination 

(bolting). VT-3 visual methods may be applied for the detection of cracking in 

non-redundant RVI components only when the flaw tolerance of the component, as

evaluated for reduced fracture toughness properties, is known and the component has 

been shown to be tolerant of easily detected large flaws, even under reduced fracture 

toughness conditions. VT-3 visual methods are acceptable for the detection of cracking 

in redundant RVI components (e.g., redundant bolts or pins used to secure a fastened 

RVI assembly).

In addition, VT-3 examinations are used to monitor/inspect for loss of material induced by 

wear and for general aging conditions, such as gross distortion caused by void swelling 

and irradiation growth or by gross effects of loss of preload caused by thermal and 

irradiation- enhanced stress relaxation and creep.

The program adopts the guidance in MRP-227-A (as supplemented) for defining the 

“Expansion Criteria” that need to be applied to the inspection findings of “Primary” 

components and for expanding the examinations to include additional “Expansion” 

components. RVI component inspections are performed consistent with the inspection 

frequency and sampling bases for “Primary” components, “Existing Programs” 

components, and “Expansion” components in MRP-227-A (as supplemented).

In some cases (as defined in MRP-227-A), physical measurements are used as 

supplemental techniques to manage for the gross effects of wear, loss of preload due to 

stress relaxation, or for changes in dimensions due to void swelling or distortion.

Inspection coverages for “Primary” and “Expansion” RVI components are implemented 

consistent with Sections 3.3.1 and 3.3.2 of the NRC SE, Revision 1, on MRP-227-A, or as 

modified by a gap analysis.

This program element should justify the appropriateness of the inspection methods, 

sample size criteria, and inspection frequency criteria for managing the effects of 

degradation during the subsequent period of extended operation, including any changes to 

these criteria from their prior assessment in MRP-227-A.
XI.M16A-5

5. Monitoring and Trending: The methods for monitoring, recording, evaluating, and 

trending the data that result from the program’s inspections are given in Section 6 of

MRP-227-A (as supplemented) and its subsections. Component reinspection frequencies 

for “Primary” and “Expansion” category components are defined in specific tables 

in Section 4 of the MRP-227-A report (as supplemented). The examination and

re-examinations that are implemented in accordance with MRP-227-A (as supplemented), 

together with the criteria specified in MRP-228 for inspection methodologies, inspection 

procedures, and inspection personnel, provide for timely detection, reporting, and 

implementation of corrective actions for the aging effects and mechanisms managed by 

the program.

The program applies applicable fracture toughness properties, including reductions for 

thermal aging or neutron embrittlement, in the flaw evaluations of the components in cases 

where cracking is detected in a RVI component and is extensive enough to warrant a 

supplemental flaw growth or flaw tolerance evaluation.

For singly-represented components, the program includes criteria to evaluate the aging 

effects in the inaccessible portions of the components and the resulting impact on the 

intended function(s) of the components. For redundant components (such as redundant 

bolts, screws, pins, keys, or fasteners, some of which are accessible to inspection and 

some of which are not accessible to inspection), the program includes criteria to evaluate 

the aging effects in the population of components that are inaccessible by the applicable 

inspection technique and the resulting impact on the intended function(s) of the assembly 

containing the components.

Flaw evaluation methods, including recommendations for flaw depth sizing and for crack 

growth determinations as well as for performing applicable limit load, linear elastic and 

elastic-plastic fracture analyses of relevant flaw indications, are defined in MRP-227-A 

(as supplemented).

6. Acceptance Criteria: Section 5 of MRP-227-A (as supplemented), which includes 

Table 5-1 for B&W-designed RVIs, Table 5-2 for CE-designed RVIs, and Table 5-3 for 

Westinghouse-designed RVIs, provides the specific examination and flaw evaluation 

acceptance criteria for the “Primary” and “Expansion” RVI component examination 

methods. For RVI components addressed by examinations performed in accordance with 

the ASME Code, Section XI, the acceptance criteria in IWB-3500 are applicable. For RVI 

components covered by other “Existing Programs,” the acceptance criteria are described 

within the applicable reference document. As applicable, the program establishes 

acceptance criteria for any physical measurement monitoring methods that are credited for 

aging management of particular RVI components.

This program element should justify the appropriateness of the acceptance criteria for 

managing the effects of degradation during the subsequent period of extended operation, 

including any changes to acceptance criteria based on the gap analysis.

7. Corrective Actions: Results that do not meet the acceptance criteria are addressed in 

the applicant’s corrective action program under those specific portions of the quality 

assurance (QA) program that are used to meet Criterion XVI, “Corrective Action,” of 

10 CFR Part 50, Appendix B. Appendix A of the Generic Aging Lessons Learned for 

Subsequent License Renewal (GALL-SLR) Report describes how an applicant may apply 

its 10 CFR Part 50, Appendix B, QA program to fulfill the corrective actions element of this 
XI.M16A-6

AMP for both safety-related and nonsafety-related structures and components (SCs) 

within the scope of this program.

Any detected conditions that do not satisfy the examination acceptance criteria are 

required to be dispositioned through the plant corrective action program, which may 

require repair, replacement, or analytical evaluation for continued service until the next 

inspection. The disposition will ensure that design basis functions of the reactor internals 

components will continue to be fulfilled for all licensing basis loads and events. The 

implementation of the guidance in MRP-227-A (as supplemented), plus the 

implementation of any ASME Code requirements, provides an acceptable level of aging 

management of safety-related components addressed in accordance with the corrective 

actions of 10 CFR Part 50, Appendix B or its equivalent, as applicable.

Other alternative corrective actions bases may be used to disposition relevant conditions if 

they have been previously approved or endorsed by the NRC. Alternative corrective 

actions not approved or endorsed by the NRC will be submitted for NRC approval prior to 

their implementation.

8. Confirmation Process: The confirmation process is addressed through those specific 

portions of the QA program that are used to meet Criterion XVI, “Corrective Action,” of 

10 CFR Part 50, Appendix B. Appendix A of the GALL-SLR Report describes how an 

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the confirmation 

process element of this AMP for both safety-related and nonsafety-related SCs within the 

scope of this program.

Site quality assurance procedures, review and approval processes, and administrative 

controls are implemented in accordance with the recommendations of NEI 03-08 and the 

requirements of 10 CFR Part 50, Appendix B, or their equivalent, as applicable. The 

implementation of the guidance in MRP-227-A (as supplemented), in conjunction with 

NEI 03-08 and other guidance documents, reports, or methodologies referenced in this 

AMP, provides an acceptable level of quality and an acceptable basis for confirming the 

quality of inspections, flaw evaluations, and corrective actions.

9. Administrative Controls: Administrative controls are addressed through the QA program 

that is used to meet the requirements of 10 CFR Part 50, Appendix B, associated with 

managing the effects of aging. Appendix A of the GALL-SLR Report describes how an 

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the 

administrative controls element of this AMP for both safety-related and nonsafety-related 

SCs within the scope of this program.

The administrative controls for these types of programs, including their implementing 

procedures and review and approval processes, are implemented in accordance with the 

recommended industry guidelines and criteria in NEI 03-08 and existing site 10 CFR 50 

Appendix B, Quality Assurance Programs, or their equivalent, as applicable. The 

evaluation in Section 3.5 of the NRC’s SE, Revision 1, on MRP-227-A provides the basis 

for endorsing NEI 03-08. This includes endorsement of the criteria in NEI 03-08 for 

notifying the NRC of any deviation from the I&E methodology in MRP-227-A and justifying 

the deviation no later than 45 days after its approval by a licensee executive.
XI.M16A-7

10. Operating Experience: The review and assessment of relevant operating experience 

(OE) for its impacts on the program, including implementing procedures, are governed by 

NEI 03-08 and Appendix A of MRP-227-A. Consistent with MRP-227-A, the reporting 

of inspection results and OE is treated as a “Needed” category item under the 

implementation of NEI 03-08.

The program is informed and enhanced when necessary through the systematic and 

ongoing review of both plant-specific and industry OE including research and development 

such that the effectiveness of the AMP is evaluated consistent with the discussion in 

Appendix B of the GALL-SLR Report.

References

10 CFR Part 50, Appendix B, “Quality Assurance Criteria for Nuclear Power Plants and Fuel 

Reprocessing Plants.” Washington, DC: U.S. Nuclear Regulatory Commission. 2016.

10 CFR Part 50.55a, “Codes and Standards.” Washington, DC: U.S. Nuclear Regulatory 

Commission. 2016.

ASME. ASME Code, Section V, “Nondestructive Examination.” 2004 Edition2

. New York,

New York: American Society of Mechanical Engineers.

_____. ASME Code, Section XI, “Rules for Inservice Inspection of Nuclear Power Plant

Components.” New York, New York: American Society of Mechanical Engineers. 2008. 

EPRI. EPRI Technical Report No.1022863, “Materials Reliability Program: Pressurized Water

Reactor Internals Inspection and Evaluation Guidelines (MRP-227-A).” Agencywide Documents 

Access and Management System (ADAMS) Accession No. ML12017A193 (Transmittal letter from

the EPRI-MRP) and ADAMS Accession Nos. ML12017A194, ML12017A196, ML12017A197,

ML12017A191, ML12017A192, ML12017A195 and ML12017A199 (Final Report). Palo Alto,

California: Electric Power Research Institute. December 2011.

_____. EPRI 1016609, “Materials Reliability Program: Inspection Standard for PWR Internals

(MRP-228).” (Non-publicly available ADAMS Accession No. ML092120574). The

non-proprietary version of the report may be accessed by members of the public at ADAMS

Accession No. ML092750569. Palo Alto, California: Electric Power Research Institute. 

July 2009. 

NEI. NEI 03-08, Revision 2, “Guideline for the Management of Materials Issues.” ADAMS 

Accession No. ML101050337. Washington, DC: Nuclear Energy Institute. January 2010. 

NRC. License Renewal Interim Staff Guidance LR-ISG-2011-04, “Updated Aging Management 

Criteria for Reactor Vessel Internal Components for Pressurized Water Reactors.” ADAMS 

Accession No. ML12270A436. Washington, DC: U.S. Nuclear Regulatory Commission. 

June 3, 2013.

 

2GALL-SLR Report Chapter I, Table 1, identifies the ASME Code Section XI editions and addenda that are 

acceptable to use for this AMP.
XI.M16A-8

_____.. License Renewal Interim Staff Guidance LR-ISG-2011-05, “Ongoing Review Of Operating

Experience.” ADAMS Accession No. ML12044A215. Washington, DC: U.S. Nuclear Regulatory 

Commission. March 16, 2012.

_____. Safety Evaluation from Robert A. Nelson (NRC) to Neil Wilmshurst (EPRI), “Revision 1 to 

the Final Safety Evaluation of Electric Power Research Institute (EPRI) Report, Materials 

Reliability Program (MRP) Report 1016596 (MRP-227), Revision 0, Pressurized Water Reactor 

Internals Inspection and Evaluation Guidelines.” ADAMS Accession No. ML11308A770. 

Washington, DC: U.S. Nuclear Regulatory Commission. December 16, 2011.
XI.M17-1

XI.M17 FLOW-ACCELERATED CORROSION

Program Description

This program manages wall thinning caused by flow-accelerated corrosion (FAC), and may also 

be used to manage wall thinning due to erosion mechanisms, if present, that are not being 

managed by another program. The program is based on commitments made in response to the 

U.S. Nuclear Regulatory Commission (NRC) Generic Letter (GL) 89-08, and relies on 

implementation of the Electric Power Research Institute (EPRI) guidelines in the Nuclear Safety 

Analysis Center (NSAC)-202L1 for an effective FAC program. The program includes

(a) identifying all susceptible piping systems and components; (b) developing FAC predictive 

models to reflect component geometries, materials, and operating parameters; (c) performing 

analyses of FAC models and, with consideration of operating experience (OE), selecting a sample 

of components for inspections; (d) inspecting components; (e) evaluating inspection data to 

determine the need for inspection sample expansion, repairs, or replacements, and to schedule 

future inspections; and (f) incorporating inspection data to refine FAC models. The program

includes the use of predictive analytical software, such as CHECWORKSTM, that uses the

implementation guidance of NSAC-202L. This program may also manage wall thinning caused by

mechanisms other than FAC, in situations where periodic monitoring is used in lieu of eliminating

the cause of various erosion mechanisms.

Evaluation and Technical Basis

1. Scope of Program: The FAC program, described by the EPRI guidelines in NSAC-202L, 

includes procedures or administrative controls to assure that structural integrity is 

maintained for carbon steel piping components containing single- and two-phase flow 

conditions. This program also includes the pressure retaining portions of pump and valve 

bodies within these systems. The FAC program was originally outlined in NUREG–1344 

and was further described through the NRC GL 89-08. The program may also include 

components that are subject to wall thinning due to erosion mechanisms such as 

cavitation, flashing, droplet impingement, or solid particle impingement in various water 

systems. Since there are no materials that are known to be totally resistant to wall 

thinning due to erosion mechanisms, susceptible components of any material may be 

included in the erosion portion of the program.

2. Preventive Actions: This is a condition monitoring program; no preventive action has 

been recommended in this program. However, it is noted that monitoring of water 

chemistry to control pH and dissolved oxygen content are effective in reducing FAC, and 

the selection of appropriate component material, geometry, and hydrodynamic conditions, 

can be effective in reducing both FAC and erosion mechanisms. 

3. Parameters Monitored or Inspected: The aging management program (AMP) monitors 

the effects of wall thinning due to FAC and erosion mechanisms by measuring wall 

thicknesses. In addition, relevant changes in system operating parameters, 

(e.g., temperature, flow rate, water chemistry, operating time), that result from off-normal 

or reduced-power operations are considered for their effects on the FAC models. Also, 

 

1As described in this AMP-R2 (Revision 2), -R3 (Revision 3), and –R4 (Revision 4) of NSAC-202L are acceptable 

versions of the EPRI guideline.
XI.M17-2

opportunistic visual inspections of internal surfaces are conducted during routine 

maintenance activities to identify degradation.

4. Detection of Aging Effects: Degradation of piping and components occurs by wall 

thinning. For FAC, the inspection program delineated in NSAC-202L includes 

identification of susceptible locations, as indicated by operating conditions or special 

considerations. For periods of extended operation beyond 60 years, piping systems that 

have been excluded from wall thickness monitoring due to operation less than 2 percent of 

plant operating time (as allowed by NSAC-202L) will be reassessed to ensure adequate 

bases exist to justify this exclusion. If actual wall thickness information is not available for 

use in this assessment, a representative sampling approach can be used. This program 

specifies nondestructive examination methods, such as ultrasonic testing (UT) and/or 

radiographic testing, to quantify the extent of wall thinning. Opportunistic visual 

inspections of up-stream and down-stream piping and components are performed during 

periodic pump and valve maintenance or during pipe replacements to assess internal 

surface conditions. Wall thicknesses are also measured at locations of suspected wall 

thinning that are identified by internal visual inspections. A representative sample of 

components is selected based on the most susceptible locations for wall thickness 

measurements at a frequency in accordance with NSAC-202L guidelines to identify and 

mitigate degradation before the component integrity is challenged. Expansion of the 

inspection sample is described in NSAC-202L, following identification of unexpected or 

inconsistent inspection results in the initial sample. The extent and schedule of the 

inspections provide for the detection of wall thinning before the loss of intended function. 

Inspections are performed by personnel qualified in accordance with site procedures and 

programs to perform the specified task.

For erosion mechanisms, the program includes the identification of susceptible locations

based on the extent-of-condition reviews from corrective actions in response to

plant-specific and industry OE. Components in this category may be treated in a manner

similar to other “susceptible-not-modeled” lines discussed in NSAC-202L. EPRI 1011231

provides guidance for identifying potential damage locations. EPRI TR-112657 or

NUREG/–CR6031 provides additional insights for cavitation.

5. Monitoring and Trending: For FAC, CHECWORKSTM or similar predictive software 

calculates component wear rates and remaining service life based on inspection data and 

changes in operating conditions (e.g., power uprate, water chemistry). Data from each 

component inspection are used to calibrate the wear rates calculated in the FAC model 

with the observed field data. The use of such predictive software to develop an inspection

schedule provides reasonable assurance that structural integrity will be maintained

between inspections. The program includes the evaluation of inspection results to

determine if additional inspections are needed to provide reasonable assurance that the

extent of wall thinning is adequately determined, that intended function will not be lost, and 

that corrective actions are adequately identified.

For erosion mechanisms, the program includes trending of wall thickness measurements

to adjust the monitoring frequency and to predict the remaining service life of the

component for scheduling repairs or replacements. Inspection results are evaluated to

determine if assumptions in the extent-of-condition review remain valid. If degradation is 

associated with infrequent operational alignments, such as surveillances or pump

starts/stops, then trending activities may need to consider the number or duration of these

occurrences. Periodic wall thickness measurements of replacement components may be 
XI.M17-3

required and should continue until the effectiveness of corrective actions has been

confirmed.

6. Acceptance Criteria: Components are suitable for continued service if calculations

determine that the predicted wall thickness at the next scheduled inspection will meet the

minimum allowable wall thickness. The minimum allowable wall thickness is the thickness

needed to satisfy the component’s design loads under the original code of construction,

but additional code requirements may also need to be met. A conservative safety factor is 

applied to the predicted wear rate determination to account for uncertainties in the wear

rate calculations and UT measurements. As discussed in NSAC-202L, the minimum 

safety factor for acceptable wall thickness and remaining service life should not be less 

than 1.1.

7. Corrective Actions: Results that do not meet the acceptance criteria are addressed in 

the applicant’s corrective action program under those specific portions of the quality 

assurance (QA) program that are used to meet Criterion XVI, “Corrective Action,” of 

Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B. Appendix A of 

the Generic Aging Lessons Learned for Subsequent License Renewal (GALL-SLR) Report 

describes how an applicant may apply its 10 CFR Part 50, Appendix B, QA program to 

fulfill the corrective actions element of this AMP for both safety-related and nonsafetyrelated structures and components (SCs) within the scope of this program. 

The program includes reevaluation, repair, or replacement of components for which the

acceptance criteria are not satisfied, prior to their return to service. For FAC, long-term

corrective actions could include adjusting operating parameters or replacing components

with FAC-resistant materials. However, if the wear mechanism has not been identified,

then the replaced components should remain in the inspection program because

FAC-resistant materials do not protect against erosion mechanisms. Furthermore, when

carbon steel piping components are replaced with FAC-resistant material, the susceptible

components immediately downstream should be monitored to identify any increased wear

due to the “entrance effect” as discussed in EPRI 1015072.

For erosion mechanisms, long-term corrective actions to eliminate the cause could include

adjusting operating parameters and/or changing components’ geometric designs; however,

the effectiveness of these corrective actions should be verified. Periodic monitoring

activities should continue for any component replaced with an alternate material, since a

material that is completely resistant to erosion mechanisms is not available.

8. Confirmation Process: The confirmation process is addressed through those specific 

portions of the QA program that are used to meet Criterion XVI, “Corrective Action,” of 

10 CFR Part 50, Appendix B. Appendix A of the GALL-SLR Report describes how an 

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the confirmation 

process element of this AMP for both safety-related and nonsafety-related SCs within the 

scope of this program.

9. Administrative Controls: Administrative controls are addressed through the QA program 

that is used to meet the requirements of 10 CFR Part 50, Appendix B, associated with 

managing the effects of aging. Appendix A of the GALL-SLR Report describes how an 

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the 

administrative controls element of this AMP for both safety-related and nonsafety-related 

SCs within the scope of this program.
XI.M17-4

10. Operating Experience: Wall-thinning problems in single-phase systems have occurred in 

feedwater and condensate systems [NRC Bulletin 87-01; NRC Information Notice 

(IN) 92-35, IN 95-11, IN 2006-08] and in two-phase piping in extraction steam lines (NRC 

IN 89-53, IN 97-84) and moisture separator reheater and feedwater heater drains (NRC 

IN 89-53, IN 91-18, IN 93-21, IN 97-84). Observed wall thinning may be due to 

mechanisms other than FAC or less commonly, due to a combination of mechanisms 

[NRC IN 99-19, Licensee Event Report (LER) 483/1999-003, LER 499/2005-004, 

LER 277/2006-003, LER 237/2007-003, LER 254/2009-004, LER 374/2013-001, 

LER 374/2015-001.

The program is informed and enhanced when necessary through the systematic and 

ongoing review of both plant-specific and industry OE including research and development 

such that the effectiveness of the AMP is evaluated consistent with the discussion in 

Appendix B of the GALL-SLR Report.

References

10 CFR Part 50, Appendix B, “Quality Assurance Criteria for Nuclear Power Plants and Fuel 

Reprocessing Plants.” Washington, DC: U.S. Nuclear Regulatory Commission. 2016.

EPRI. EPRI 1011231, “Recommendations for Controlling Cavitation, Flashing, Liquid Droplet 

Impingement, and Solid Particle Erosion in Nuclear Power Plant Piping Systems.” 

Palo Alto, California: Electric Power Research Institute. November 2004.

_____. EPRI 1015072, “Flow-Accelerated Corrosion–The Entrance Effect.” 

Palo Alto, California: Electric Power Research Institute. November 2007.

_____. EPRI TR–112657, “Revised Risk-Informed Inservice Inspection Evaluation Procedure.” 

Revision B-A. Agencywide Documents Access and Management System (ADAMS) Accession 

No. ML013470102. Palo Alto, California: Electric Power Research Institute. December 1999.

Licensee Event Report 237/2007-003, “Dresden Unit 2, High Pressure Coolant Injection System 

Declared Inoperable.” ADAMS Accession No. ML072750663. 

https://lersearch.inl.gov/LERSearchCriteria.aspx. September 2007.

Licensee Event Report 254/2009-004, “Quad Cities Unit 1, Pinhole Leak in Core Spray Piping 

Results in Loss of Containment Integrity and Plant Shutdown for Repairs.” ADAMS Accession 

No. ML093170206. https://lersearch.inl.gov/LERSearchCriteria.aspx. November 2009.

Licensee Event Report 277/2006-003, “Peach Bottom Unit 2, Elbow Leak on Piping Attached to 

Suppression Pool Results in Loss of Containment Integrity.” ADAMS Accession No.

ML063420059. https://lersearch.inl.gov/LERSearchCriteria.aspx. December 2006

Licensee Event Report 374/2013-001, “LaSalle Unit 2, Pin Hole Leaks Identified in High Pressure 

Core Spray Piping.” ADAMS Accession No. ML13168A576. 

https://lersearch.inl.gov/LERSearchCriteria.aspx. June 2013.

Licensee Event Report 374/2015-001, “LaSalle Unit 2, High Pressure Core Spray Inoperable Due 

to Division 3 Diesel Generator Cooling Water Pump Casing Leak.” ADAMS Accession 

No. ML15058A462. https://lersearch.inl.gov/LERSearchCriteria.aspx. February 2015.
XI.M17-5

Licensee Event Report 483/1999-003, “Callaway, Manual Reactor Trip due to Heater Drain 

System Pipe Rupture Caused by Flow Accelerated Corrosion.” ADAMS Accession 

No. ML003712775. https://lersearch.inl.gov/LERSearchCriteria.aspx. May 2000. 

Licensee Event Report 499/2005-004, “South Texas Project Unit 2, Inoperability of Essential 

Cooling Water 2A and 2B Trains.” ADAMS Accession No. ML053410155. 

https://lersearch.inl.gov/LERSearchCriteria.aspx. November 2005.

NRC. Bulletin 87-01, “Thinning of Pipe Walls in Nuclear Power Plants.” ADAMS Accession 

No. ML031210862. Washington, DC: U.S. Nuclear Regulatory Commission. July 1987.

_____. Generic Letter 89-08, “Erosion/Corrosion-Induced Pipe Wall Thinning.” ADAMS 

Accession No. ML031200731. Washington, DC: U.S. Nuclear Regulatory Commission. 

May 1989.

_____. Information Notice 89-53, “Rupture of Extraction Steam Line on High Pressure Turbine.” 

ADAMS Accession No. ML031180660. Washington, DC: U.S. Nuclear Regulatory Commission. 

June 1989.

_____. Information Notice 91-18, “High-Energy Piping Failures Caused by Wall Thinning.” 

ADAMS Accession No. ML031190529. Washington, DC: U.S. Nuclear Regulatory Commission. 

March 1991.

_____. Information Notice 91-18, “High-Energy Piping Failures Caused by Wall Thinning.” 

Supplement 1. ADAMS Accession No. ML082840749. Washington, DC: U.S. Nuclear 

Regulatory Commission. December 1991.

_____. Information Notice 92-35, “Higher than Predicted Erosion/Corrosion in Unisolable Reactor 

Coolant Pressure Boundary Piping inside Containment at a Boiling Water Reactor.” ADAMS 

Accession No. ML031200365. Washington, DC: U.S. Nuclear Regulatory Commission. 

May 1992.

_____. Information Notice 93-21, “Summary of NRC Staff Observations Compiled During

Engineering Audits or Inspections of Licensee Erosion/Corrosion Programs.” ADAMS Accession 

No. ML031080042. Washington, DC: U.S. Nuclear Regulatory Commission. March 1993.

_____. Information Notice 95-11, “Failure of Condensate Piping Because of Erosion/Corrosion at

a Flow Straightening Device.” ADAMS Accession No. ML031060332. Washington, DC: 

U.S. Nuclear Regulatory Commission. February 1995.

_____. Information Notice 97-84, “Rupture in Extraction Steam Piping as a Result of FlowAccelerated Corrosion.” ADAMS Accession No. ML031050037. Washington, DC: U.S. Nuclear 

Regulatory Commission. December 1997.

_____. Information Notice 99-19, “Rupture of the Shell Side of a Feedwater Heater at the Point 

Beach Nuclear Plant.” ADAMS Accession No. ML031040409. Washington, DC: U.S. Nuclear 

Regulatory Commission. June 1999.

_____. Information Notice 2006-08, “Secondary Piping Rupture at the Mihama Power Station in 

Japan.” ADAMS Accession No. ML052910008. Washington, DC: U.S. Nuclear Regulatory 

Commission. March 2006.
XI.M17-6

_____. License Renewal Interim Staff Guidance LR-ISG-2012-01, “Wall Thinning Due to Erosion 

Mechanisms.” ADAMS Accession No. ML12352A057. Washington, DC: U.S. Nuclear 

Regulatory Commission. April 2013.

_____. NUREG–1344, “Erosion/Corrosion-Induced Pipe Wall Thinning in U.S. Nuclear Power 

Plants.” Washington, DC: U.S. Nuclear Regulatory Commission. April 1989.

_____. NUREG/CR–6031, “Cavitation Guide for Control Valves.” Washington DC: U.S. Nuclear

Regulatory Commission. April 1993.

NSAC. NSAC-202L-R2, “Recommendations for an Effective Flow-Accelerated Corrosion

Program.” Palo Alto, California: Electric Power Research Institute, Nuclear Safety Analysis

Center (NSAC). April 1999.

_____. NSAC-202L-R3, “Recommendations for an Effective Flow-Accelerated Corrosion

Program (1011838).” Palo Alto, California: Electric Power Research Institute, Nuclear Safety

Analysis Center (NSAC). May 2006.

_____. NSAC-202L-R4, “Recommendations for an Effective Flow-Accelerated Corrosion 

Program (3002000563).” Palo Alto, California: Electric Power Research Institute, Nuclear Safety

Analysis Center (NSAC). November 2013.
XI.M18-1

XI.M18 BOLTING INTEGRITY

Program Description

The program manages aging of closure bolting for pressure retaining components. The program 

relies on recommendations for a comprehensive bolting integrity program, as delineated in the 

following documents:

 NUREG–1339, “Resolution of Generic Safety Issue 29: Bolting Degradation or Failure 

in Nuclear Power Plants.”

 Electric Power Research Institute (EPRI) NP-5769, “Degradation and Failure of Bolting in 

Nuclear Power Plants” (with the exceptions noted in NUREG–1339 for safety-related 

bolting). 

 EPRI Report 1015336, “Nuclear Maintenance Application Center: Bolted 

Joint Fundamentals.”

 EPRI Report 1015337, “Nuclear Maintenance Applications Center: Assembling Gasketed, 

Flanged Bolted Joints.” 

The program includes periodic visual inspection of closure bolting for indications of loss of 

preload, cracking, and loss of material due to general, pitting, and crevice corrosion, 

microbiologically influenced corrosion (MIC), and wear as evidenced by leakage. Closure bolting 

that is submerged or located in piping systems that contain air or gas for which leakage is difficult 

to detect, is inspected or tested by alternative means. The program also includes sampling-based 

volumetric examinations of high-strength closure bolting to detect indications of cracking. The 

program also includes preventive measures to preclude or minimize loss of preload and cracking.

Generic Aging Lessons Learned for Subsequent License Renewal (GALL-SLR) Report aging 

management program (AMP) XI.M1, “ASME Section XI Inservice Inspections, Subsections IWB, 

IWC, and IWD,” manages aging effects associated with closure bolting within the scope of 

American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code)

Section XI and supplements this bolting integrity program. GALL-SLR Report AMPs XI.S1, 

“ASME Section XI, Subsection IWE,” XI.S3, “American Society of Mechanical Engineers Boiler 

and Pressure Vessel Code (ASME Code) Section XI, Subsection IWF,” XI.S6, “Structures 

Monitoring,” XI.S7, “Inspection of Water-Control Structures Associated with Nuclear Power 

Plants,” XI.M23, “Inspection of Overhead Heavy Load and Light Load (Related to Refueling) 

Handling Systems,” manage aging effects associated with safety-related and nonsafety-related 

structural bolting, and GALL-SLR Report AMP XI.M36, “External Surfaces Monitoring of 

Mechanical Components,” manages aging effects associated with heating, ventilation, and air 

conditioning (HVAC) closure bolting. 

Evaluation and Technical Basis

1. Scope of Program: This program manages the effects of aging of closure bolting for 

pressure retaining components (aging effects associated with HVAC closure bolting are 

managed by GALL-SLR Report AMP XI.M36) within the scope of license renewal. This 

program does not manage aging of reactor head closure stud bolting (GALL-SLR Report

AMP XI.M3) or structural bolting (GALL-SLR Report AMPs XI.S1, XI.S3, XI.S6, XI.S7, 

and XI.M23).
XI.M18-2

2. Preventive Actions: Selection of bolting material and the use of lubricants and sealants 

is in accordance with the guidelines of EPRI Reports 1015336 and 1015337 and the 

additional recommendations of NUREG–1339 to prevent or mitigate stress corrosion 

cracking (SCC). Of particular note, use of molybdenum disulfide (MoS2) as a lubricant has 

been shown to be a potential contributor to SCC and should not be used. Preventive 

measures also include using bolting material that has an actual measured yield strength 

less than 150 kilo-pounds per square inch (ksi) or 1,034 megapascals (MPa). Bolting 

replacement activities include proper torquing of the bolts and checking for uniformity of 

the gasket compression after assembly. Maintenance practices require the application 

of an appropriate preload based on guidance in EPRI documents, manufacturer 

recommendations, or engineering evaluation.

3. Parameters Monitored or Inspected: This program monitors the effects of aging on the 

intended function of closure bolting. Closure bolting is inspected for signs of leakage. 

Closure bolting that is submerged or where the piping systems contains air or gas for 

which leakage is difficult to detect are inspected or tested by alternative means. High 

strength closure bolting {with actual yield strength greater than or equal to 150 ksi 

(1,034 MPa), and bolting for which yield strength is unknown, is monitored for surface and 

subsurface discontinuities indicative of cracking.

4. Detection of Aging Effects: AMP XI.M1 implements inspection of Class 1, Class 2, and 

Class 3 pressure retaining bolting in accordance with requirements of ASME Code 

Section XI, Tables IWB-2500-1, IWC-2500-1, and IWD-2500-1. These include volumetric 

and visual (i.e., VT-1, VT-2) examinations, as appropriate.

Degradation of pressure boundary closure bolting due to crack initiation, loss of preload, or 

loss of material may result in leakage from the mating surfaces or joint connections of 

pressure boundary components. Periodic inspections of ASME Code class and 

non-ASME Code class bolted joints for signs of leakage are conducted at least once per 

refueling cycle. The inspections may be performed as part of ASME Code Section XI 

leakage tests or as part of other periodic inspection activities, such as system walkdowns 

or GALL-SLR Report AMP XI.M36 inspections. Bolted joints that are not readily visible 

during plant operations and refueling outages are inspected when they are made 

accessible and at such intervals that would provide reasonable assurance the 

components’ intended functions are maintained. Closure bolting inspections includes

consideration of the guidance applicable for pressure boundary bolting in NUREG–1339 

and in EPRI NP-5769.

High strength closure bolting [actual measured yield strength greater than or equal to 

150 ksi (1,034 MPa)] may be subject to SCC. For all closure bolting greater than 2 inches 

in diameter (regardless of code classification) with actual yield strength greater than 

or equal to 150 ksi (1,034 MPa) and closure bolting for which yield strength is 

unknown, volumetric examination in accordance to that of ASME Code Section XI, 

Table IWB-2500-1, Examination Category B-G-1, is performed (e.g., acceptance 

standards, extent and frequency of examination). Specified bolting material properties 

(e.g., design and procurement specifications, fabrication and vendor drawings, material 

test reports) may be used to determine if the bolting exceeds the threshold to be classified 

as high strength.
XI.M18-3

Closure bolting in locations that preclude detection of joint leakage, such as in submerged 

environments or where the piping systems contains air or gas for which leakage is difficult 

to detect, is inspected as follows:

• Submerged closure bolting is visually inspected for loss of material during 

maintenance activities. In this case, bolt heads are inspected when made 

accessible, and bolt threads are inspected when joints are disassembled. In each 

10-year period during the subsequent period of extended operation a 

representative sample of bolt heads and threads is inspected. If opportunistic

maintenance activities will not provide access to 20 percent of the population 

(for a material/environment combination) up to a maximum of 25 bolt heads and 

threads over a 10-year period, then the subsequent license renewal application 

(SLRA) states how integrity of the bolted joint will be demonstrated. For example: 

(a) periodic pump vibration measurements are taken and trended; or (b) sump 

pump operator walkdowns are performed demonstrating that the pumps are 

appropriately maintaining sump levels.

• For closure bolting where the piping systems contains air or gas for which leakage 

is difficult to detect, the SLRA states how integrity of the bolted joint will be 

demonstrated. For example: (a) inspections are performed consistent with that of 

submerged closure bolting; (b) a visual inspection for discoloration is conducted 

when leakage of the environment inside the piping systems would discolor the 

external surfaces; (c) monitoring and trending of pressure decay is performed 

when the bolted connection is located within an isolated boundary; (d) soap 

bubble testing is performed; or (e) when the temperature of the fluid is higher than 

ambient conditions, thermography testing is performed.

• For closure bolting for components that are not normally pressurized, the SLRA

states how aging effects associated with the closure bolting will be managed 

(e.g., checking the torque to the extent that the closure bolting is not loose). 

The inspection includes a representative sample of 20 percent of the population of bolt 

heads and threads (defined as bolts with the same material and environment combination) 

or a maximum of 25 bolts per population at each unit. For multi-unit sites where the 

sample size is not based on the percentage of the population, it is acceptable to reduce 

the total number of inspections at the site as follows. For two-unit sites, 19 bolt heads and 

threads are inspected per unit and for a three-unit site, 17 bolt heads and threads are 

inspected per unit. In order to conduct 17 or 19 inspections at a unit in lieu of 25, the 

applicant states in the SLRA the basis for why the operating conditions at each unit are 

similar enough (e.g., chemistry) to provide representative inspection results. The basis 

should include consideration of potential differences such as the following:

• Are there any systems which have had an out-of-spec water chemistry condition 

for a longer period of time or out-of-spec conditions, which have occurred 

more frequently?

• For lubricating or fuel oil systems, are there any components that were exposed to 

the more severe contamination levels?
XI.M18-4

• For raw water systems, is the water source from different sources where one or the 

other is more susceptible to microbiologically influenced corrosion or other 

aging mechanisms?

Inspections are performed by personnel qualified in accordance with site procedures and 

programs to perform the specified task. Inspections within the scope of the ASME Code 

follow procedures consistent with the ASME Code. Non-ASME Code inspections follow 

site procedures that include inspection parameters for items such as lighting, distance, 

and offset, which provide an adequate examination.

5. Monitoring and Trending: Where practical, identified degradation is projected until the 

next scheduled inspection. Results are evaluated against acceptance criteria to confirm 

that the timing of subsequent inspections will maintain the components’ intended functions 

throughout the subsequent period of extended operation based on the projected rate of 

degradation. For sampling-based inspections, results are evaluated against acceptance 

criteria to confirm that the sampling bases (e.g., selection, size, frequency) will maintain

the components’ intended functions throughout the subsequent period of extended 

operation based on the projected rate and extent of degradation.

6. Acceptance Criteria: Any indications of aging effects in ASME pressure retaining bolting 

are evaluated in accordance with Section XI of the ASME Code. Leaking joints do not 

meet acceptance criteria. Plant-specific acceptance criteria are established when 

alternative inspections or testing is conducted for submerged closure bolting or closure 

bolting where the piping systems contains air or gas for which leakage is difficult to detect. 

7. Corrective Actions: Results that do not meet the acceptance criteria are addressed in 

the applicant’s corrective action program under those specific portions of the quality 

assurance (QA) program that are used to meet Criterion XVI, “Corrective Action,” of 

10 CFR Part 50, Appendix B. Appendix A of the Generic Aging Lessons Learned for 

Subsequent License Renewal (GALL-SLR) Report describes how an applicant may apply 

its 10 CFR Part 50, Appendix B, QA program to fulfill the corrective actions element of this 

AMP for both safety-related and nonsafety-related structures and components (SCs) 

within the scope of this program.

Replacement of ASME pressure retaining bolting is performed in accordance with the

requirements of ASME Code Section XI, as subject to the additional guidelines and 

recommendations of EPRI Reports 1015336 and 1015337. Replacement of other 

pressure retaining closure bolting (i.e., non-ASME Code class closure bolting) is 

performed in accordance with the guidelines and recommendations of EPRI 

Reports 1015336 and 1015337.

If a bolted connection for pressure retaining components is reported to be leaking, 

follow-up periodic visual inspections are conducted in accordance with plant-specific 

procedures until the leak is corrected. If the leak rate is increasing, more frequent 

inspections are warranted. The effects of leakage from bolted connections that have 

an intended function identified in 10 CFR 54.4(a)(2) are evaluated for its impact on 

components with an intended function identified in 10 CFR 54.4(a)(1) and located within 

the vicinity of the leaking bolted connection.

For sampling-based inspections, if the cause of the aging effect for each applicable 

material and environment is not corrected by repair or replacement for all components 
XI.M18-5

constructed of the same material and exposed to the same environment, additional 

inspections are conducted if one of the inspections does not meet acceptance criteria. 

The number of increased inspections is determined in accordance with the site’s corrective 

action process; however, there are no fewer than five additional inspections for each 

inspection that did not meet acceptance criteria, or 20 percent of each applicable material, 

environment, and aging effect combination is inspected, whichever is less. If subsequent 

inspections do not meet acceptance criteria, an extent of condition and extent of cause 

analysis is conducted to determine the further extent of inspections. Additional samples 

are inspected for any recurring degradation to ensure corrective actions appropriately 

address the associated causes. At multi-unit sites, the additional inspections include 

inspections at all of the units with the same material, environment, and aging effect 

combination. The additional inspections are completed within the interval (e.g., refueling 

outage interval, 10-year inspection interval) in which the original inspection was 

conducted. If any projected inspection results will not meet acceptance criteria prior to the 

next scheduled inspection, sampling frequencies are adjusted as determined by the site’s 

corrective action program.

8. Confirmation Process: The confirmation process is addressed through those specific 

portions of the QA program that are used to meet Criterion XVI, “Corrective Action,” of 

10 CFR Part 50, Appendix B. Appendix A of the GALL-SLR Report describes how 

an applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the 

confirmation process element of this AMP for both safety-related and nonsafety-related 

SCs within the scope of this program.

9. Administrative Controls: Administrative controls are addressed through the QA program 

that is used to meet the requirements of 10 CFR Part 50, Appendix B, associated with 

managing the effects of aging. Appendix A of the GALL-SLR Report describes how an 

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the 

administrative controls element of this AMP for both safety-related and nonsafety-related 

SCs within the scope of this program.

10. Operating Experience: Degradation of threaded bolting and fasteners in closures for the 

reactor coolant pressure boundary has occurred from boric acid corrosion, SCC, 

and fatigue loading [NRC Inspection and Enforcement Bulletin (IEB) 82-02, NRC Generic 

Letter (GL) 91-17]. SCC has occurred in high strength bolts used for nuclear steam supply 

system component supports (EPRI NP-5769). The bolting integrity program developed 

and implemented in accordance with the applicant’s docketed responses to the 

U.S. Nuclear Regulatory Commission (NRC) communications on bolting events 

have provided an effective means of ensuring bolting reliability. These programs are 

documented in EPRI Reports NP-5769, 1015336, and 1015337 and represent 

industry consensus.

Degradation related failures have occurred in downcomer tee-quencher bolting in 

boiling water reactors (BWRs) designed with drywells (ADAMS Accession No.

ML050730347). Leakage from bolted connections has been observed in reactor building 

closed cooling systems of BWRs (Licensee Event Report 341/2005-001).

SCC of A-286 stainless steel closure bolting has occurred when seal cap enclosures have 

been installed to mitigate gasket leakage at valve body-to-bonnet joints (NRC Information 

Notice 2012-15). The enclosures surrounding the bolts filled with hot reactor coolant that 
XI.M18-6

had leaked from the joint and mixed with the oxygen-containing atmosphere trapped within 

the enclosure. The enclosures did not allow for inspections of the bolted joints.

The applicant is to evaluate applicable operating experience (OE) to support the 

conclusion that the effects of aging are adequately managed.

The program is informed and enhanced when necessary through the systematic and 

ongoing review of both plant-specific and industry OE including research and development 

such that the effectiveness of the AMP is evaluated consistent with the discussion in 

Appendix B of the GALL-SLR Report.

References

10 CFR Part 50, Appendix B, “Quality Assurance Criteria for Nuclear Power Plants and Fuel 

Reprocessing Plants.” Washington DC: U.S. Nuclear Regulatory Commission. 2016.

10 CFR 50.55a, “Codes and Standards.” Washington, DC: U.S. Nuclear Regulatory 

Commission. 2016.

ASME. ASME Code Section XI, “Rules for Inservice Inspection of Nuclear Power Plant 

Components.” New York, New York: The American Society of Mechanical Engineers. 2008. 

EPRI. EPRI 1015336, “Nuclear Maintenance Application Center: Bolted Joint Fundamentals.” 

Palo Alto, California: Electric Power Research Institute. December 2007.

_____. EPRI 1015337, “Nuclear Maintenance Applications Center: Assembling Gasketed, 

Flanged Bolted Joints.” Palo Alto, California: Electric Power Research Institute. 

December 2007.

_____. EPRI NP-5769, “Degradation and Failure of Bolting in Nuclear Power Plants.” Volumes 1 

and 2. Palo Alto, California: Electric Power Research Institute. April 1988. 

Licensee Event Report 341/2005-001, “Manual Reactor Shutdown Due to Containment Cooler 

Leak.” https://lersearch.inl.gov/LERSearchCriteria.aspx. March 2005.

NRC. Generic Letter 91-17, “Generic Safety Issue 79, Bolting Degradation or Failure in Nuclear 

Power Plants.” Washington, DC: U.S. Nuclear Regulatory Commission. October 1991.

_____. IE Bulletin 82-02, “Degradation of Threaded Fasteners in the Reactor Coolant Pressure 

Boundary of PWR Plants.” Washington, DC: U.S. Nuclear Regulatory Commission. June 1982.

_____. Information Notice 2012-15, “Use of Seal Cap Enclosures to Mitigate Leakage From 

Joints That Use A-286 Bolts.” Washington, DC: U.S. Nuclear Regulatory Commission. 

August 2012.

_____. Morning Report, “Failure of Safety/Relief Valve Tee-Quencher Support Bolts.” 

Agencywide Documents Access and Management System (ADAMS) Accession 

No. ML050730347. Washington, DC: U.S. Nuclear Regulatory Commission. March 14, 2005.

_____. NUREG–1339, “Resolution of Generic Safety Issue 29: Bolting Degradation or Failure in 

Nuclear Power Plants.” Washington, DC: U.S. Nuclear Regulatory Commission. June 1990.
XI.M19-1

XI.M19 STEAM GENERATORS

Program Description

The Steam Generator program is applicable to managing the aging of steam generator tubes, 

plugs, sleeves, divider plate assemblies, tube-to-tubesheet welds, heads (interior surfaces of 

channel or lower/upper heads), tubesheet(s) (primary side), and secondary side components that 

are contained within the steam generator (i.e., secondary side internals). The aging of steam 

generator pressure vessel welds is managed by other programs such as Generic Aging Lessons 

Learned for Subsequent License Renewal (GALL-SLR) Report aging management program 

(AMP) XI.M1, “ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD,” and 

AMP XI.M2, “Water Chemistry.”

The establishment of a steam generator program for ensuring steam generator tube integrity is 

required by plant technical specifications (TS). The steam generator tube integrity portion of the 

TS at each pressurized water reactor (PWR) contains the same fundamental requirements as 

outlined in the standard TS of NUREG–1430, Volume 1, Revision 4, for Babcock & Wilcox (B&W) 

PWRs; NUREG–1431, Volume 1, Revision 4, for Westinghouse PWRs; and NUREG–1432, 

Volume 1, Revision 4, for Combustion Engineering PWRs. The requirements pertaining to steam 

generators in these three versions of the standard TS are essentially identical. The TS require 

tube integrity to be maintained and specify performance criteria, condition monitoring 

requirements, inspection scope and frequency, acceptance criteria for the plugging or repair of 

flawed tubes, acceptable tube repair methods, and leakage monitoring requirements.

The nondestructive examination techniques used to inspect steam generator components 

covered by this program are intended to identify components (e.g., tubes, plugs) with degradation 

that may need to be removed from service (e.g., tubes), repaired, or replaced, as appropriate.

The Steam Generator program at PWRs is modeled after Nuclear Energy Institute (NEI) 97-06, 

Revision 3, “Steam Generator Program Guidelines.” This program references a number of 

industry guidelines (e.g., the Electric Power Research Institute (EPRI) PWR Steam Generator 

Examination Guidelines, PWR Primary-to-Secondary Leak Guidelines, PWR Primary Water 

Chemistry Guidelines, PWR Secondary Water Chemistry Guidelines, Steam Generator Integrity 

Assessment Guidelines, Steam Generator In Situ Pressure Test Guidelines) and incorporates a 

balance of prevention, mitigation, inspection, evaluation, repair, and leakage monitoring 

measures. The NEI 97-06 document (a) includes performance criteria that are intended to 

provide assurance that tube integrity is being maintained consistent with the plant’s licensing 

basis and (b) provides guidance for monitoring and maintaining the tubes to provide assurance 

that the performance criteria are met at all times between scheduled inspections of the tubes. 

Steam generator tube integrity can be affected by degradation of steam generator plugs, sleeves, 

and secondary side components. The NEI 97-06 program has been effective in managing the 

aging effects associated with steam generator tubes, plugs, sleeves, and secondary side 

components.

Degradation of divider plate assemblies, tube-to-tubesheet welds, heads (internal surfaces), or 

tubesheets (primary side) may have safety implications. Therefore, all of these components and 

the steam generator tubes, plugs, sleeves and secondary side components are addressed by 

this AMP.
XI.M19-2

Evaluation and Technical Basis

1. Scope of Program: This program addresses degradation associated with steam 

generator tubes, plugs, sleeves, divider plate assemblies, tube-to-tubesheet welds, heads 

(interior surfaces of channel or lower/upper heads), tubesheet(s) (primary side), and 

secondary side components that are contained within the steam generator (i.e., secondary 

side internals). The program does not cover the steam generator secondary side shell, 

any nozzles attached to the secondary side shell or steam generator head, or the welds 

associated with these components. In addition, the program does not cover steam 

generator head welds (other than general corrosion of these welds caused as a result of 

degradation (defects/flaws) in the primary side cladding). 

2. Preventive Actions: This program includes preventive and mitigative actions for 

addressing degradation. Preventive and mitigative measures that are part of the Steam 

Generator program include foreign material exclusion programs, and other primary and 

secondary side maintenance activities. The program includes foreign material exclusion 

as a means to inhibit wear degradation and secondary side maintenance activities, such 

as sludge lancing, for removing deposits that may contribute to degradation. Guidance on 

foreign material exclusion is provided in NEI 97-06. Guidance on maintenance of 

secondary side integrity is provided in the EPRI Steam Generator Integrity Assessment 

Guidelines. Primary side preventive maintenance activities include replacing plugs made 

with corrosion susceptible materials with more corrosion resistant materials and 

preventively plugging tubes susceptible to degradation.

Extensive deposit buildup in the steam generators could affect tube integrity. The EPRI 

Steam Generator Integrity Assessment Guidelines, which are referenced in NEI 97-06, 

provide guidance on maintaining the secondary side of the steam generator, including 

secondary side cleaning. Secondary side water chemistry plays an important role in 

controlling the introduction of impurities into the steam generator and potentially limiting 

their deposition on the tubes. Maintaining high water purity reduces susceptibility to stress 

corrosion cracking (SCC) or intergranular stress corrosion cracking (IGSCC). Water 

chemistry is monitored and maintained in accordance with the Water Chemistry program. 

The program description and evaluation and technical basis of monitoring and maintaining 

water chemistry are addressed in the GALL-SLR Report AMP XI.M2, “Water Chemistry.”

3. Parameters Monitored or Inspected: There are currently three types of steam generator 

tubing used in the United States: (i) mill annealed Alloy 600, (ii) thermally treated 

Alloy 600, and (iii) thermally treated Alloy 690. Mill annealed Alloy 600 steam generator 

tubes have experienced degradation due to corrosion (e.g., primary water SCC, outside 

diameter SCC, intergranular attack, pitting, and wastage) and mechanically induced 

phenomena (e.g., denting, wear, impingement damage, and fatigue). Thermally treated 

Alloy 600 steam generator tubes have experienced degradation due to corrosion (primarily 

cracking) and mechanically induced phenomena (primarily wear). Thermally treated 

Alloy 690 tubes have only experienced tube degradation due to mechanically induced 

phenomena (primarily wear). 

Degradation of tube plugs, sleeves, heads, tubesheet(s), and secondary side internals has

also been observed, depending, in part, on the material of construction of the specific 

component. The potential for degradation exists for divider plate assemblies and 

tube-to-tubesheet welds, depending, in part, on the materials of construction for 

the components.
XI.M19-3

The program includes an assessment of the forms of degradation to which a component is 

susceptible and implementation of inspection techniques capable of detecting those 

forms of degradation. The parameter monitored is specific to the component and the 

acceptance criteria for the inspection. For example, the severity of tube degradation may 

be evaluated in terms of the depth of degradation or measured voltage, dependent on 

whether a depth-based or voltage-based tube repair criteria (acceptance criteria) is being 

implemented for that specific degradation mechanism. Other parameters monitored 

include signals of excessive deposit buildup (e.g., steam generator water level

oscillations), which may result in fatigue failure of tubes or corrosion of the tubes; water 

chemistry parameters, which may indicate unacceptable levels of impurities; primary-tosecondary leakage, which may indicate excessive tube, plug, or sleeve degradation; and 

the presence of loose parts or foreign objects on the primary and secondary side of the 

steam generator, which may result in tube damage.

Water chemistry parameters are also monitored and controlled, as discussed in 

GALL-SLR Report AMP XI.M2. The EPRI PWR Steam Generator Primary-to-Secondary 

Leakage Guidelines (EPRI 1022832) provides guidance on monitoring primary-tosecondary leakage. The EPRI Steam Generator Integrity Assessment Guidelines 

(EPRI 3002007571) provide guidance on secondary side activities.

In summary, the NEI 97-06 program provides guidance on parameters to be monitored or 

inspected except for steam generator divider plate assemblies, tube-to-tubesheet welds, 

heads (channel or lower/upper heads), and tubesheets. For these latter components, 

visual inspections are performed at least every 72 effective full power months or every 

third refueling outage, whichever results in more frequent inspections. These inspections 

of the steam generator head interior surfaces including the divider plate are intended to 

identify signs that cracking or loss of material may be occurring (e.g., through identification 

of rust stains).

4. Detection of Aging Effects: The TS require that a Steam Generator program be 

established and implemented to maintain the integrity of the steam generator tubes. In 

accordance with this requirement, components that could compromise tube integrity are 

properly evaluated or monitored (e.g., degradation of a secondary side component that 

could result in a loss of tube integrity is managed by this program). The inspection 

requirements in the TS are intended to detect degradation (i.e., aging effects), if they 

should occur.

The TS are performance-based, and the actual scope of the inspection and the expansion 

of sample inspections are justified based on the results of the inspections. The goal is to 

perform inspections at a frequency sufficient to provide reasonable assurance of steam 

generator tube integrity for the period of time between inspections. 

The general condition of some components (e.g., plugs, secondary side components, 

divider plates, and primary side cladding of channel heads and tubesheets) is monitored. 

It may be monitored visually, and, subsequently, more detailed inspections may be 

performed if degradation is detected.

NEI 97-06 provides additional guidance on inspection programs to detect degradation of 

tubes, sleeves, plugs, and secondary side internals. The frequencies of the inspections 

are based on technical assessments. Guidance on performing these technical 

assessments is contained in NEI 97-06 and the associated industry guidelines.
XI.M19-4

The inspections and monitoring are performed by qualified personnel using qualified 

techniques in accordance with approved licensee procedures. The EPRI PWR Steam 

Generator Examination Guidelines (EPRI 3002007572) contains guidance on the 

qualification of steam generator tube inspection techniques.

The primary-to-secondary leakage monitoring program provides a potential indicator of a 

loss of steam generator tube integrity. NEI 97-06 and the associated EPRI guidelines 

provide information pertaining to an effective leakage monitoring program.

5. Monitoring and Trending: Condition monitoring assessments are performed to 

determine whether the structural- and accident-induced leakage performance criteria were 

satisfied during the prior operating interval. Operational assessments are performed to 

verify that structural and leakage integrity will be maintained for the planned operating 

interval before the next inspection. If tube integrity cannot be maintained for the planned 

operating interval before the next inspection, corrective actions are taken in accordance 

with the plant’s corrective action program. Comparisons of the results of the condition 

monitoring assessment to the predictions of the previous operational assessment are 

performed to evaluate the adequacy of the previous operational assessment methodology. 

If the operational assessment was not conservative in terms of the number and/or severity 

of the condition, corrective actions are taken in accordance with the plant’s corrective 

action program.

The TS require condition monitoring and operational assessments to be performed 

(although the TS do not explicitly require operational assessments, these assessments are 

necessary to ensure that the tube integrity will be maintained until the next inspection). 

Condition monitoring and operational assessments are done in accordance with the TS 

requirements and guidance in NEI 97-06 and the EPRI Steam Generator Integrity 

Assessment Guidelines.

The goal of the inspection program for all components covered by this AMP is to ensure 

that the components continue to function consistent with the design and licensing basis of 

the facility (including regulatory safety margins).

Assessments of the degradation that may occur in the components covered by this AMP, 

except for steam generator divider plate assemblies, tube-to-tubesheet welds, heads, and 

tubesheets as noted above, are performed in accordance with the guidance in the EPRI 

Steam Generator Integrity Assessment Guidelines. All assessments of component 

degradation are performed to confirm that the components continue to function consistent 

with the design and licensing basis and to confirm that TS requirements are satisfied.

6. Acceptance Criteria: Assessment of tube and sleeve integrity and plugging or repair

criteria of flawed and sleeved tubes is in accordance with plant TS. The criteria for 

plugging or repairing steam generator tubes and sleeves are based on the U.S. Nuclear 

Regulatory Commission (NRC) Regulatory Guide (RG) 1.121 and are incorporated into 

plant TS. Guidance on assessing the acceptability of flaws is also provided in NEI 97-06 

and the associated EPRI guidelines, including the EPRI PWR Steam Generator 

Examination Guidelines (EPRI 3002007572), EPRI Steam Generator In-Situ Pressure 

Test Guidelines (EPRI 1025132) and EPRI Steam Generator Integrity Assessment 

Guidelines (EPRI 3002007571).
XI.M19-5

Degraded plugs, divider plate assemblies, tube-to-tubesheet welds, heads (interior 

surfaces), tubesheets (primary side), and secondary side internals are evaluated for 

continued acceptability on a case-by-case basis, as is done for leaving a loose part or a 

foreign object in a steam generator. NEI 97-06 and the associated EPRI guidelines 

provide guidance on the performance of some of these evaluations. The intent of all 

evaluations is to ensure that the components will continue to perform their functions 

consistent with the design and licensing basis of the facility, and will not affect the integrity 

of other components (e.g., by generating loose parts).

Guidance on the acceptability of primary-to-secondary leakage and water chemistry 

parameters also are discussed in NEI 97-06 and the associated EPRI guidelines.

7. Corrective Actions: Results that do not meet the acceptance criteria are addressed in 

the applicant’s corrective action program under those specific portions of the quality 

assurance (QA) program that are used to meet Criterion XVI, “Corrective Action,” of 

Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B. Appendix A of 

the GALL-SLR Report describes how an applicant may apply its 10 CFR Part 50, 

Appendix B, QA program to fulfill the corrective actions element of this AMP for both 

safety-related and nonsafety-related structures and components (SCs) within the scope of 

this program.

For degradation of steam generator tubes and sleeves (if applicable), the TS provide 

requirements on the actions to be taken when the acceptance criteria are not met. For 

degradation of other components, the appropriate corrective action is evaluated per 

NEI 97-06 and the associated EPRI guidelines, the American Society of Mechanical 

Engineers Boiler and Pressure Vessel Code (ASME Code) Section XI,

1 10 CFR 50.65, 

and 10 CFR Part 50, Appendix B, as appropriate. 

8. Confirmation Process: The confirmation process is addressed through those specific 

portions of the QA program that are used to meet Criterion XVI, “Corrective Action,” of 

10 CFR Part 50, Appendix B. Appendix A of the GALL-SLR Report describes how an 

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the confirmation 

process element of this AMP for both safety-related and nonsafety-related SCs within the 

scope of this program.

The adequacy of the preventive measures in the Steam Generator program is confirmed

through periodic inspections.

9. Administrative Controls: Administrative controls are addressed through the QA program 

that is used to meet the requirements of 10 CFR Part 50, Appendix B, associated with 

managing the effects of aging. Appendix A of the GALL-SLR Report describes how an 

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the 

administrative controls element of this AMP for both safety-related and nonsafety-related 

SCs within the scope of this program.

 

1GALL-SLR Report Chapter I, Table 1, identifies the ASME Code Section XI editions and addenda that are 

acceptable to use for this AMP.
XI.M19-6

10. Operating Experience: Several generic communications have been issued by the NRC 

related to the steam generator programs implemented at plants. The reference section 

lists many of these generic communications. In addition, NEI 97-06 provides guidance to 

the industry for routinely sharing pertinent steam generator operating experience (OE) and 

for incorporating lessons learned from plant operation into guidelines referenced in 

NEI 97-06. The latter includes providing interim guidance to the industry, when needed.

The NEI 97-06 program has been effective at managing the aging effects associated with 

steam generator tubes, plugs, sleeves, and secondary side components that are 

contained within the steam generator (i.e., secondary side internals), such that the steam 

generators can perform their intended safety function.

The program is informed and enhanced when necessary through the systematic and 

ongoing review of both plant-specific and industry OE including research and development 

such that the effectiveness of the AMP is evaluated consistent with the discussion in 

Appendix B of the GALL-SLR Report.

References

10 CFR Part 50, Appendix B, “Quality Assurance Criteria for Nuclear Power Plants and Fuel 

Reprocessing Plants.” Washington, DC: U.S. Nuclear Regulatory Commission. 2016.

10 CFR 50.55a, “Codes and Standards.” Washington, DC: U.S. Nuclear Regulatory 

Commission. 2016.

10 CFR 50.65, “Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power 

Plants.” Washington, DC: U.S. Nuclear Regulatory Commission. 2016.

ASME. ASME Code Section XI, “Rules for Inservice Inspection of Nuclear Power Plant 

Components.” New York, New York: The American Society of Mechanical Engineers. 2008.

2

EPRI. EPRI 1014986, “PWR Primary Water Chemistry Guidelines.” Revision 7, Volumes 1 and 

2. Palo Alto, California: Electric Power Research Institute. April 2014.

_____. EPRI 1016555, “PWR Secondary Water Chemistry Guidelines.” Revision 7. 

Palo Alto, California: Electric Power Research Institute. February 2009.

_____. EPRI 1022832, “PWR Primary-to-Secondary Leak Guidelines.” Revision 4. 

Palo Alto, California: Electric Power Research Institute. November 2011.

_____. EPRI 1025132, “Steam Generator In-Situ Pressure Test Guidelines.” Revision 4. 

Palo Alto, California: Electric Power Research Institute. October 2012.

_____. EPRI 3002007571, “Steam Generator Integrity Assessment Guidelines.” Revision 4. 

Palo Alto, California: Electric Power Research Institute. June 2016.

 

2GALL-SLR Report Chapter I, Table 1, identifies the ASME Code Section XI editions and addenda that are 

acceptable to use for this AMP.
XI.M19-7

_____. EPRI 3002007572, “PWR Steam Generator Examination Guidelines.” Revision 8. 

Palo Alto, California: Electric Power Research Institute. June 2016.

NEI. NEI 97-06, “Steam Generator Program Guidelines.” Revision 3. Washington, DC: Nuclear 

Energy Institute. January 2011.

NRC. Bulletin 88-02, “Rapidly Propagating Cracks in Steam Generator Tubes.” Washington, DC: 

U.S. Nuclear Regulatory Commission. February 1988.

_____. Bulletin 89-01, “Failure of Westinghouse Steam Generator Tube Mechanical Plugs.” 

Washington, DC: U.S. Nuclear Regulatory Commission. May 1989.

_____. Bulletin 89-01, “Failure of Westinghouse Steam Generator Tube Mechanical Plugs.” 

Supplement 1. Washington, DC: U.S. Nuclear Regulatory Commission. November 1990.

_____. Bulletin 89-01, “Failure of Westinghouse Steam Generator Tube Mechanical Plugs.” 

Supplement 2. Washington, DC: U.S. Nuclear Regulatory Commission. June 1991.

_____. Draft Regulatory Guide DG-1074, “Steam Generator Tube Integrity.” Washington, DC: 

U.S. Nuclear Regulatory Commission. December 1998.

_____. Generic Letter 95-03, “Circumferential Cracking of Steam Generator Tubes.” 

Washington, DC: U.S. Nuclear Regulatory Commission. April 1995.

_____. Generic Letter 95-05, “Voltage-Based Repair Criteria for Westinghouse Steam Generator 

Tubes Affected by Outside Diameter Stress Corrosion Cracking.” Washington, DC: U.S. Nuclear 

Regulatory Commission. August 1995.

_____. Generic Letter 97-06, “Degradation of Steam Generator Internals.” Washington, DC: 

U.S. Nuclear Regulatory Commission. December 1997.

_____. Generic Letter 2004-01, “Requirements for Steam Generator Tube Inspections.” 

Washington, DC: U.S. Nuclear Regulatory Commission. August 2004.

_____. Generic Letter 2006-01, “Steam Generator Tube Integrity and Associated Technical 

Specifications.” Washington, DC: U.S. Nuclear Regulatory Commission. January 2006.

_____. Information Notice 85-37, “Chemical Cleaning of Steam Generators at Millstone 2.” 

Washington, DC: U.S. Nuclear Regulatory Commission. May 1985.

_____. Information Notice 88-06, “Foreign Objects in Steam Generators.” Washington, DC: 

U.S. Nuclear Regulatory Commission. February 1988.

_____. Information Notice 88-99, “Detection and Monitoring of Sudden and/or Rapidly Increasing 

Primary-to-Secondary Leakage.” Washington, DC: U.S. Nuclear Regulatory Commission. 

December 1988.

_____. Information Notice 89-65, “Potential for Stress Corrosion Cracking in Steam Generator 

Tube Plugs Supplied by Babcock and Wilcox.” Washington, DC: U.S. Nuclear Regulatory 

Commission. September 1989.
XI.M19-8

_____. Information Notice 90-49, “Stress Corrosion Cracking in PWR Steam Generator Tubes.” 

Washington, DC: U.S. Nuclear Regulatory Commission. August 1990.

_____. Information Notice 91-19, “Steam Generator Feedwater Distribution Piping Damage.” 

Washington, DC: U.S. Nuclear Regulatory Commission. March 1991.

_____. Information Notice 91-43, “Recent Incidents Involving Rapid Increases in Primary-toSecondary Leak Rate.” Washington, DC: U.S. Nuclear Regulatory Commission. July 1991.

_____. Information Notice 91-67, “Problems with the Reliable Detection of Intergranular Attack 

(IGA) of Steam Generator Tubing.” Washington, DC: U.S. Nuclear Regulatory Commission. 

October 1991.

_____. Information Notice 92-80, “Operation with Steam Generator Tubes Seriously Degraded.” 

Washington, DC: U.S. Nuclear Regulatory Commission. December 1992.

_____. Information Notice 93-52, Draft NUREG–1477, “Voltage-Based Interim Plugging Criteria 

for Steam Generator Tubes.” Washington, DC: U.S. Nuclear Regulatory Commission. 

July 1993.

_____. Information Notice 93-56, “Weaknesses in Emergency Operating Procedures Found as a 

Result of Steam Generator Tube Rupture.” Washington, DC: U.S. Nuclear Regulatory 

Commission. July 1993.

_____. Information Notice 94-05, “Potential Failure of Steam Generator Tubes Sleeved With 

Kinetically Welded Sleeves.” Washington, DC: U.S. Nuclear Regulatory Commission. 

January 1994.

_____. Information Notice 94-43, “Determination of Primary-to-Secondary Steam Generator Leak 

Rate.” Washington, DC: U.S. Nuclear Regulatory Commission. June 1994.

_____. Information Notice 94-62, “Operational Experience on Steam Generator Tube Leaks and 

Tube Ruptures.” Washington, DC: U.S. Nuclear Regulatory Commission. August 1994.

_____. Information Notice 94-87, “Unanticipated Crack in a Particular Heat of Alloy 600 Used for 

Westinghouse Mechanical Plugs for Steam Generator Tubes.” Washington, DC: U.S. Nuclear 

Regulatory Commission. December 1994.

_____. Information Notice 94-88, “Inservice Inspection Deficiencies Result in Severely Degraded 

Steam Generator Tubes.” Washington, DC: U.S. Nuclear Regulatory Commission. 

December 1994.

_____. Information Notice 95-40, “Supplemental Information to Generic Letter 95-03, 

Circumferential Cracking of Steam Generator Tubes.” Washington, DC: U.S. Nuclear Regulatory 

Commission. September 1995.

_____. Information Notice 96-09, “Damage in Foreign Steam Generator Internals.” 

Washington, DC: U.S. Nuclear Regulatory Commission. February 1996.

_____. Information Notice 96-09, “Damage in Foreign Steam Generator Internals.” 

Supplement 1. Washington, DC: U.S. Nuclear Regulatory Commission. July 1996.
XI.M19-9

_____. Information Notice 96-38, “Results of Steam Generator Tube Examinations.” 

Washington, DC: U.S. Nuclear Regulatory Commission. June 1996.

_____. Information Notice 97-26, “Degradation in Small-Radius U-Bend Regions of Steam 

Generator Tubes.” Washington, DC: U.S. Nuclear Regulatory Commission. May 1997.

_____. Information Notice 97-49, “B&W Once-Through Steam Generator Tube Inspection 

Findings.” Washington, DC: U.S. Nuclear Regulatory Commission. July 1997.

_____. Information Notice 97-79, “Potential Inconsistency in the Assessment of the Radiological 

Consequences of a Main Steam Line Break Associated with the Implementation of Steam 

Generator Tube Voltage-Based Repair Criteria.” Washington, DC: U.S. Nuclear Regulatory 

Commission. November 1997.

_____. Information Notice 97-88, “Experiences During Recent Steam Generator Inspections.” 

Washington, DC: U.S. Nuclear Regulatory Commission. December 1997.

_____. Information Notice 98-27, “Steam Generator Tube End Cracking.” Washington, DC: 

U.S. Nuclear Regulatory Commission. July 1998.

_____. Information Notice 2000-09, “Steam Generator Tube Failure at Indian Point Unit 2.” 

Washington, DC: U.S. Nuclear Regulatory Commission. June 2000.

_____. Information Notice 2001-16, “Recent Foreign and Domestic Experience with Degradation 

of Steam Generator Tubes and Internals.” Washington, DC: U.S. Nuclear Regulatory 

Commission. October 2001.

_____. Information Notice 2002-02, “Recent Experience with Plugged Steam Generator Tubes.” 

Washington, DC: U.S. Nuclear Regulatory Commission. January 2002.

_____. Information Notice 2002-02, “Recent Experience with Plugged Steam Generator Tubes.” 

Supplement 1. Washington, DC: U.S. Nuclear Regulatory Commission. July 2002.

_____. Information Notice 2002-21, “Axial Outside-Diameter Cracking Affecting Thermally 

Treated Alloy 600 Steam Generator Tubing.” Washington, DC: U.S. Nuclear Regulatory 

Commission. June 2002.

_____. Information Notice 2002-21, “Axial Outside-Diameter Cracking Affecting Thermally 

Treated Alloy 600 Steam Generator Tubing.” Supplement 1. Washington, DC: U.S. Nuclear 

Regulatory Commission. April 2003.

_____. Information Notice 2003-05, “Failure to Detect Freespan Cracks in PWR Steam 

Generator Tubes.” Washington, DC: U.S. Nuclear Regulatory Commission. June 2003.

_____. Information Notice 2003-13, “Steam Generator Tube Degradation at Diablo Canyon.” 

Washington, DC: U.S. Nuclear Regulatory Commission. August 2003.

_____. Information Notice 2004-10, “Loose Parts in Steam Generators.” Washington, DC: 

U.S. Nuclear Regulatory Commission. May 2004.
XI.M19-10

_____. Information Notice 2004-16, “Tube Leakage Due to a Fabrication Flaw in a Replacement 

Steam Generator.” Washington, DC: U.S. Nuclear Regulatory Commission. August 2004.

_____. Information Notice 2004-17, “Loose Part Detection and Computerized Eddy Current Data 

Analysis in Steam Generators.” Washington, DC: U.S. Nuclear Regulatory Commission. 

August 2004.

_____. Information Notice 2005-09, “Indications in Thermally Treated Alloy 600 Steam Generator 

Tubes and Tube-to-Tubesheet Welds.” Washington, DC: U.S. Nuclear Regulatory Commission. 

April 2005.

_____. Information Notice 2005-29, “Steam Generator Tube and Support Configuration.” 

Washington, DC: U.S. Nuclear Regulatory Commission. October 2005.

_____. Information Notice 2007-37, “Buildup of Deposits in Steam Generators.” 

Washington, DC: U.S. Nuclear Regulatory Commission. November 2007.

_____. Information Notice 2008-07, “Cracking Indications in Thermally Treated Alloy 600 Steam 

Generator Tubes.” Washington, DC: U.S. Nuclear Regulatory Commission. April 2008.

_____. Information Notice 2010-05, “Management of Steam Generator Loose Parts and 

Automated Eddy Current Data Analysis.” Washington, DC: U.S. Nuclear Regulatory 

Commission. February 2010.

_____. Information Notice 2010-21, “Crack-Like Indication in the U-Bend Region of a Thermally 

Treated Alloy 600 Steam Generator Tube.” Washington, DC: U.S. Nuclear Regulatory 

Commission. October 2010.

_____. Information Notice 2012-07, “Tube-To-Tube Contact Resulting in Wear in Once-Through 

Steam Generators.” Washington, DC: U.S. Nuclear Regulatory Commission. July 2012.

_____. Information Notice 2013-11, “Crack-Like Indications at Dents/Dings and in the Freespan 

Region of Thermally Treated Alloy 600 Steam Generator Tubes.” Washington, DC: U.S. Nuclear 

Regulatory Commission. July 2013.

_____. Information Notice 2013-20, “Steam Generator Channel Head and Tubesheet 

Degradation.” Washington, DC: U.S. Nuclear Regulatory Commission. July 2013.

_____. NUREG–1430, “Standard Technical Specifications for Babcock and Wilcox Pressurized 

Water Reactors.” Volume 1, Revision 4. Washington DC: U.S. Nuclear Regulatory Commission. 

April 2012.

_____. NUREG–1431, “Standard Technical Specifications for Westinghouse Pressurized Water 

Reactors.” Volume 1, Revision 4. Washington DC: U.S. Nuclear Regulatory Commission. 

April 2012.

_____. NUREG–1432, “Standard Technical Specifications for Combustion Engineering 

Pressurized Water Reactors.” Volume 1, Revision 4. Washington DC: U.S. Nuclear Regulatory 

Commission. April 2012.
XI.M19-11

_____. Regulatory Guide 1.121, “Bases for Plugging Degraded PWR Steam Generator Tubes.” 

Washington, DC: U.S. Nuclear Regulatory Commission. August 1976.

_____. Regulatory Issue Summary 2000-22, “Issues Stemming from NRC Staff Review of Recent 

Difficulties Experienced in Maintaining Steam Generator Tube Integrity.” Washington DC: 

U.S. Nuclear Regulatory Commission. November 2000.

_____. Regulatory Issue Summary 2007-20, “Implementation of Primary-to-Secondary Leakage 

Performance Criteria.” Washington DC: U.S. Nuclear Regulatory Commission. August 2007.

_____. Regulatory Issue Summary 2009-04, “Steam Generator Tube Inspection Requirements.” 

Washington DC: U.S. Nuclear Regulatory Commission. April 2009.

XI.M20-1

XI.M20 OPEN-CYCLE COOLING WATER SYSTEM

Program Description

The program relies, in part, on implementing portions of the recommendations for the 

U.S. Nuclear Regulatory Commission (NRC) Generic Letter (GL) 89-13 to provide reasonable 

assurance that the effects of aging on the open-cycle cooling water (OCCW) (or service water) 

system will be managed for the subsequent period of extended operation. NRC GL 89-13 defines 

the OCCW system as a system or systems that transfer heat from safety-related systems, 

structures, and components (SSCs) to the ultimate heat sink. The program is comprised of the 

aging management aspects of the applicant’s response to NRC GL 89-13 including: (a) a 

program of surveillance and control techniques to significantly reduce the incidence of flow 

blockage problems as a result of biofouling; (b) a program to verify heat transfer capabilities of all 

safety-related heat exchangers cooled by the OCCW system; and (c) a program for routine 

inspection and maintenance to provide reasonable assurance that loss of material, corrosion, 

erosion, cracking, fouling, and biofouling cannot degrade the performance of safety-related 

systems serviced by the OCCW system. Since the guidance in NRC GL 89-13 was not 

specifically developed to address aging management, this program includes enhancements to the 

guidance in NRC GL 89-13 that address operating experience (OE) to provide reasonable 

assurance that aging effects are adequately managed.

The OCCW system program manages aging effects of components in raw water systems, such 

as service water, by using a combination of preventive, condition monitoring, and performance 

monitoring activities. These include: (a) surveillance and control techniques to manage aging 

effects caused by biofouling, corrosion, erosion, and fouling in the OCCW system or structures 

and components (SCs) serviced by the OCCW system; (b) inspection of components for signs of 

loss of material, corrosion, erosion, cracking, fouling, and biofouling; and (c) testing of the heat 

transfer capability of heat exchangers that remove heat from components important to safety. 

For buried OCCW system piping, the aging effects on the external surfaces are managed by the 

Generic Aging Lessons Learned for Subsequent License Renewal (GALL-SLR) Report aging 

management program (AMP) XI.M41, “Buried and Underground Piping and Tanks,” but the 

internal surfaces are managed by this program. The aging management of closed-cycle cooling 

water systems is described in AMP XI.M21A, “Closed Treated Water Systems,” and is not 

included as part of this program. Service water system components or components in other raw 

water systems that are not included within the scope of GL 89-13 may be managed by 

AMP XI.M38, “Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components.” 

However, water systems for fire protection are managed by AMP XI.M27, “Fire Water System.” If 

the OCCW system program manages loss of coating integrity for internal coatings or linings, the 

program includes the guidance provided in the “scope of program” program element of 

AMPXI.M42, “Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat 

Exchangers, and Tanks.”

Evaluation and Technical Basis

1. Scope of Program: The program addresses piping, piping components, piping elements, 

and heat exchanger components exposed to raw water in the OCCW system. The 

program applies to components constructed of various materials including steel, stainless 

steel (SS), aluminum, copper alloys, titanium, nickel alloy, fiberglass, polymeric materials, 

and concrete. The program may manage loss of coating integrity as provided in the 
XI.M20-2

recommendations of AMP XI.M42. This program references NRC GL 89-13; plant 

activities in response to NRC GL 89-13 may be credited for this program, as appropriate.

2. Preventive Actions: This program is primarily a condition monitoring program; however, 

some preventive actions may be effective. Implementation of NRC GL 89-13 includes 

control techniques, such as chemical treatment whenever the potential for biofouling 

exists. Treatment with chemicals mitigates microbiologically influenced corrosion (MIC)

and buildup of macroscopic biofouling debris from biota such as blue mussels, oysters, or 

clams. Periodic flushing of infrequently used cooling loops removes accumulations of 

biofouling agents, corrosion products, debris, and silt. The use of degradation resistant 

materials and the application of internal coatings or lining may be included.

3. Parameters Monitored or Inspected: This program addresses loss of material, 

reduction of heat transfer, flow blockage, and in some materials, cracking. This program: 

(a) inspects surfaces of components exposed to raw water for presence of fouling; 

(b) monitors heat transfer performance of components affected by fouling in the OCCW 

system; and (c) monitors the condition of piping and components to provide reasonable 

assurance that loss of material, loss of coating or lining integrity (when this program is 

used in lieu of AMP XI.M42), cracking, and flow blockage do not degrade the performance 

of the safety-related systems supplied by the OCCW system. For those portions of the 

OCCW system where flow monitoring is not performed, test results from the monitored 

portions of the system are used to calculate friction (or roughness) factors and are used to 

confirm that design flow rates will be achieved with the overall fouling identified in the 

system. If the aging effects associated with concrete piping are being managed, American 

Concrete Institute (ACI) 349.3R and ACI 201.R1 provide acceptable bases for parameters 

monitored or inspected.

4. Detection of Aging Effects: Inspection scope, methods (e.g., visual or volumetric 

inspections, performance testing), and frequencies are in accordance with the applicant’s 

docketed response to NRC GL 89-13. As noted in NRC GL 89-13, testing frequencies can 

be adjusted to provide assurance that equipment will perform the intended function 

between test intervals, but should not exceed 5 years. Visual inspections are used to 

identify fouling, and loss of coating or lining integrity (when this program is used in lieu of 

AMP XI.M42) and provide a qualitative assessment for loss of material due to various 

forms of corrosion and erosion. Examinations of polymeric and concrete materials should 

be consistent with the examinations described in AMP XI.M38. Volumetric examinations, 

such as ultrasonic testing, eddy current testing, and radiography are used to quantify the 

extent of wall thinning or loss of material. 

Inspections and tests are performed by personnel qualified in accordance with site 

procedures and programs to perform the specified task. Inspections within the scope of 

the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME 

Code) should follow procedures consistent with the ASME Code. Non-ASME Code 

inspections follow site procedures that include requirements for items such as lighting, 

distance, offset, surface coverage, presence of protective coatings, and cleaning 

processes. For concrete components, the qualifications of personnel performing 

inspections and evaluations are specified in ACI 349.3R.
XI.M20-3

5. Monitoring and Trending: For heat exchangers that are tested for heat transfer 

capability, test results are trended to verify adequacy of testing frequencies. For heat 

exchangers that are inspected for degradation in lieu of testing, inspection results are 

trended to evaluate adequacy of inspection frequencies. If fouling is identified, the system 

is evaluated for the impact on the heat transfer capability of the system. Friction (or 

roughness) factors are trended to confirm design flow rates can be achieved in the 

portions of the OCCW system where flow monitoring is not performed. Evidence of 

corrosion is evaluated for its potential impact on the integrity of the piping. For ongoing 

degradation due to specific aging mechanisms (e.g., MIC), the program includes trending 

of wall thickness measurements at susceptible locations to adjust the monitoring 

frequency and the number of inspection locations.

6. Acceptance Criteria: Predicted wall thicknesses at the next scheduled inspection are 

greater than the components’ minimum wall thickness requirements. As applicable, 

coatings or linings meet the acceptance criteria from AMP XI.M42. For heat exchangers, 

heat removal capability is within design values. For ongoing degradation mechanisms 

(e.g., MIC), the program includes criteria for the extent or rate of degradation that will 

prompt more comprehensive corrective actions. If concrete piping is being managed, 

acceptance criteria are derived from ACI 349.3R, as applicable. 

7. Corrective Actions: Results that do not meet the acceptance criteria are addressed in 

the applicant’s corrective action program under those specific portions of the quality 

assurance (QA) program that are used to meet Criterion XVI, “Corrective Action,” of 

Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B. Appendix A of 

the GALL-SLR Report describes how an applicant may apply its 10 CFR Part 50, 

Appendix B, QA program to fulfill the corrective actions element of this AMP for both 

safety-related and nonsafety-related SCs within the scope of this program. 

The program includes reevaluation, repair, or replacement of components that do not 

meet minimum wall thickness requirements. If fouling is identified, the overall effect is 

evaluated for reduction of heat transfer, flow blockage, loss of material, and (if applicable) 

chemical treatment effectiveness. For ongoing degradation mechanisms (e.g., MIC), the 

frequency and extent of wall thickness inspections are increased commensurate with the 

significance of the degradation.

If the cause of the aging effect for each applicable material and environment is not 

corrected by repair or replacement for all components constructed of the same material 

and exposed to the same environment, additional inspections are conducted if one of the 

inspections does not meet acceptance criteria. The number of increased inspections is 

determined in accordance with the site’s corrective action program; however, no fewer 

than five additional inspections are conducted for each inspection that did not meet 

acceptance criteria, or 20 percent of each applicable material, environment, and aging 

effect combination is inspected, whichever is less. At multi-unit sites, the additional 

inspections include inspections at all of the units with the same material, environment, and 

aging effect combination.

8. Confirmation Process: The confirmation process is addressed through those specific 

portions of the QA program that are used to meet Criterion XVI, “Corrective Action,” of 

10 CFR Part 50, Appendix B. Appendix A of the GALL-SLR Report describes how an 

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the confirmation 
XI.M20-4

process element of this AMP for both safety-related and nonsafety-related SCs within the 

scope of this program. 

9. Administrative Controls: Administrative controls are addressed through the QA program 

that is used to meet the requirements of 10 CFR Part 50, Appendix B, associated with 

managing the effects of aging. Appendix A of the GALL-SLR Report describes how an 

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the 

administrative controls element of this AMP for both safety-related and nonsafety-related 

SCs within the scope of this program. 

10. Operating Experience: Loss of material due to corrosion, including MIC and erosion, has 

been identified [NRC Information Notice (IN) 85-30, IN 2007-06, Licensee Event Reports 

(LER) 247/2001-006, LER 306/2004-001, LER 483/2005-002, LER 331/2006-003, 

LER 255/2007-002, LER 454/2007-002, LER 254/2011-001, LER 255/2013-001, 

LER 286/2014-002]. Protective coatings have failed, leading to unanticipated corrosion 

(IN 85-24, IN 2007-06, LER 286/2002-001, LER 286/2011-003). Reduction of heat 

transfer and flow blockage due to fouling has occurred in piping and in heat exchangers 

from protective coating failures, and accumulations of silt and sediment (IN 81-21, 

IN 86-96, IN 2004-07, IN 2006-17, IN 2007-28, IN 2008-11, LER 413/1999-010, 

LER 305/2000-007, LER 266/2002-003, LER 413/2003-004, LER 263/2007-004, 

LER 321/2010-002, LER 457/2011-001, LER 457/2011-002, LER 397/2013-002). 

Cracking due to stress corrosion cracking has occurred in brass tubing 

(LER 305/2002-002), and pitting in SS has occurred (LER 247/2013-004).

The review of plant-specific OE during the development of this program is to be broad and 

sufficiently detailed to detect instances of aging effects that have repeatedly occurred. In 

some instances, recurring internal corrosion may warrant program enhancements. 

Standard Review Plan for Review of Subsequent License Renewal Applications for 

Nuclear Power Plants (SRP-SLR) Sections 3.2.2.2.7, 3.3.2.2.7, and 3.4.2.2.6, “Loss of 

Material Due to Recurring Internal Corrosion,” include criteria to identify instances of 

recurring internal corrosion and recommendations for augmenting aging 

management activities.

The program is informed and enhanced when necessary through the systematic and 

ongoing review of both plant-specific and industry OE including research and development 

such that the effectiveness of the AMP is evaluated consistent with the discussion in 

Appendix B of the GALL-SLR Report.

References

10 CFR Part 50, Appendix B, “Quality Assurance Criteria for Nuclear Power Plants and Fuel 

Reprocessing Plants.” Washington, DC: U.S. Nuclear Regulatory Commission. 2016.

10 CFR 50.55a, “Codes and Standards.” Washington, DC: U.S. Nuclear Regulatory 

Commission. 2016.

ACI. ACI Standard 201.1R-08, “Guide for Conducting a Visual Inspection of Concrete in Service.” 

Farmington Hills, Michigan: American Concrete Institute. 2008.

_____. ACI Standard 349.3R-02, “Evaluation of Existing Nuclear Safety-Related Concrete 

Structures.” Farmington Hills, Michigan: American Concrete Institute. 2002.
XI.M20-5

ASME. ASME Code Section XI, “Rules for Inservice Inspection of Nuclear Power Plant 

Components.” New York, New York: The American Society of Mechanical Engineers. 2008.

1

 

EPRI. EPRI 1008282, “Life Cycle Management Sourcebook for Nuclear Plant Service Water 

Systems.” Palo Alto, California: Electric Power Research Institute. March 2005.

_____. EPRI 1010059, “Service Water Piping Guideline.” Palo Alto, California: Electric Power 

Research Institute. September 2005.

Licensee Event Report 247/2001-006, “Pipe Erosion Results in Service Water System Leakage in 

Containment.” Agencywide Documents Access and Management System (ADAMS) Accession 

No. ML020090594. https://lersearch.inl.gov/LERSearchCriteria.aspx. December 2001.

Licensee Event Report 247/2013-004, “Technical Specification Prohibited Condition Due to an 

Inoperable Essential Service Water Header as a Result of Pin Hole Leaks in Code Class 3 SW 

Piping.” ADAMS Accession No. ML13319B082. https://lersearch.inl.gov/LERSearchCriteria.aspx. 

November 2013.

Licensee Event Report 254/2011-001, “Loss of Both Divisions of Residual Heat Removal 

System.” ADAMS Accession No. ML11174A039. 

https://lersearch.inl.gov/LERSearchCriteria.aspx. June 2011.

Licensee Event Report 255/2007-002, “Inoperable Containment Due to Containment Air Cooler 

Through-Wall Flaw.” ADAMS Accession No. ML070871046. 

https://lersearch.inl.gov/LERSearchCriteria.aspx. March 2007.

Licensee Event Report 255/2013-001, “Technical Specification Required Shutdown Due to a 

Component Cooling Water System Leak.” ADAMS Accession No. ML13100A019. 

https://lersearch.inl.gov/LERSearchCriteria.aspx. April 2013.

Licensee Event Report 263/2007-004, “Degradation of Emergency Service Water Flow to 

Emergency Core Cooling System Room Cooler.” ADAMS Accession No. ML072430882. 

https://lersearch.inl.gov/LERSearchCriteria.aspx. August 2007.

Licensee Event Report 266/2002-003, “Possible Common Mode Failure of AFW Due to Partial 

Clogging of Recirculation Orifices.” ADAMS Accession No. ML032890115. 

https://lersearch.inl.gov/LERSearchCriteria.aspx. October 2003.

Licensee Event Report 286/2002-001, “Operation in a Condition Prohibited by Technical 

Specifications Due to an Inoperable Service Water Pipe Caused by a Leak that Exceeded 

Allowable Outage Time.” ADAMS Accession No. ML022000155. 

https://lersearch.inl.gov/LERSearchCriteria.aspx. July 2002.

 

1GALL-SLR Report Chapter I, Table 1, identifies the ASME Code Section XI editions and addenda that are 

acceptable to use for this AMP.
XI.M20-6

Licensee Event Report 286/2011-003, “Technical Specification Required Shutdown and a Safety 

System Functional Failure for a Leaking Service Water Pipe Causing Flooding in the SW Valve Pit 

Preventing Access for Accident Mitigation.” ADAMS Accession No. ML11123A165. 

https://lersearch.inl.gov/LERSearchCriteria.aspx. April 2011.

Licensee Event Report 286/2014-002, “Technical Specification Prohibited Condition Due to an 

Inoperable Essential Service Water Header as a Result of Socket Weld Leak in Code Class 3 SW 

Piping.” ADAMS Accession No. ML14087A009. https://lersearch.inl.gov/LERSearchCriteria.aspx. 

March 2014.

Licensee Event Report 305/2000-007, “Alternate Service Water Supply Piping Obstructed.” 

ADAMS Accession No. ML003726758. https://lersearch.inl.gov/LERSearchCriteria.aspx. 

June 2000.

Licensee Event Report 305/2002-002, “Technical Specifications Required Shutdown: CCW 

System Leak Could Not Be Repaired Within LCO.” ADAMS Accession No. ML021920465. 

https://lersearch.inl.gov/LERSearchCriteria.aspx. July 2002.

Licensee Event Report 306/2004-001, “Shutdown Required by Technical Specifications Due to 

Two Trains of Containment Cooling Inoperable.” ADAMS Accession No. ML050890314. 

https://lersearch.inl.gov/LERSearchCriteria.aspx. March 2005.

Licensee Event Report 321/2010-002, “Degraded Plant Service Water Cooling to Main Control 

Room Air Conditioner Results in Loss of Function.” ADAMS Accession No. ML101650089. 

https://lersearch.inl.gov/LERSearchCriteria.aspx. June 2010.

Licensee Event Report 331/2006-003, “Residual Heat Removal Service Water Pump Inoperable 

Due to Motor Cooler Failures.” ADAMS Accession No. ML062490486. 

https://lersearch.inl.gov/LERSearchCriteria.aspx. August 2006.

Licensee Event Report 397/2013-002, “Main Control Room Cooler Failed Surveillance.” ADAMS 

Accession No. ML13141A288. https://lersearch.inl.gov/LERSearchCriteria.aspx. May 2013.

Licensee Event Report 413/1999-010, “Both Catawba Units Operated Outside Their Design Basis 

and Unit 2 Experienced a Forced Shutdown as a Result of Flow Restriction Caused by Corrosion 

of the Auxiliary Feedwater System Assured Suction Source Piping Due to Inadequate Testing.” 

https://lersearch.inl.gov/LERSearchCriteria.aspx. July 1999.

Licensee Event Report 413/2003-004, “1A Containment Spray System Inoperable for Longer than 

Technical Specifications Allow Due to Heat Exchanger Fouling.” ADAMS Accession 

No. ML031970061. https://lersearch.inl.gov/LERSearchCriteria.aspx. July 2003.

Licensee Event Report 454/2007-002, “Technical Specification Required Shutdown of Unit 1 and 

Unit 2 Due to an Ultimate Heat Sink Pipe Leak.” ADAMS Accession No. ML080660544. 

https://lersearch.inl.gov/LERSearchCriteria.aspx. March 2008.

Licensee Event Report 457/2011-001, “Asiatic Clam Shells in Essential Service Water Supply 

Piping to the 2A Auxiliary Feedwater Pump Resulted in the Auxiliary Feedwater System 

Inoperability.” ADAMS Accession No. ML112010177. 

https://lersearch.inl.gov/LERSearchCriteria.aspx. July 2011.
XI.M20-7

Licensee Event Report 457/2011-002, “Auxiliary Feedwater System Inoperability Due to 

Additional Asiatic Clam Shells in Essential Service Water Supply Piping.” ADAMS Accession No.

ML11263A185. https://lersearch.inl.gov/LERSearchCriteria.aspx. September 2011.

Licensee Event Report 483/2005-002, “Plant Shutdown Required by Technical Specification 3.7.8 

for an Inoperable Train of Essential Service Water.” ADAMS Accession No. ML051460343. 

https://lersearch.inl.gov/LERSearchCriteria.aspx. May 2005.

NRC. Generic Letter 89-13, “Service Water System Problems Affecting Safety-Related 

Components.” Washington, DC: U.S. Nuclear Regulatory Commission. July 1989. 

_____. Generic Letter 89-13, Supplement 1, “Service Water System Problems Affecting 

Safety-Related Components.” Washington, DC: U.S. Nuclear Regulatory Commission. 

April 1990.

_____. Information Notice 81-21, “Potential Loss of Direct Access to Ultimate Heat Sink.” 

Washington, DC: U.S. Nuclear Regulatory Commission. July 1981.

_____. Information Notice 85-24, “Failures of Protective Coatings in Pipes and Heat Exchangers.” 

Washington, DC: U.S. Nuclear Regulatory Commission. March 1985.

_____. Information Notice 85-30, “Microbiologically Induced Corrosion of Containment Service 

Water System.” Washington, DC: U.S. Nuclear Regulatory Commission. April 1985.

_____. Information Notice 86-96, “Heat Exchanger Fouling Can Cause Inadequate Operability 

of Service Water Systems.” Washington, DC: U.S. Nuclear Regulatory Commission. 

November 1986.

_____. Information Notice 2004-07, “Plugging of Safety Injection Pump Lubrication Oil Coolers 

with Lakeweed.” Washington, DC: U.S. Nuclear Regulatory Commission. April 2004.

_____. Information Notice 2006-17, “Recent Operating Experience of Service Water Systems 

Due to External Conditions.” Washington, DC: U.S. Nuclear Regulatory Commission. July 2006.

_____. Information Notice 2007-06, “Potential Common Cause Vulnerabilities in Essential 

Service Water Systems.” Washington, DC: U.S. Nuclear Regulatory Commission. 

February 2007.

_____. Information Notice 2007-28, “Potential Common Cause Vulnerabilities in Essential 

Service Water Systems Due to Inadequate Chemistry Controls.” Washington, DC: U.S. Nuclear 

Regulatory Commission. September 2007.

_____. Information Notice 2008-11, “Service Water System Degradation at Brunswick Steam 

Electric Plant Unit.” Washington, DC: U.S. Nuclear Regulatory Commission. June 2008.

XI.M21A-1

XI.M21A CLOSED TREATED WATER SYSTEMS

Program Description

Nuclear power plants contain many closed, treated water systems. These systems undergo water 

treatment to control water chemistry and prevent corrosion (i.e., treated water systems). These 

systems are also recirculating systems in which the rate of recirculation is much higher than the 

rate of addition of makeup water (i.e., closed systems). This is a mitigation program that also 

includes condition monitoring to verify the effectiveness of the mitigation activities. The program 

includes: (a) water treatment, including the use of corrosion inhibitors, to modify the chemical 

composition of the water such that the function of the equipment is maintained and such that the 

effects of corrosion are minimized; (b) chemical testing of the water to demonstrate that the water 

treatment program maintains the water chemistry within acceptable guidelines; and (c) inspections 

to determine the presence or extent of degradation. Depending on the water treatment program

selected for use in association with this aging management program (AMP) and/or plant operating 

experience (OE), this program also may include corrosion monitoring (e.g., corrosion coupon 

testing) and microbiological testing. 

The water used in systems covered by this AMP may be, but need not be, demineralized and 

receives chemical treatment, including corrosion inhibitors, unless the systems meet the industry 

guidance for pure water systems. Otherwise, untreated water systems are addressed using other 

AMPs, such as Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components 

(XI.M38). Examples of systems managed by this AMP include closed-cycle cooling water 

(CCCW) systems (as defined by the U.S. Nuclear Regulatory Commission (NRC) Generic Letter 

(GL) 89-131

); closed portions of heating, ventilation, and air conditioning systems; and diesel 

generator cooling water. Examples of systems not addressed by this AMP include those systems 

containing boiling water reactor (BWR) coolant, pressurized water reactor (PWR) primary and

secondary water, and PWR/BWR condensate that does not contain corrosion inhibitors. Aging in 

these systems is managed by the water chemistry AMP (XI.M2) and the American Society of 

Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code), Section XI, Inservice 

Inspection, Subsections IWB, IWC, and IWD AMP (XI.M1).

2

 Treated fire water systems, if 

present, are also not included in this AMP.

Evaluation and Technical Basis

1. Scope of Program: This program manages the aging effects of loss of material due to 

corrosion, cracking due to stress corrosion cracking (SCC), and reduction of heat transfer 

due to fouling of the internal surfaces of piping, piping components, piping elements and 

heat exchanger components fabricated from any material and exposed to treated water.

 

1NRC GL 89-13 defines a service water system as “the system or systems that transfer heat from safety-related 

structures, systems, or components to the ultimate heat sink.” NRC GL 89-13 further defines a closed-cycle system 

as a part of the service water system that is not subject to significant sources of contamination, one in which water 

chemistry is controlled and in which heat is not directly rejected to an ultimate heat sink.

2GALL-SLR Report Chapter I, Table 1, identifies the ASME Code Section XI editions and addenda that are acceptable 

to use for this AMP.
XI.M21A-2

2. Preventive Actions: This program mitigates the aging effects of loss of material, 

cracking, and reduction of heat transfer through water treatment. The water treatment 

program includes corrosion inhibitors and is designed to maintain the function of 

associated equipment and minimize the corrosivity of the water and the accumulation of 

corrosion products that can foul heat transfer surfaces.

3. Parameters Monitored or Inspected: This program monitors water chemistry 

parameters (preventive monitoring) and the condition of surfaces exposed to the water 

(condition monitoring). Depending on the water treatment program selected for use in 

association with this AMP and/or plant OE, this program may also include corrosion 

monitoring (e.g., corrosion coupon testing) and microbiological testing. 

Water chemistry parameters (such as the concentration of iron, copper, silica, oxygen, and 

hardness, alkalinity, specific conductivity, and pH) are monitored because maintenance of 

optimal water chemistry prevents loss of material and cracking due to corrosion and SCC. 

The specific water chemistry parameters monitored and the acceptable range of values for 

these parameters are in accordance with the Electric Power Research Institute (EPRI) 

1007820 “Closed Cooling Water Chemistry Guideline,” which is used in its entirety for the 

water chemistry control or guidance.

The visual appearance of surfaces is evaluated for evidence of loss of material. The 

results of surface or volumetric examinations are evaluated for surface discontinuities 

indicative of cracking. The heat transfer capability of heat exchanger surfaces is 

evaluated by either visual inspections to determine surface cleanliness, or functional 

testing to verify that design heat removal rates are maintained.

4. Detection of Aging Effects: In this program, aging effects are detected through water 

testing and periodic inspections. Water testing determines whether the water treatment 

program effectively maintains acceptable water chemistry. Water testing frequency is 

conducted in accordance with the selected water treatment program. 

Because the control of water chemistry may not be fully effective in mitigating the aging 

effects, inspections are conducted. Visual inspections of internal surfaces are conducted 

whenever the system boundary is opened. At a minimum, in each 10-year period during 

the subsequent period of extended operation, a representative sample of 20 percent of the 

population (defined as components having the same material, water treatment program, 

and aging effect combination) or a maximum of 25 components per population at each unit 

is inspected using techniques capable of detecting loss of material, cracking, and fouling, 

as appropriate. The 20 percent minimum is surface area inspected unless the component 

is measured in linear feet, such as piping. In that case, any combination of 1-foot 

length sections and components can be used to meet the recommended extent of 

25 inspections. Technical justification for an alternative sampling methodology is included 

in the program’s documentation. For multi-unit sites where the sample size is not based 

on the percentage of the population, it is acceptable to reduce the total number of 

inspections at the site as follows. For two-unit sites, 19 components are inspected per unit 

and for a three-unit site, 17 components are inspected per unit. In order to conduct 17 or 

19 inspections at a unit in lieu of 25, the subsequent license renewal application 

includes the basis for why the operating conditions at each unit are sufficiently similar 

(e.g., flowrate, chemistry, temperature, excursions) to provide representative inspection 

results. The basis should include consideration of potential differences such as 

the following:
XI.M21A-3

• Have power uprates been performed and, if so, could more aging have occurred 

on one unit that has been in the uprate period for a longer time period?

• Are there any systems which have had an out-of-spec water chemistry condition 

for a longer period of time or out-of-spec conditions occur more frequently?

If degradation is identified in the initial sample, additional samples are inspected to 

determine the extent of the condition.

The ongoing opportunistic visual inspections are credited towards the representative 

samples for the loss of material and fouling; however, surface or volumetric examinations 

are used to detect cracking. The inspections focus on the components most susceptible 

to aging because of time in service and severity of operating conditions, including 

locations where local conditions may be significantly more severe than those in the bulk 

water (e.g., heat exchanger tube surfaces).

Inspections and tests are performed by personnel qualified in accordance with site 

procedures and programs to perform the specified task. Inspections within the scope of 

the ASME Code should follow procedures consistent with the ASME Code. Non-ASME 

Code inspections follow site procedures that include requirements for items such as 

lighting, distance, offset, surface coverage, presence of protective coatings, and 

cleaning processes.

5. Monitoring and Trending: Water chemistry data are evaluated against the standards 

contained in the selected water treatment program. These data are trended, so corrective

actions are taken, based on trends in water chemistry, prior to loss of intended function. 

Where practical, identified degradation is projected until the next scheduled inspection. 

Results are evaluated against acceptance criteria to confirm that the sampling bases 

(e.g., selection, size, frequency) will maintain the components’ intended functions 

throughout the subsequent period of extended operation based on the projected rate and 

extent of degradation.

6. Acceptance Criteria: Water chemistry concentrations are maintained within the limits 

specified in the selected industry standard documents. Due to the water chemistry 

controls, no age-related degradation is expected. Therefore, any detectable loss of 

material, cracking, or fouling is evaluated in the corrective action program.

7. Corrective Actions: Results that do not meet the acceptance criteria are addressed in 

the applicant’s corrective action program under those specific portions of the quality 

assurance (QA) program that are used to meet Criterion XVI, “Corrective Action,” of 

Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B. Appendix A of 

the Generic Aging Lessons Learned for Subsequent License Renewal (GALL-SLR) Report 

describes how an applicant may apply its 10 CFR Part 50, Appendix B, QA program 

to fulfill the corrective actions element of this AMP for both safety-related and 

nonsafety-related structures and components (SCs) within the scope of this program. 

Water chemistry concentrations that are not in accordance with the selected water 

treatment program should be returned to the normal operating range within the prescribed 

timeframe for each action level. If fouling is identified, the overall effect is evaluated for 

reduction of heat transfer, flow blockage, and loss of material.
XI.M21A-4

If the cause of the aging effect for each applicable material and environment is not 

corrected by repair or replacement for all components constructed of the same material 

and exposed to the same environment, additional inspections are conducted if one of the 

inspections does not meet acceptance criteria. The number of increased inspections is 

determined in accordance with the site’s corrective action process; however, there are no 

fewer than five additional inspections for each inspection that did not meet acceptance 

criteria, or 20 percent of each applicable material, environment, and aging effect 

combination is inspected, whichever is less. If subsequent inspections do not meet 

acceptance criteria, an extent of condition and extent of cause analysis is conducted to 

determine the further extent of inspections. Additional samples are inspected for any 

recurring degradation to ensure corrective actions appropriately address the associated 

causes. At multi-unit sites, the additional inspections include inspections at all of the units 

with the same material, environment, and aging effect combination. The additional 

inspections are completed within the interval (e.g., refueling outage interval, 10-year 

inspection interval) in which the original inspection was conducted.

8. Confirmation Process: The confirmation process is addressed through those specific 

portions of the QA program that are used to meet Criterion XVI, “Corrective Action,” of 

10 CFR Part 50, Appendix B. Appendix A of the GALL-SLR Report describes how 

an applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the 

confirmation process element of this AMP for both safety-related and nonsafety-related 

SCs within the scope of this program.

9. Administrative Controls: Administrative controls are addressed through the QA program 

that is used to meet the requirements of 10 CFR Part 50, Appendix B, associated with 

managing the effects of aging. Appendix A of the GALL-SLR Report describes how an 

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the 

administrative controls element of this AMP for both safety-related and nonsafety-related 

SCs within the scope of this program.

10. Operating Experience: Degradation of CCCW systems due to corrosion product buildup 

[Licensee Event Report (LER) 327/1993-029] or through-wall cracks in supply lines 

(LER 280/1991-019) has been observed in operating plants. In addition, SCC of stainless 

steel reactor recirculation pump seal heat exchanger coils has been attributed to localized 

boiling of the closed cooling water, concentrating water impurities on the coil surfaces 

(LER 263/2014-001). Accordingly, OE demonstrates the need for this program.

The program is informed and enhanced when necessary through the systematic and 

ongoing review of both plant-specific and industry OE including research and development 

such that the effectiveness of the AMP is evaluated consistent with the discussion in 

Appendix B of the GALL-SLR Report.

References

10 CFR Part 50, Appendix B, “Quality Assurance Criteria for Nuclear Power Plants and Fuel 

Reprocessing Plants.” Washington, DC: U.S. Nuclear Regulatory Commission. 2016. 

10 CFR 50.55a, “Codes and Standards.” Washington, DC: U.S. Nuclear Regulatory 

Commission. 2016. 
XI.M21A-5

ASME. ASME Code Section XI, “Rules for Inservice Inspection of Nuclear Power Plant 

Components.” New York, New York: The American Society of Mechanical Engineers. 2008. 3

EPRI. EPRI 1007820, “Closed Cooling Water Chemistry Guideline.” Palo Alto, California: 

Electric Power Research Institute. April 2004. 

Flynn, Daniel. The Nalco Water Handbook. Nalco Company. 2009.

Licensee Event Report 263/2014-001, “Primary System Leakage Found in Recirculation Pump 

Upper Seal Heat Exchanger.” Agencywide Documents Access and Management System 

(ADAMS) Accession No. ML14073A599. https://lersearch.inl.gov/LERSearchCriteria.aspx. 

March 2014. 

Licensee Event Report 280/1991-019, “Loss of Containment Integrity due to Crack in Component 

Cooling Water Piping.” https://lersearch.inl.gov/LERSearchCriteria.aspx. October 1991.

Licensee Event Report 327/1993-029, “Inoperable Check Valve in the Component Cooling 

System as a Result of a Build-Up of Corrosion Products between Valve Components.” 

https://lersearch.inl.gov/LERSearchCriteria.aspx. December 1993.

NRC. Generic Letter 89-13, “Service Water System Problems Affecting Safety-Related 

Components.” Washington, DC: U.S. Nuclear Regulatory Commission. July 1989.

_____. Generic Letter 89-13, Supplement 1, “Service Water System Problems Affecting 

Safety-Related Components.” Washington, DC: U.S. Nuclear Regulatory Commission. 

April 1990.

 

3GALL-SLR Report Chapter I, Table 1, identifies the ASME Code Section XI editions and addenda that are 

acceptable to use for this AMP.

XI.M22-1

XI.M22 BORAFLEX MONITORING

Program Description

Many neutron‐absorbing materials, such as Boraflex, Boral, Metamic, boron steel, and 

carborundum, are used in spent fuel pools. This aging management program (AMP) addresses 

aging management of spent fuel pools using Boraflex as the neutron‐absorbing material. Generic 

Aging Lessons Learned for Subsequent License Renewal (GALL-SLR) Report AMP XI.M40, 

“Monitoring of Neutron‐Absorbing Material Other Than Boraflex,” addresses aging management of 

spent fuel pools using neutron‐absorbing materials other than Boraflex, such as Boral, Metamic, 

boron steel, and carborundum. When a spent fuel pool criticality analysis credits Boraflex and 

materials other than Boraflex, the guidance in both GALL-SLR Report AMPs XI.M22 and 

XI.M40 applies.

For Boraflex panels in spent fuel storage racks, gamma irradiation and long-term exposure to the 

wet fuel pool environment causes shrinkage resulting in gap formation, gradual degradation of the 

polymer matrix, and the release of silica to the spent fuel storage pool water. This results in the 

loss of boron carbide in the neutron absorber sheets. A monitoring program for the Boraflex 

panels in the spent fuel storage racks is implemented to assure that no unexpected degradation of 

the Boraflex material compromises the criticality analysis in support of the design of spent fuel 

storage racks. This AMP relies on periodic inspection, testing, monitoring, and analysis of the 

criticality design to assure that the required 5 percent subcriticality margin is maintained. 

Therefore, this AMP includes: (a) completing sampling and analysis for silica levels in the spent 

fuel pool water on a regular basis, such as monthly, quarterly, or annually (depending on Boraflex 

panel condition), and trending the results by using the Electric Power Research Institute (EPRI) 

RACKLIFE predictive code or its equivalent; and (b) performing neutron attenuation testing to 

determine gap formation in Boraflex panels or measuring boron-10 areal density by techniques 

such as the BADGER device.

Evaluation and Technical Basis

1. Scope of Program: This program manages the effect of reduction in neutron-absorbing 

capacity due to degradation in sheets of neutron-absorbing material made of Boraflex 

affixed to spent fuel racks.

2. Preventive Actions: This program is a performance monitoring program and does not 

include preventive actions.

3. Parameters Monitored or Inspected: The parameters monitored include physical 

conditions of the Boraflex panels, such as gap formation and decreased boron-10 areal 

density, and the concentration of the silica in the spent fuel pool. These are conditions 

directly related to degradation of the Boraflex material. When Boraflex is subjected to 

gamma radiation and long-term exposure to the spent fuel pool environment, the silicon 

polymer matrix becomes degraded and silica filler and boron carbide are released into the 

spent fuel pool water. As indicated in the U.S. Nuclear Regulatory Commission (NRC) 

Information Notice (IN) 95-38 and NRC Generic Letter (GL) 96-04, the loss of boron 

carbide (washout) from Boraflex is characterized by slow dissolution of silica from the 

surface of the Boraflex and a gradual thinning of the material. Because Boraflex contains 

about 25 percent silica, 25 percent polydimethyl siloxane polymer, and 50 percent boron 

carbide, sampling and analysis for the presence of silica in the spent fuel pool provide an 
XI.M22-2

indication of depletion of boron carbide from Boraflex; however, the degree to which 

Boraflex has degraded is ascertained through measurement of the boron-10 areal density. 

4. Detection of Aging Effects: Aging effects on Boraflex panels are detected by monitoring 

silica levels in the spent fuel storage pool on a regular basis, such as monthly, quarterly, or 

annually (depending on Boraflex panel condition); by measuring boron-10 areal density on 

a frequency determined by the material condition of the Boraflex panels, with a minimum 

frequency of once every 5 years; and by applying predictive methods to the measured 

results. The amount of boron-10 carbide present in the Boraflex panels is determined

through direct measurement of boron-10 areal density by periodic verification of boron-10 

loss through areal density measurement techniques, such as the BADGER device. 

Frequent Boraflex testing is sufficient to verify that Boraflex panel degradation does not 

compromise criticality analysis for the spent fuel pool storage racks. Additionally, changes 

in the level of silica present in the spent fuel pool water provide an indication of changes in 

the rate of degradation of Boraflex panels. 

5. Monitoring and Trending: The periodic inspection measurements and analysis are 

compared to values of previous measurements and analysis providing a continuing level 

of data for trend analysis. Sampling and analysis for silica levels in the spent fuel pool 

water is performed on a regular basis, such as monthly, quarterly, or annually (depending 

on Boraflex panel condition), and results are trended using the EPRI RACKLIFE predictive 

code or its equivalent. Silica concentration is monitored against time to trend degradation. 

Rapid increases of silica concentration may indicate accelerated Boraflex degradation. 

The frequency to perform boron-10 areal density testing will be determined by the material 

condition of the Boraflex panels, with an interval not to exceed 5 years.

6. Acceptance Criteria: The 5 percent subcriticality margin of the spent fuel racks is 

maintained for the subsequent period of extended operation.

7. Corrective Actions: Results that do not meet the acceptance criteria are addressed in 

the applicant’s corrective action program under those specific portions of the quality 

assurance (QA) program that are used to meet Criterion XVI, “Corrective Action,” of 

Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B. Appendix A of 

the GALL-SLR Report describes how an applicant may apply its 10 CFR Part 50, 

Appendix B, QA program to fulfill the corrective actions element of this AMP for both 

safety-related and nonsafety-related structures and components (SCs) within the scope of 

this program. 

Corrective actions are initiated if the test results find that the 5 percent subcriticality margin 

cannot be maintained because of the current or projected future degradation. Corrective 

actions consist of providing additional neutron-absorbing capacity by Boral or boron steel 

inserts or other options which are available to maintain a subcriticality margin of 5 percent. 

8. Confirmation Process: The confirmation process is addressed through those specific 

portions of the QA program that are used to meet Criterion XVI, “Corrective Action,” of 

10 CFR Part 50, Appendix B. Appendix A of the GALL-SLR Report describes how 

an applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the 

confirmation process element of this AMP for both safety-related and nonsafety-related 

SCs within the scope of this program.
XI.M22-3

9. Administrative Controls: Administrative controls are addressed through the QA program 

that is used to meet the requirements of 10 CFR Part 50, Appendix B, associated with 

managing the effects of aging. Appendix A of the GALL-SLR Report describes how an 

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the 

administrative controls element of this AMP for both safety-related and nonsafety-related 

SCs within the scope of this program. 

10. Operating Experience: NRC IN 87-43 addresses the problems of development of tears 

and gaps (average 1-2 inches, with the largest 4 inches) in Boraflex sheets due to gamma 

radiation-induced shrinkage of the material. NRC IN 93-70, NRC IN 95-38, and NRC 

GL 96-04 address several cases of significant degradation of Boraflex test coupons due to 

accelerated dissolution of Boraflex caused by pool water flow through panel enclosures 

and high accumulated gamma dose. In such cases, the Boraflex may be replaced by 

boron steel inserts or by a completely new rack system using Boral. Experience with 

boron steel is limited; however, the application of Boral for use in the spent fuel storage 

racks predates the manufacturing and use of Boraflex. The experience with Boraflex 

panels indicates that coupon surveillance programs are not reliable. Therefore, during the 

subsequent period of extended operation, the measurement of boron-10 areal density 

correlated, through a predictive code, with silica levels in the pool water, is verified. These 

monitoring programs provide assurance that degradation of Boraflex sheets is monitored 

so that appropriate actions can be taken in a timely manner if significant loss of 

neutron-absorbing capability is occurring. These monitoring programs provide reasonable 

assurance that the Boraflex sheets maintain their integrity and are effective in performing 

their intended function. 

The program is informed and enhanced when necessary through the systematic and 

ongoing review of both plant-specific and industry operating experience including research

and development such that the effectiveness of the AMP is evaluated consistent with the 

discussion in Appendix B of the GALL-SLR Report.

References

10 CFR Part 50, Appendix B, “Quality Assurance Criteria for Nuclear Power Plants and Fuel 

Reprocessing Plants.” Washington, DC: U.S. Nuclear Regulatory Commission. 2016.

EPRI. EPRI 1003413, “Guidance and Recommended Procedure for Maintaining and Using 

RACKLIFE Version 1.10.” Palo Alto, California: Electric Power Research Institute. April 2002.

_____. EPRI NP-6159, “An Assessment of Boraflex Performance in Spent-Nuclear-Fuel Storage 

Racks.” Palo Alto, California: Electric Power Research Institute. December 1988.

_____. EPRI TR–101986, “Boraflex Test Results and Evaluation, Electric Power Research 

Institute.” Palo Alto, California: Electric Power Research Institute. March 1993.

_____. EPRI TR–103300, “Guidelines for Boraflex Use in Spent-Fuel Storage Racks.” 

Palo Alto, California: Electric Power Research Institute. December 1993.

NRC. BNL–NUREG–25582, “Corrosion Considerations in the Use of Boral in Spent Fuel Storage 

Pool Racks.” Washington, DC: U.S. Nuclear Regulatory Commission. January 1979.
XI.M22-4

_____. Generic Letter 96-04, “Boraflex Degradation in Spent Fuel Pool Storage Racks.” 

Agencywide Documents Access and Management System (ADAMS) Accession No.

ML031110008. Washington, DC: U.S. Nuclear Regulatory Commission. June 26, 1996.

_____. Information Notice 87-43, “Gaps in Neutron Absorbing Material in High Density Spent 

Fuel Storage Racks.” ADAMS Accession No. ML031130349. Washington, DC: U.S. Nuclear 

Regulatory Commission. September 8, 1987.

_____. Information Notice 93-70, “Degradation of Boraflex Neutron Absorber Coupons.” ADAMS 

Accession No. ML031070107. Washington, DC: U.S. Nuclear Regulatory Commission. 

September 10, 1993.

_____. Information Notice 95-38, “Degradation of Boraflex Neutron Absorber in Spent Fuel 

Storage Racks.” ADAMS Accession No. ML031060277. Washington, DC: U.S. Nuclear 

Regulatory Commission. September 8, 1995.

_____. Regulatory Guide 1.26, Revision 3, “Quality Group Classifications and Standards for 

Water, Steam, and Radioactive-Waste-Containing Components of Nuclear Power Plants 

(for Comment).” ADAMS Accession No. ML003739964. Washington, DC: U.S. Nuclear 

Regulatory Commission. February 29, 1979.
XI.M23-1

XI.M23 INSPECTION OF OVERHEAD HEAVY LOAD AND LIGHT LOAD 

(RELATED TO REFUELING) HANDLING SYSTEMS

Program Description

The Inspection of Overhead Heavy Load and Light Load (Related to Refueling) Handling Systems 

program evaluates the effectiveness of maintenance monitoring activities for cranes and hoists 

that are within the scope of license renewal. This program addresses the inspection and 

monitoring of crane-related structures and components to provide reasonable assurance that the 

handling system does not affect the intended function of nearby safety-related equipment. Many 

crane systems and components are not within the scope of this program because they perform an 

intended function with moving parts or with a change in configuration, or they are subject to 

replacement based on qualified life. 

The program includes periodic visual inspections to detect loss of material due to general 

corrosion and wear, deformed or cracked bridges, structural members, and structural 

components; and loss of material due to general corrosion, cracking and loss of preload on bolted 

connections. NUREG-0612, “Control of Heavy Loads at Nuclear Power Plants,” provides specific 

guidance on the control of overhead heavy load cranes. The activities to manage aging effects 

specified in this program utilize the guidance provided in American Society of Mechanical 

Engineers (ASME) Safety Standard B30.2, “Overhead and Gantry Cranes (Top Running Bridge, 

Single or Multiple Girder, Top Running Trolley Hoist),” which is referenced by NUREG–0612, or 

other appropriate standards in the ASME B30 series. In addition, monitoring and maintenance of 

structural components of crane handling systems follow the maintenance rule requirements 

provided in Title 10 of the Code of Federal Regulations (10 CFR) 50.65 for other crane types.

Evaluation and Technical Basis

1. Scope of Program: The program manages the aging effects associated with handling 

systems that are within the scope of 10 CFR 54.4. Portions of the handling system that 

are within the scope of this program include the bridges, structural members, and 

structural components. 

2. Preventive Actions: This program is a condition monitoring program. No preventive 

actions are identified. 

3. Parameters Monitored or Inspected: Surface condition is monitored by visual inspection 

to provide reasonable assurance that loss of material is not occurring due to general 

corrosion or wear and the bridges, structural members, and structural components do not 

exhibit deformation or cracking. In addition, bolted connections are monitored for loss of 

material, cracking, and loose bolts, missing or loose nuts, and other conditions indicative 

of loss of preload. 

4. Detection of Aging Effects: Load handling systems are visually inspected at a frequency 

in accordance ASME B30.2, “Overhead and Gantry Cranes (Top Running Bridge, Single 

or Multiple Girder, Top Running Trolley Hoist),” or other appropriate standard in the 

ASME B30 series. ASME B30.2 establishes inspection frequencies based on the severity 

of service, as defined by the number and magnitude of lifts. For systems that are 

infrequently in service, such as containment polar cranes, periodic inspections are 

performed once every refueling cycle just prior to use. Visual inspections consist of the 

following:
XI.M23-2

• Bridges, structural members, and structural components are visually inspected for 

loss of material due to general corrosion; deformation; cracking, and wear.

• Bolted connections are visually inspected for loss of material due to general 

corrosion; cracking; and loose or missing bolts or nuts, and other conditions 

indicative of loss of preload.

Visual inspection activities are performed by personnel qualified in accordance with 

plant-specific procedures and processes.

5. Monitoring and Trending: Deficiencies are documented using plant-specific processes 

and procedures, such that results can be trended; however, the program does not include 

formal trending. 

6. Acceptance Criteria: Any visual indication of loss of material, deformation, or cracking, 

and any visual sign of loss of bolting preload is evaluated according to ASME B30.2 or 

other applicable industry standard in the ASME B30 series.

7. Corrective Actions: Results that do not meet the acceptance criteria are addressed in 

the applicant’s corrective action program under those specific portions of the quality 

assurance (QA) program that are used to meet Criterion XVI, “Corrective Action,” of 

10 CFR Part 50, Appendix B. Appendix A of the Generic Aging Lessons Learned for 

Subsequent License Renewal (GALL-SLR) Report describes how an applicant may apply 

its 10 CFR Part 50, Appendix B, QA program to fulfill the corrective actions element of this 

aging management program (AMP) for both safety-related and nonsafety-related 

structures and components (SCs) within the scope of this program. 

Repairs are performed as specified in ASME B30.2 or other appropriate standard in the 

ASME B30 series.

8. Confirmation Process: The confirmation process is addressed through those specific 

portions of the QA program that are used to meet Criterion XVI, “Corrective Action,” of 

10 CFR Part 50, Appendix B. Appendix A of the GALL-SLR Report describes how an 

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the confirmation 

process element of this AMP for both safety-related and nonsafety-related SCs within the 

scope of this program.

9. Administrative Controls: Administrative controls are addressed through the QA program 

that is used to meet the requirements of 10 CFR Part 50, Appendix B, associated with 

managing the effects of aging. Appendix A of the GALL-SLR Report describes how an 

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the 

administrative controls element of this AMP for both safety-related and nonsafety-related 

SCs within the scope of this program. 

10. Operating Experience: There has been no history of corrosion-related degradation that 

threatened the ability of a crane to perform its intended function. Likewise, because 

cranes have not been operated beyond their design lifetime, there have been no 

significant fatigue-related structural failures. Operating experience indicates that loss of 

bolt preload has occurred, but not to the extent that it has threatened the ability of a crane 

structure to perform its intended function.
XI.M23-3

The program is informed and enhanced when necessary through the systematic and 

ongoing review of both plant-specific and industry operating experience including research

and development such that the effectiveness of the AMP is evaluated consistent with the 

discussion in Appendix B of the GALL-SLR Report.

References

10 CFR Part 50, Appendix B, “Quality Assurance Criteria for Nuclear Power Plants and Fuel 

Reprocessing Plants.” Washington, DC: U.S. Nuclear Regulatory Commission. 2016.

10 CFR 54.4, “Scope.” Washington, DC: U.S. Nuclear Regulatory Commission. 2015.

ASME. Safety Standard B30.2, “Overhead and Gantry Cranes (Top Running Bridge, Single or 

Multiple Girder, Top Running Trolley Hoist).” New York, New York: American Society of 

Mechanical Engineers. 2005.

NRC. Generic Letter 80-113, “Control of Heavy Loads.” Agencywide Documents Access and 

Management System (ADAMS) Accession No. ML071080219. Washington, DC: U.S. Nuclear 

Regulatory Commission. December 22, 1980.

_____. Generic Letter 81-07, “Control of Heavy Loads.” ADAMS Accession No. ML031080524. 

Washington, DC: U.S. Nuclear Regulatory Commission. February 3, 1981.

_____. NUREG–0612, “Control of Heavy Loads at Nuclear Power Plants.” ADAMS Accession 

No. ML070250180. Washington, DC: U.S. Nuclear Regulatory Commission. July 31, 1980.

_____. Regulatory Guide 1.160, “Monitoring the Effectiveness of Maintenance at Nuclear Power 

Plants.” Revision 2. ADAMS Accession No. ML003761662. U.S. Nuclear Regulatory 

Commission, March 31, 1997.

XI.M24-1

XI.M24 COMPRESSED AIR MONITORING

Program Description

The purpose of the compressed air monitoring program is to provide reasonable assurance of the 

integrity of the compressed air system downstream of the instrument air dryers. The program 

consists of monitoring moisture content, corrosion, and performance of the compressed air 

system. This includes (a) preventive monitoring of water (moisture) and other potentially corrosive

contaminants to keep within the specified limits; and (b) opportunistic inspection of components 

for indications of loss of material due to corrosion.

This aging management program (AMP) does not change the applicant’s docketed response to 

U.S. Nuclear Regulatory Commission (NRC) Generic Letter (GL) 88-14 for the rest of its 

operations. The AMP also incorporates the air quality provisions provided in the guidance of the 

Electric Power Research Institute (EPRI) TR-108147. The American Society of Mechanical 

Engineers (ASME) operations and maintenance standards and guides (ASME OM-2012, 

Division 2, Part 28) provides additional guidance for maintenance of the instrument air system by 

offering recommended test methods, test intervals, parameters to be measured and evaluated, 

and records requirements.

Evaluation and Technical Basis

1. Scope of Program: The program manages the aging effects of loss of material due to 

corrosion in compressed air system components located downstream of the compressed 

air system air dryers, or for components exposed to an internal gas environment 

(e.g., nitrogen-filled accumulators). Aging effects associated with components located 

upstream of the air dryers, or those exposed to an air environment that is not subject to 

the preventive actions of this program, are managed by Generic Aging Lessons Learned 

for Subsequent License Renewal (GALL-SLR) Report AMP XI.M38, “Inspection of Internal 

Surfaces in Miscellaneous Piping and Ducting Components.”

2. Preventive Actions: For the purposes of aging management, moisture and other 

corrosive contaminants in the system’s air are maintained below specified limits to provide 

reasonable assurance that the system and components maintain their intended functions. 

These limits are prepared from consideration of the manufacturer’s recommendations for 

individual components and guidelines based on ASME OM-2012, Division 2, Part 28; 

ANSI/ISA-7.0.01-1996; and EPRI TR–108147.

3. Parameters Monitored or Inspected: Periodic air samples are taken and analyzed for 

moisture content and corrosive contaminants. Opportunistic visual inspections of 

accessible internal surfaces are performed for signs of corrosion and abnormal corrosion 

products that might indicate a loss of material within the system.

4. Detection of Aging Effects: The program periodically samples and tests the air in the 

compressed system in accordance with industry standards (i.e., ANSI/ISA-7.0.01-1996). 

Compressed air systems have in-line dew point instrumentation that either continuously 

monitors using an automatic alarm system or is checked at least daily to determine 

whether moisture content is within the recommended range. Additionally, opportunistic

visual inspections of component internal surfaces exposed to an air-dry environment are 

performed for signs of loss of material due to corrosion. Guidance for inspection 
XI.M24-2

frequency and inspection methods of these components is provided in standards or 

documents such as ASME OM-2012, Division 2, Part 28.

Inspections and tests are performed by personnel qualified in accordance with site 

procedures and programs to perform the specified task.

5. Monitoring and Trending: If daily readings of system dew points are taken, they are 

recorded and trended. Air quality analysis results are reviewed to determine if alert levels 

or limits have been reached or exceeded. This review also checks for unusual trends. 

ASME OM-2012, Division 2, Part 28, provides guidance for monitoring and trending data. 

The effects of corrosion are monitored by visual inspection. Test data are analyzed and 

compared to data from previous tests to provide for the timely detection of aging effects on 

passive components.

6. Acceptance Criteria: Acceptance criteria for air quality moisture limits are established 

based on accepted industry standards, such as American National Standards 

Institute/International Society of Automation (ANSI/ISA)-7.0.01-1996. Internal surfaces do

not show signs of corrosion (general, pitting, and crevice) that could indicate the potential 

loss of function of the component. Suppliers’ certifications can be used to demonstrate 

that bottled gases meet acceptable quality standards. 

7. Corrective Actions: Results that do not meet the acceptance criteria are addressed in 

the applicant’s corrective action program under those specific portions of the quality 

assurance (QA) program that are used to meet Criterion XVI, “Corrective Action,” of 

Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B. Appendix A of 

the Generic Aging Lessons Learned for Subsequent License Renewal (GALL-SLR) Report 

describes how an applicant may apply its 10 CFR Part 50, Appendix B, QA program to 

fulfill the corrective actions element of this AMP for both safety-related and nonsafetyrelated structures and components (SCs) within the scope of this program.

Corrective actions are taken if any parameters, such as moisture content in the system air, 

are out of acceptable ranges, or if corrosion is identified on internal surfaces. 

8. Confirmation Process: The confirmation process is addressed through those specific 

portions of the QA program that are used to meet Criterion XVI, “Corrective Action,” of 

10 CFR Part 50, Appendix B. Appendix A of the GALL-SLR Report describes how an 

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the confirmation 

process element of this AMP for both safety-related and nonsafety-related SCs within the 

scope of this program.

9. Administrative Controls: Administrative controls are addressed through the QA program 

that is used to meet the requirements of 10 CFR Part 50, Appendix B, associated with 

managing the effects of aging. Appendix A of the GALL-SLR Report describes how an 

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the 

administrative controls element of this AMP for both safety-related and nonsafety-related 

SCs within the scope of this program. 

10. Operating Experience: Potentially significant safety-related problems pertaining to air 

systems have been documented in NRC Information Notice (IN) 81-38; IN 87-28; 

IN 87-28, Supplement 1; and Licensee Event Report 237/94-005-3. Some of the systems 

that have been significantly degraded or that have failed due to the problems in the air 
XI.M24-3

system include the decay heat removal, auxiliary feedwater, main steam isolation, 

containment isolation, and fuel pool seal systems. In 2008, one plant incurred an 

unplanned reactor trip from a failure of a mechanical joint in the instrument air system 

(NRC IN 2008-06). Nevertheless, as a result of NRC GL 88-14 and in consideration of

Institute of Nuclear Power Operations Significant Operating Experience Report (INPO 

SOER) 88-01 and EPRI TR–108147, performance of air systems has improved

significantly.

The program is informed and enhanced when necessary through the systematic and 

ongoing review of both plant-specific and industry operating experience including research

and development such that the effectiveness of the AMP is evaluated consistent with the 

discussion in Appendix B of the GALL-SLR Report.

References

10 CFR Part 50, Appendix B, “Quality Assurance Criteria for Nuclear Power Plants and Fuel 

Reprocessing Plants.” Washington, DC: U.S. Nuclear Regulatory Commission. 2016.

ANSI. ANSI/ISA-7.0.01-1996, “Quality Standard for Instrument Air.” Washington, DC: American 

National Standards Institute. 1996.

ASME. ASME OM-2012, “Performance Testing of Instrument Air Systems in Light-Water Reactor 

Power Plants.” Division 2, Part 28. New York, New York: American Society of Mechanical 

Engineers. 2012.

EPRI. EPRI TR–108147, “Compressor and Instrument Air System Maintenance Guide: Revision 

to NP-7079.” Palo Alto, California: Electric Power Research Institute. March 1998.

INPO. INPO Significant Operating Experience Report 88-01, “Instrument Air System Failures.” 

Atlanta, Georgia: Institute of Nuclear Power Operations. May 1988.

Licensee Event Report 237/94-005-3, “Manual Reactor Scram due to Loss of Instrument Air 

Resulting from Air Receiver Pipe Failure Caused by Improper Installation of Threaded Pipe during 

Initial Construction.” https://lersearch.inl.gov/LERSearchCriteria.aspx. April 3, 1997.

NRC. Generic Letter 88-14, “Instrument Air Supply Problems Affecting Safety-Related 

Components.” Agencywide Documents Access and Management System (ADAMS) Accession 

No. ML031130440. Washington, DC: U.S. Nuclear Regulatory Commission. August 8, 1988.

_____. Information Notice 81-38, “Potentially Significant Components Failures Resulting from 

Contamination of Air-Operated Systems.” ADAMS Accession No. ML 8107230040. 

Washington, DC: U.S. Nuclear Regulatory Commission. December 17, 1981.

_____. Information Notice 87-28, “Air Systems Problems at U.S. Light Water Reactors.” ADAMS 

Accession No. ML031130569. Washington, DC: U.S. Nuclear Regulatory Commission. 

June 22, 1987.

_____. Information Notice 87-28, “Air Systems Problems at U.S. Light Water Reactors.” 

Supplement 1. ADAMS Accession No. ML031130670. Washington, DC: U.S. Nuclear 

Regulatory Commission. December 28, 1987.
XI.M24-4

_____. Information Notice 2008-06, “Instrument Air System Failure Resulting In Manual Reactor 

Trip.” ADAMS Accession No. ML073540243. Washington, DC: U.S. Nuclear Regulatory 

Commission. April 10, 2008.
XI.M25-1

XI.M25 BWR REACTOR WATER CLEANUP SYSTEM

Program Description

This program is a condition monitoring program that provides inspections to manage cracking due 

to stress corrosion cracking (SCC) or intergranular stress corrosion cracking (IGSCC) on the 

intended function of certain austenitic stainless steel (SS) piping in the reactor water cleanup 

(RWCU) system of boiling water reactors (BWRs). Based on the U.S. Nuclear Regulatory 

Commission (NRC) criteria related to inspection guidelines for RWCU piping welds outboard of 

the second isolation valve, the program includes the measures delineated in NUREG–0313, 

Revision 2, and NRC Generic Letter (GL) 88-01 and its Supplement 1. 

NRC GL 88-01 applies to all BWR piping made of austenitic SS that is 4 inches or larger in 

nominal diameter and contains reactor coolant at a temperature above 93 °C (Celsius) [200 °F

(Fahrenheit)] during power operation, regardless of the American Society of Mechanical 

Engineers Boiler and Pressure Vessel Code (ASME Code) classification. NRC GL 88-01 

requests, in part, that affected licensees implement an inservice inspection (ISI) program 

conforming to staff positions for austenitic SS piping covered under the scope of the letter. In 

response to NRC GL 88-01, affected licensees undertook ISI in accordance with the scope and 

schedules described in the letter and included affected portions of RWCU piping outboard of the 

second isolation valves within their ISI programs.

The NRC issued GL 88-01, Supplement 1, to provide acceptable alternatives to the staff positions 

delineated in NRC GL 88-01. In NRC GL 88-01, Supplement 1, the staff noted, in part, that the 

position stated in NRC GL 88-01 on inspection sample size of RWCU system welds outboard of 

the second isolation valves had created an unnecessary hardship for affected licensees because 

of the very high radiation levels associated with this portion of RWCU piping. The staff also noted 

that affected licensees had requested that they be exempted from NRC GL 88-01 with regard to 

inspection of this piping of the RWCU system. Although NRC GL 88-01, Supplement 1, does not 

provide explicit generic guidance with regard to staff criteria for reduction or elimination of RWCU 

weld inspections, it does suggest that the staff would be receptive to modifications to a licensee’s 

original docketed NRC GL 88-01 response for RWCU weld inspections, provided that all issues of 

reactor safety were adequately addressed. The staff has subsequently allowed individual 

licensees to modify their docketed responses to GL-88-01 to reduce or eliminate their ISI of 

RWCU welds in the piping outboard of the second isolation valves. This program only applies in 

cases where the NRC has not previously approved the complete elimination of the augmented 

GL 88 01 inspections for RWCU system piping outboard the second containment isolation valves.

Evaluation and Technical Basis

1. Scope of Program: This program provides ISI to manage cracking due to SCC or 

IGSCC in austenitic SS piping outboard of the second containment isolation valves in the 

RWCU system.

The components included in this program are the welds in piping that have a nominal 

diameter of 4 inches or larger and that contain reactor coolant at a temperature above 

93 °C (Celsius) [200 °F (Fahrenheit)] during power operation, regardless of ASME Code 

classification.
XI.M25-2

2. Preventive Actions: The comprehensive program outlined in NUREG–0313 and 

NRC GL 88-01 addresses improvements in all three elements that, in combination, cause 

SCC or IGSCC. These elements are a susceptible (sensitized) material, a significant 

tensile stress, and an aggressive environment. The program delineated in NUREG–0313 

and NRC GL 88-01 includes recommendations regarding selection of materials that are 

resistant to sensitization, use of special processes that reduce residual tensile stresses, 

and monitoring and maintenance of coolant chemistry. The resistant materials are used 

for new and replacement components and include low-carbon grades of austenitic SS and 

weld metal, with a maximum carbon of 0.035 weight percent and a minimum ferrite of 

7.5 percent in weld metal and cast austenitic stainless steel. Special processes are used 

for existing as well as new and replacement components. These processes include 

solution heat treatment, heat sink welding, induction heating, and mechanical stress 

improvement. Reactor coolant water chemistry is monitored and maintained in 

accordance with activities that meet the guidelines in the Generic Aging Lessons Learned 

for Subsequent License Renewal (GALL-SLR) Report AMP XI.M2, “Water Chemistry.”

3. Parameters Monitored or Inspected: The aging management program (AMP) monitors 

SCC or IGSCC of austenitic SS piping by detecting and sizing cracks in accordance with 

the guidelines of NUREG–0313, NRC GL 88-01, and NRC GL 88-01, Supplement 1.

4. Detection of Aging Effects: The extent, method, and schedule of the inspections 

delineated in the NRC inspection criteria for RWCU piping and NRC GL 88-01 are 

designed to maintain structural integrity and to detect aging effects before the loss of 

intended function of austenitic SS piping and fittings. Guidelines for the inspection 

schedule, methods, personnel, and sample expansion are based on NRC GL 88-01 and 

GL 88-01, Supplement 1, and any applicable alternatives to these inspections that were 

subsequently approved by the NRC. These alternative inspections are implemented in 

accordance with the current licensing basis for the plant. Typically, if all of the GL 89-10 

actions had not been satisfactorily completed, then one alternative inspection would 

include 10 percent of the welds every refueling outage. Another alternative inspection 

would typically include at least 2 percent of the welds or 2 welds every refueling outage, 

whichever sample is larger, if: (a) all of the GL 89-10 actions had been satisfactorily 

completed, (b) no IGSCC had been detected in RWCU piping welds inboard of the second 

containment isolation valves, and (c) no IGSCC had been detected in RWCU piping welds 

outboard of the second containment isolation valves after a minimum of 10 percent of the 

susceptible welds were inspected. 

5. Monitoring and Trending: The extent and schedule for inspection in accordance with the 

recommendations of NRC GL 88-01 provide for the timely detection of cracks. Based on 

inspection results, NRC GL 88-01 provides guidelines for additional samples of welds to 

be inspected when one or more cracked welds are found in a weld category.

6. Acceptance Criteria: NRC GL 88-01 recommends that any indication detected be 

evaluated in accordance with the requirements of ASME Code, Section XI, 

Subsection IWB-3640.

7. Corrective Actions: Results that do not meet the acceptance criteria are addressed in 

the applicant’s corrective action program under those specific portions of the quality 

assurance (QA) program that are used to meet Criterion XVI, “Corrective Action,” of 

Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B. Appendix A of 

the GALL-SLR Report describes how an applicant may apply its 10 CFR Part 50, 
XI.M25-3

Appendix B, QA program to fulfill the corrective actions element of this AMP for both 

safety-related and nonsafety-related structures and components (SCs) within the scope of 

this program.

The guidelines in NRC GL 88-01 are followed for replacements, stress improvement, and 

weld overlay repairs. 

8. Confirmation Process: The confirmation process is addressed through those specific 

portions of the QA program that are used to meet Criterion XVI, “Corrective Action,” of 

10 CFR Part 50, Appendix B. Appendix A of the GALL-SLR Report describes how an 

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the confirmation 

process element of this AMP for both safety-related and nonsafety-related SCs within the 

scope of this program.

9. Administrative Controls: Administrative controls are addressed through the QA program 

that is used to meet the requirements of 10 CFR Part 50, Appendix B, associated with 

managing the effects of aging. Appendix A of the GALL-SLR Report describes how an 

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the 

administrative controls element of this AMP for both safety-related and nonsafety-related 

SCs within the scope of this program.

10. Operating Experience: IGSCC has occurred in small- and large-diameter BWR piping 

made of austenitic SS. The comprehensive program outlined in NRC GL 88-01 and 

NUREG–0313 addresses improvements in all elements that cause SCC or IGSCC 

(e.g., susceptible material, significant tensile stress, and an aggressive environment) and 

is effective in managing IGSCC in austenitic SS piping in the RWCU system.

The program is informed and enhanced when necessary through the systematic and 

ongoing review of both plant-specific and industry operating experience including research

and development such that the effectiveness of the AMP is evaluated consistent with the 

discussion in Appendix B of the GALL-SLR Report.

References

10 CFR Part 50, Appendix B, “Quality Assurance Criteria for Nuclear Power Plants and Fuel 

Reprocessing Plants.” Washington, DC: U.S. Nuclear Regulatory Commission. 2016.

10 CFR 50.55a, “Codes and Standards.” Washington, DC: U.S. Nuclear Regulatory 

Commission. 2016.

ASME. ASME Code Section XI, “Rules for Inservice Inspection of Nuclear Power Plant 

Components.” New York, New York: The American Society of Mechanical Engineers. 2008.

1

NRC. Generic Letter 88-01, “NRC Position on IGSCC in BWR Austenitic Stainless Steel Piping.” 

Agencywide Documents Access and Management System (ADAMS) Accession 

No. ML031150675. Washington, DC: U.S. Nuclear Regulatory Commission. January 27, 1988.

 

1GALL-SLR Report Chapter I, Table 1, identifies the ASME Code Section XI editions and addenda that are 

acceptable to use for this AMP.
XI.M25-4

_____. Generic Letter 88-01, “NRC Position on IGSCC in BWR Austenitic Stainless Steel Piping.” 

Supplement 1. ADAMS Accession No. ML031130421. Washington, DC: U.S. Nuclear 

Regulatory Commission. February 4, 1992.

_____. Generic Letter 89-10, “Safety-related Motor Operated Valve Testing and Surveillance.” 

ADAMS Accession No. ML031150307. Washington, DC: U.S. Nuclear Regulatory Commission. 

August 3, 1990.

_____. NUREG–0313, “Technical Report on Material Selection and Processing Guidelines for 

BWR Coolant Pressure Boundary Piping.” Revision 2. ADAMS Accession No. ML031470422. 

Washington, DC: U.S. Nuclear Regulatory Commission. January 31, 1988.

_____. Pulsifer, Robert M., U.S. Nuclear Regulatory Commission, letter to Michael A Balduzzi, 

Vermont Yankee Nuclear Power Corporation, “Review of Request to Discontinue Intergranular 

Stress Corrosion Cracking Inspection of RWCU Piping Welds Outboard of the Second 

Containment Isolation Valves (TAC No. MB0468).” ADAMS Accession No. ML010780094. 

March 27, 2001.

_____. Shea, Joseph W., U.S. Nuclear Regulatory Commission, letter to George A. Hunger, Jr., 

PECO Energy Company, “Reactor Water Cleanup (RWCU) System Weld Inspections at Peach 

Bottom Atomic Power Station, Units 2 and 3 (TAC Nos. M92442 and M92443).” 

ADAMS Accession No. ML090930466. September 15, 1995.
XI.M26-1

XI.M26 FIRE PROTECTION

Program Description

The Fire Protection aging management program (AMP) includes a fire barrier inspection program. 

The fire barrier inspection program requires periodic visual inspection of fire barrier penetration 

seals; fire barrier walls, ceilings, and floors; fire damper assemblies; and periodic visual inspection 

and functional tests of fire-rated doors to provide reasonable assurance that their operability is 

maintained. The AMP also includes periodic inspection and testing of the halon/carbon dioxide 

(CO2) or clean agent fire suppression system. Additionally, this AMP is complemented by the 

Generic Aging Lessons Learned for Subsequent License Renewal (GALL-SLR) Report 

AMP XI.S6, “Structures Monitoring,” which consists of periodic visual inspections by personnel 

qualified to monitor structures and components (SCs) for applicable aging effects. 

In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 50.48(a), each operating 

nuclear power plant licensee must have a fire protection plan that satisfies General Design 

Criteria 3, “Fire Protection,” of Appendix A, “General Design Criteria for Nuclear Power Plants,” to 

10 CFR Part 50, “Domestic Licensing of Production and Utilization Facilities.”

Licensees of plants that were licensed to operate before January 1, 1979, must meet the 

requirements of Appendix R, “Fire Protection Program for Nuclear Power Facilities Operating Prior 

to January 1, 1979,” to 10 CFR Part 50, except to the extent provided for in 10 CFR 50.48(b). 

Licensees of plants licensed to operate after January 1, 1979, must meet the plant-specific fire 

protection licensing basis. Regulatory Guide (RG) 1.189, “Fire Protection for Nuclear Power 

Plants,” provides guidance for compliance with 10 CFR 50.48(b) and plant-specific fire protection 

licensing basis. 

As an alternative to 10 CFR 50.48(b) or to plant-specific fire protection licensing basis, licensees 

may also adopt and maintain a fire protection program that meets 10 CFR 50.48(c), “National Fire 

Protection Association Standard NFPA 805,” that incorporates by reference National Fire 

Protection Association (NFPA) 805, “Performance-Based Standard for Fire Protection for Light 

Water Reactor Electric Generating Plants, 2001 Edition,” with certain exceptions. RG 1.205, 

Risk-Informed, Performance-Based Fire Protection for Existing Light-Water Nuclear Power 

Plants,” provides guidance for compliance with 10 CFR 50.48(c).

The deterministic means for meeting these requirements come from 10 CFR Part 50, Appendix R, 

and 10 CFR 50.48 or from plant-specific requirements incorporated into the operating license of 

plants licensed after that date. The U.S. Nuclear Regulatory Commission (NRC) deterministic fire 

protection requirements are documented in 10 CFR Part 50, Appendix R and 10 CFR 50.48.

1. Scope of Program: This program manages the effects of loss of material and cracking, 

increased hardness, shrinkage and loss of strength on the intended function of the 

penetration seals; fire barrier walls, ceilings, and floors; fire damper assemblies; and other 

fire resistance materials (e.g., Flamemastic, 3M fire wrapping, spray-on fire proofing 

material, intumescent coating, etc.) that serve a fire barrier function; and all fire-rated 

doors (automatic or manual) that perform a fire barrier function. It also manages the aging 

effects on the intended function of the halon/CO2 or clean agent fire suppression system. 

2. Preventive Actions: This is a condition monitoring program. However, the fire hazard 

analysis assesses the fire potential and fire hazard in all plant areas. It also specifies 

measures for fire prevention, fire detection, fire suppression, and fire containment and 
XI.M26-2

alternative shutdown capability for each fire area containing structures, systems, and 

components important to safety. 

3. Parameters Monitored or Inspected: Visual inspection of penetration seals examines 

the surface condition of the seals for any sign of degradation. Visual inspection of the 

surface condition of the fire barrier walls, ceilings, and floors and other fire barrier 

materials detects any sign of degradation including structural steel fire proofing. Fire 

damper assemblies are inspected for signs of corrosion and cracking. Fire-rated doors 

are visually inspected to detect any degradation of door surfaces. 

The periodic visual inspections of the surface condition for the halon/CO2 or clean agent 

fire suppression system are performed. 

4. Detection of Aging Effects: Visual inspection of penetration seals detects cracking, seal 

separation from walls and components, and rupture and puncture of seals. Visual 

inspection by fire protection qualified personnel of not less than 10 percent of each type of 

seal in walkdowns is performed at a frequency in accordance with an NRC-approved fire 

protection program (e.g., Technical Requirements Manual, Appendix R program) or at 

least once every refueling outage. Visual inspection to detect cracking and loss of 

material are conducted by fire protection qualified personnel of the fire barrier walls, 

ceilings, floors, and doors (e.g., wear, missing parts); fire damper assemblies; and other 

fire barrier materials including structural steel fire proofing during walkdowns at a

frequency in accordance with an NRC-approved fire protection program. Periodic 

functional tests are conducted on fire doors. 

Visual inspections of the halon/CO2 or clean agent fire suppression system are performed 

to detect any sign of corrosion before the loss of the component intended function. 

Periodic testing of the halon/carbon dioxide (CO2) or clean agent fire suppression systems 

is conducted on a schedule in accordance with an NRC-approved fire protection program.

5. Monitoring and Trending: The results of inspections of the aging effects of cracking and 

loss of material on fire barrier penetration seals, fire barriers, fire damper assemblies, and 

fire doors are trended to provide for timely detection of aging effects so that the 

appropriate corrective actions can be taken. Where practical, identified degradation is 

projected until the next scheduled inspection. Results are evaluated against acceptance 

criteria to confirm that the timing of subsequent inspections will maintain the components’ 

intended functions throughout the subsequent period of extended operation based on the 

projected rate of degradation. For sampling-based inspections, results are evaluated 

against acceptance criteria to confirm that the sampling bases (e.g., selection, size, 

frequency) will maintain the components’ intended functions throughout the subsequent 

period of extended operation based on the projected rate and extent of degradation. The 

performance of the halon/CO2 fire suppression system is monitored during the periodic test 

to detect any degradation in the system. These periodic tests provide data necessary for 

trending.

6. Acceptance Criteria: Inspection results are acceptable if there are no signs of 

degradation that could result in the loss of the fire protection capability due to loss of 

material. The acceptance criteria include (a) no visual indications (outside those allowed 

by approved penetration seal configurations) of cracking, separation of seals from walls 

and components, separation of layers of material, or ruptures or punctures of seals; (b) no 

significant indications of cracking and loss of material of fire barrier walls, ceilings, and 
XI.M26-3

floors and in other fire barrier materials; (c) no visual indications of missing parts, holes, 

and wear; (d) no visual indications of cracks or corrosion of fire damper assemblies; and 

(e) no deficiencies in the functional tests of fire doors. Also, inspection results for the 

halon/CO2 or clean agent fire suppression system are acceptable if there are no 

indications of excessive loss of material. 

7. Corrective Actions: Results that do not meet the acceptance criteria are addressed in 

the applicant’s corrective action program under those specific portions of the quality 

assurance (QA) program that are used to meet Criterion XVI, “Corrective Action,” of 

10 CFR Part 50, Appendix B. Appendix A of the GALL-SLR Report describes how an 

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the corrective 

actions element of this AMP for both safety-related and nonsafety-related SCs within the 

scope of this program. 

For fire protection SCs identified that are subject to an aging management review for 

license renewal, the applicant’s 10 CFR Part 50, Appendix B, program is used for 

corrective actions, confirmation process, and administrative controls for aging 

management during the subsequent period of extended operation.

During the inspection of penetration seals, if any sign of degradation is detected within that 

sample, the scope of the inspection is expanded to include additional seals in accordance 

with the plant’s approved fire protection program. If any projected inspection results will 

not meet acceptance criteria prior to the next scheduled inspection, inspection frequencies 

are adjusted as determined by the site’s corrective action program.

8. Confirmation Process: The confirmation process is addressed through those specific 

portions of the QA program that are used to meet Criterion XVI, “Corrective Action,” of 

10 CFR Part 50, Appendix B. Appendix A of the GALL-SLR Report describes how an 

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the confirmation 

process element of this AMP for both safety-related and nonsafety-related SCs within the 

scope of this program.

9. Administrative Controls: Administrative controls are addressed through the QA program 

that is used to meet the requirements of 10 CFR Part 50, Appendix B, associated with 

managing the effects of aging. Appendix A of the GALL-SLR Report describes how an 

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the 

administrative controls element of this AMP for both safety-related and nonsafety-related 

SCs within the scope of this program.

10. Operating Experience: Silicone foam fire barrier penetration seals have experienced 

splits, shrinkage, voids, lack of fill, and other failure modes [NRC Information Notice 

(IN) 88-56, IN 94-28, and IN 97-70]. Degradation of electrical raceway fire barrier such as 

small holes, cracking, and unfilled seals are found on routine walkdown (NRC IN 91-47 

and NRC Generic Letter 92-08). Fire doors have experienced wear of the hinges 

and handles.

The program is informed and enhanced when necessary through the systematic and 

ongoing review of both plant-specific and industry operating experience including research

and development such that the effectiveness of the AMP is evaluated consistent with the 

discussion in Appendix B of the GALL-SLR Report.
XI.M26-4

References

10 CFR Part 50, Appendix B, “Quality Assurance Criteria for Nuclear Power Plants and Fuel 

Reprocessing Plants.” Washington, DC: U.S. Nuclear Regulatory Commission. 2016.

10 CFR Part 50, Appendix R, “Fire Protection Program for Nuclear Power Facilities Operating 

Prior to January 1, 1979.” Washington, DC: U.S. Nuclear Regulatory Commission. 2016.

10 CFR 50.48, “Fire Protection.” Washington, DC: U.S. Nuclear Regulatory Commission. 2016.

NFPA. NFPA 805, “Performance-Based Standard for Fire Protection for Light Water Reactor 

Electric Generating Plants, 2001 Edition.” Quincy, Massachusetts: National Fire Protection 

Association. 2001.

NRC. Generic Letter 92-08, “Thermo-Lag 330-1 Fire Barrier.” Agencywide Documents Access 

and Management System (ADAMS) Accession No. ML031130425. Washington, DC: 

U.S. Nuclear Regulatory Commission. December 17, 1992.

_____. Information Notice 88-56, “Potential Problems with Silicone Foam Fire Barrier Penetration 

Seals.” ADAMS Accession No. ML031150042. Washington, DC: U.S. Nuclear Regulatory 

Commission. August 4, 1988.

_____. Information Notice 91-47, “Failure of Thermo-Lag Fire Barrier Material to Pass Fire 

Endurance Test.” ADAMS Accession No. ML031190452. Washington, DC: U.S. Nuclear 

Regulatory Commission. August 6, 1991. 

_____. Information Notice 94-28, “Potential Problems with Fire-Barrier Penetration Seals.” 

ADAMS Accession No. ML031060475. Washington, DC: U.S. Nuclear Regulatory Commission. 

April 5, 1994.

_____. Information Notice 97-70, “Potential Problems with Fire Barrier Penetration Seals.” 

ADAMS Accession No. ML031050108. Washington, DC: U.S. Nuclear Regulatory Commission. 

September 19, 1997.

_____. Regulatory Guide 1.189, “Fire Protection for Nuclear Power Plants.” Revision 2. ADAMS 

Accession No. ML092580550. Washington, DC: U.S. Nuclear Regulatory Commission. 

October 27, 2009.

_____. Regulatory Guide 1.205, “Risk-Informed, Performance-Based Fire Protection for Existing 

Light-Water Nuclear Power Plants.” Revision 1. ADAMS Accession No. ML092730314. 

Washington, DC: U.S. Nuclear Regulatory Commission. December 31, 2009.
XI.M27-1

XI.M27 FIRE WATER SYSTEM

Program Description

This aging management program (AMP) applies to water-based fire protection system 

components, including sprinklers; nozzles; fittings; valve bodies; fire pump casings; hydrants;

hose stations; standpipes; water storage tanks; and aboveground, buried, and underground piping 

and components that are tested in accordance with the applicable National Fire Protection 

Association (NFPA) codes and standards. Full-flow testing and visual inspections are conducted

in order to ensure that loss of material, cracking, and flow blockage are adequately managed. In 

addition to NFPA codes and standards, portions of the water-based fire protection system that 

are: (a) normally dry but periodically are subject to flow (e.g., dry-pipe or preaction sprinkler 

system piping and valves) and (b) that cannot be drained or allow water to collect, are subjected 

to augmented testing or inspections. Also, portions of the system (e.g., fire service main, 

standpipe) are normally maintained at required operating pressure and monitored such that loss 

of system pressure is immediately detected and corrective actions are initiated. 

Either sprinklers are replaced before reaching 50 years inservice or a representative sample of 

sprinklers from one or more sample areas is tested by using the guidance of NFPA 25, 

“Inspection, Testing and Maintenance of Water-Based Fire Protection Systems.” Generic Aging 

Lessons Learned for Subsequent License Renewal (GALL-SLR) Report AMP XI.M41, “Buried and 

Underground Piping and Tanks,” is used to monitor the external surfaces of buried and 

underground water-based fire protection system piping and tanks.

Evaluation and Technical Basis

1. Scope of Program: Components within the scope of water-based fire protection systems 

include items such as sprinklers, nozzles, fittings, valve bodies, fire pump casings, 

hydrants, hose stations, fire water storage tanks, fire service mains, and standpipes. The 

internal surfaces of water-based fire protection system piping that is normally drained, 

such as dry-pipe sprinkler system piping, are included within the scope of the AMP. Fire 

hose stations and standpipes are considered piping in the AMP. Fire hoses and gaskets 

can be excluded from the scope of license renewal if the standards that are relied upon to 

prescribe replacement of the hose and gaskets are identified in the scoping methodology 

description.

2. Preventive Actions: Flushes (e.g., NFPA 25, Section 7.3.2.1) mitigate or prevent fouling, 

which can cause flow blockage or loss of material, by clearing corrosion products and 

sediment.

3. Parameters Monitored or Inspected: Loss of material and cracking could result in 

system failure. Flow blockage due to fouling from the buildup of corrosion products or 

sediment in the system could occur. Therefore, the parameters monitored are the 

system’s ability to maintain required pressure, flow rates, and the system’s internal 

conditions. Periodic flow tests, flushes, internal and external visual inspections, and 

testing of sprinklers are performed. When visual inspections are used to detect loss of 

material, the inspection technique is capable of detecting surface irregularities that could 

indicate an unexpected level of degradation due to corrosion and corrosion product 

deposition. Where such irregularities are detected, follow-up volumetric wall thickness 

examinations are performed. Volumetric wall thickness inspections are conducted on 

portions of water-based fire protection system components that are periodically subjected 
XI.M27-2

to flow but are normally dry. Visual examinations of cementitious materials are conducted 

to detect indications of loss of material and cracking that could affect the system’s ability to 

maintain pressure.

4. Detection of Aging Effects: Water-based fire protection system components are subject 

to flow testing (except for fire water storage tanks), other testing, and visual inspections. 

Testing and visual inspections are performed in accordance with Table XI.M27-1, “Fire 

Water System Inspection and Testing Recommendations.” Unless recommended 

otherwise, external visual inspections are conducted on a refueling outage interval.

a. Flow tests confirm the system is functional by verifying the capability of the system 

to deliver water to fire suppression systems at required pressures and flow rates. 

b. Visual inspections are capable of evaluating: (i) the condition of the external 

surfaces of components, (ii) the conditions of the internal surfaces of components 

that could indicate wall loss or cracking, and (iii) the inner diameter of the piping as 

it applies to the design flow of the fire protection system (i.e., to verify that 

corrosion product buildup has not resulted in flow blockage due to fouling). 

Internal visual inspections used to detect loss of material are capable of detecting 

surface irregularities that could be indicative of an unexpected level of degradation 

due to corrosion and corrosion product deposition. Where such irregularities are 

detected, follow-up volumetric examinations are performed.

c. Visual inspection of yard fire hydrants, fire hydrant hose hydrostatic tests, gasket 

inspections, and fire hydrant flow tests are conducted to provide opportunities to 

detect degradation before a loss of intended function can occur. 

Portions of water-based fire protection system components that have been wetted but are 

normally dry, such as dry-pipe or preaction sprinkler system piping and valves, are 

subjected to augmented testing and inspections beyond those of Table XI.M27-1. The 

augmented tests and inspections are conducted on piping segments that cannot be 

drained or piping segments that allow water to collect:

• In each 5-year interval, beginning 5 years prior to the subsequent period of 

extended operation, either conduct a flow test or flush sufficient to detect potential 

flow blockage, or conduct a visual inspection of 100 percent of the internal surface 

of piping segments that cannot be drained or piping segments that allow water 

to collect.

• In each 5-year interval of the subsequent period of extended operation, 20 percent 

of the length of piping segments that cannot be drained or piping segments that 

allow water to collect is subject to volumetric wall thickness inspections. 

Measurement points are obtained to the extent that each potential degraded 

condition can be identified (e.g., general corrosion, MIC). The 20 percent of piping 

that is inspected in each 5-year interval is in different locations than previously 

inspected piping.

If the results of a 100-percent internal visual inspection are acceptable, and the 

segment is not subsequently wetted, no further augmented tests or inspections 

are necessary.
XI.M27-3

For portions of the normally dry piping that are configured to drain (e.g., pipe slopes 

towards a drain point) the tests and inspections of Table XI.M27-1 do not need to 

be augmented.

The inspections and tests of all water based fire protection components occur at the 

intervals specified in NFPA 25, or as modified by Table XI.M27-1. Fire water storage tank 

bottom surfaces exposed to soil or concrete are inspected in accordance with GALL-SLR 

Report AMP XI.M29, “Outdoor and Large Atmospheric Metallic Storage Tanks,”

Table XI.M29-1. For indoor fire water storage tanks exposed to concrete, this only applies 

if the tank bottom to concrete interface surface is periodically exposed to moisture. 

If the environmental (e.g., type of water, flowrate, temperature) and material that exist on 

the interior surface of the underground and buried fire protection piping are similar to the 

conditions that exist within the above grade fire protection piping, the results of the 

inspections of the above grade fire protection piping can be extrapolated to evaluate the 

condition of buried and underground fire protection piping for the purpose of identifying 

inside diameter loss of material.

The water-based fire protection systems are normally maintained at required operating 

pressure and monitored in such a way that loss of system pressure is immediately 

detected and corrected when acceptance criteria are exceeded. Continuous system 

pressure monitoring or equivalent methods (e.g., number of jockey fire pump starts or run 

time) are conducted.

Inspections and tests are performed by personnel qualified in accordance with site 

procedures and programs to perform the specified task. The inspections and tests follow 

site procedures that include inspection parameters for items such as lighting, distance,

offset, presence of protective coatings, and cleaning processes.

Aging effects associated with fire water system components having only CLB intended 

functions of leakage boundary (spatial) or structural integrity (attached) as defined in the 

Standard Review Plan for Review of Subsequent License Renewal Applications for 

Nuclear Power Plants (SRP-SLR) Table 2.1-4(b) may be managed by the GALL-SLR

Report AMP XI.M36, “External Surfaces Monitoring of Mechanical Components,” and 

GALL-SLR Report AMP XI.M38, “Inspection of Internal Surfaces in Miscellaneous Piping 

and Ducting Components.” Flow blockage due to fouling need not be managed for these 

components.
XI.M27-4

Table XI.M27-1. Fire Water System Inspection and Testing Recommendations1, 2, 5, 9

Description NFPA 25 Section

Sprinkler Systems

Sprinkler inspections5 5.2.1.110

Sprinkler testing7 5.3.1

Standpipe and Hose Systems

Flow tests 6.3.1

Private Fire Service Mains

Underground and exposed piping flow tests 7.3.1

Hydrants 7.3.210

Fire Pumps

Suction screens 8.3.3.710

Water Storage Tanks

Exterior inspections 9.2.5.510

Interior inspections 9.2.64, 9.2.7

Valves and System-Wide Testing

Main drain test 13.2.510

Water Spray Fixed Systems

Strainers (after each system actuation) 10.2.1.610, 10.2.1.710, 10.2.710

Operation test (refueling outage interval) 10.3.4.38

Foam Water Sprinkler Systems

Strainers (after each system actuation) 11.2.7.1

Operational Test Discharge Patterns (annually)6 11.3.2.610

Storage tanks (internal–10 years) Visual inspection for internal corrosion

Obstruction Investigation

Obstruction, internal inspection of piping3 14.2 and 14.3

1. All terms and references are to NFPA 25. The staff cites NFPA 25 for the description of the scope and periodicity of specific 

inspections and tests. This table specifies those inspections and tests that are related to age-managing applicable aging 

effects associated with loss of material and flow blockage for passive long-lived in-scope components in the fire water system. 

Inspections and tests not related to the above continue to be conducted in accordance with the plant’s CLB. If the CLB

specifies more frequent inspections than required by NFPA 25 or this table, the plant’s CLB continues to be met.

2. A reference to a section includes all sub bullets unless otherwise noted. Section 5.2.1.1 includes Sections 5.2.1.1.1 

through 5.2.1.1.7.

3. The alternative nondestructive examination methods permitted by Sections 14.2.1.1 and 14.3.2.3 are limited to those that can 

ensure that flow blockage will not occur.

4. In regard to Sections 9.2.6.4 and 9.2.7: When degraded coatings are detected, the acceptance criteria and corrective action 

recommendations in GALL-SLR Report AMP XI.M42 are followed in lieu of Section 9.2.7 (1), (2), and (4). When interior pitting 

or general corrosion (beyond minor surface rust) is detected, tank wall thickness measurements are conducted as stated in 

Section 9.2.7 (3) in the vicinity of the loss of material. Vacuum box testing as stated in Section 9.2.7 (6) is conducted when 

pitting, cracks, or loss of material is detected in the immediate vicinity of welds. 

5. Items in areas that are inaccessible because of safety considerations such as those raised by continuous process operations, 

radiological dose, or energized electrical equipment are inspected during each scheduled shutdown but not more often than 

every refueling outage interval.

6. Where the nature of the protected property is such that foam cannot be discharged, the nozzles or open sprinklers are 

inspected for correct orientation and the system tested with air to ensure that the nozzles are not obstructed.

7. For wet pipe sprinkler systems, the subsequent license renewal application either:

• Provides a plant-specific evaluation demonstrating that the water is not corrosive to the sprinklers (e.g., corrosion-resistant 

sprinklers); or

• Proposes a one-time test of sprinklers that have been exposed to water including the sample size, sample selection 

criteria, and minimum time in service of tested sprinklers; or

• Proposes to test the sprinklers in accordance with NFPA 25 Section 5.3.1.1.2.

8. If past testing results demonstrate that potential nozzle plugging does not impede discharge patterns or prevent the discharge 

pattern from reaching wetted surfaces to be protected, the test frequency does not exceed 3 years. Otherwise, tests are 

conducted annually except protected components that are inaccessible because of safety considerations such as those raised 

by continuous process operations, radiological dose, or energized electrical equipment are tested during each scheduled 

shutdown but not more often than every refueling outage interval.

9. Calibration of measuring and test equipment is conducted in accordance with plant-specific procedures in lieu of 

NFPA 25 requirements.

10. Where NFPA 25 or this table cite annual testing or inspections, testing and inspections can be conducted on a refueling outage 

interval if plant-specific OE has shown no loss of intended function of the in-scope SSC due to aging effects being managed for 

the specific component (e.g., loss of material, flow blockage due to fouling).
XI.M27-5

5. Monitoring and Trending: Visual inspection results are monitored and evaluated. 

System discharge pressure or equivalent methods (e.g., number of jockey fire pump starts 

or run time) are monitored continuously and evaluated. Results of flow testing 

(e.g., buried and underground piping, fire mains, and sprinkler), flushes, and wall thickness 

measurements are monitored and trended. Degradation identified by flow testing, flushes, 

and inspections is evaluated.

Where practical, degradation identified is projected until the next scheduled inspection. 

Results are evaluated against acceptance criteria to confirm that the timing of subsequent 

inspections will maintain the components’ intended functions throughout the subsequent 

period of extended operation based on the projected rate of degradation. For 

sampling-based inspections, results are evaluated against acceptance criteria to confirm 

that the sampling bases (e.g., selection, size, frequency) will maintain the components’ 

intended functions throughout the subsequent period of extended operation based on the 

projected rate and extent of degradation.

6. Acceptance Criteria: The acceptance criteria are: (a) the water-based fire protection 

system is able to maintain required pressure and flow rates, (b) minimum design wall 

thickness is maintained, and (c) no loose fouling products exists in systems that could 

cause flow blockage in the sprinklers or deluge nozzles. 

7. Corrective Actions: Results that do not meet the acceptance criteria are addressed in 

the applicant’s corrective action program under those specific portions of the quality 

assurance (QA) program that are used to meet Criterion XVI, “Corrective Action,” of 

Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B. Appendix A of 

the GALL-SLR Report describes how an applicant may apply its 10 CFR Part 50, 

Appendix B, QA program to fulfill the corrective actions element of this AMP for both 

safety-related and nonsafety-related structures and components (SCs) within the scope of 

this program.

If the presence of sufficient foreign organic or inorganic material to obstruct pipe 

or sprinklers is detected during pipe inspections, the material is removed and 

the inspection results are entered into the site’s Corrective Action Program for 

further evaluation.

If a flow test (i.e., NFPA 25 Section 6.3.1) or a main drain test (i.e., NFPA Section 13.2.5) 

does not meet acceptance criteria due to current or projected degradation (i.e., trending) 

additional tests are conducted. The number of increased tests is determined in

accordance with the site’s corrective action process; however, there are no fewer than two

additional tests for each test that did not meet acceptance criteria. The additional 

inspections are completed within the interval (i.e., 5 years, annual) in which the original 

test was conducted. If subsequent tests do not meet acceptance criteria, an extent of 

condition and extent of cause analysis is conducted to determine the further extent of 

tests. At multi-unit sites, the additional tests include at least one test at the other unit on 

site, or one of the units at a three unit site with the same material, environment, and aging 

effect combination.

An evaluation is conducted to determine if deposits need to be removed to determine if 

loss of material has occurred. When loose fouling products that could cause flow 

blockage in the sprinklers is detected, a flush is conducted in accordance with the 

guidance in NFPA 25 Appendix D.5, “Flushing Procedures.” If any projected inspection 
XI.M27-6

results will not meet acceptance criteria prior to the next scheduled inspection, inspection 

frequencies are adjusted as determined by the site’s corrective action program.

8. Confirmation Process: The confirmation process is addressed through those specific 

portions of the QA program that are used to meet Criterion XVI, “Corrective Action,” of 

10 CFR Part 50, Appendix B. Appendix A of the GALL-SLR Report describes how an 

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the confirmation 

process element of this AMP for both safety-related and nonsafety-related SCs within the 

scope of this program.

9. Administrative Controls: Administrative controls are addressed through the QA program 

that is used to meet the requirements of 10 CFR Part 50, Appendix B, associated with 

managing the effects of aging. Appendix A of the GALL-SLR Report describes how an 

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the 

administrative controls element of this AMP for both safety-related and nonsafety-related 

SCs within the scope of this program.

10. Operating Experience: Operating experience (OE) shows that water-based fire 

protection systems are subject to loss of material due to corrosion, MIC, or fouling; and 

flow blockages due to fouling. Loss of material has resulted in sprinkler system flow 

blockages, failed flow tests, and piping leaks. Inspections and testing performed in 

accordance with NFPA standards coupled with visual inspections are capable of detecting 

degradation prior to loss of intended function. The following OE may be of significance to 

an applicant’s program:

a. In October 2004, a fire main failed its periodic flow test due to a low cleanliness 

factor. The low cleanliness factor was attributed to fouling because of an 

accumulation of corrosion products on the interior of the pipe wall and 

tuberculation. Subsequent chemical cleaning to remove the corrosion products 

from the pipe wall revealed several leaks. Corrosion products removed during the 

chemical cleaning were observed to settle out in normally stagnant sections of the 

water-based fire protection system, resulting in flow blockages in small diameter 

piping and valve leak-by. [Discussions as part of Requests for Additional 

Information are available at Agencywide Documents Access and Management 

System (ADAMS) Accession Nos. ML12220A162, ML12306A332, and 

ML13029A244].

b. In October 2010, a portion of a preaction spray system failed its functional flow test 

because of flow blockages. Two branch lines were found to have significant 

blockages. The blockage in one branch line was determined to be a buildup of 

corrosion products. A rag was found in the other branch line. (ADAMS Accession 

No. ML13014A100).

c. In August 2011, an intake fire protection preaction sprinkler system was unable to 

pass flow during functional testing. Subsequent visual inspections identified flow 

blockages in the inspector’s test valve, the piping leading to the inspector’s test 

valves, and three vertical risers. The flow blockages were determined to be a 

buildup of corrosion products. (ADAMS Accession No. ML113050425).
XI.M27-7

d. In March 2012, the staff and licensee personnel found that a portion of the 

internally galvanized piping of a 6-inch preaction sprinkler system could not be 

properly drained because the drainage points were located on a smaller diameter 

pipe that tied into the side of the 6-inch pipe. A boroscopic inspection of the lower 

portions of the pipe showed that it contained residual water, that the galvanizing 

had been removed, and that significant quantities of corrosion products were 

present whereas in the upper dry portions, the galvanized coating was still intact. 

(Information Notice 2013-06).

The review of plant-specific OE during the development of this program is to be broad and 

detailed enough to detect instances of aging effects that have occurred repeatedly. In 

some instances, repeatedly occurring aging effects (i.e., recurring internal corrosion) might 

result in augmented aging management activities. Further evaluation aging management 

review line items in SRP-SLR Sections 3.2.2.2.7, 3.3.2.2.7, and 3.4.2.2.6, “Loss of 

Material due to Recurring Internal Corrosion,” include criteria to determine whether 

recurring internal corrosion is occurring and recommendations related to augmenting 

aging management activities.

The program is informed and enhanced when necessary through the systematic and 

ongoing review of both plant-specific and industry OE including research and development 

such that the effectiveness of the AMP is evaluated consistent with the discussion in 

Appendix B of the GALL-SLR Report.

References

10 CFR Part 50, Appendix B, “Quality Assurance Criteria for Nuclear Power Plants and Fuel 

Reprocessing Plants.” Washington, DC: U.S. Nuclear Regulatory Commission. 2016.

NFPA. NFPA 25, “Inspection, Testing, and Maintenance of Water-Based Fire Protection 

Systems, 2011 Edition.” Quincy, Massachusetts: National Fire Protection Association. 2011.

NRC. Information Notice 2013-06, “Corrosion in Fire Protection Piping Due to Air and Water 

Interaction.” Agencywide Documents Access and Management System (ADAMS) Accession 

No. ML13031A618. Washington, DC: U.S. Nuclear Regulatory Commission. March 25, 2013.

XI.M29-1

XI.M29 OUTDOOR AND LARGE ATMOSPHERIC METALLIC STORAGE TANKS

Program Description

The Outdoor and Large Atmospheric Metallic Storage Tanks aging management program (AMP) 

manages the effects of loss of material and cracking on the outside and inside surfaces of metallic 

aboveground tanks constructed on concrete or soil. All metallic outdoor tanks (except fire water 

storage tank interior surfaces and exterior surfaces not exposed to soil or concrete) and certain 

indoor metallic tanks are included. If the tank exterior is fully accessible, tank outside surfaces 

may be inspected under the program for inspection of external surfaces [Generic Aging Lessons 

Learned for Subsequent License Renewal (GALL-SLR) Report AMP XI.M36] for visual 

inspections of external surfaces recommended in this AMP; surface examinations are conducted 

in accordance with the recommendations of this AMP. This program credits the standard industry 

practice of coating or painting the external surfaces of steel tanks as a preventive measure to 

mitigate corrosion. The program relies on periodic inspections to monitor degradation of the 

protective paint or coating. Tank inside surfaces are inspected by visual or surface examinations 

as required to detect applicable aging effects.

For storage tanks supported on earthen or concrete foundations, thickness measurements of the 

tank bottom are conducted because corrosion could occur at inaccessible locations.

Evaluation and Technical Basis

1. Scope of Program: Tanks within the scope of this program include: (a) all metallic 

outdoor tanks (except fire water storage tank interior surfaces and exterior surfaces not 

exposed to soil or concrete) constructed on soil or concrete; (b) indoor large volume 

metallic storage tanks (i.e., those with a capacity greater than 100,000 gallons) designed 

to internal pressures approximating atmospheric pressure and exposed internally to water; 

and (c) other indoor metallic tanks that sit on, or are embedded in concrete where plantspecific operating experience reveals that the tank bottom (or sides for embedded tanks) 

to concrete interface is periodically exposed to moisture. If the tank exterior is fully 

accessible, tank outside surfaces may be inspected under the program for inspection of 

external surfaces (GALL-SLR Report AMP XI.M36). Aging effects for fire water storage 

tank interior surfaces and exterior surfaces not exposed to soil or concrete are managed 

using GALL-SLR Report AMP XI.M27. Visual inspections are conducted on tank 

insulation and jacketing when these are installed.

This program may be used to manage the aging effects for coatings/linings that are 

applied to the internal surfaces of components included in the scope of this program as 

long as the following are met:

• The recommendations of GALL-SLR Report AMP XI.M42 are incorporated into 

this AMP.

• Exceptions or enhancements associated with the recommendations in 

GALL-SLR Report AMP XI.M42 are included in this AMP.

• The Final Safety Analysis Report (FSAR) supplement for GALL-SLR Report 

AMP XI.M42, as shown in Table XI-01, “FSAR Supplement Summaries for 

GALL-SLR Report Chapter XI Aging Management Programs,” is included in the 

application with a reference to this AMP.
XI.M29-2

2. Preventive Actions: In accordance with industry practice, steel tanks may be coated with 

protective paint or coating to mitigate corrosion by protecting the external surface of the 

tank from environmental exposure. For outdoor tanks, sealant or caulking is applied at 

the interface between the tank external surface and concrete or earthen surface 

(e.g., foundation, tank interface joint in a partially encased tank) to mitigate corrosion of the 

tank by minimizing the amount of water and moisture penetrating the interface. Certain 

tank configurations may minimize the amount of water and moisture penetrating these 

interfaces by design, (e.g., foundation is sloped in a manner that prevents water from 

accumulating).

3. Parameters Monitored or Inspected: The program consists of periodic inspections of 

metallic tanks (with or without coatings) to manage the effects of corrosion and cracking 

on the intended function of these tanks. Inspections cover all surfaces of the tank 

(i.e., outside uninsulated surfaces, outside insulated surfaces, bottom, interior surfaces). 

The AMP uses periodic plant inspections to monitor degradation of coatings, sealants, and 

caulking because it is a condition directly related to the potential loss of material or 

cracking. Thickness measurements of the bottoms of the tanks are conducted

periodically. Periodic internal visual inspections and surface examinations, as required to 

detect applicable aging effects, are performed to detect degradation that could be 

occurring on the inside of the tank. Where the exterior surface is insulated for outdoor 

tanks and indoor tanks operated below the dew point, a representative sample of the 

insulation is periodically removed or inspected to detect the potential for loss of material or 

cracking underneath the insulation, unless it is demonstrated that the aging effect 

[i.e., stress corrosion cracking (SCC), loss of material] is not applicable, see 

Table XI.M29-1, “Tank Inspection Recommendations.”

4. Detection of Aging Effects: Tank inspections are conducted in accordance with 

Table XI.M29-1 and the associated table notes. Degradation of an exterior metallic

surface can occur in the presence of moisture; therefore, periodic visual inspections at 

each outage are conducted to confirm that the paint, coating, sealant, and caulking are 

intact. The visual inspections of sealant and caulking are supplemented with physical 

manipulation to detect degradation. If the exterior surface is not coated, visual inspections 

of the tank’s surface are conducted within sufficient proximity (e.g., distance, angle of 

observation) to detect loss of material. If the tank is insulated, the inspections include 

locations where potential leakage past the insulation could be accumulating.

When necessary to detect cracking in materials susceptible to cracking such as stainless 

steel, and aluminum, the program includes surface examinations. When surface 

examinations are required to detect an aging effect, the program states how many surface 

examinations will be conducted, the area covered by each examination, and how 

examination sites will be selected.

If the exterior surface of an outdoor tank or indoor tank exposed to condensation (because 

the in-scope component being operated below the dew point) is insulated, sufficient 

insulation is removed to determine the condition of the exterior surface of the tank, unless 

it is demonstrated that the aging effect (i.e., SCC, loss of material) is not applicable, see 

Table XI.M29-1, “Tank Inspection Recommendations.” When an aging effect requires 

management, periodic inspections are conducted. During each 10-year period of the 

subsequent period of extended operation, remove a minimum of either 25 one-square foot 

sections or 20 percent of the tank insulation and perform inspection of the exposed 

exterior surface of the tank. Aging effects associated with corrosion under insulation for 
XI.M29-3

outdoor tanks may be managed by GALL-SLR Report AMP XI.M36, “External Surfaces 

Monitoring of Mechanical Components.”

The sample inspection points are distributed in such a way that inspections occur on the 

tank dome (if it is flat), near the bottom, at points where structural supports, pipe, or 

instrument nozzles penetrate the insulation and where water could collect such as on top of 

stiffening rings. In addition, inspection locations are based on the likelihood of corrosion 

under insulation occurring (e.g., given how often a potential inspection location is subject to 

alternate wetting and drying in environments where trace contaminants could be present, 

how long a system at a potential inspection location operates below the dew point).

Alternatives to Removing Insulation:

a. Subsequent inspections may consist of examination of the exterior surface of the 

insulation for indications of damage to the jacketing or protective outer layer of the 

insulation when the results of the initial inspection meet the following criteria:

i. No loss of material due to general, pitting or crevice corrosion, beyond that 

which could have been present during initial construction is observed, and

ii. No evidence of SCC is observed.

If the external visual inspections of the insulation reveal damage to the exterior surface of 

the insulation or jacketing, or there is evidence of water intrusion through the insulation 

(e.g., water seepage through insulation seams/joints), periodic inspections under the 

insulation continue as conducted for the initial inspection.

b. Removal of tightly adhering insulation that is impermeable to moisture is not 

required unless there is evidence of damage to the moisture barrier. If the 

moisture barrier is intact, the likelihood of corrosion under insulation is low for 

tightly adhering insulation. Tightly adhering insulation is considered to be a 

separate population from the remainder of insulation installed on in-scope 

components. The entire population of in-scope tanks that have tightly adhering 

insulation is visually inspected for damage to the moisture barrier with the same 

frequency as for other types of insulation inspections. These inspections are not 

credited towards the inspection quantities for other types of insulation.

Potential loss of material and cracking of tank bottoms is determined from volumetric 

inspections of the tank bottoms that are performed whenever the tank is drained or at 

intervals not less than those recommended in Table XI.M29-1.

When inspections are conducted on a sampling basis, subsequent inspections are 

conducted in different locations unless the program states the basis for why repeated 

inspections will be conducted in the same location.

Inspections and tests are performed by personnel qualified in accordance with site 

procedures and programs to perform the specified task. Inspections and tests within the 

scope of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code 

(ASME Code) follow procedures consistent with the ASME code. Non-ASME Code 

inspections and tests follow site procedures that include inspection parameters for items 

such as lighting, distance, offset, surface coverage, presence of protective coatings, and 

cleaning processes.
XI.M29-4

Table XI.M29-1. Tank Inspection Recommendations1, 2 

Inspections to Identify Degradation of Inside Surfaces of Tank Shell, Roof4, and Bottom5, 6

Material Environment

Aging Effect 

Requiring 

Management 

(AERM)

Inspection 

Technique3 Inspection Frequency

Steel

Air, 

condensation

Loss of 

material

Visual from 

inside 

surface (IS) 

or

Volumetric 

from 

outside 

surface 

(OS)7

Each 10-year period starting 10 years 

before the subsequent period of 

extended operation

Raw water, 

waste water

Loss of 

material

Each 10-year period starting 10 years 

before the subsequent period of 

extended operation

Treated water Loss of 

material

One-time inspection conducted in 

accordance with GALL-SLR Report

AMP XI.M328

Stainless 

steel8

Air, 

condensation

Loss of 

material Visual

Each refueling outage interval or 

one-time inspection, see SRP-SLR 

Sections 3.2.2.2.2, 3.3.2.2.4, or 

3.4.2.2.3.

Cracking Surface11

Each 10-year period starting 10 years 

before the subsequent period of 

extended operation, or one-time 

inspection, see SRP-SLR Sections 

3.2.2.2.4, 3.3.2.2.3, or 3.4.2.2.2.

Raw water, 

waste water

Loss of 

material Visual

Each 10-year period starting 10 years 

before the subsequent period of 

extended operation

Treated water, 

treated borated 

water

Loss of 

material

Visual from 

IS or

Volumetric 

from OS7

One-time inspection conducted in 

accordance with GALL-SLR Report

AMP XI.M328 

Aluminum

Air, 

condensation

Loss of 

material Visual

Each 10-year period starting 10 years 

before the subsequent period of 

extended operation, or one-time 

inspection, see SRP-SLR Sections 

3.2.2.2.10, 3.3.2.2.10, or 3.4.2.2.9.

Cracking Surface11

Each 10-year period starting 10 years 

before the subsequent period of 

extended operation, or demonstrate 

that SCC is not an applicable aging 

effect, see SRP-SLR Sections 

3.2.2.2.8, 3.3.2.2.8, or 3.4.2.2.7.

Treated water, 

treated borated 

water

Loss of 

material

Visual from 

IS or

Volumetric 

from OS7

One-time inspection conducted in 

accordance with GALL-SLR Report

AMP XI.M328
XI.M29-5

Table XI.M29-1. Tank Inspection Recommendations1, 2 

Raw water, 

waste water

Loss of 

material Visual

Each 10-year period starting 10 years 

before the subsequent period of 

extended operation, or one-time 

inspection, see SRP-SLR Sections 

3.2.2.2.10, 3.3.2.2.10, or 3.4.2.2.9.

Cracking Surface11

Each 10-year period starting 10 years 

before the subsequent period of 

extended operation, or demonstrate 

that SCC is not an applicable aging 

effect, see SRP-SLR Sections 

3.2.2.2.8, 3.3.2.2.8, or 3.4.2.2.7.

Inspections to Identify Degradation of External Surfaces9 of Tank Shell, Roof, and Bottom

Material Environment AERM

Inspection 

Technique3 Inspection Frequency

Steel

Air – indoor 

uncontrolled

Air – outdoor

Loss of 

material

Visual from 

OS Each refueling outage interval

Soil, concrete Loss of 

material

Volumetric 

from IS12

Each 10-year period starting 10 years 

before the subsequent period of 

extended operation13

Stainless 

Steel

Air, 

condensation

Loss of 

material

Visual from 

OS

Each refueling outage interval or 

one-time inspection, see SRP-SLR 

Sections 3.2.2.2.2, 3.3.2.2.4, or 

3.4.2.2.3.

Cracking Surface11

Each 10-year period starting 10 years 

before the subsequent period of 

extended operation or one-time 

inspection, see SRP-SLR Sections 

3.2.2.2.4, 3.3.2.2.3, or 3.4.2.2.2.

Soil, concrete 

Loss of 

material

Volumetric 

from IS12

Each 10-year period starting 10 years 

before the subsequent period of 

extended operation13

Cracking Volumetric 

from IS12

Each 10-year period starting 10 years 

before the subsequent period of 

extended operation13
XI.M29-6

Table XI.M29-1. Tank Inspection Recommendations1, 2 

Aluminum

Air, 

condensation

Cracking Surface11

Each 10-year period starting 10 years 

before the subsequent period of 

extended operation or demonstrate that 

SCC is not an applicable aging effect, 

see SRP-SLR Sections 3.2.2.2.8, 

3.3.2.2.8, or 3.4.2.2.7.

Loss of 

material

Visual from 

OS

Each 10-year period starting 10 years 

before the subsequent period of 

extended operation, or one-time 

inspection, see SRP-SLR Sections 

3.2.2.2.10, 3.3.2.2.10, or 3.4.2.2.9.

Soil, concrete

Loss of 

material

Volumetric 

from IS12

Each 10-year period starting 10 years 

before the subsequent period of 

extended operation13

Cracking Volumetric 

from IS12

Each 10-year period starting 10 years 

before the subsequent period of 

extended operation13 or demonstrate 

that SCC is not an applicable aging 

effect, see SRP-SLR Sections 

3.2.2.2.8, 3.3.2.2.8, or 3.4.2.2.7.
XI.M29-7

Table XI.M29-1. Tank Inspection Recommendations1, 2 

1. GALL-SLR Report AMP XI.M30, “Fuel Oil Chemistry,” is used to manage loss of material on the internal surfaces of fuel oil 

storage tanks. However, for outdoor fuel oil storage tanks exposed to soil or concrete and indoor tanks exposed to 

periodically wetted concrete or exposed to soil, inspections to identify aging of the external surfaces of tanks are conducted 

in accordance with GALL-SLR Report AMP XI.M29. GALL-SLR Report AMP XI.M41 is used to manage loss of material 

and cracking for the external surfaces of buried tanks.

2. When one-time internal inspections in accordance with these footnotes are used in lieu of periodic inspections, the one-time 

inspection must occur within the 5-year period before the start of the subsequent period of extended operation.

3. Alternative inspection methods may be used to inspect both surfaces (i.e., internal, external) or the opposite surface 

(e.g., inspecting the internal surfaces for loss of material from the external surface, inspecting for corrosion under external 

insulation from the internal surfaces of the tank) as long as the method has been demonstrated to be effective at detecting 

the AERM and a sufficient amount of the surface is inspected to provide reasonable assurance that localized aging effects 

are detected. For example, in some cases, subject to being demonstrated effective by the applicant, the low frequency 

electromagnetic technique (LFET) can be used to scan an entire surface of a tank. If follow-up ultrasonic examinations are 

conducted in any areas where the wall thickness is below nominal, an LFET inspection can effectively detect loss of 

material in the tank shell, roof, or bottom.

4. Nonwetted surfaces on the inside of a tank (e.g., roof, surfaces above the normal waterline) are inspected in the same 

manner as the wetted surfaces based on the material, environment, and AERM.

5. Visual inspections to identify degradation of the inside surfaces of tank shell, roof, and bottom cover all the inside surfaces. 

Where this is not possible because of the tank’s configuration (e.g., tanks with floating covers or bladders), the SLRA 

includes a justification for how aging effects will be detected before the loss of the tank’s intended function.

6. For tank configurations in which deleterious materials could accumulate on the tank bottom (e.g., sediment, silt), the internal 

inspections of the tank’s bottom include inspections of the side wall of the tank up to the top of the sludge-affected region.

7. At least 20 percent of the tank’s internal surface is to be inspected using a method capable of precisely determining wall 

thickness. The inspection method is capable of detecting both general and pitting corrosion and be demonstrated effective 

by the applicant.

8. At least one tank for each material and environment combination is inspected at each site. The tank inspection can be 

credited towards the sample population for GALL-SLR Report AMP XI.M32.

9. For insulated tanks, the external inspections of tank surfaces that are insulated are conducted in accordance with the 

sampling recommendations in this AMP. If the initial inspections meet the criteria described in the preceding “Alternatives 

to Removing Insulation” portion of this AMP, subsequent inspections may consist of external visual inspections of the 

jacketing in lieu of surface examinations. Tanks with tightly adhering insulation may use the “Alternatives to Removing 

Insulation” portion of this AMP for initial and all follow-on inspections.

10. Not used.

11. A minimum of either 25 sections of the tank’s surface (e.g., 1-square-foot sections for tank surfaces, 1-linear-foot sections 

of weld length) or 20 percent of the tank’s surface are examined. The sample inspection points are distributed in such a 

way that inspections occur in those areas most susceptible to degradation (e.g., areas where contaminants could collect, 

inlet and outlet nozzles, welds).

12. When volumetric examinations of the tank bottom cannot be conducted because the tank is coated, an exception is stated, 

and the accompanying justification for not conducting inspections includes the considerations in footnote 13, below, or 

propose an alternative examination methodology.

13. A one-time inspection conducted in accordance with GALL-SLR Report AMP XI.M32 may be conducted in lieu of periodic 

inspections if an evaluation conducted before the subsequent period of extended operation and during each 10-year period 

during the subsequent period of extended operation demonstrates that the soil under the tank is not corrosive using actual 

soil samples that are analyzed for each individual parameter (e.g., resistivity, pH, redox potential, sulfides, sulfates, 

moisture) and overall soil corrosivity. The evaluation includes soil sampling from underneath the tank.

Alternatively, a one-time inspection conducted in accordance with GALL-SLR Report AMP XI.M32 may be conducted in lieu 

of periodic inspections if the bottom of the tank has been cathodically protected in such a way that the availability and 

effectiveness criteria of GALL-SLR Report AMP XI.M41, ‘Buried and Underground Piping and Tanks’,” Table XI.M41-3., 

“Inspections of Buried Tanks for all Inspection Periods,” have been met beginning 5 years prior to the subsequent period of 

extended operation, and the criteria continue to be met throughout the subsequent period of extended operation. 
XI.M29-8

5. Monitoring and Trending: The effects of corrosion of the tank surfaces are detectable by 

visual and surface (for cracking) examination techniques. Based on operating experience

(OE), periodic inspections provide for timely detection of aging effects. Where practical, 

identified degradation is projected until the next scheduled inspection. Results are 

evaluated against acceptance criteria to confirm that the timing of subsequent inspections 

will maintain the components’ intended functions throughout the subsequent period of 

extended operation based on the projected rate of degradation.

6. Acceptance Criteria: Any degradation of paints or coatings (cracking, flaking, or peeling), 

or evidence of corrosion is reported and requires further evaluation to determine whether 

repair or replacement of the paints or coatings should be conducted. Non-pliable, cracked, 

or missing sealant and caulking is unacceptable. When degraded sealant or caulking is 

detected, an evaluation is conducted to determine the need to conduct follow up 

examination of the tank’s surfaces. Indications of cracking are analyzed in accordance 

with the applicable design requirements for the tank. Ultrasonic testing (UT) thickness 

measurements of the tank bottom are evaluated against the design thickness and 

corrosion allowance.

7. Corrective Actions: Results that do not meet the acceptance criteria are addressed in 

the applicant’s corrective action program under those specific portions of the quality 

assurance (QA) program that are used to meet Criterion XVI, “Corrective Action,” of 

Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B. Appendix A of 

the GALL-SLR Report describes how an applicant may apply its 10 CFR Part 50, 

Appendix B, QA program to fulfill the corrective actions element of this AMP for both 

safety-related and nonsafety-related structures and components (SCs) within the scope of 

this program.

Flaws in the caulking or sealant are repaired and follow-up examination of the tank’s 

surfaces is conducted if deemed appropriate.

Additional inspections are conducted if one of the inspections does not meet acceptance 

criteria due to current or projected degradation (i.e., trending). The number of increased 

inspections is determined in accordance with the site’s corrective action process; however:

• For inspections where only one tank of a material, environment, and aging effect 

was inspected, all tanks in that grouping are inspected.

• For other sampling-based inspections (e.g., 20 percent, 25 locations) the smaller of 

five additional inspections or 20 percent of the inspection population is conducted. 

If subsequent inspections do not meet acceptance criteria, an extent of condition 

and extent of cause is conducted to determine the further extent of inspection. At 

multi-unit sites, the additional inspections include inspections at all of the units with 

the same material, environment, and aging effect combination.

The timing of the additional inspections is based on the severity of the degradation 

identified and is commensurate with the potential for loss of intended function. However, 

with the exception of external visual inspections of tanks without insulation, the additional 

inspections are completed within the interval in which the original inspection was 

conducted or, if identified in the latter half of the current inspection interval, within the first 

half of the next inspection interval. These additional inspections conducted in the next 

inspection interval cannot also be credited towards the number of inspections in the latter 
XI.M29-9

interval. External visual inspections when the tank is not insulated are conducted within 

the original refueling outage interval.

If any projected inspection results will not meet acceptance criteria prior to the next 

scheduled inspection, inspection frequencies are adjusted as determined by the site’s 

corrective action program. However, for one-time inspections that do not meet 

acceptance criteria, inspections are subsequently conducted at least at 10-year inspection 

intervals.

8. Confirmation Process: The confirmation process is addressed through those specific 

portions of the QA program that are used to meet Criterion XVI, “Corrective Action,” of 

10 CFR Part 50, Appendix B. Appendix A of the GALL-SLR Report describes how an 

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the confirmation 

process element of this AMP for both safety-related and nonsafety-related SCs within the 

scope of this program.

9. Administrative Controls: Administrative controls are addressed through the QA program 

that is used to meet the requirements of 10 CFR Part 50, Appendix B, associated with 

managing the effects of aging. Appendix A of the GALL-SLR Report describes how an 

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the 

administrative controls element of this AMP for both safety-related and nonsafety-related 

SCs within the scope of this program.

10. Operating Experience: A review of OE reveals that there have been instances involving 

defects variously described as wall thinning, pinhole leaks, cracks, and through-wall flaws 

in tanks. In addition, internal blistering, delamination of coatings, rust stains, and holidays 

have been found on the bottom of tanks.

The review of plant-specific OE during the development of this program is to be broad and 

detailed enough to detect instances of aging effects that have occurred repeatedly. In 

some instances, repeatedly occurring aging effects (i.e., recurring internal corrosion) might

result in augmented aging management activities. Further evaluation aging management 

review line items in SRP-SLR Sections 3.2.2.2.7, 3.3.2.2.7, and 3.4.2.2.6, “Loss of 

Material Due to Recurring Internal Corrosion,” include criteria to determine whether 

recurring internal corrosion is occurring and recommendations related to augmenting 

aging management activities.

The program is informed and enhanced when necessary through the systematic and 

ongoing review of both plant-specific and industry OE including research and development 

such that the effectiveness of the AMP is evaluated consistent with the discussion in 

Appendix B of the GALL-SLR Report.

References

10 CFR Part 50, Appendix B, “Quality Assurance Criteria for Nuclear Power Plants and Fuel 

Reprocessing Plants.” Washington, DC: U.S. Nuclear Regulatory Commission. 2016.

NRC. Information Notice 2013-18, “Refueling Water Storage Tank Degradation.” Agencywide 

Documents Access and Management System (ADAMS) Accession No. ML13128A118. 

Washington, DC: U.S. Nuclear Regulatory Commission. September 13, 2013.

XI.M30-1

XI.M30 FUEL OIL CHEMISTRY

Program Description

The program includes (a) surveillance and maintenance procedures to mitigate corrosion and 

(b) measures to verify the effectiveness of the mitigative actions and confirm the insignificance of 

an aging effect. Fuel oil quality is maintained by monitoring and controlling fuel oil contamination 

in accordance with the plant’s technical specifications (TS). Guidelines of the American Society for 

Testing and Materials (ASTM) Standards, such as ASTM D 0975, D 1796, D 2276, D 2709, 

D 6217, and D 4057, also may be used. Exposure to fuel oil contaminants, such as water and 

microbiological organisms, is minimized by periodic draining or cleaning of tanks and by verifying 

the quality of new oil before its introduction into the storage tanks. However, corrosion may occur 

at locations in which contaminants may accumulate, such as tank bottoms. Accordingly, the 

effectiveness of the program is verified to provide reasonable assurance that significant 

degradation is not occurring and that the component’s intended function is maintained during the 

subsequent period of extended operation. Thickness measurement of the tank bottom is an 

acceptable verification program.

The fuel oil chemistry program is generally effective in removing impurities from areas that 

experience flow. The Generic Aging Lessons Learned for Subsequent License Renewal 

(GALL-SLR) Report identifies those circumstances in which the fuel oil chemistry program is 

augmented to manage the effects of aging for subsequent license renewal (SLR). For example, 

the fuel oil chemistry program may not be effective in stagnant areas. Accordingly, in certain 

cases as identified in this GALL-SLR Report, verification of the effectiveness of the fuel oil 

chemistry program is conducted. As discussed in this GALL-SLR Report for these specific cases, 

an acceptable verification program is a one-time inspection of selected components at susceptible 

locations in the system.

Evaluation and Technical Basis

1. Scope of Program: Components within the scope of the program are the diesel fuel oil 

storage tanks, piping, and other metal components subject to aging management review 

that are exposed to an environment of diesel fuel oil. 

2. Preventive Actions: The program reduces the potential for (a) exposure of the 

component internal surfaces to fuel oil contaminated with water and microbiological 

organisms, reducing the potential for age-related degradation in other components 

exposed to diesel fuel oil; and (b) transport of corrosion products, sludge, or particulates to 

components serviced by the fuel oil storage tanks. Biocides or corrosion inhibitors may be 

added as a preventive measure. Periodic cleaning of a tank allows removal of sediments, 

and periodic draining of water collected at the bottom of a tank minimizes the amount of 

water and the length of contact time. Accordingly, these measures are effective in 

mitigating corrosion inside diesel fuel oil tanks. Coatings, if used, prevent or mitigate 

corrosion by protecting the internal surfaces of components from contact with water and 

microbiological organisms.

3. Parameters Monitored or Inspected: The program is focused on managing loss of 

material due to general, pitting, and crevice corrosion; and microbiologically influenced

corrosion (MIC) of component internal surfaces. The aging management program (AMP) 

monitors fuel oil quality through receipt testing and periodic sampling of stored fuel oil. 

Parameters monitored include water and sediment content, total particulate concentration, 
XI.M30-2

and the levels of microbiological organisms in the fuel oil. Water and microbiological 

organisms in the fuel oil storage tank increase the potential for corrosion. Sediment and 

total particulate content may be indicative of water intrusion or corrosion. Periodic visual 

inspections of tank internal surfaces and thickness measurements of the bottoms of the 

tanks are conducted as an additional measure to provide reasonable assurance that loss 

of material is not occurring.

4. Detection of Aging Effects: Loss of material due to corrosion of the diesel fuel oil tank or 

other components exposed to diesel fuel oil cannot occur without exposure of the tank’s 

internal surfaces to contaminants in the fuel oil, such as water and microbiological 

organisms. Periodic multilevel sampling provides assurance that fuel oil contaminants are 

below unacceptable levels. If tank design features do not allow for multilevel sampling, a 

sampling methodology that includes a representative sample from the lowest point in the 

tank may be used.

At least once during the 10-year period prior to the subsequent period of extended 

operation, each diesel fuel tank is drained and cleaned, the internal surfaces are visually 

inspected (if physically possible) and volumetrically-inspected if evidence of degradation is 

observed during visual inspection, or if visual inspection is not possible. During the 

subsequent period of extended operation, at least once every 10 years, each diesel fuel 

tank is drained and cleaned, the internal surfaces are visually inspected (if physically 

possible), and, if evidence of degradation is observed during inspections, or if visual 

inspection is not possible, these diesel fuel tanks are volumetrically inspected. The 

external surfaces of tank bottoms for outdoor tanks exposed to soil or concrete and indoor 

tanks exposed to periodically wetted concrete or exposed to soil are volumetrically 

inspected in accordance with GALL-SLR Report AMP XI.M29, Table XI.M29-1, 

Footnote 1. 

Prior to the subsequent period of extended operation, a one-time inspection 

(i.e., GALL-SLR Report AMP XI.M32) of selected components exposed to diesel fuel oil is 

performed to verify the effectiveness of the Fuel Oil Chemistry program. Certain one-time 

inspections are not conducted subject to the following:

• For components constructed of the same material as the fuel oil storage tank, 

when the fuel oil storage tank is not coated on its internal surface, one-time

inspections are not conducted.

• For components constructed of materials other than the fuel oil storage tank (when 

the tank is not internally coated), one-time inspections are not conducted when the 

SLR application states the basis for why water pooling or separation is not possible 

for a specific material type.

5. Monitoring and Trending: Water, biological activity, and particulate contamination 

concentrations are monitored and trended in accordance with the plant’s technical 

specifications or at least quarterly. Where practical, identified degradation is projected 

until the next scheduled inspection. Results are evaluated against acceptance criteria to 

confirm that the timing of subsequent inspections will maintain the components’ intended 

functions throughout the subsequent period of extended operation based on the projected 

rate of degradation.
XI.M30-3

6. Acceptance Criteria: Acceptance criteria for fuel oil quality parameters are as invoked or 

referenced in a plant’s TS. Additional acceptance criteria may be implemented using 

guidance from industry standards and equipment manufacturer or fuel oil supplier 

recommendations. ASTM D 0975 or other appropriate standards may be used to develop 

fuel oil quality acceptance criteria. Suspended water concentrations are in accordance 

with the applicable fuel oil quality specifications. Corrective actions are taken if 

microbiological activity is detected. Any degradation of the tank internal surfaces is 

reported and is evaluated using the corrective action program. Thickness measurements 

of the tank bottom are evaluated against the design thickness and corrosion allowance.

7. Corrective Actions: Results that do not meet the acceptance criteria are addressed in 

the applicant’s corrective action program under those specific portions of the quality 

assurance (QA) program that are used to meet Criterion XVI, “Corrective Action,” of 

Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B. Appendix A of 

the GALL-SLR Report describes how an applicant may apply its 10 CFR Part 50, 

Appendix B, QA program to fulfill the corrective actions element of this AMP for both 

safety-related and nonsafety-related structures and components (SCs) within the scope of 

this program.

Corrective actions are taken to prevent recurrence when the specified limits for fuel oil 

standards are exceeded or when water is drained during periodic surveillance. If 

accumulated water is found in a fuel oil storage tank, it is immediately removed. In 

addition, when the presence of biological activity is confirmed, or if there is evidence of 

MIC, a biocide is added to fuel oil.

8. Confirmation Process: The confirmation process is addressed through those specific 

portions of the QA program that are used to meet Criterion XVI, “Corrective Action,” of 

10 CFR Part 50, Appendix B. Appendix A of the GALL-SLR Report describes how an 

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the confirmation 

process element of this AMP for both safety-related and nonsafety-related SCs within the 

scope of this program. 

9. Administrative Controls: Administrative controls are addressed through the QA program 

that is used to meet the requirements of 10 CFR Part 50, Appendix B, associated with 

managing the effects of aging. Appendix A of the GALL-SLR Report describes how an 

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the 

administrative controls element of this AMP for both safety-related and nonsafety-related 

SCs within the scope of this program. 

10. Operating Experience: The operating experience (OE) at some plants has included 

identification of water in the fuel, particulate contamination, and biological fouling. In 

addition, when a diesel fuel oil storage tank at one plant was cleaned and visually 

inspected, the inside of the tank was found to have unacceptable pitting corrosion 

(> 50 percent of the wall thickness), which was repaired in accordance with American 

Petroleum Institute (API) 653 standard by welding patch plates over the affected area.

The program is informed and enhanced when necessary through the systematic and 

ongoing review of both plant-specific and industry OE including research and development 

such that the effectiveness of the AMP is evaluated consistent with the discussion in 

Appendix B of the GALL-SLR Report.
XI.M30-4

References

10 CFR Part 50, Appendix B, “Quality Assurance Criteria for Nuclear Power Plants and Fuel 

Reprocessing Plants.” Washington, DC: U.S. Nuclear Regulatory Commission. 2016.

API. 653, “Tank Inspection, Repair, Alteration, and Reconstruction.” Washington, DC: American 

Petroleum Institute. April 2009.

ASTM. ASTM D 0975-13, “Standard Specification for Diesel Fuel Oils.” West Conshohocken, 

Pennsylvania: American Society for Testing Materials. 2004.

_____. ASTM D 1796-11, “Standard Test Method for Water and Sediment in Fuel Oils by the 

Centrifuge Method.” West Conshohocken, Pennsylvania: American Society for Testing Materials. 

1997.

_____. ASTM D 2276-00, “Standard Test Method for Particulate Contaminant in Aviation Fuel by 

Line Sampling.” West Conshohocken, Pennsylvania: American Society for Testing Materials. 

2000.

_____. ASTM D 2709-96 (Reapproved 2011), “Standard Test Method for Water and Sediment in 

Middle Distillate Fuels by Centrifuge.” West Conshohocken, Pennsylvania: American Society for 

Testing Materials. 1996.

_____. ASTM D 4057-06 (Reapproved 2011), “Standard Practice for Manual Sampling of 

Petroleum and Petroleum Products.” West Conshohocken, Pennsylvania: American Society for 

Testing Materials. 2000.

_____. ASTM D 6217-11, “Standard Test Method for Particulate Contamination in Middle 

Distillate Fuels by Laboratory Filtration.” West Conshohocken, Pennsylvania: American Society 

for Testing Materials. 1998.

NRC. Regulatory Guide 1.137, “Fuel-Oil Systems for Standby Diesel Generators.” Revision 2. 

Agencywide Documents Access and Management System (ADAMS) Accession 

No. ML12300A122. Washington, DC: U.S. Nuclear Regulatory Commission, June 2013.

_____. “Safety Evaluation Report Related to the License Renewal of Three Mile Island Nuclear 

Unit 1, Section 3.0.3.2.12, Fuel Oil Chemistry–Operating Experience.” ADAMS Accession No.

ML091660470. Washington, DC: U.S. Nuclear Regulatory Commission. June 30, 2009.
XI.M31-1

XI.M31 REACTOR VESSEL MATERIAL SURVEILLANCE

Program Description

Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix H, requires 

implementation of a Reactor Vessel Material Surveillance program when the peak neutron fluence 

at the end of the design life of the vessel exceeds 1017 n/cm2 (E > 1 MeV). The purpose of the 

material surveillance program is to monitor the changes in fracture toughness to the ferritic reactor 

vessel beltline materials. As described in Regulatory Issue Summary 2014-11, beltline materials 

are those ferritic reactor vessel materials with a projected neutron fluence greater than 1017 n/cm2

(E > 1 MeV) at the end of the license period (for example, the subsequent period of extended 

operation), which are evaluated to identify the extent of neutron radiation embrittlement for the 

material. The surveillance capsules contain reactor vessel material specimens and are located 

near the inside vessel wall in the beltline region so that the specimens duplicate, as closely as

possible, the neutron spectrum, temperature history, and maximum neutron fluence experienced 

at the reactor vessel’s inner surface. Because of the location of the capsules between the reactor 

core and the reactor vessel wall, surveillance capsules typically receive neutron fluence 

exposures that are higher than the inner surface of the reactor vessel. This allows surveillance 

capsules to be withdrawn and tested prior to the inner surface receiving an equivalent neutron 

fluence so that the surveillance test results bound the conditions at the end of the subsequent

period of extended operation.

The surveillance program must meet the requirements of 10 CFR Part 50, Appendix H. The 

American Society for Testing Materials (ASTM) standards incorporated by reference in 

10 CFR Part 50, Appendix H, include recommended surveillance capsule withdrawal schedules

based on plant operation during the original 40-year license term. Therefore, standby capsules or 

capsules containing reconstituted specimens may need to be incorporated into the Reactor 

Vessel Material Surveillance program to provide reasonable assurance of appropriate monitoring 

during the subsequent period of extended operation. Surveillance capsules are designed and 

located to permit insertion of replacement capsules. If standby capsule(s) will be incorporated into 

the Reactor Vessel Material Surveillance program for withdrawal and testing to address the 

subsequent period of extended operation and the capsule(s) has already been withdrawn from the 

reactor vessel and placed in storage, the surveillance capsule(s) should be reinserted, if 

necessary, in a location with an appropriate lead factor to ensure that the neutron fluence of the 

surveillance capsule and the test results will, at a minimum, bound the peak neutron fluence of 

interest projected to the end of the subsequent period of extended operation.

This program includes withdrawal and testing of at least one surveillance capsule addressing the 

subsequent period of extended operation, with a neutron fluence of the surveillance capsule

between one and two times the peak neutron fluence of interest projected at the end of the 

subsequent period of extended operation. The peak reactor vessel neutron fluence of interest at 

the end of the subsequent period of extended operation should address the time-limited aging 

analyses (TLAAs) described in the following sections of the Standard Review Plan for Review of 

Subsequent License Renewal Applications for Nuclear Power Plants (SRP-SLR), as applicable: 

Sections 4.2.2.1.2 (Upper-Shelf Energy), 4.2.3.1.3 (Pressurized Thermal Shock) and 4.2.3.1.4 

(Pressure-Temperature Limits) for pressurized water reactors (PWRs); and Sections 4.2.2.1.2 

(Upper-Shelf Energy), 4.2.3.1.4 (Pressure Temperature Limits), 4.2.3.1.5 (Elimination of Boiling 

Water Reactor Circumferential Weld Inspection) and 4.2.3.1.6 (Boiling Water Reactor Axial 

Welds) for boiling water reactors (BWRs). If a capsule meeting this neutron fluence criterion has 

not been tested prior to entering the subsequent period of extended operation, then the program 

includes the withdrawal and testing (or alternatively the retrieval from storage, reinsertion for 

additional neutron fluence accumulation, if necessary, and testing) of one capsule addressing the 
XI.M31-2

subsequent period of extended operation to meet this criterion. If a surveillance capsule was 

previously identified for withdrawal and testing to address the initial period of extended operation, 

it is not acceptable to redirect or postpone the withdrawal and testing of that capsule to achieve a 

higher neutron fluence that meets the neutron fluence criterion for the subsequent period of 

extended operation.

An integrated surveillance program (ISP), alternatively, may be considered for a set of reactors 

that have similar design and operating features, as described in 10 CFR Part 50, Appendix H, 

Paragraph III.C. The plant-specific implementation of the ISP is consistent with the latest version 

of the ISP plan that has received approval by the U.S. Nuclear Regulatory Commission (NRC) for 

the subsequent period of extended operation.

The objective of this Reactor Vessel Material Surveillance program is to provide sufficient material 

data and dosimetry to (a) monitor irradiation embrittlement to a neutron fluence level which is 

greater than the projected peak neutron fluence of interest projected to the end of the subsequent 

period of extended operation, and (b) provide adequate dosimetry monitoring during the

subsequent period of extended operation. If surveillance capsules are not withdrawn during the 

subsequent period of extended operation, provisions are made to perform dosimetry monitoring. 

An in-vessel standby capsule, or a standby capsule which has been retrieved from storage and 

reinserted, when coupled with the use of an NRC-approved methodology for determining neutron 

fluence consistent with Regulatory Guide (RG) 1.190, “Calculational and Dosimetry Methods for 

Determining Pressure Vessel Neutron Fluence,” provides an acceptable means of dosimetry 

monitoring.

The program is a condition monitoring program that measures the increase in Charpy V-notch 

30 foot-pound (ft-lb) transition temperature and the drop in the upper-shelf energy (USE) as a 

function of neutron fluence and irradiation temperature. The data from this surveillance program 

are used to monitor neutron irradiation embrittlement of the reactor vessel, and are inputs to the 

neutron embrittlement TLAAs described in Section 4.2 of the SRP-SLR. The Reactor Vessel 

Material Surveillance program is also used in conjunction with the Generic Aging Lessons 

Learned for Subsequent License Renewal (GALL-SLR) Report, AMP X.M2, “Neutron 

Fluence Monitoring.”

All surveillance capsules, including those previously withdrawn from the reactor vessel, must meet 

the test procedures and reporting requirements of the applicable ASTM standards referenced in 

10 CFR Part 50, Appendix H, to the extent practicable, for the configuration of the specimens in 

the capsule. Any changes to the surveillance capsule withdrawal schedule, including the 

incorporation and change of status of standby capsules to capsules scheduled for withdrawal and 

testing (or alternatively retrieval from storage, reinsertion for additional neutron fluence 

accumulation, if necessary, and testing) under this program must be approved by the NRC prior to 

implementation, in accordance with 10 CFR Part 50, Appendix H, Paragraph III.B.3. Standby 

capsules placed in storage (e.g., withdrawn from the reactor vessel) are maintained for possible 

future insertion, and tested specimens are retained in storage for possible reconstitution.

Evaluation and Technical Basis

The Reactor Vessel Material Surveillance program is plant-specific and depends on the 

composition and availability of the limiting materials, the availability of surveillance capsules, and 

the projected neutron fluence at the end of the subsequent period of extended operation. In 

accordance with 10 CFR Part 50, Appendix H, an applicant submits its proposed withdrawal 

schedule for NRC approval prior to implementation.
XI.M31-3

1. Scope of Program: The program addresses neutron embrittlement of all ferritic reactor 

vessel beltline materials as defined by 10 CFR Part 50, Appendix G, as the region of the 

reactor vessel that directly surrounds the effective height of the active core and the 

adjacent regions of the reactor vessel that are predicted to experience sufficient neutron 

damage to be considered in the selection of the limiting material with regard to radiation 

damage. Materials with a projected neutron fluence greater than 1017 n/cm2 (E > 1 MeV) at 

the end of the license period (for example, the subsequent period of extended operation),

are considered to experience sufficient neutron damage to be included in the beltline. 

Materials monitored within the licensee’s existing, materials surveillance program typically 

continue to serve as the basis for the reactor vessel surveillance aging management 

program (AMP).

For ISPs, the plant-specific implementation of the ISP in this Reactor Vessel Material 

Surveillance program is maintained consistent with the latest version of the ISP plan that 

has received approval by the NRC for the subsequent period of extended operation. 

2. Preventive Actions: This program is a surveillance program; no preventive actions 

are identified.

3. Parameters Monitored or Inspected: The program monitors reduction of fracture 

toughness of reactor vessel beltline materials due to neutron irradiation embrittlement, 

through the periodic testing of material specimens at different intervals that have been 

irradiated in the surveillance capsules that are a part of the program. The program also 

monitors the long-term operating conditions of the reactor vessel (i.e., vessel beltline 

operating temperature and neutron fluence, the latter using GALL-SLR AMP X.M2, 

“Neutron Fluence Monitoring”) that could affect neutron irradiation embrittlement of the 

reactor vessel.

The program uses two parameters to monitor the effects of neutron irradiation: (a) the 

increase in the Charpy V-notch 30 ft-lb transition temperature, and (b) the drop in the 

Charpy V-notch USE. The program uses neutron dosimeters to monitor the neutron 

fluence of the surveillance capsule and to provide information to benchmark neutron 

fluence calculations. Low melting point elements or low melting point eutectic alloys may 

be used as a check on peak specimen irradiation temperature. Results from these 

temperature monitors are used to ensure that the exposure temperature of the 

surveillance capsule is consistent with the reactor vessel beltline operating temperature. 

The Charpy V-notch specimens, neutron dosimeters, and temperature monitors are 

placed in capsules that are located within the reactor vessel; the capsules are withdrawn 

periodically to monitor the reduction in fracture toughness due to neutron irradiation.

This program includes withdrawal and testing of at least one capsule addressing the 

subsequent period of extended operation with a neutron fluence of the capsule between 

one and two times the peak neutron fluence of interest at the end of the subsequent period 

of extended operation. The peak reactor vessel neutron fluence of interest at the end of 

the subsequent period of extended operation should address the TLAAs as described in 

the following sections of the SRP-SLR, as applicable: Sections 4.2.2.1.2 (Upper-Shelf 

Energy), 4.2.3.1.3 (Pressurized Thermal Shock) and 4.2.3.1.4 (Pressure-Temperature 

Limits) for PWRs; and Sections 4.2.2.1.2 (Upper-Shelf Energy), 4.2.3.1.4 (Pressure 

Temperature Limits), 4.2.3.1.5 (Elimination of Boiling Water Reactor Circumferential Weld 

Inspection) and 4.2.3.1.6 (Boiling Water Reactor Axial Welds) for BWRs. If a capsule 

meeting this neutron fluence criterion has not been tested prior to entering the subsequent 
XI.M31-4 

period of extended operation, then the program includes the withdrawal and testing (or 

alternatively the retrieval from storage, reinsertion for additional neutron fluence 

accumulation, if necessary, and testing) of one capsule to address the subsequent period 

of extended operation to meet this criterion. If a surveillance capsule was previously 

identified for withdrawal and testing to address the initial period of extended operation, it is 

not acceptable to redirect or postpone the withdrawal and testing of that capsule to 

achieve a higher neutron fluence that meets the neutron fluence criterion for the 

subsequent period of extended operation. Test results are reported consistent with the 

requirements of 10 CFR Part 50, Appendix H. Because the degree of neutron irradiation 

embrittlement is a function of the neutron fluence, calculations of the capsule neutron

fluence, the reactor vessel wall neutron fluence, and the peak neutron fluence of interest 

projected to the end of the subsequent period of extended operation are important parts of 

the program. The methods used to determine both capsule and reactor vessel wall 

neutron fluence values are consistent with RG 1.190, as described in GALL-SLR 

AMP X.M2, “Neutron Fluence Monitoring.”

This program uses separate dosimeter capsules or ex-vessel dosimeters to monitor 

neutron fluence independent of the specimen capsules if there are no surveillance 

capsules installed in the reactor vessel.

4. Detection of Aging Effects: Reactor vessel materials are monitored by a surveillance

program in which surveillance capsules are withdrawn from the reactor vessel and tested

consistent with 10 CFR Part 50, Appendix H. The ASTM standards referenced in

Appendix H describe the methods used to monitor irradiation embrittlement (as described

in Element 3, above), selection of materials, and the withdrawal schedule for surveillance

capsules. Because the withdrawal schedule in Table 1 of ASTM E185-82 is based on

plant operation during the original 40-year license term, standby capsules may need to be

incorporated into the program as capsules to be tested within a withdrawal schedule that

covers the subsequent period of extended operation. Alternatively, this program can

propose implementation of in-vessel irradiation of capsule(s) with reconstituted specimens

from previously tested capsules and appropriate neutron fluence monitoring.

Alternatively, an ISP for the subsequent period of extended operation may be considered 

for a set of reactors that have similar design and operating features as described in

10 CFR Part 50, Appendix H, Paragraph III.C. For an ISP, in some cases the plant

Reactor Vessel Material Surveillance program may result in no surveillance capsules

being irradiated in the plant’s reactor vessel, with the plant relying on data from testing of

the ISP capsules from the host plants of the capsules. Additional surveillance capsules

may also be needed for the subsequent period of extended operation for an ISP. For

ISPs, the plant-specific implementation of the ISP in the Reactor Vessel Material

Surveillance program is maintained consistent with the latest version of the ISP plan that 

has received approval by the NRC for the subsequent period of extended operation. 

The plant implements dosimetry monitoring as required by the approved ISP to meet 

the provision of 10 CFR Part 50, Appendix H, Paragraph III.C.1.b, that each reactor in an 

ISP has an adequate dosimetry program. 

If no in-vessel surveillance capsules are available, an alternative neutron fluence 

monitoring program uses alternative dosimetry, either from in-vessel capsules or ex-vessel 

capsules, to monitor neutron fluence during the subsequent period of extended operation. 

The methods used in this alternative neutron fluence monitoring program are consistent 
XI.M31-5

with RG 1.190, including appropriate benchmarking, as described in GALL-SLR Report 

AMP X.M2, “Neutron Fluence Monitoring.”

If not previously approved, the capsule withdrawal schedule for the Reactor Vessel 

Material Surveillance program shall be submitted as part of the subsequent license 

renewal application.

If the reactor vessel exposure conditions (neutron flux, spectrum, irradiation temperature, 

etc.) are altered, then the basis for the projection of neutron fluence to the end of the 

subsequent period of extended operation is reviewed and appropriate modifications are 

made to the Reactor Vessel Material Surveillance program. Any changes to the Reactor 

Vessel Material Surveillance program must be submitted for NRC review and approval in 

accordance with 10 CFR Part 50, Appendix H, prior to implementation.

5. Monitoring and Trending: The program provides data on neutron embrittlement of the 

reactor vessel materials and neutron fluence data. These data are used to evaluate the 

TLAAs on neutron irradiation embrittlement (e.g., USE, pressurized thermal shock (PTS),

pressure-temperature limits evaluations, etc.) as needed to demonstrate compliance with 

the requirements of 10 CFR Part 50, Appendix G, and 10 CFR 50.61 or 10 CFR 50.61a for 

the subsequent period of extended operation, as described in the SRP-SLR, Section 4.2.

The plant-specific surveillance program or ISP has at least one capsule that has attained 

or will attain neutron fluence between one and two times the peak reactor vessel wall 

neutron fluence of interest at the end of the subsequent period of extended operation. If a 

capsule meeting this neutron fluence criterion has not been tested previously, then the 

program includes withdrawal and testing (or alternatively the retrieval from storage, 

reinsertion for additional neutron fluence accumulation, if necessary, and testing) of one 

capsule addressing the subsequent period of extended operation. (If a surveillance 

capsule was previously identified for withdrawal and testing to address the initial period of 

extended operation, it is not acceptable to redirect or postpone the withdrawal and testing 

of that capsule to achieve a higher neutron fluence that meets the neutron fluence criterion 

for the subsequent period of extended operation.) The program withdraws, and 

subsequently tests, the capsule(s) at an outage in which the capsule receives a neutron 

fluence of between one and one and two times the peak reactor vessel neutron fluence of 

interest at the end of the subsequent period of extended operation. Test results from this 

capsule are reported as described in 10 CFR Part 50, Appendix H. If an existing standby 

capsule that has been previously withdrawn from the reactor vessel is used for testing to 

meet the neutron fluence criterion for the subsequent period of extended operation and the 

capsule does not require additional irradiation, then that (formerly standby) capsule is 

incorporated into the surveillance capsule withdrawal schedule of the Reactor Vessel 

Material Surveillance program upon receipt of the subsequently renewed license, and 

reporting of the test results is consistent with 10 CFR Part 50, Appendix H, with the 

“withdrawal date” of the capsule considered to be no later than the date of the 

subsequently renewed license. If a plant has ample capsules remaining for future use, all 

pulled and tested samples placed in storage with reactor vessel neutron fluence less than 

37.5 percent of the projected neutron fluence at the end of the subsequent period of 

extended operation, may be discarded. All pulled and tested samples with a neutron 

fluence greater than 37.5 percent of the projected reactor vessel neutron fluence at the 

end of the subsequent period of extended operation and all untested capsules are placed 

in storage (these specimens and capsules are saved for possible future reconstitution and 
XI.M31-6

reinsertion use) unless the applicant has gained NRC approval to discard the pulled and 

tested samples or capsules.

If an applicant does not have ample capsules remaining for future use, all withdrawn and 

tested capsule specimens are placed in storage. These specimens are saved for future 

reconstitution, in case irradiation embrittlement monitoring by the surveillance program 

is reestablished. Tested surveillance specimens may be withdrawn from storage and 

used in research activities (e.g., microstructural examination, mechanical testing, and/or 

additional irradiation) without NRC approval if the licensee determines that a sufficient 

number of specimens will remain.

6. Acceptance Criteria: Although there are no specific acceptance criteria that apply to the 

surveillance data themselves, the program meets the requirements of 10 CFR Part 50, 

Appendix H. The reactor vessel embrittlement projections are used to demonstrate 

compliance with the requirements of 10 CFR Part 50, Appendix G, and 10 CFR 50.61 or 

10 CFR 50.61a, and acceptability of other plant-specific analyses, throughout the 

subsequent period of extended operation, as described in the SRP-SLR, Section 4.2.

7. Corrective Actions: Results that do not meet the acceptance criteria are addressed in 

the applicant’s corrective action program under those specific portions of the quality 

assurance (QA) program that are used to meet Criterion XVI, “Corrective Action,” of 

10 CFR Part 50, Appendix B. Appendix A of the GALL-SLR Report describes how an 

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the corrective 

actions element of this AMP for both safety-related and nonsafety-related structures and 

components (SCs) within the scope of this program.

Since the data from this program are used for reactor vessel embrittlement projections to 

comply with regulations (e.g., 10 CFR Part 50, Appendix G, requirements, and 

10 CFR 50.61 or 10 CFR 50.61a limits) through the subsequent period of extended 

operation, corrective actions would be necessary if these requirements are not satisfied, or 

if this program fails to meet the requirements of 10 CFR Part 50, Appendix H. If plant 

operating characteristics exceed the operating restrictions identified previously, such as a 

lower reactor vessel operating temperature or higher neutron fluence, this program 

provides reasonable assurance that the impact of actual plant operation characteristics on 

the extent of reactor vessel embrittlement is evaluated, and the NRC is notified.

8. Confirmation Process: The confirmation process is addressed through those specific 

portions of the QA program that are used to meet Criterion XVI, “Corrective Action,” of 

10 CFR Part 50, Appendix B. Appendix A of the GALL-SLR Report describes how an 

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the confirmation 

process element of this AMP for both safety-related and nonsafety-related SCs within the 

scope of this program.

9. Administrative Controls: Administrative controls are addressed through the QA program 

that is used to meet the requirements of 10 CFR Part 50, Appendix B, associated with 

managing the effects of aging. Appendix A of the GALL-SLR Report describes how an 

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the 

administrative controls element of this AMP for both safety-related and nonsafety-related 

SCs within the scope of this program.
XI.M31-7

10. Operating Experience: The existing reactor vessel material surveillance program 

provides sufficient material data and dosimetry to (a) monitor irradiation embrittlement at 

the end of the subsequent period of extended operation, and (b) determine the need for 

operating restrictions on the inlet temperature, neutron fluence, and neutron flux.

The program is informed and enhanced when necessary through the systematic and 

ongoing review of both plant-specific and industry operating experience including research

and development such that the effectiveness of the AMP is evaluated consistent with the 

discussion in Appendix B of the GALL-SLR Report.

References

10 CFR Part 50, Appendix B, “Quality Assurance Criteria for Nuclear Power Plants and Fuel 

Reprocessing Plants.” Washington, DC: U.S. Nuclear Regulatory Commission. 2016.

10 CFR Part 50, Appendix G, “Fracture Toughness Requirements.” Washington, DC: 

U.S. Nuclear Regulatory Commission. 2016.

10 CFR Part 50, Appendix H, “Reactor Vessel Material Surveillance Program Requirements.” 

Washington, DC: U.S. Nuclear Regulatory Commission. 2016.

10 CFR 50.61, “Fracture Toughness Requirements for Protection Against Pressurized Thermal 

Shock Events.” Washington, DC: U.S. Nuclear Regulatory Commission. 2015.

10 CFR 50.61a, “Alternate Fracture Toughness Requirements for Protection Against Pressurized 

Thermal Shock Events.” Washington, DC: U.S. Nuclear Regulatory Commission. 2015.

ASTM. ASTM E 185-82, “Standard Practice for Conducting Surveillance Tests of Light-Water 

Cooled Nuclear Power Reactor Vessels.” Philadelphia, Pennsylvania: American Society for 

Testing Materials. (Versions of ASTM E 185 to be used for the various aspects of the reactor 

vessel surveillance program are as specified in 10 CFR Part 50, Appendix H). 1982.

_____. ASTM E 185-79, “Standard Practice for Conducting Surveillance Tests for Light-Water 

Cooled Nuclear Power Reactor Vessels.” Philadelphia, Pennsylvania: American Society for 

Testing Materials. 1979.

_____. ASTM E 185-73, “Standard Recommended Practice for Surveillance Tests for Nuclear 

Reactor Vessels.” Philadelphia, Pennsylvania: American Society for Testing Materials. 1973.

Eason, E.D., G.R. Odette, R.K. Nanstad, and T. Yamamoto. “A Physically Based Correlation of 

Irradiation-Induced Transition Temperature Shifts for RPV Steels.” ORNL/TM-2006/530. 

ML081000630. Oak Ridge, Tennessee: Oak Ridge National Laboratory. November 2007.

NRC. Regulatory Guide 1.99, “Radiation Embrittlement of Reactor Vessel Materials.” Revision 2. 

Agencywide Documents Access and Management System (ADAMS) Accession No.

ML003740284. Washington, DC: U.S. Nuclear Regulatory Commission. May 31, 1988.

_____. Regulatory Guide 1.190, “Calculational and Dosimetry Methods for Determining Pressure 

Vessel Neutron Fluence.” ADAMS Accession No. ML010890301. Washington, DC: U.S. Nuclear 

Regulatory Commission. March 31, 2001.
XI.M31-8

_____. Regulatory Issue Summary 2014-11, “Information on Licensing Applications for Fracture 

Toughness Requirements for Ferritic Reactor Coolant Pressure Boundary Components.” ADAMS 

Accession No. ML14149A165. Washington, DC: U.S. Nuclear Regulatory Commission. 

October 14, 2014.
XI.M32-1

XI.M32 ONE-TIME INSPECTION 

Program Description

A one-time inspection of selected components is conducted just prior to the beginning of a 

subsequent period of extended operation (e.g., prior to the second period of extended operation) 

in order to verify the system-wide effectiveness of an aging management program (AMP) that is 

designed to prevent or minimize aging to the extent that it will not cause the loss of intended 

function during the subsequent period of extended operation. For example, effective control of 

water chemistry under the Generic Aging Lessons Learned for Subsequent License Renewal 

(GALL-SLR) Report AMP XI.M2, “Water Chemistry,” program can prevent some aging effects and 

minimize others. However, there may be locations that are isolated from the flow stream for 

extended periods and are susceptible to the gradual accumulation or concentration of agents that 

promote certain aging effects. This program provides inspections that verify that unacceptable

degradation is not occurring.

This program can also be used to verify the lack of significance of an aging effect. Situations in 

which additional confirmation is appropriate include: (a) an aging effect is not expected to occur, 

but the data are insufficient to rule it out with reasonable confidence; or (b) an aging effect is 

expected to progress very slowly in the specified environment, but the local environment may be 

more adverse than generally expected. For these cases, confirmation demonstrates that either 

the aging effect is not occurring or that the aging effect is occurring very slowly and does not affect 

the component’s or structure’s intended function during the subsequent period of extended 

operation based on prior operating experience (OE) data.

In addition, for steel components exposed to water environments that do not include corrosion 

inhibitors as a preventive action (e.g., treated water, treated borated water, raw water, waste 

water), this program verifies that long-term loss of material due to general corrosion will not cause 

a loss of intended function [e.g., pressure boundary, leakage boundary (spatial), structural 

integrity (attached)].

This program does not address Class 1 piping less than 4 inches nominal pipe size. That piping 

is addressed in GALL-SLR Report AMP XI.M35, “ASME Code Class 1 Small-Bore Piping.” 

The elements of the program include: (a) determination of the sample size of components to be 

inspected based on an assessment of materials of fabrication, environments, plausible aging 

effects, and OE; (b) identification of the inspection locations in the system or component based on 

the potential for the aging effect to occur; (c) determination of the examination technique, including 

acceptance criteria that would be effective in managing the aging effect for which the component 

is examined; and (d) evaluation of the need for follow-up examinations to monitor the progression 

of aging if age-related degradation is found that could jeopardize an intended function before the 

end of the subsequent period of extended operation. 

The program may include a review of routine maintenance, repair, or inspection records to confirm 

that selected components have been inspected for aging degradation within the recommended 

time period for the inspections related to the subsequent period of extended operation, and that 

significant aging degradation has not occurred. A one-time inspection program is acceptable to 

verify the effectiveness of GALL-SLR Report AMP XI.M2, “Water Chemistry,” GALL-SLR Report

AMP XI.M30, “Fuel Oil Chemistry,” and GALL-SLR Report AMP XI.M39, “Lubricating Oil 

Analysis,” where the environment in the subsequent period of extended operation is expected to 

be equivalent to that in the prior operating period and for which no aging effects have been 
XI.M32-2

observed. However, the one-time inspection for environments that do not fall in the above 

category, or of any other action or program created to verify the effectiveness of an AMP and 

confirm the absence of an aging effect, is to be reviewed by the staff on a plant-specific basis.

This program cannot be used for structures or components with known age-related degradation 

mechanisms or when the environment in the subsequent period of extended operation is not 

expected to be equivalent to that in the prior operating period. Periodic inspections are proposed 

in these cases.

Evaluation and Technical Basis

1. Scope of Program: The scope of this program includes systems and components that 

are subject to aging management using GALL-SLR Report AMPs XI.M2, “Water 

Chemistry;” XI.M30, “Fuel Oil Chemistry;” and XI.M39, “Lubricating Oil Analysis;” and for 

which no aging effects have been observed or for which the aging effect is occurring very 

slowly and will not affect the component’s or structure’s intended function during the 

subsequent period of extended operation based on prior OE data. The scope of this 

program also may include other components and materials where the environment in the 

subsequent period of extended operation is expected to be equivalent to that in the prior 

operating period and for which no aging effects have been observed. The scope of this 

program includes managing long-term loss of material due to general corrosion for steel 

components. Long-term loss of material due to general corrosion for steel components 

need not be managed if one of the following two conditions is met: (i) the environment for 

the steel components includes corrosion inhibitors as a preventive action; or (ii) wall 

thickness measurements on a representative sample of each environment will be 

conducted between the 50th and 60th year of operation. Environments such as treated 

water, treated borated water, raw water, and waste water do not typically include 

corrosion inhibitors.

The program cannot be used for structures or components:

• Subjected to known age-related degradation mechanisms as determined based on 

a review of plant-specific and industry OE for the prior operating period, 

• When the environment in the subsequent period of extended operation is not 

expected to be equivalent to that in the prior operating period, or

• When aging effects that do not meet acceptance criteria are identified during the 

one-time inspection conducted in the prior operating period or during the review of 

plant-specific or industry OE.

Periodic inspections are proposed in these cases.

2. Preventive Actions: One-time inspection is a condition monitoring program. It does not 

include methods to mitigate or prevent age-related degradation.
XI.M32-3

3. Parameters Monitored or Inspected: The program monitors parameters directly related 

to the age-related degradation of a component. Examples of parameters monitored and 

the related aging effect are provided in Table XI.M32-1, “Examples of Parameters 

Monitored or Inspected and Aging Effect for Specific Structure or Component.” Inspection 

is performed using a variety of nondestructive examination (NDE) methods, including 

visual, volumetric, and surface techniques. 

Table XI.M32-1. Examples of Parameters Monitored or Inspected and Aging Effect for Specific 

Structure or Component1

Aging Effect

Aging 

Mechanism

Parameter(s) 

Monitored Inspection Method2

Loss of Material3 Crevice Corrosion Surface Condition 

or Wall Thickness

Visual (e.g., VT-1) or Volumetric 

(e.g., UT)

Loss of Material General 

Corrosion

Surface Condition 

or Wall Thickness

Visual (e.g., VT-3) or Volumetric 

(e.g., UT)

Loss of Material Microbiologically

influenced

Corrosion

Surface Condition 

or Wall Thickness

Visual (e.g., VT-3) or Volumetric 

(e.g., UT)

Loss of Material3 Pitting Corrosion Surface Condition 

or Wall Thickness

Visual (e.g., VT-1) or Volumetric 

(e.g., UT)

Long-term Loss 

of Material 

General 

Corrosion

Wall Thickness Volumetric (e.g., UT)

Reduction of 

Heat Transfer

Fouling Tube Fouling Visual (e.g., VT-3)

Cracking3 SCC or Cyclic 

Loading

Surface Condition 

or Cracks

Enhanced Visual (e.g., EVT-1) or Surface 

Examination (magnetic particle, liquid 

penetrant) or Volumetric (radiographic 

testing or UT) 1The examples provided in the table may not be appropriate for all relevant situations. If the applicant chooses to 

use an alternative to the recommendations in this table, a technical justification is provided as an exception to this 

AMP. This exception lists the aging management review line item component, examination technique, acceptance 

criteria, evaluation standard, and a description of the justification. 2Visual inspection may be used only when the inspection methodology examines the surface potentially 

experiencing the aging effect.

3Visual inspections conducted to detect potential loss of material or cracking of SS and aluminum alloy support 

members; welds; bolted connections; support anchorage to building structure exposed to air or condensation (see 

SRP-SLR Section 3.5.2.2.2.4) may be conducted consistent with those for the GALL-SLR Report AMP XI.S6, 

“Structures Monitoring.”

4. Detection of Aging Effects: Elements of the program include (a) determination of the 

sample size of components to be inspected based on an assessment of materials of 

fabrication, environment, plausible aging effects, and OE; (b) identification of the 

inspection locations in the system or component based on the potential for the aging effect 

to occur; and (c) determination of the examination technique, including acceptance criteria 

that would be effective in managing the aging effect for which the component is examined.

The inspection includes a representative sample of each population (defined as 

components having the same material, environment, and aging effect combination) and, 

where practical, focuses on the bounding or lead components most susceptible to aging 

due to time in service, and severity of operating conditions. A representative sample size 

is 20 percent of the population or a maximum of 25 components at each unit. Otherwise, 

a technical justification of the methodology and sample size used for selecting 

components for one-time inspection is included as part of the program’s documentation.
XI.M32-4

The program relies on established NDE techniques, including visual, ultrasonic, and 

surface techniques. Inspections and tests are performed by personnel qualified in 

accordance with site procedures and programs to perform the type of examination 

specified. Inspections and tests within the scope of the American Society of Mechanical 

Engineers Boiler and Pressure Vessel Code (ASME Code)1 follow procedures consistent 

with the ASME Code. Non-ASME Code inspections follow site procedures that include 

inspection parameters for items such as lighting, distance, offset, surface coverage, 

presence of protective coatings, and cleaning processes. In addition, a description of 

enhanced visual examination (EVT)-1 is found in Boiling Water Reactor Vessel and 

Internals Project (BWRVIP)-03 and Materials Reliability Program (MRP)-228.

When using this AMP to conduct one-time inspections of aluminum piping, piping 

components and tanks exposed to air, aluminum structures and components (SCs) are 

grouped by material type. The high strength heat treatable aluminum alloys (i.e., 2xxx and 

7xxx series) may be treated as a separate population when performing inspections and 

interpreting results due to their relatively lower corrosion resistance. The relative 

susceptibility of moderate and lower strength alloys varies based on composition (primarily 

weight percent Cu, Mg, and Fe) and temper designation. Grouping of air environments 

consistent with the Detection of Aging Effects program element of GALL-SLR Report 

AMP XI.M38 is acceptable.

In addition, when using this AMP to conduct inspections of stainless steel (SS), nickel 

alloy, and aluminum components exposed to any air environment or condensation to 

detect loss of material or stress corrosion cracking, the internal surfaces of these 

components do not need to be inspected if: (a) the review of plant-specific OE does not 

reveal a history of pitting or crevice corrosion; and (b) inspection results for external 

surfaces demonstrate that the aging effect is not applicable. Inspection results associated 

with the periodic introduction of either moisture or halides from secondary sources (e.g.,

leaking flanges) may be treated as a separate population of components. 

An inspection of a component in a more severe environment may be credited as an 

inspection for the specified environment and for the same material and aging effects in a 

less severe environment (e.g., a high-humidity environment is more severe than an indoor 

controlled air environment because the moisture in the former environment is more likely 

to result in aging effects than would be expected from the normally dry surfaces 

associated with the latter environment). Alternatively, similar environments (e.g., internal 

uncontrolled indoor, controlled indoor, dry air environments) can be combined into a larger 

population provided that the inspections occur on components located in the most 

severe environment (e.g., in the locality of flanges that have leaked in the past).

 

1 GALL-SLR Report Chapter I, Table 1, identifies the ASME Code Section XI editions and addenda that are 

acceptable to use for this AMP.
XI.M32-5

For managing long-term loss of material, exceptions need not be stated for the following:

• Conducting wall thickness measurements for long-term loss of material in a 

different AMP (e.g., AMP XI.M20) as long as the alternative AMP cites the 

necessary detail (e.g., environment, sample size, purpose of inspection).

• Utilization of the data from recurring internal corrosion wall thickness 

measurements as long as the material and environment is consistent with that for 

long-term loss of material.

• The use of scanning techniques (e.g., low frequency electromagnetic testing) as 

long as the method, coverage, and threshold for follow-up wall thickness 

measurements when indications are detected are stated in the subsequent license 

renewal application.

With respect to inspection timing, the sample of components are inspected before the end 

of the current operating term to provide reasonable assurance that the aging effect will not 

compromise any intended function during the subsequent period of extended operation. 

Inspections need to be timed to allow the inspected components to attain sufficient age 

such that the aging effects with long incubation periods (i.e., those that may affect 

intended functions near the end of the subsequent period of extended operation) are 

identified. Within these constraints, the applicant schedules the inspection no earlier than 

10 years prior to the subsequent period of extended operation. 

5. Monitoring and Trending: Inspection results for each material, environment, and aging 

effect are compared to those obtained during previous inspections when available. Where 

practical, these results are trended in order to project observed degradation to the end of 

the subsequent period of extended operation. 

6. Acceptance Criteria: The acceptance criteria for this program considers both the results

of observed degradation during current inspections and the results of projecting observed 

degradation of the inspections for each material, environment and aging effect

combinations.

• Any indications or relevant conditions are evaluated. Acceptance criteria may 

be based on applicable ASME Code or other appropriate standards, design 

basis information, or vendor-specified requirements and recommendations

(e.g., ultrasonic thickness measurements are compared to predetermined limits); 

however, crack-like indications are not acceptable.

• Where it is practical to project observed degradation to the end of the subsequent 

period of extended operation, the projected degradation will not: (a) affect the 

intended function of a system, structure, or component; (b) result in a potential 

leak; or (c) result in heat transfer rates below that required by the current licensing 

basis to meet design limits.

Where measurable degradation has occurred, but acceptance criteria have been met, the 

inspection results are entered into the applicant’s corrective action program for future 

monitoring and trending.
XI.M32-6

7. Corrective Actions: Results that do not meet the acceptance criteria are addressed in 

the applicant’s corrective action program under those specific portions of the quality

assurance (QA) program that are used to meet Criterion XVI, “Corrective Action,” of 

Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B. Appendix A of 

the GALL-SLR Report describes how an applicant may apply its 10 CFR Part 50, 

Appendix B, QA program to fulfill the corrective actions element of this AMP for both 

safety-related and nonsafety-related SCs within the scope of this program.

If the cause of the aging effect for each applicable material and environment is not 

corrected by repair of replacement for all components constructed of the same material 

and exposed to the same environment, additional inspections are conducted if one of the 

inspections does not meet acceptance criteria. The number of increased inspections is 

determined in accordance with the site’s corrective action process; however, there are no 

fewer than five additional inspections for each inspection that did not meet acceptance 

criteria, or 20 percent of each applicable material, environment, and aging effect 

combination is inspected, whichever is less. If subsequent inspections do not meet 

acceptance criteria, an extent of condition and extent of cause analysis is conducted to 

determine the further extent of inspections. At multi-unit sites, the additional inspections 

include inspections at all of the units with the same material, environment, and aging effect 

combination.

Where an aging effect identified during an inspection does not meet acceptance criteria or 

projected results of the inspections of a material, environment, and aging effect 

combination do not meet the above acceptance criteria, a periodic inspection program is 

developed for the specific material, environment, and aging effect combination. The 

periodic inspection program is implemented at all of the units on site with same 

combination(s) of material, environment, and aging effect.

8. Confirmation Process: The confirmation process is addressed through those specific 

portions of the QA program that are used to meet Criterion XVI, “Corrective Action,” of 

10 CFR Part 50, Appendix B. Appendix A of the GALL-SLR Report describes how 

an applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the 

confirmation process element of this AMP for both safety-related and nonsafety-related 

SCs within the scope of this program.

9. Administrative Controls: Administrative controls are addressed through the QA program 

that is used to meet the requirements of 10 CFR Part 50, Appendix B, associated with 

managing the effects of aging. Appendix A of the GALL-SLR Report describes how an 

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the 

administrative controls element of this AMP for both safety-related and nonsafety-related 

SCs within the scope of this program.

10. Operating Experience: The elements that comprise inspections associated with this 

program (the scope of the inspections and inspection techniques) are consistent with 

industry practice. An applicant’s OE with detection of aging effects should be adequate to 

demonstrate that the program is capable of detecting the presence or noting the absence 

of aging effects in the components, materials, and environments where one-time 

inspection is used to confirm system-wide effectiveness of another preventive or 

mitigative AMP.
XI.M32-7

The program is informed and enhanced when necessary through the systematic and 

ongoing review of both plant-specific and industry OE including research and development 

such that the effectiveness of the AMP is evaluated consistent with the discussion in 

Appendix B of the GALL-SLR Report.

References

10 CFR Part 50, Appendix B, “Quality Assurance Criteria for Nuclear Power Plants and Fuel 

Reprocessing Plants.” Washington, DC: U.S. Nuclear Regulatory Commission. 2016.

10 CFR 50.55a, “Codes and Standards. Washington, DC: U.S. Nuclear Regulatory Commission. 

2016.

ASME. ASME Code Section XI, “Rules for Inservice Inspection of Nuclear Power Plant 

Components.” New York, New York: The American Society of Mechanical Engineers. 2008.

2

EPRI. BWRVIP-03, Revision 6 (EPRI 105696-R6), “BWR Vessel and Internals Project, Reactor 

Pressure Vessel and Internals Examination Guidelines.” Agencywide Documents Access and 

Management System Accession No. ML040440261. Palo Alto, California: Electric Power 

Research Institute. December 2003.

_____. MRP-228, “Materials Reliability Program: Inspection Standard for PWR Internals.” 

Palo Alto, California: Electric Power Research Institute. 2009.

 

2GALL-SLR Report Chapter I, Table 1, identifies the ASME Code Section XI editions and addenda that are 

acceptable to use for this AMP.

XI.M33-1

XI.M33 SELECTIVE LEACHING

Program Description

The program for selective leaching (dealloying) of materials includes components made of gray 

cast iron, ductile iron, and copper alloys (except for inhibited brass) that contain greater than 

15 percent zinc or greater than 8 percent aluminum exposed to a raw water, closed-cycle cooling 

water (CCCW), treated water, waste water, or soil environment. Depending on the environment, 

the aging management program (AMP) includes one-time, or opportunistic or periodic visual 

inspections of selected components that are susceptible to selective leaching, coupled with 

mechanical examination techniques (e.g., chipping, scraping). Destructive examinations of 

components to determine the presence of and depth of dealloying through-wall thickness are also 

conducted. These techniques can determine whether loss of material due to selective leaching is 

occurring and whether selective leaching will affect the ability of the components to perform their 

intended function for the subsequent period of extended operation.

The selective leaching process involves the preferential removal of one of the alloying 

components from the material. Dezincification (loss of zinc from brass) and graphitization or 

graphitic corrosion (removal of iron from gray cast iron and ductile iron) are examples of such a 

process. Susceptible materials exposed to high operating temperatures, stagnant-flow conditions, 

and a corrosive environment (e.g., acidic solutions for brasses with high zinc content and 

dissolved oxygen) are conducive to selective leaching. A dealloyed component often retains its 

shape and may appear to be unaffected; however, the functional cross-section of the material has 

been reduced. The aging effect attributed to selective leaching is loss of material because the 

affected volume has a permanent change in density and does not retain mechanical properties 

that can be credited for structural integrity.

Evaluation and Technical Basis

1. Scope of Program: Components include piping, valve bodies and bonnets, pump 

casings, and heat exchanger components that are susceptible to selective leaching. The 

materials of construction for these components may include gray cast iron, ductile iron,

and copper alloys (except for inhibited brass) containing greater than 15 percent zinc or 

greater than 8 percent aluminum. These components may be exposed to raw water, 

CCCW, treated water, waste water, or soil.

Depending on plant-specific operating experience (OE) and implementation of preventive 

actions, certain components may be excluded from the scope of this program in each 

10-year inspection interval as follows:

• The internal surfaces of internally-coated components for which loss of coating 

integrity is managed by Generic Aging Lessons Learned for Subsequent License 

Renewal (GALL-SLR) Report AMP XI.M42, “Internal Coatings/Linings for In-Scope 

Piping, Piping Components, Heat Exchangers, and Tanks.”

• The external surfaces of buried components that are externally-coated in 

accordance with Table XI.M41-1, of GALL-SLR Report AMP XI.M41, “Buried and 

Underground Piping and Tanks,” and where direct visual examinations of buried 

piping in the scope of license renewal have not revealed any coating damage.
XI.M33-2

• The external surfaces of buried gray cast iron and ductile iron components that 

have been cathodically protected since installation and meet the criteria for 

Preventive Actions Category C in GALL-SLR Report AMP XI.M41,

Table XI.M41-2, “Inspections of Buried and Underground Piping and Tanks.”

• The external surfaces of buried copper alloy components that meet the above 

cathodic protection recommendations, if technical justification is submitted with the 

subsequent license renewal application (SLRA) that demonstrates the 

effectiveness of cathodic protection in the prevention of selective leaching for 

those alloys.

2. Preventive Actions: Although the program does not provide guidance on preventive 

actions, water chemistry control of certain parameters (e.g., pH, concentration of corrosive 

contaminants, dissolved oxygen), cathodic protection, and coatings can be effective in 

minimizing selective leaching.

3. Parameters Monitored or Inspected: This program monitors visual appearance 

(e.g., color, porosity, abnormal surface conditions), surface conditions through mechanical 

examination techniques (e.g., chipping, scraping), and the presence of and depth of 

dealloying through-wall thickness through destructive examinations.

4. Detection of Aging Effects: Inspections and examinations consist of the following:

• Visual inspections of all accessible surfaces. In certain copper-based alloys

selective leaching can be detected by visual inspection through a change in color 

from a normal yellow color to a reddish copper color or green copper oxide. 

Graphitized cast iron cannot be reliably identified through visual examination, as 

the appearance of the graphite surface layer created by selective leaching does 

not always differ appreciably from the typical cast iron surface.

• Mechanical examination techniques, such as chipping and scraping, augment

visual inspections for gray cast iron and ductile iron components.

• Destructive examinations are used to determine the presence of and depth of 

dealloying through-wall thickness of components.

One-time and periodic inspections are conducted of a representative sample of each 

population. A population is defined as the same material and environment combination. 

Opportunistic inspections are conducted whenever components are opened, or buried or 

submerged surfaces are exposed.

One-time inspections are only conducted for components exposed to CCCW or treated 

water when no plant-specific OE of selective leaching exists in these environments. In the 

10-year period prior to a subsequent period of extended operation, a sample of 3 percent 

of the population or a maximum of 10 components per population at each unit are visually 

and mechanically (for gray cast iron and ductile iron components) inspected. Inspections, 

where possible, focus on the bounding or lead components most susceptible to aging 

based on time-in-service and severity of operating conditions for each population.

Opportunistic and periodic inspections are conducted for components exposed to raw 

water, waste water, or soil, and for components in CCCW or treated water where 
XI.M33-3

plant-specific OE includes selective leaching in these environments. Opportunistic 

inspections are conducted whenever components are opened, or buried or submerged 

surfaces are exposed. Periodic inspections are conducted in the 10-year period prior to a 

subsequent period of extended operation and in each 10-year period during a subsequent 

period of extended operation. If the inspection conducted for ductile iron in the 10-year 

period prior to a subsequent period of extended operation (i.e., the initial inspection) meets 

acceptance criteria, periodic inspections do not need to be conducted during the 

subsequent period of extended operation for ductile iron. In these periodic inspections, a 

sample of 3 percent of the population or a maximum of 10 components per population are 

visually and mechanically (for gray cast iron and ductile iron components) inspected at 

each unit. When inspections are conducted on piping, a 1-foot axial length section is 

considered as one inspection. In addition, for sample populations with greater than 

35 susceptible components, two destructive examinations are performed in each material

and environment population in each 10-year period at each unit. When there are less than 

35 susceptible components in a sample population, one destructive examination is

performed for that population. Otherwise, a technical justification of the methodology and 

sample size used for selecting components for inspection is included as part of the 

program’s documentation. The number of visual and mechanical inspections may be 

reduced by two for each component that is destructively examined beyond the minimum 

number of destructive examinations recommended in each 10-year interval. Inspections, 

where possible, focus on the bounding or lead components most susceptible to aging 

based on time-in-service and severity of operating conditions for each population. 

Opportunistic inspections may be credited as periodic inspections as long as the 

inspection locations selection criteria are met.

For multi-unit sites where the sample size is not based on the percentage of the population 

and the inspections are conducted periodically (not one-time inspections), it is acceptable 

to reduce the total number of inspections at the site as follows. For two unit sites, eight 

visual and mechanical inspections and two destructive examinations are conducted at 

each unit. For two unit sites with less than 35 susceptible components in a sample 

population at each unit, one destructive examination is performed for that sample 

population. For three unit sites, seven visual and mechanical and one destructive 

examination are conducted at each unit. In order to conduct the reduced number of 

inspections, the applicant states in the SLRA the basis for why the operating conditions at 

each unit are similar enough (e.g., flowrate, chemistry, temperature, excursions) to provide 

representative inspection results. The basis should include consideration of potential 

differences such as the following:

• Have power uprates been performed and if so, could more aging have occurred on 

one unit that has been in the uprate period for a longer time period?

• Are there any systems which have had an out-of-spec water chemistry condition 

for a longer period of time or out-of-spec conditions occurred more frequently?

• For raw water systems, is the water source from different sources where one or the 

other is more susceptible to microbiologically influenced corrosion or other aging 

effects?

For raw water and waste water environments, the populations may be combined as long 

as an evaluation is conducted to determine the more severe environment and the 
XI.M33-4

inspections and examinations are conducted on components in the most severe 

environment, with one inspection being conducted in the less severe environment.

Dependent on plant-specific OE and implementation of preventive actions, the exclusions 

for external surface coatings of buried components may no longer apply and the 

inspection population is adjusted as follows. When minor through coating damage has 

been identified in plant-specific OE, but the components are coated in accordance with 

Table XI.M41-1 of GALL-SLR Report AMP XI.M41, the inspection sample size may be 

reduced by 50 percent (inspection quantities are rounded up) of that recommended in 

the “detection of aging effects” program element of this AMP if the following conditions 

are met:

• There were no more than two instances of coating damage identified in each 

10-year period of the prior operating period

• An analysis demonstrates that, if the pipe surface area affected by the coating 

damage is assumed to have been a through-wall hole, the pipe could be shown to 

meet unreinforced opening criteria of the applicable piping code

Inspections follow site procedures that include inspection parameters such as lighting, 

distance, offset, surface coverage, presence of protective coatings, and cleaning 

processes.

5. Monitoring and Trending: Where practical, identified degradation is projected until the 

next scheduled inspection. Results are evaluated against acceptance criteria to confirm 

that the sampling bases (e.g., selection, size, frequency) will maintain the components’ 

intended functions throughout the subsequent period of extended operation based on the 

projected rate and extent of degradation.

6. Acceptance Criteria: The acceptance criteria are: (a) for copper-based alloys, no 

noticeable change in color from the normal yellow color to the reddish copper color or 

green copper oxide; (b) for gray cast iron and ductile iron, the absence of a surface layer

that can be easily removed by chipping or scraping or identified in the destructive 

examinations, (c) the presence of no more than a superficial layer of dealloying, as 

determined by removal of the dealloyed material by mechanical removal, and (d) the 

components meet system design requirements such as minimum wall thickness, when 

extended to the end of the subsequent period of extended operation. When evaluating a 

component in relation to criterion (c) no credit is used for the material properties of the 

dealloyed portion of the component.

7. Corrective Actions: Results that do not meet the acceptance criteria are addressed in 

the applicant’s corrective action program under those specific portions of the quality 

assurance (QA) program that are used to meet Criterion XVI, “Corrective Action,” of 

Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B. Appendix A of 

the GALL-SLR Report describes how an applicant may apply its 10 CFR Part 50, 

Appendix B, QA program to fulfill the corrective actions element of this AMP for both 

safety-related and nonsafety-related structures and component (SCs) within the scope of 

this program.

When the acceptance criteria are not met such that it is determined that the affected 

component should be replaced prior to the end of the subsequent period of extended 
XI.M33-5

operation, additional inspections are performed if the cause of the aging effect for each 

applicable material and environment is not corrected by repair or replacement for all 

components constructed of the same material and exposed to the same environment. 

The number of additional inspections is equal to the number of failed inspections for each 

material and environment population with a minimum of five additional visual and 

mechanical inspections when visual and mechanical inspections(s) did not meet 

acceptance criteria, or 20 percent of each applicable material and environment

combination is inspected, whichever is less, and a minimum of one additional destructive 

examination when destruction examination(s) did not meet acceptance criteria. If 

subsequent inspections do not meet acceptance criteria, an extent of condition and extent 

of cause analysis is conducted to determine the further extent of inspections. The timing 

of the additional inspections is based on the severity of the degradation identified and is

commensurate with the potential for loss of intended function. However, in all cases, the 

additional inspections are completed within the interval in which the original inspection was 

conducted or, if identified in the latter half of the current inspection interval, within the next 

refueling outage interval. These additional inspections conducted in the next inspection 

interval cannot also be credited towards the number of inspections in the latter interval. 

Additional samples are inspected for any recurring degradation to ensure corrective 

actions appropriately address the associated causes. At multi-unit sites, the additional 

inspections include inspections at all of the units with the same material, environment, and 

aging effect combination.

The program includes a process to evaluate difficult-to-access surfaces (e.g., heat 

exchanger shell interiors, exterior of heat exchanger tubes) if unacceptable inspection 

findings occur within the same material and environment population.

8. Confirmation Process: The confirmation process is addressed through those specific 

portions of the QA program that are used to meet Criterion XVI, “Corrective Action,” of 

10 CFR Part 50, Appendix B. Appendix A of the GALL-SLR Report describes how an 

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the confirmation 

process element of this AMP for both safety-related and nonsafety-related SCs within the 

scope of this program.

9. Administrative Controls: Administrative controls are addressed through the QA program 

that is used to meet the requirements of 10 CFR Part 50, Appendix B, associated with 

managing the effects of aging. Appendix A of the GALL-SLR Report describes how an 

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the 

administrative controls element of this AMP for both safety-related and nonsafety-related 

SCs within the scope of this program.

10. Operating Experience: OE shows that selective leaching has been detected in 

components constructed from gray cast iron, ductile iron, brass, bronze, and aluminum 

bronze. The following OE may be of significance to an applicant’s program:

a. In March 2013, a licensee submitted an American Society of Mechanical 

Engineers Boiler and Pressure Vessel Code (ASME Code) Section XI relief 

request because it had detected weeping through aluminum bronze (susceptible to 

dealloying) valve bodies exposed to sea water. The degraded area was 

characterized by corrosion debris or wetness that returned following cleaning and 

drying of the surface. [Agencywide Documents Access and Management System 

(ADAMS) Accession No. ML13091A038 and ML14182A634].
XI.M33-6

b. During a one-time inspection for selective leaching, a licensee identified 

degradation in four gray cast iron valve bodies in the service water system 

exposed to raw water. The mechanical test used by the licensee to identify the 

graphitization was tapping and scraping of the surface. The licensee sand blasted 

two of the valve bodies and, after all of the graphite was removed; the licensee 

determined that the leaching progressed to a depth of approximately 3/32 inch. 

Based on the estimated corrosion rate, the licensee determined that the valve 

bodies had adequate wall thickness for at least 20 years of additional service. 

(ADAMS Accession No. ML14017A289).

c. Based on visual inspections conducted as part of implementing a one-time 

inspection for selective leaching, a licensee identified selective leaching in a gray 

cast iron drain plug of an auxiliary feedwater pump outboard bearing cooler. 

Possible selective leaching was also found on multimatic valves on the underside 

of the clapper. As a result, the licensee incorporated quarterly inspections of the 

components in its periodic surveillance and preventive maintenance program. 

(ADAMS Accession No. ML13122A009).

d. In September 2008, a licensee identified the dealloying of an aluminum bronze 

strainer drum exposed to brackish water. This was identified after an unexpected 

material failure occurred, during a planned maintenance evolution at an offsite 

repair facility. The maintenance evolution involved rigging the strainer drum into 

position for a machining operation. During the rigging, the strainer drum material 

failed at the rigging attachment point to the strainer. This failure of the strainer 

drum exposed the inner portion of the drum material where dealloying of the 

drum was visually observed during an inspection. (ADAMS Accession 

No. ML092400531). 

e. A licensee has reported occurrences of selective leaching of aluminum bronze 

components for an extensive number of years. (ADAMS Accession 

No. ML17142A263).

f. U.S. Nuclear Regulatory Commission (NRC) Information Notice (IN) 84-71,

Graphitic Corrosion of Cast Iron in Salt Water, September 06, 1984.

g. NRC IN 94-59, Accelerated Dealloying of Cast Aluminum-Bronze Valves Caused

by Microbiologically Induced Corrosion, August 17, 1994.

h. The basis for inclusion of ductile iron in this GALL-SLR Report AMP XI.M33, along 

with OE examples, is cited in the GALL-SLR and SRP-SLR Supplemental Staff 

Guidance document. (ADAMS Accession No. ML16041A090).

The program is informed and enhanced when necessary through the systematic and ongoing 

review of both plant-specific and industry OE including research and development such that 

the effectiveness of the AMP is evaluated consistent with the discussion in Appendix B of the 

GALL-SLR Report.
XI.M33-7

References

10 CFR Part 50, Appendix B, “Quality Assurance Criteria for Nuclear Power Plants and Fuel 

Reprocessing Plants.” Washington, DC: U.S. Nuclear Regulatory Commission. 2016.

EPRI. EPRI TR–107514, “Age Related Degradation Inspection Method and Demonstration.” 

Palo Alto, California: Electric Power Research Institute. April 1998.

Fontana, M.G. Corrosion Engineering. McGraw Hill. pp. 86-90. 1986.

NRC. “GALL-SLR and SRP-SLR Supplemental Staff Guidance.” Agencywide Documents

Access and Management System (ADAMS) Accession No. ML16041A090. Washington, DC: 

U.S. Nuclear Regulatory Commission. March 2016.

XI.M35-1

XI.M35 ASME CODE CLASS 1 SMALL-BORE PIPING

Program Description

This program is a condition monitoring program for detecting cracking in small-bore, American 

Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code) 1 Class 1 piping. 

The program augments the inservice inspections (ISI) specified by ASME Code, Section XI, for 

certain ASME Code Class 1 piping that is less than 4 inches nominal pipe size (NPS) and greater 

than or equal to 1 inch NPS.

Industry operating experience (OE) demonstrates that welds in ASME Code Class 1 small-bore 

piping are susceptible to stress corrosion cracking (SCC) and cracking due to thermal or vibratory 

fatigue loading. Such cracking is frequently initiated from the inside diameter of the piping; 

therefore, volumetric examinations are needed to detect cracks. However, ASME Code, 

Section XI, generally does not call for volumetric examinations of this class and size of piping. 

Specifically, ASME Code, Section XI, Subarticle IWB-1220, exempts all components that are less 

than or equal to 1 inch nominal pipe size (NPS) from volumetric examinations. In addition, with 

the exception of certain pressurized water reactor high pressure safety injection system piping 

components, ASME Code, Section XI, Table IWB-2500-1, calls for surface examinations and 

visual inspections during system leakage tests of piping components that are less than 

4 inches NPS.

This program supplements the ASME Code, Section XI, examinations with volumetric 

examinations, or alternatively, destructive examinations, to detect cracks that may originate from 

the inside diameter of butt welds, socket welds, and their base metal materials. The examination 

schedule and extent is based on plant-specific OE and whether actions have been implemented 

that would successfully mitigate the causes of any past cracking. The program relies on a sample 

size as specified in Table XI.M35-1 as means to determine whether cracking is occurring in the 

total population of ASME Code Class 1 small-bore piping in the plant.

Evaluation and Technical Basis

1. Scope of Program: This program manages the effects of SCC and cracking due to 

thermal or vibratory fatigue loading for certain ASME Code Class 1 small-bore piping. For 

the purposes of this program, small-bore piping includes piping that is less than 4 inches 

NPS and greater than or equal to 1 inch NPS.

2. Preventive Actions: This is a condition monitoring program only; therefore, it has no 

preventive actions.

3. Parameters Monitored or Inspected: Cracking is detected through either destructive or 

nondestructive examinations of piping welds and base metal materials. The volume of 

these materials is examined to detect flaws or other discontinuities that may indicate the 

presence of cracks.

 

1 GALL-SLR Report. Chapter 1, Table 1, identifies the ASME Code Section XI editions and addenda that are 

acceptable to use for this AMP.
XI.M35-2

4. Detection of Aging Effects: A sample of ASME Code Class 1 small-bore piping welds is 

examined in accordance with the categories specified in Table XI.M35-1. The initial 

schedule of examinations, either one-time for Categories A and B or periodic for 

Category C, is based on plant-specific OE and whether actions that would successfully 

mitigate the causes of any past cracking have been implemented. Periodic examinations 

are implemented as per Category C if the one-time examinations detect any unacceptable 

flaws or relevant conditions. The scope of the examinations includes both full penetration 

(butt) welds and partial penetration (socket) welds. 

The welds to be examined are selected from those locations that are determined to be the 

most risk significant and most susceptible to SCC and cracking due to thermal or vibratory 

fatigue loading. Other factors, such as plant-specific and industry OE, accessibility, and 

personnel exposure, can also be considered to select the most appropriate locations for 

the examinations. The guidelines from Electric Power Research Institute Technical 

Report 1011955, “Materials Reliability Program: Management of Thermal Fatigue in 

Normally Stagnant Non-Isolable Reactor Coolant System Branch Lines (MRP-146),” and 

Technical Report 1018330, “Materials Reliability Program: Management of Thermal 

Fatigue in Normally Stagnant Non-Isolable Reactor Coolant System Branch Lines–

Supplemental Guidance (MRP-146S),” may be used to determine the locations that are 

most susceptible to thermal fatigue. Because more information can be obtained from a 

destructive examination than from a nondestructive examination, the applicant can take 

credit for each weld destructively examined as equivalent to having volumetrically 

examined two welds.

Table XI.M35-1. Examinations

Category

Plant 

Operating 

Experience

Mitigation Examination Schedule Sample Size Examination 

Method

A

No 

age-related 

cracking (1) 

(2)

Not 

applicable

One-time:

completed within 

6 years prior to the start 

of the subsequent 

period of extended 

operation

Full penetration

(butt) welds: 3% of 

total population per 

unit, up to 10 (4)

Partial penetration 

(socket) welds: 3% of 

total population per 

unit, up to 10 (4)

Volumetric or 

destructive (5) 

(6)

B Age-related 

cracking (2) Yes (3)

One-time:

completed within 

6 years prior to the start 

of the subsequent 

period of extended 

operation

Full penetration

(butt) welds: 10% of 

total population per 

unit, up to 25 (4)

Partial penetration 

(socket) welds: 10% 

of total population per 

unit, up to 25 (4)

Volumetric or 

destructive (5) 

(6)
XI.M35-3

Table XI.M35-1. Examinations

Category

Plant 

Operating 

Experience

Mitigation Examination Schedule Sample Size Examination 

Method

C Age-related 

cracking (2) No

Periodic:

first examination 

completed within the 

6 years prior to the start 

of the subsequent 

period of extended 

operation with 

subsequent 

examinations every 

10 years thereafter

Full penetration

(butt) welds: 10% of 

total population per 

unit, up to 25 (4)

Partial penetration 

(socket) welds: 10% 

of total population per 

unit, up to 25 (4)

Volumetric or 

destructive (5) 

(6)

NOTES:

(1) Must have no history of age-related cracking.

(2) Age-related cracking includes piping leaks or other flaws where fatigue or stress corrosion cracking are 

contributing factors.

(3) Actions must have been taken to mitigate the cause of the cracking. These actions, such as design changes, 

would generally go beyond typical repair or replacement activities. If welds that have been redesigned or repaired

and the applicant could demonstrate through OE that no additional failures have been reported for the last 30 years, 

then the inspection sample size could follow the guidance in Category A.

(4) The welds to be examined are selected from locations that are determined to be the most risk significant and 

most susceptible to cracking. Other factors, such as plant-specific and industry OE, accessibility, and personnel 

exposure, can also be considered in selecting the most appropriate locations for the examinations.

(5) Volumetric examinations must employ techniques that have been demonstrated to be capable of detecting flaws 

and discontinuities in the examination volume of interest.

(6) Each partial penetration (socket) weld subject to destructive examination may be credited twice towards the total 

number of examinations because more information can be obtained from a destructive examination than from a 

nondestructive examination.

5. Monitoring and Trending: For plants that are either in Categories A or B, a one-time 

examination provides confirmation that cracking is not occurring or that it is occurring so 

slowly that it will not affect the component’s intended function during the subsequent 

period of extended operation. Periodic examinations provide for the timely detection of 

cracks for those plants that are in Category C. If a component containing flaws or 

relevant conditions is accepted for continued service by analytical evaluation, then it

is subsequently reexamined to meet the intent of ASME Code, Section XI,

Subarticle IWB-2420.

6. Acceptance Criteria: Examination results are evaluated in accordance ASME Code, 

Section XI, Paragraph IWB-3132.

7. Corrective Actions: Results that do not meet the acceptance criteria are addressed in 

the applicant’s corrective action program under those specific portions of the quality 

assurance (QA) program that are used to meet Criterion XVI, “Corrective Action,” of 

10 CFR Part 50, Appendix B. Appendix A of the Generic Aging Lessons Learned for 

Subsequent License Renewal (GALL-SLR) Report describes how an applicant may apply 

its 10 CFR Part 50, Appendix B, QA program to fulfill the corrective actions element of this 

aging management program (AMP) for both safety-related and nonsafety-related 

structures and components (SCs) within the scope of this program.

The corrective actions are to include examinations of additional ASME Code Class 1 

small-bore piping welds to meet the intent of ASME Code, Section XI, 

Subarticle IWB-2430. In addition, for those plants that are either in Categories A or B, 
XI.M35-4

periodic examinations are then implemented in accordance with the schedule specified in 

Category C.

8. Confirmation Process: The confirmation process is addressed through those specific 

portions of the QA program that are used to meet Criterion XVI, “Corrective Action,” of 

10 CFR Part 50, Appendix B. Appendix A of the GALL-SLR Report describes how an 

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the confirmation 

process element of this AMP for both safety-related and nonsafety-related SCs within the 

scope of this program.

9. Administrative Controls: Administrative controls are addressed through the QA program 

that is used to meet the requirements of 10 CFR Part 50, Appendix B, associated with 

managing the effects of aging. Appendix A of the GALL-SLR Report describes how an 

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the 

administrative controls element of this AMP for both safety-related and nonsafety-related 

SCs within the scope of this program.

10. Operating Experience: Through-wall cracking in ASME Code Class 1 small-bore piping 

has occurred at a number of plants. Causes include SCC and thermal and vibratory 

fatigue loading as described in the U.S. Nuclear Regulatory Commission Information 

Notice 97-46, “Unisolable Crack in High-Pressure Injection Piping.” This program 

augments the ASME Code, Section XI, inspections to provide assurance that cracks will 

be detected before there is a loss of intended function. Licensee Event Reports (LERs) 

259/2008-002 and LER 387/2012-007-00 provide a sample of relevant OE.

The program is informed and enhanced when necessary through the systematic and 

ongoing review of both plant-specific and industry OE including research and development 

such that the effectiveness of the AMP is evaluated consistent with the discussion in 

Appendix B of the GALL-SLR Report.

References

10 CFR Part 50, Appendix B, “Quality Assurance Criteria for Nuclear Power Plants and Fuel 

Reprocessing Plants.” Washington, DC: U.S. Nuclear Regulatory Commission. 2016.

10 CFR 50.55a, “Codes and Standards.” Washington, DC: U.S. Nuclear Regulatory 

Commission. 2016.

ASME. ASME Code Section XI, “Rules for Inservice Inspection of Nuclear Power Plant 

Components.” New York, New York: The American Society of Mechanical Engineers. 2008.

EPRI. Technical Report 1011955, “Materials Reliability Program: Management of Thermal 

Fatigue in Normally Stagnant Non-Isolable Reactor Coolant System Branch Lines (MRP-146).” 

Palo Alto, California: Electric Power Research Institute. June 2005.

_____. Technical Report 1018330, “Materials Reliability Program: Management of Thermal 

Fatigue in Normally Stagnant Non-Isolable Reactor Coolant System Branch Lines – Supplemental 

Guidance (MRP-146S).” Palo Alto, California: Electric Power Research Institute. 

December 2008.
XI.M35-5

Licensee Event Report 259/2008-002 and LER 259/2008-002-01, “ASME Code Class 1 Pressure 

Boundary Leak on an Instrument Line Connected to the Reactor Vessel.” 

https://lersearch.inl.gov/LERSearchCriteria.aspx. March 2009.

Licensee Event Report 387/2012-007-00, “Unplanned Shutdown Due to Unidentified Drywell 

Leakage.” https://lersearch.inl.gov/LERSearchCriteria.aspx. September 2012.

NRC. Information Notice 97-46, “Unisolable Crack in High-Pressure Injection Piping.” 

Washington, DC: U.S. Nuclear Regulatory Commission. July 1997.

XI.M36-1

XI.M36 EXTERNAL SURFACES MONITORING OF MECHANICAL COMPONENTS

Program Description

The External Surfaces Monitoring of Mechanical Components program is based on system 

inspections and walkdowns. This program consists of periodic visual inspections of metallic, 

polymeric, and cementitious components, such as piping, piping components, ducting, ducting 

components; heating, ventilation, and air conditioning (HVAC) closure bolting; heat exchanger 

components, and seals. The program manages aging effects through visual inspection of 

external surfaces for evidence of loss of material, cracking, hardening or loss of strength, reduced 

thermal insulation resistance, loss of preload for HVAC closure bolting, and reduction of heat 

transfer due to fouling. When appropriate for the component and material (e.g., elastomers, 

flexible polymers, polyvinyl chloride), physical manipulation is used to augment visual inspection 

to confirm the absence of hardening or loss of strength, or reduction in impact strength. This 

program may also be used to manage cracking due to stress corrosion cracking (SCC) in 

aluminum and stainless steel (SS) components exposed to aqueous solutions and air 

environments containing halides.

Reduced thermal insulation resistance due to moisture intrusion, associated with insulation that is 

jacketed, is managed by visual inspection of the condition of the jacketing when the insulation has 

an intended function to reduce heat transfer from the insulated components. Outdoor insulated 

components, and indoor components exposed to condensation, have portions of the insulation 

inspected or removed, when applicable, to determine whether the exterior surface of the 

component is degrading or has the potential to degrade. Loss of material due to boric acid 

corrosion is managed by the Generic Aging Lessons Learned for Subsequent License Renewal 

(GALL-SLR) Report aging management program (AMP) XI.M10, “Boric Acid Corrosion.”

Evaluation and Technical Basis

1. Scope of Program: This program visually inspects the external surfaces of mechanical 

components. The program also inspects heat exchanger surfaces exposed to air for 

evidence of reduction of heat transfer due to fouling.

For situations where the similarity of the internal and external environments are such that 

the external surface condition is representative of the internal surface condition, external 

inspections of components may be credited for managing: (a) loss of material and 

cracking of internal surfaces for metallic and cementitious components, (b) loss of 

material, and cracking of internal surfaces for polymeric components, and (c) hardening or 

loss of strength of internal surfaces for elastomeric components. When credited, the 

program provides the basis to establish that the external and internal surface condition 

and environment are sufficiently similar.

Aging effects associated with underground piping and tanks that are below grade but are 

contained within a tunnel or vault such that they are in contact with air and are located 

where access for inspection is restricted, are managed by GALL-SLR Report 

AMP XI.M41, “Buried and Underground Piping and Tanks.” Aging effects associated with 

below grade components that are accessible during normal operations or refueling 

outages for which access is not restricted are managed by this program.

2. Preventive Actions: Depending on the material, components may be coated to mitigate 

corrosion by protecting the external surface of the component from environmental 
XI.M36-2

exposure. Inspections to verify the integrity of the insulation jacketing can limit or prevent 

water in-leakage in the insulation.

3. Parameters Monitored or Inspected: This program uses periodic plant system 

inspections and walkdowns to monitor for material degradation, accumulation of debris,

and leakage. This program inspects components such as piping, piping components, 

ducting, seals, insulation jacketing, and air-side heat exchangers. For metallic 

components, coatings deterioration is an indicator of possible underlying degradation. 

Cementitious components are visually inspected for indications loss of material and 

cracking. Periodic visual or surface examinations are conducted if this program is being 

used to manage cracking in SS or aluminum components. 

Examples of inspection parameters for metallic components include:

 Corrosion and surface imperfections (loss of material or cracking) 

 Loss of wall thickness (loss of material)

 Flaking or oxide-coated surfaces (loss of material)

 Corrosion stains on thermal insulation (loss of material)

 Cracking, flaking, or blistering of protective coating (loss of coating integrity)

 Leakage for detection of cracks on the surfaces of SS and aluminum components 

exposed to air and aqueous solutions containing halides (cracking)

 Accumulation of debris on heat exchanger tube surfaces (reduction of heat 

transfer)

The aging effects for elastomeric and flexible polymeric components are monitored

through a combination of visual inspection and manual or physical manipulation of the 

material. Manual or physical manipulation of the material includes touching, pressing on, 

flexing, bending, or otherwise manually interacting with the material. The purpose of the 

manual manipulation is to reveal changes in material properties, such as hardness, and to 

make the visual examination process more effective in identifying aging effects such as 

cracking. Flexing of polyvinyl chloride piping exposed directly to sunlight (i.e., not located 

in a structure restricting access to sunlight such as manholes, enclosures, and vaults or 

isolated from the environment by coatings) is conducted to detect potential reduction in

impact strength as indicated by a crackling sound or surface cracks when flexed.

Examples of inspection parameters for elastomers and polymers include:

 Surface cracking, crazing, scuffing, and dimensional change (e.g., “ballooning” 

and “necking”) 

 Loss of thickness

 Discoloration (evidence of a potential change in material properties that could be 

indicative of polymeric degradation)
XI.M36-3

 Exposure of internal reinforcement for reinforced elastomers

 Hardening as evidenced by a loss of suppleness during manipulation where the 

component and material are appropriate to manipulation 

Examples of inspection parameters for cementitious materials include:

 Spalling

 Scaling

 Cracking

4. Detection of Aging Effects: This program manages the aging effects of loss of material, 

cracking, hardening or loss of strength, reduced thermal insulation resistance, loss of 

preload for HVAC closure bolting, and reduction of heat transfer due to fouling using visual 

inspections. In addition, physical manipulation is used to manage hardening or loss of 

strength and reduction in impact strength. For coated surfaces, confirmation of the 

integrity of the coating is an effective method for managing the effects of corrosion on the 

metallic surface.

Inspections are performed by personnel qualified in accordance with site procedures and 

programs to perform the specified task. When required by the American Society of 

Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code), inspections are 

conducted in accordance with the applicable code requirements. Non-ASME Code 

inspections and tests follow site procedures that include inspection parameters for items 

such as lighting, distance, offset, surface coverage, and presence of protective coatings. 

The inspections are capable of detecting age-related degradation and, with the exception 

of examinations to detect cracking in SS or aluminum components, are performed at a 

frequency not to exceed one refueling cycle. This frequency accommodates inspections 

of components that may be in locations normally accessible only during outages (e.g., high 

dose areas). Surfaces that are not readily visible during plant operations and refueling 

outages are inspected when they are made accessible and at such intervals that would 

ensure the components’ intended functions are maintained.

Periodic visual inspections or surface examinations are conducted on SS and aluminum

components to manage cracking every 10 years during the subsequent period of extended 

operation when applicable (e.g., see Standard Review Plan for Review of Subsequent 

License Renewal Applications for Nuclear Power Plants (SRP-SLR) Sections 3.2.2.2.4

and 3.2.2.2.8). One or more of the following three options may be used to implement the 

periodic visual inspections or surface examinations:

• Surface examination conducted in accordance with plant-specific procedures.

• ASME Code Section XI VT-1 inspections (including those inspections conducted 

on non-ASME Code components).

• Visual inspections may be conducted where it has been analytically demonstrated 

that surface cracks can be detected by leakage prior to a crack challenging the 

structural integrity or intended function of the component. The subsequent license 
XI.M36-4

renewal application (SLRA) includes an overview of the analytical method, input 

variables, assumptions, basis for use of bounding analyses, and results.

When using this option, cracks can be detected in gas-filled systems by methods 

such as, but not limited to: (a) for diesel exhaust piping, detecting staining on 

external surfaces of components; (b) for accumulators and piping connecting the 

accumulators to components, monitoring and trending accumulator pressures or 

refill frequency; and (c) soap bubble testing when systems are pressurized. The 

SLRA includes the specific methods used.

Surface examinations or VT-1 examinations are conducted on 20 percent of the surface 

area unless the component is measured in linear feet, such as piping. Alternatively, any 

combination of 1-foot length sections and components can be used to meet the 

recommended extent of 25 inspections. The provisions of GALL-SLR Report AMP XI.M38 

to conduct inspections in a more severe environment and combination of air environments 

may be incorporated for these inspections.

In some instances, thermal insulation (e.g., calcium silicate) has been included in-scope to 

reduce heat transfer from components because absent the insulation, the thermal effects 

could affect a function described in Title 10 of the Code of Federal Regulations 

(10 CFR) 54.4(a). When metallic jacketing has been used, it is acceptable to conduct 

external visual inspections of the jacketing in order to detect damage to the jacketing that 

would permit in leakage of moisture as long as the jacketing has been installed in 

accordance with plant-specific procedures that include configuration features such as 

minimum overlap, location of seams, etc. If plant-specific procedures do not include these 

features, an alternative inspection methodology should be proposed. 

Component surfaces that are insulated and exposed to condensation (because the 

in-scope component is operated below the dew point), and insulated outdoor components, 

(aging effects associated with corrosion under insulation for outdoor tanks may be 

managed by this AMP or GALL-SLR Report AMP XI.M29, “Outdoor and Large 

Atmospheric Metallic Storage Tanks”) are periodically inspected every 10 years during the 

subsequent period of extended operation. For all outdoor components and any indoor 

components exposed to condensation (because the in-scope component is operated 

below the dew point), inspections are conducted of each material type (e.g., steel, SS, 

copper alloy, aluminum) and environment (e.g., air outdoor, air accompanied by leakage) 

where condensation or moisture on the surfaces of the component could occur routinely or 

seasonally. In some instances, significant moisture can accumulate under insulation 

during high humidity seasons, even in conditioned air. A minimum of 20 percent of the 

in-scope piping length, or 20 percent of the surface area for components whose 

configuration does not conform to a 1-foot axial length determination (e.g., valve, 

accumulator, tank) is inspected after the insulation is removed. Alternatively, any 

combination of a minimum of twenty-five 1-foot axial length sections and components for 

each material type is inspected. Inspection locations should focus on the bounding or lead 

components most susceptible to aging because of time in service, severity of operating 

conditions (e.g., amount of time that condensate would be present on the external 

surfaces of the component), and lowest design margin. Inspections for cracking due to 

SCC in aluminum components need not be conducted if it has been determined that SCC 

is not an applicable aging effect, see SRP-SLR Sections 3.2.2.2.8, 3.3.2.2.8, or 3.4.2.2.7. 

The following are alternatives to removing insulation after the initial inspection:
XI.M36-5

a. Subsequent inspections may consist of examination of the exterior surface of the 

insulation with sufficient acuity to detect indications of damage to the jacketing or 

protective outer layer (if the protective outer layer is waterproof) of the insulation 

when the results of the initial inspections meet the following criteria:

i. No loss of material due to general, pitting, or crevice corrosion beyond that 

which could have been present during initial construction is observed

during the first set of inspections, and

ii. No evidence of SCC is observed during the first set of inspections.

If: (a) the external visual inspections of the insulation reveal damage to the exterior 

surface of the insulation or jacketing, (b) there is evidence of water intrusion 

through the insulation (e.g., water seepage through insulation seams/joints), or 

(c) the protective outer layer (where jacketing is not installed) is not waterproof, 

periodic inspections under the insulation should continue as conducted for the 

initial inspection.

b. Removal of tightly adhering insulation that is impermeable to moisture is not 

required unless there is evidence of damage to the moisture barrier. If the 

moisture barrier is intact, the likelihood of corrosion under insulation is low for 

tightly adhering insulation. Tightly adhering insulation is considered to be a 

separate population from the remainder of insulation installed on in-scope 

components. The entire population of in-scope piping that has tightly adhering 

insulation is visually inspected for damage to the moisture barrier with the same 

frequency as for other types of insulation inspections. These inspections are not 

credited towards the inspection quantities for other types of insulation.

Visual inspection will identify indirect indicators of elastomer and flexible polymer 

hardening or loss of strength, including the presence of surface cracking, crazing, 

discoloration, and, for elastomers with internal reinforcement, the exposure of reinforcing 

fibers, mesh, or underlying metal. Visual inspections cover 100 percent of accessible 

component surfaces. Visual inspection will identify direct indicators of loss of material due 

to wear to include dimension change, scuffing, and, for flexible polymeric materials with 

internal reinforcement, the exposure of reinforcing fibers, mesh, or underlying metal. 

Manual or physical manipulation can be used to augment visual inspection to confirm the 

absence of hardening or loss of strength for elastomers and flexible polymeric materials 

(e.g., heating, ventilation, and air conditioning flexible connectors) where appropriate. The 

sample size for manipulation is at least 10 percent of available surface area. 

5. Monitoring and Trending: Where practical, identified degradation is projected until the 

next scheduled inspection. Results are evaluated against acceptance criteria to confirm 

that the timing of subsequent inspections will maintain the components’ intended functions 

throughout the subsequent period of extended operation based on the projected rate of 

degradation. For sampling-based inspections, results are evaluated against acceptance 

criteria to confirm that the sampling bases (e.g., selection, size, frequency) will maintain 

the components’ intended functions throughout the subsequent period of extended 

operation based on the projected rate and extent of degradation. 

6. Acceptance Criteria: For each component and aging effect combination, the acceptance 

criteria are defined to ensure that the need for corrective actions will be identified before 
XI.M36-6

loss of intended functions. Acceptance criteria are developed from plant-specific design 

standards and procedural requirements, current licensing basis (CLB), industry codes or 

standards (e.g., ASME Code Section III, ANSI/ASME B31.1), and engineering evaluation. 

Acceptance criteria, which permit degradation, are based on maintaining the intended 

function(s) under all CLB design loads. The evaluation projects the degree of observed 

degradation to the end of the subsequent period of extended operation or the next 

scheduled inspection, whichever is shorter. Where practical, acceptance criteria are 

quantitative (e.g., minimum wall thickness, percent shrinkage allowed in an elastomeric 

seal). Where qualitative acceptance criteria are used, the criteria are clear enough to 

reasonably ensure that a singular decision is derived based on the observed condition of 

the systems, structures, and components. For example, cracks are absent in rigid 

polymers, the flexibility of an elastomeric sealant is sufficient to ensure that it will properly 

adhere to surfaces. Electric Power Research Institute technical reports (TR)-1007933, 

“Aging Assessment Field Guide,” and TR-1009743, “Aging Identification and Assessment 

Checklist,” provide general guidance for evaluation of materials and criteria for their 

acceptance when performing visual/tactile inspections.

7. Corrective Actions: Results that do not meet the acceptance criteria are addressed in 

the applicant’s corrective action program under those specific portions of the quality 

assurance (QA) program that are used to meet Criterion XVI, “Corrective Action,” of 

10 CFR Part 50, Appendix B. Appendix A of the GALL-SLR Report describes how an 

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the corrective 

actions element of this AMP for both safety-related and nonsafety-related structures and 

components (SCs) within the scope of this program.

For the sampling-based inspections to detect cracking in aluminum and stainless steel 

components, additional inspections are conducted if one of the inspections does not meet 

acceptance criteria due to current or projected degradation (i.e., trending) unless the 

cause of the aging effect for each applicable material and environment is corrected by 

repair or replacement for all components constructed of the same material and exposed to 

the same environment. The number of increased inspections is determined in accordance 

with the site’s corrective action process; however, there are no fewer than five additional 

inspections for each inspection that did not meet acceptance criteria, or 20 percent of each 

applicable material, environment, and aging effect combination is inspected, whichever is 

less. The additional inspections are completed within the interval (i.e., 10-year inspection 

interval) in which the original inspection was conducted. If subsequent inspections do not 

meet acceptance criteria, an extent of condition and extent of cause analysis is conducted 

to determine the further extent of inspections. Additional samples are inspected for any 

recurring degradation to ensure corrective actions appropriately address the associated 

causes. At multi-unit sites, the additional inspections include inspections at all of the units 

with the same material, environment, and aging effect combination.

If any projected inspection results will not meet acceptance criteria prior to the next 

scheduled inspection, inspection frequencies are adjusted as determined by the site’s 

corrective action program.

8. Confirmation Process: The confirmation process is addressed through those specific 

portions of the QA program that are used to meet Criterion XVI, “Corrective Action,” of 

10 CFR Part 50, Appendix B. Appendix A of the GALL-SLR Report describes how an 

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the confirmation 
XI.M36-7

process element of this AMP for both safety-related and nonsafety-related SCs within the 

scope of this program.

9. Administrative Controls: Administrative controls are addressed through the QA program 

that is used to meet the requirements of 10 CFR Part 50, Appendix B, associated with

managing the effects of aging. Appendix A of the GALL-SLR Report describes how 

an applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the 

administrative controls element of this AMP for both safety-related and nonsafety-related 

SCs within the scope of this program.

10. Operating Experience: External surface inspections through system inspections and 

walkdowns have been in effect at many utilities since the mid-1990s in support of the 

Maintenance Rule (10 CFR 50.65) and have proven effective in maintaining the 

material condition of plant systems. The elements that comprise these inspections 

(e.g., the scope of the inspections and inspection techniques) are consistent with 

industry practice.

The program is informed and enhanced when necessary through the systematic and 

ongoing review of both plant-specific and industry operating experience including research

and development such that the effectiveness of the AMP is evaluated consistent with the 

discussion in Appendix B of the GALL-SLR Report.

References

10 CFR Part 50, Appendix B, “Quality Assurance Criteria for Nuclear Power Plants and Fuel 

Reprocessing Plants.” Washington, DC: U.S. Nuclear Regulatory Commission. 2016.

10 CFR 50.65, “Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power 

Plants.” Washington, DC: U.S. Nuclear Regulatory Commission. 2016.

10 CFR 54.4(a), “Scope.” Washington, DC: U.S. Nuclear Regulatory Commission. 2016.

EPRI. Technical Report 1009743, “Aging Identification and Assessment Checklist.” 

Palo Alto, California: Electric Power Research Institute. August 2004.

_____. Technical Report 1007933, “Aging Assessment Field Guide.” Palo Alto, California: 

Electric Power Research Institute. December 2003.

INPO. Good Practice TS-413, “Use of System Engineers.” INPO 85-033. Washington, DC: 

Institute of Nuclear Power Operations. May 1988.

XI.M37-1

XI.M37 FLUX THIMBLE TUBE INSPECTION 

Program Description

The Flux Thimble Tube Inspection is a condition monitoring program used to inspect for thinning 

of the flux thimble tube wall, which provides a path for the incore neutron flux monitoring system 

detectors and forms part of the reactor coolant system (RCS) pressure boundary. Flux thimble 

tubes are subject to loss of material at certain locations in the reactor vessel where flow-induced 

fretting causes wear at discontinuities in the path from the reactor vessel instrument nozzle to the 

fuel assembly instrument guide tube. A periodic nondestructive examination methodology, such 

as eddy current testing (ECT) or other applicant-justified and the U.S. Nuclear Regulatory 

Commission (NRC)-accepted inspection method, is used to monitor for wear of the flux 

thimble tubes. This program implements the recommendations of NRC Bulletin 88-09, as 

described below.

Evaluation and Technical Basis

1. Scope of Program: The flux thimble tube inspection encompasses all of the flux thimble 

tubes that form part of the RCS pressure boundary. The instrument guide tubes 

are not in the scope of this program. Within scope are the licensee responses to 

NRC Bulletin 88-09, as accepted by the staff in its closure letters on the bulletin, and any 

amendments to the licensee responses as approved by the staff.

2. Preventive Actions: The program consists of inspection and evaluation and provides no 

guidance on preventive actions.

3. Parameters Monitored or Inspected: Flux thimble tube wall thickness is monitored 

to detect loss of material from the flux thimble tubes during the subsequent period of 

extended operation.

4. Detection of Aging Effects: An inspection methodology (such as ECT) that has been 

demonstrated to be capable of adequately detecting wear of the flux thimble tubes is used 

to detect loss of material during the subsequent period of extended operation. Justification 

for methods other than ECT should be provided unless use of the alternative method has 

been previously accepted by the NRC.

Examination frequency is based upon actual plant-specific wear data and wear predictions 

that have been technically justified as providing conservative estimates of flux thimble tube 

wear. The interval between inspections is established such that no flux thimble tube is 

predicted to incur wear that exceeds the established acceptance criteria before the next 

inspection. The examination frequency may be adjusted based on plant-specific wear 

projections. Rebaselining of the examination frequency should be justified using plantspecific wear-rate data unless prior plant-specific NRC acceptance for the rebaselining is 

received outside the license renewal process. If design changes are made to use more 

wear-resistant thimble tube materials [e.g., chrome-plated stainless steel (SS)], sufficient 

inspections are conducted at an adequate inspection frequency, as described above, for 

the new materials.

5. Monitoring and Trending: Flux thimble tube wall thickness measurements are trended 

and wear rates are calculated based on plant-specific data using a methodology that 

includes sufficient conservatism to ensure that wall thickness acceptance criteria continue 
XI.M37-2

to be met during plant operation between scheduled inspections. Corrective actions are 

taken when trending results project that acceptance criteria would not be met prior to the 

next planned inspection or the end of the subsequent period of extended operation.

6. Acceptance Criteria: Appropriate acceptance criteria, such as percent through-wall 

wear, are established, and inspection results are evaluated and compared with the 

acceptance criteria. The acceptance criteria are technically justified to provide an 

adequate margin of safety to ensure that the integrity of the reactor coolant system 

pressure boundary is maintained. The acceptance criteria include allowances for factors 

such as instrument uncertainty, uncertainties in wear scar geometry, and other potential 

inaccuracies, as applicable, to the inspection methodology chosen for use in the program. 

Acceptance criteria different from those previously documented in the applicant’s response 

to NRC Bulletin 88-09 and amendments thereto, as accepted by the NRC, should 

be justified.

7. Corrective Actions: Results that do not meet the acceptance criteria are addressed in 

the applicant’s corrective action program under those specific portions of the quality 

assurance (QA) program that are used to meet Criterion XVI, “Corrective Action,” of 

Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B. Appendix A of 

the Generic Aging Lessons Learned for Subsequent Licensing Renewal (GALL-SLR) 

Report describes how an applicant may apply its 10 CFR Part 50, Appendix B, QA 

program to fulfill the corrective actions element of this aging management program (AMP) 

for both safety-related and nonsafety-related structures and components (SCs) within the 

scope of this program.

Flux thimble tubes with wall thickness that do not meet the established acceptance criteria 

are isolated, capped, plugged, withdrawn, replaced, or otherwise removed from service in 

a manner that ensures the integrity of the reactor coolant system pressure boundary is 

maintained. Analyses may allow repositioning of flux thimble tubes that are approaching 

the acceptance criteria limit. Repositioning of a tube exposes a different portion of the 

tube to the discontinuity that is causing the wear.

Flux thimble tubes that cannot be inspected over the tube length, that are subject to wear 

due to restriction or other defects, and that cannot be shown by analysis to be satisfactory 

for continued service are removed from service to ensure the integrity of the reactor 

coolant system pressure boundary.

8. Confirmation Process: The confirmation process is addressed through those specific 

portions of the QA program that are used to meet Criterion XVI, “Corrective Action,” of 

10 CFR Part 50, Appendix B. Appendix A of the GALL-SLR Report describes how an 

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the confirmation 

process element of this AMP for both safety-related and nonsafety-related SCs within the 

scope of this program.

9. Administrative Controls: Administrative controls are addressed through the QA program 

that is used to meet the requirements of 10 CFR Part 50, Appendix B, associated with 

managing the effects of aging. Appendix A of the GALL-SLR Report describes how an 

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the 

administrative controls element of this AMP for both safety-related and nonsafety-related 

SCs within the scope of this program.
XI.M37-3

10. Operating Experience: In NRC Bulletin 88-09 the NRC requested that licensees 

implement a flux thimble tube inspection program due to several instances of leaks and 

due to licensees identifying wear. Utilities established inspection programs in accordance 

with NRC Bulletin 88-09, which have shown excellent results in identifying and managing 

wear of flux thimble tubes. However, leakage events due to accelerated wear have 

occurred (see NRC Event Notification Report 42822, dated August 31, 2006).

As discussed in NRC Bulletin 88-09, the amount of vibration the thimble tubes experience 

is determined by many plant-specific factors. Therefore, the only effective method for 

determining thimble tube integrity is through inspections, which are adjusted to account for 

plant-specific wear patterns and history.

The program is informed and enhanced when necessary through the systematic and 

ongoing review of both plant-specific and industry operating experience including research

and development such that the effectiveness of the AMP is evaluated consistent with the 

discussion in Appendix B of the GALL-SLR Report.

References

10 CFR Part 50, Appendix B, “Quality Assurance Criteria for Nuclear Power Plants and Fuel 

Reprocessing Plants.” Washington, DC: U.S. Nuclear Regulatory Commission. 2016.

NRC. Bulletin 88-09, “Thimble Tube Thinning in Westinghouse Reactors.” Washington, DC: 

U.S. Nuclear Regulatory Commission. July 1988.

_____. Information Notice No. 87-44, “Thimble Tube Thinning in Westinghouse Reactors.” 

Washington, DC: U.S. Nuclear Regulatory Commission. September 1987.

_____. Information Notice No. 87-44, “Thimble Tube Thinning in Westinghouse Reactors.” 

Supplement 1. Washington, DC: U.S. Nuclear Regulatory Commission. March 1988.

_____. Licensee Event Notification [EN] 42822, “Technical Specification Required Shutdown Due 

to Unidentified Reactor Coolant System Leak.” Washington, DC: U.S. Nuclear Regulatory 

Commission. August 2006.

XI.M38-1

XI.M38 INSPECTION OF INTERNAL SURFACES IN MISCELLANEOUS 

PIPING AND DUCTING COMPONENTS

Program Description

The program consists of inspections of the internal surfaces of piping, piping components, 

ducting, heat exchanger components, and other components exposed to potentially aggressive 

environments. These environments include air, air with borated water leakage, condensation, 

gas, diesel exhaust, fuel oil, lubricating oil, and any water-filled systems. Aging effects associated 

with components (except for elastomers and flexible polymeric components) within the scope of

Generic Aging Lessons Learned for Subsequent License Renewal (GALL-SLR) Report, aging 

management program (AMP) XI.M20, “Open-cycle Cooling Water System,” AMP XI.M21A, 

Closed Treated Water Systems,” and AMP XI.M27, “Fire Water System,” are not managed by this 

program. Aging effects associated with elastomers and flexible polymeric components installed in 

open-cycle cooling water, closed-cycle cooling water, ultimate heat sink, and fire water systems

are managed by this program in lieu of GALL-SLR Report AMP XI.M20, AMP XI.M21A, and 

AMP XI.M27. In addition, aging effects associated with fire water system components with only a 

leakage boundary (spatial) or structural integrity (attached) intended function may be managed by 

this program.

These internal inspections are performed during the periodic system and component surveillances 

or during the performance of maintenance activities when the surfaces are made accessible for 

visual inspection. The program includes visual inspections and when appropriate, surface 

examinations. For certain materials, such as flexible polymers, physical manipulation or 

pressurization to detect hardening or loss of strength is used to augment the visual examinations 

conducted under this program. This program may also be used to manage cracking due to stress 

corrosion cracking (SCC) in aluminum and stainless steel (SS) components exposed to aqueous 

solutions and air environments containing halides. If visual inspection of internal surfaces is not 

possible, then the applicant needs to provide a plant-specific program.

This program, as written, is not intended for use on components in which recurring internal 

corrosion is evident based on a search of plant-specific operating experience (OE) conducted 

during the subsequent license renewal application (SLRA) development. If OE indicates that 

there has been recurring internal corrosion, a plant-specific program will be necessary unless this 

program, or another new or existing program, includes augmented requirements that address

recurring aging effects (e.g., Standard Review Plan for Review of Subsequent License Renewal 

Applications for Nuclear Power Plants (SRP-SLR) Sections 3.2.2.2.7, 3.3.2.2.7, and 3.4.2.2.6). 

Following failure due to recurring internal corrosion, this program may be used if the failed 

material is replaced by one that is more corrosion resistant in the environment of interest, or 

corrective actions have been taken to prevent recurrence of the recurring internal corrosion.

Evaluation and Technical Basis

1. Scope of Program: This program includes the internal surfaces of piping, piping 

components, ducting, heat exchanger components, and other components. Inspections 

are performed when the internal surfaces are accessible during the performance of 

periodic surveillances or during maintenance activities or scheduled outages. This 

program is not intended for components where loss of intended function has occurred due 

to age-related degradation.
XI.M38-2

For situations in which the material and environment combinations are similar for the 

internal and external surfaces such that the external surface condition is representative of 

the internal surface condition, external inspections of components may be credited for 

managing: (a) loss of material and cracking of internal surfaces of metallic and 

cementitious components, (b) loss of material, cracking of internal surfaces for polymeric 

components, and (c) hardening or loss of strength for the internal surfaces of elastomeric 

materials. When credited, the program describes the component’s internal environment 

and the credited external component’s environment inspected and provides the basis to 

justify that the external and internal surface condition and environment are sufficiently 

similar.

2. Preventive Actions: This program is a condition monitoring program to detect signs of 

degradation and does not provide guidance for prevention.

3. Parameters Monitored or Inspected: This program manages loss of material, cracking, 

reduction of heat transfer due to fouling, hardening or loss of strength of elastomeric 

components, and flow blockage. This program monitors surface conditions or wall 

thickness to identify loss of material due to corrosion mechanisms for metals and loss of 

material due to wear for elastomers and polymers. This program also monitors for 

changes in visual appearance for elastomers and polymers and suppleness to identify 

changes in hardening of loss of strength of elastomers and flexible polymers. 

Periodic surface examinations are conducted if this program is being used to manage 

cracking in SS or aluminum components. Visual inspections for leakage or surface cracks 

are an acceptable alternative to conducting surface examinations to detect cracking if it 

has been determined that cracks will be detected prior to challenging the structural 

integrity or intended function of the component. 

Examples of indicators of aging effects for metallic components include the following:

 Corrosion and surface imperfections

 Loss of wall thickness

 Flaking or oxide-coated surfaces

 Debris accumulation on heat exchanger tube surfaces 

 Leakage for detection of cracks on the surfaces of SS and aluminum components 

exposed to air and aqueous solutions containing halides 

 Accumulation of particulate fouling, biofouling, or macro fouling

Examples of indicators of loss of material and changes in material properties of 

elastomeric and polymeric materials include the following:

 Surface cracking, crazing, scuffing, loss of sealing, and dimensional change 

(e.g., “ballooning” and “necking”)

 Loss of wall thickness
XI.M38-3

 Discoloration (evidence of a potential change in material properties that could be 

indicative of polymeric degradation)

 Exposure of internal reinforcement for reinforced elastomers

 Hardening as evidenced by a loss of suppleness during manipulation where the 

component and material are appropriate to manipulation

Examples of inspection parameters for cementitious materials include:

• Spalling

• Scaling

• Cracking 

4. Detection of Aging Effects: Visual and mechanical (e.g., involving manipulation or 

pressurization of elastomers and flexible polymeric components) inspections conducted 

under this program are opportunistic in nature; they are conducted whenever piping, heat 

exchangers, or ducting are opened for any reason. At a minimum, in each 10-year period 

during the subsequent period of extended operation, a representative sample of 

20 percent of the population (defined as components having the same material, 

environment, and aging effect combination) or a maximum of 25 components per 

population is inspected at each unit. Otherwise, a technical justification of the 

methodology and sample size used for selecting components for inspection is included as 

part of the program’s documentation. For multi-unit sites where the sample size is not 

based on the percentage of the population, it is acceptable to reduce the total number of 

inspections at the site as follows. For two-unit sites, 19 components are inspected per unit 

and for a three-unit site, 17 components are inspected per unit. In order to conduct 17 or 

19 inspections at a unit in lieu of 25, the applicant states in the SLRA the basis for why the 

operating conditions at each unit are similar enough (e.g., flowrate, chemistry, 

temperature, excursions) to provide representative inspection results. The basis should 

include consideration of potential differences such as the following:

• Have power uprates been performed and if so, could more aging have occurred on 

one unit that has been in the uprate period for a longer time period?

• Are there any systems which have had an out-of-spec water chemistry condition 

for a longer period of time or out-of-spec conditions occurred more frequently?

• For raw water systems, is the water source from different sources where one or the 

other is more susceptible to microbiologically influenced corrosion or other aging 

effects?

• For components exposed to diesel exhaust, have certain diesels more operating 

more frequently and thus exposed to more cool down transients such that more 

deleterious materials could accumulate?

Where practical, the inspection includes a representative sample of the system population 

and focuses on the bounding or lead components most susceptible to aging because of 

time in service and severity of operating conditions. This minimum sample size does not 
XI.M38-4

override the opportunistic inspection basis of this AMP. Opportunistic inspections continue 

even though in a given 10-year period, 20 percent or 25 components might have already 

been inspected. An inspection of a component in a more severe environment may be 

credited as an inspection for the specified environment and for the same material and 

aging effects in a less severe environment (e.g., a condensation environment is more 

severe than an indoor controlled air environment because the moisture in the former 

environment is more likely to result in loss of material than would be expected from the 

normally dry surfaces associated with the latter environment). Alternatively, similar 

environments (e.g., internal uncontrolled indoor, controlled indoor, dry air environments) 

can be combined into a larger population provided that the inspections occur on 

components located in the most severe environment.

Internal visual inspections used to assess loss of material are capable of detecting surface 

irregularities that could be indicative of an unexpected level of degradation due to 

corrosion and corrosion product deposition. Where such irregularities are detected for 

steel components exposed to raw water, raw water (potable), or waste water, follow-up 

volumetric examinations are performed.

Periodic visual inspections or surface examinations are conducted on SS and aluminum to 

manage cracking every 10 years during the subsequent period of extended operation

when applicable (e.g., see SRP-SLR Sections 3.2.2.2.4 and 3.2.2.2.8). One or more of 

the following three options may be used to implement the periodic visual inspections or 

surface examinations:

• Surface examination conducted in accordance with plant-specific procedures.

• ASME Code Section XI VT-1 inspections (including those inspections conducted 

on non-ASME Code components).

• Visual inspections are conducted where it has been analytically demonstrated that 

surface cracks can be detected by leakage prior to a crack challenging the 

structural integrity or intended function of the component. The SLRA includes an 

overview of the analytical method, input variables, assumptions, basis for use of 

bounding analyses, and results.

When using this option, cracks can be detected in gas-filled systems by methods 

such as, but not limited to: (a) for diesel exhaust piping, detecting staining on 

external surfaces of components; (b) for accumulators and piping connecting the 

accumulators to components, monitoring and trending accumulator pressures or 

refill frequency; and (c) soap bubble testing when systems are pressurized. The 

SLRA includes the specific methods used.

Surface examinations or VT-1 examinations are conducted on 20 percent of the surface 

area inspected unless the component is measured in linear feet, such as piping. 

Alternatively, any combination of 1-foot length sections and components can be used to 

meet the recommended extent of 25 inspections. Opportunistic inspections need not be 

conducted once the minimum sample inspections are completed.

To determine the condition of internal surfaces of buried and underground components, 

inspections of the interior surfaces of accessible (i.e., above ground) components may be 
XI.M38-5

credited if the accessible and the buried or the underground component material, 

environment, and aging effects are similar.

Visual inspections include all accessible surfaces. Inspections and tests are performed by 

personnel qualified in accordance with site procedures and programs to perform the 

specified task. Unless otherwise required [e.g., by the American Society of Mechanical 

Engineers Boiler and Pressure Vessel Code (ASME Code)], inspections follow site 

procedures that include inspection parameters for items such as lighting, distance, offset, 

surface coverage, presence of protective coatings, and cleaning processes. The 

inspection procedures must be capable of detecting the aging effect(s) under 

consideration. These inspections provide for the detection of aging effects before the loss 

of component function.

Visual inspection of flexible polymeric components is performed whenever the component 

surface is accessible. Visual inspection can provide indirect indicators of the presence of 

surface cracking, crazing, and discoloration. For elastomers with internal reinforcement, 

visual inspection can detect the exposure of reinforcing fibers, mesh, or underlying metal. 

Visual and tactile inspections are performed when the internal surfaces become 

accessible during the performance of periodic surveillances or during maintenance 

activities or scheduled outages. Visual inspection provides direct indicators of loss of 

material due to wear, including dimensional change, scuffing, and the exposure of 

reinforcing fibers, mesh, or underlying metal for flexible polymeric materials with 

internal reinforcement.

Manual or, physical manipulation or pressurization of flexible polymeric components is 

used to augment visual inspection, where appropriate, to assess loss of material or 

strength. The sample size for manipulation is at least 10 percent of accessible surface 

area, including visually identified suspect areas. For flexible polymeric materials, 

hardening, loss of strength, or loss of material due to wear is expected to be detectable 

before any loss of intended function.

5. Monitoring and Trending: Where practical, identified degradation is projected until the 

next scheduled inspection. Results are evaluated against acceptance criteria to confirm 

that the sampling bases (e.g., selection, size, frequency) will maintain the components’ 

intended functions throughout the subsequent period of extended operation based on the 

projected rate and extent of degradation.

6. Acceptance Criteria: For each component and aging effect combination, the acceptance 

criteria are defined to ensure that the need for corrective actions is identified before the 

loss of intended functions. Acceptance criteria are developed from plant-specific design 

standards and procedural requirements, current licensing basis (CLB), industry codes or 

standards (e.g., ASME Code Section III, ANSI/ASME B31.1), and engineering evaluation. 

Acceptance criteria, which permit degradation, are based on maintaining the intended 

function(s) under all CLB design loads. The evaluation projects the degree of observed 

degradation to the end of the subsequent period of extended operation or the next 

scheduled inspection, whichever is shorter. Where practical, acceptance criteria are 

quantitative (e.g., minimum wall thickness, percent shrinkage allowed in an elastomeric 

seal). Where qualitative acceptance criteria are used, the criteria are clear enough to 

reasonably ensure that a singular decision is derived based on the observed condition of 

the systems, structures, and components (SSC). For example, cracks are absent in rigid 
XI.M38-6

polymers, the flexibility of an elastomeric sealant is sufficient to ensure that it will properly 

adhere to surfaces. 

7. Corrective Actions: Results that do not meet the acceptance criteria are addressed in 

the applicant’s corrective action program under those specific portions of the quality 

assurance (QA) program that are used to meet Criterion XVI, “Corrective Action,” of 

Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B. Appendix A of 

the GALL-SLR Report describes how an applicant may apply its 10 CFR Part 50, 

Appendix B, QA program to fulfill the corrective actions element of this AMP for both 

safety-related and nonsafety-related structures and components (SCs) within the scope of 

this program.

Additional inspections are conducted if one of the inspections (i.e., opportunistic, minimum 

sample size for a 10-year interval) does not meet acceptance criteria due to current or 

projected degradation (i.e., trending) unless the cause of the aging effect for each 

applicable material and environment is corrected by repair or replacement for all 

components constructed of the same material and exposed to the same environment. 

The number of increased inspections is determined in accordance with the site’s corrective 

action process; however, there are no fewer than five additional inspections for each 

inspection that did not meet acceptance criteria, or 20 percent of each applicable material, 

environment, and aging effect combination is inspected, whichever is less. The timing of 

the additional inspections is based on the severity of the degradation identified and is 

commensurate with the potential for loss of intended function. However, in all cases, the 

additional inspections are completed within the interval in which the original inspection was 

conducted or, if identified in the latter half of the current inspection interval, within the next 

refueling outage interval. These additional inspections conducted in the next inspection 

interval cannot also be credited towards the number of inspections in the latter interval. If 

subsequent inspections do not meet acceptance criteria, an extent of condition and extent 

of cause analysis is conducted to determine the further extent of inspections. Additional 

samples are inspected for any recurring degradation to ensure corrective actions 

appropriately address the associated causes. At multi-unit sites, the additional inspections 

include inspections at all of the units with the same material, environment, and aging effect 

combination. If any projected inspection results will not meet acceptance criteria prior to 

the next scheduled inspection, inspection frequencies are adjusted as determined by the 

site’s corrective action program.

8. Confirmation Process: The confirmation process is addressed through those specific 

portions of the QA program that are used to meet Criterion XVI, “Corrective Action,” of 

10 CFR Part 50, Appendix B. Appendix A of the GALL-SLR Report describes how an 

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the confirmation 

process element of this AMP for both safety-related and nonsafety-related SCs within the 

scope of this program.

9. Administrative Controls: Administrative controls are addressed through the QA program 

that is used to meet the requirements of 10 CFR Part 50, Appendix B, associated with 

managing the effects of aging. Appendix A of the GALL-SLR Report describes how an 

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the 

administrative controls element of this AMP for both safety-related and nonsafety-related 

SCs within the scope of this program.
XI.M38-7

10. Operating Experience: Inspections of internal surfaces during the performance of 

periodic surveillance and maintenance activities have been in effect at many utilities in 

support of plant component reliability programs. These activities have proven effective in 

maintaining the material condition of plant systems, structures, and components. The 

elements that comprise these inspections (e.g., the scope of the inspections and 

inspection techniques) are consistent with industry practice and staff expectations. The 

applicant evaluates recent OE and provides objective evidence to support the conclusion 

that the effects of aging are adequately managed.

The review of plant-specific OE during the development of this program is to be broad and 

detailed enough to detect instances of aging effects that have occurred repeatedly. In 

some instances, repeatedly occurring aging effects (i.e., recurring internal corrosion) might 

result in augmented aging management activities. Further evaluation aging management 

review line items in SRP-SLR Sections 3.2.2.2.7, 3.3.2.2.7, and 3.4.2.2.6, “Loss of 

Material due to Recurring Internal Corrosion,” include criteria to determine whether 

recurring internal corrosion is occurring and recommendations related to augmenting 

aging management activities.

The program is informed and enhanced when necessary through the systematic and 

ongoing review of both plant-specific and industry OE including research and development 

such that the effectiveness of the AMP is evaluated consistent with the discussion in 

Appendix B of the GALL-SLR Report.

References

10 CFR Part 50, Appendix B, “Quality Assurance Criteria for Nuclear Power Plants and Fuel 

Reprocessing Plants.” Washington, DC: U.S. Nuclear Regulatory Commission. 2016.

EPRI. Technical Report 1007933, “Aging Assessment Field Guide.” Palo Alto, California: 

Electric Power Research Institute. December 2003.

_____. Technical Report 1009743, “Aging Identification and Assessment Checklist.” 

Palo Alto, California: Electric Power Research Institute. August 2004.

INPO. Good Practice TS-413, “Use of System Engineers.” INPO 85-033. Atlanta, Georgia: 

Institute of Nuclear Power Operations. May 1988.

XI.M39-1

XI.M39 LUBRICATING OIL ANALYSIS

Program Description

The purpose of the Lubricating Oil Analysis program is to provide reasonable assurance that the 

oil environment in the mechanical systems is maintained to the required quality to prevent or 

mitigate age-related degradation of components within the scope of this program. This program 

maintains oil systems (lubricating and hydraulic) contaminants (primarily water and particulates) 

within acceptable limits, thereby preserving an environment that is not conducive to loss of 

material or reduction of heat transfer. Oil testing activities include sampling and analysis of 

lubricating oil for detrimental contaminants. The presence of water or particulates may also be 

indicative of inleakage and corrosion product buildup.

Although primarily a sampling program, the Generic Aging Lessons Learned for Subsequent 

License Renewal (GALL-SLR) Report identifies when the program is to be augmented to manage 

the effects of aging for subsequent license renewal. Accordingly, in certain cases identified in this 

GALL-SLR Report, verification of the effectiveness of the Lubricating Oil Analysis program is 

conducted. For these specific cases, an acceptable verification program is a one-time inspection 

of selected components at susceptible locations in the system.

Evaluation and Technical Basis

1. Scope of Program: Components within the scope of the program include piping, piping 

components; heat exchanger tubes; reactor coolant pump elements; and any other plant 

components subject to aging management review (AMR) that are exposed to an 

environment of lubricating oil (including nonwater-based hydraulic oils).

2. Preventive Actions: The Lubricating Oil Analysis program maintains oil system 

contaminants (primarily water and particulates) within acceptable limits.

3. Parameters Monitored or Inspected: This program performs a check for water and a 

particle count to detect evidence of contamination by moisture or excessive corrosion. 

4. Detection of Aging Effects: Moisture or corrosion products increase the potential for, or 

may be indicative of, loss of material due to corrosion and reduction of heat transfer due to 

fouling. The program performs periodic sampling and testing of lubricating oil for moisture 

and corrosion particles in accordance with industry standards. The program recommends 

sampling and testing of the old oil following periodic oil changes or on a schedule 

consistent with equipment manufacturer’s recommendations or industry standards 

[e.g., American Society of Testing Materials (ASTM) D 6224-02]. Plant-specific operating 

experience (OE) also may be used to adjust manufacturer’s recommendations or industry 

standards in determining the schedule for periodic sampling and testing when justified by 

prior sampling results. For hydraulic fluids, if the fluid is replaced based on a periodicity 

recommended by the fluid manufacturer, equipment vendor, or plant-specific documents, 

testing need not be conducted for inservice oils. Alternatively, the hydraulic fluid is tested 

for water content if the oil is not clear or bright, and for particulate count.

In certain cases, as identified by the AMR Items in this GALL-SLR Report, inspection of 

selected components is to be undertaken to verify the effectiveness of the program such 

that significant degradation is not occurring and that the component intended function is 

maintained during the subsequent period of extended operation.
XI.M39-2

5. Monitoring and Trending: Oil analysis results are reviewed to determine if alert levels or 

limits have been reached or exceeded. This review also checks for unusual trends.

6. Acceptance Criteria: Water and particle concentration should not exceed limits based on 

equipment manufacturer’s recommendations or industry standards. Phase-separated 

water in any amount is not acceptable.

7. Corrective Actions: Results that do not meet the acceptance criteria are addressed in 

the applicant’s corrective action program under those specific portions of the quality 

assurance (QA) program that are used to meet Criterion XVI, “Corrective Action,” of 

Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B. Appendix A of 

the GALL-SLR Report describes how an applicant may apply its 10 CFR Part 50, 

Appendix B, QA program to fulfill the corrective actions element of this aging management 

program (AMP) for both safety-related and nonsafety-related structures and components 

(SCs) within the scope of this program.

Corrective actions may include increased monitoring, corrective maintenance, further 

laboratory analysis, and engineering evaluation of the system. If a limit is reached or 

exceeded, actions to address the condition are taken.

8. Confirmation Process: The confirmation process is addressed through those specific 

portions of the QA program that are used to meet Criterion XVI, “Corrective Action,” of 

10 CFR Part 50, Appendix B. Appendix A of the GALL-SLR Report describes how an 

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the confirmation 

process element of this AMP for both safety-related and nonsafety-related SCs within the 

scope of this program.

9. Administrative Controls: Administrative controls are addressed through the QA program 

that is used to meet the requirements of 10 CFR Part 50, Appendix B, associated with 

managing the effects of aging. Appendix A of the GALL-SLR Report describes how an 

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the 

administrative controls element of this AMP for both safety-related and nonsafety-related 

SCs within the scope of this program.

10. Operating Experience: The OE at some plants has identified (a) water in the lubricating 

oil and (b) particulate contamination. However, no instances of component failures 

attributed to lubricating oil contamination have been identified.

The program is informed and enhanced when necessary through the systematic and 

ongoing review of both plant-specific and industry OE including research and development 

such that the effectiveness of the AMP is evaluated consistent with the discussion in 

Appendix B of the GALL-SLR Report.

References

10 CFR Part 50, Appendix B, “Quality Assurance Criteria for Nuclear Power Plants and Fuel 

Reprocessing Plants.” Washington, DC: U.S. Nuclear Regulatory Commission. 2016.

ASTM. ASTM D 6224-02, “Standard Practice for In-Service Monitoring of Lubricating Oil for 

Auxiliary Power Plant Equipment.” West Conshohocken, Pennsylvania: American Society of 

Testing Materials. 2002.
XI.M40-1

XI.M40 MONITORING OF NEUTRON-ABSORBING MATERIALS OTHER

THAN BORAFLEX

Program Description

Many neutron‐absorbing materials are used in spent fuel pools. This aging management program 

(AMP) addresses aging management of spent fuel pools that use materials other than Boraflex, 

such as Boral, Metamic, boron steel, and Carborundum. Generic Aging Lessons Learned for 

Subsequent License Renewal (GALL-SLR) Report AMP XI.M22, “Boraflex Monitoring,” addresses 

aging management of spent fuel pools that use Boraflex as the neutron-absorbing material. 

When a spent fuel pool criticality analysis credits both Boraflex and materials other than Boraflex, 

the guidance in both AMPs XI.M22 and XI.M40 applies.

A monitoring program is implemented to assure that degradation of the neutron-absorbing 

material used in spent fuel pools that could compromise the criticality analysis will be detected. 

The AMP relies on periodic inspection, testing, monitoring, and analysis of the criticality design to 

assure that the required 5 percent subcriticality margin is maintained during the period 

of subsequent license renewal. 

Evaluation and Technical Basis

1. Scope of Program: The AMP manages the effects of aging on neutron-absorbing 

components/materials other than Boraflex used in spent fuel racks.

2. Preventive Actions: This AMP is a condition monitoring program. Therefore, there are 

no preventative actions.

3. Parameters Monitored or Inspected: For these materials, gamma irradiation and/or 

long-term exposure to the wet pool environment may cause loss of material and changes 

in dimension (such as gap formation, formation of blisters, pits and bulges) that could 

result in loss of neutron-absorbing capability of the material. The parameters monitored 

include the physical condition of the neutron-absorbing materials, such as in-situ gap 

formation, geometric changes in the material (formation of blisters, pits, and bulges) as 

observed from coupons or in situ, and decreased boron-10 areal density, etc. The 

parameters monitored are directly related to determination of the loss of material or loss of 

neutron absorption capability of the material(s).

4. Detection of Aging Effects: The loss of material and the degradation of neutron 

absorbing material capacity are determined through coupon and/or direct in-situ testing. 

Such testing should include periodic verification of boron loss through boron-10 areal 

density measurement of coupons or through direct in-situ techniques. In addition to 

measuring boron content, testing should also be capable of identifying indications of 

geometric changes in the material (blistering, pitting, and bulging). The frequency of the 

inspection and testing depends on the condition of the neutron-absorbing material and 

is determined and justified with plant-specific operating experience (OE) by the 

licensee. The maximum interval between inspections for polymer-based materials 

(e.g., Carborundum, Tetrabor), regardless of OE, should not exceed 5 years. The 

maximum interval between inspections for nonpolymer-based materials (e.g., Boral, 

Metamic, Boralcan, borated stainless steel), regardless of OE, should not exceed

10 years.
XI.M40-2

5. Monitoring and Trending: The measurements from periodic inspections and analysis 

are compared to baseline information or prior measurements and analysis for trend 

analysis. The approach for relating the measurements to the performance of the spent 

fuel neutron absorber materials is specified by the applicant, considering differences in 

exposure conditions, vented/nonvented test samples, and spent fuel racks, etc.

6. Acceptance Criteria: Although the goal is to ensure maintenance of the 5 percent 

subcriticality margin for the spent fuel pool, the specific acceptance criteria for the 

measurements and analyses are specified by the applicant.

7. Corrective Actions: Results that do not meet the acceptance criteria are addressed in 

the applicant’s corrective action program under those specific portions of the quality 

assurance (QA) program that are used to meet Criterion XVI, “Corrective Action,” of 

Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B. Appendix A of 

the GALL-SLR Report describes how an applicant may apply its 10 CFR Part 50, 

Appendix B, QA program to fulfill the corrective actions element of this AMP for both 

safety-related and nonsafety-related structures and components (SCs) within the scope of 

this program. 

Corrective actions are initiated if the results from measurements and analysis indicate that 

the 5 percent subcriticality margin cannot be maintained because of current or projected 

future degradation of the neutron-absorbing material. Corrective actions may consist of 

providing additional neutron-absorbing capacity with an alternate material, or applying 

other options, which are available to maintain the subcriticality margin. 

8. Confirmation Process: The confirmation process is addressed through those specific 

portions of the QA program that are used to meet Criterion XVI, “Corrective Action,” of 

10 CFR Part 50, Appendix B. Appendix A of the GALL-SLR Report describes how an 

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the confirmation 

process element of this AMP for both safety-related and nonsafety-related SCs within the 

scope of this program.

9. Administrative Controls: Administrative controls are addressed through the QA program 

that is used to meet the requirements of 10 CFR Part 50, Appendix B, associated with 

managing the effects of aging. Appendix A of the GALL-SLR Report describes how an 

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the 

administrative controls element of this AMP for both safety-related and nonsafety-related 

SCs within the scope of this program.

10. Operating Experience: Applicants for license renewal reference plant-specific OE and 

industry experience to provide reasonable assurance that the program is able to detect 

degradation of the neutron absorbing material in the applicant’s spent fuel pool. Some of 

the industry OE that should be included is discussed in Information Notice 2009-26, 

Degradation of Neutron-Absorbing Materials in the Spent Fuel Pool, and listed below:

1. Loss of material from the neutron absorbing material has been seen at many 

plants, including loss of aluminum, which was detected by monitoring the 

aluminum concentration in the spent fuel pool. One instance of this was 

documented in the Vogtle license renewal application Water Chemistry 

Program B.3.28.
XI.M40-3

2. Blistering has also been noted at many plants. Examples include blistering at 

Seabrook and Beaver Valley.

3. The significant loss of neutron-absorbing capacity of the plate-type Carborundum 

material has been reported at Palisades.

4. The coupon testing program at Kewaunee has observed loss of boron-10 areal 

density of Tetrabor. 

5. The coupon testing programs at Calvert Cliffs Unit 1 and Crystal River Unit 3 have 

observed weight loss of sheet-type Carborundum.

The applicant should describe how the monitoring program described above is capable of 

detecting the aforementioned degradation mechanisms. 

The program is informed and enhanced when necessary through the systematic and 

ongoing review of both plant-specific and industry OE including research and development 

such that the effectiveness of the AMP is evaluated consistent with the discussion in 

Appendix B of the GALL-SLR Report.

References

10 CFR Part 50, Appendix B, “Quality Assurance Criteria for Nuclear Power Plants and Fuel 

Reprocessing Plants.” Washington, DC: U.S. Nuclear Regulatory Commission. 2016.

Franke, Jon A., Progress Energy, letter to the U.S. Nuclear Regulatory Commission, Crystal River 

Unit 3–Response to Request for Additional Information for the Review of the Crystal River Unit 3, 

Nuclear Generating Plant, License Renewal Application. Agencywide Documents Access and 

Management System (ADAMS) Accession No. ML100290366. January 2010.

NRC. Information Notice 2009-26, “Degradation of Neutron-Absorbing Materials in the Spent Fuel 

Pool.” Washington, DC: U.S. Nuclear Regulatory Commission. October 2009.

_____. License Renewal Interim Staff Guidance LR-ISG-2009-01, “Aging Management of Spent 

Fuel Pool Neutron-Absorbing Materials Other Than Boraflex.” Washington, DC: U.S. Nuclear 

Regulatory Commission. 2010.

Ostrowski, Kevin L., FirstEnergy Nuclear Operating Company, letter to the U.S. Nuclear 

Regulatory Commission, Supplemental Information for the Review of the Beaver Valley Power 

Station, Units 1 and 2, License Renewal Application (TAC Nos. MD6593 and MD6594) and 

License Renewal Application Amendment No. 34. ADAMS Accession No. ML090220216. 

Washington, DC: U.S. Nuclear Regulatory Commission. January 2009.

Schwarz, Christopher J., Entergy Nuclear Operations, Inc., Palisades Nuclear Plant, letter to the 

U.S. Nuclear Regulatory Commission, Commitments to Address Degraded Spent Fuel Pool 

Storage Rack Neutron Absorber. ADAMS Accession No. ML082410132. Washington, DC: 

U.S. Nuclear Regulatory Commission. August 2008.

Southern Nuclear Operating Company. “License Renewal Application Vogtle Electric Generating 

Plant Units 1 and 2.” ADAMS Accession No. ML071840360. Birmingham, Alabama: Southern 

Nuclear Operating Company, Inc. June 2007.
XI.M40-4

Spina, James A., Constellation Energy Nuclear Generation Group, letter to the U.S. Nuclear 

Regulatory Commission, Calvert Cliffs 1 Response to Request for Additional Information–LongTerm Carborundum Coupon Surveillance Program. ADAMS Accession No. ML080140341. 

Washington, DC: U.S. Nuclear Regulatory Commission. January 2008.

Warner, Mark E., FPL Energy Seabrook Station, letter to the U.S. Nuclear Regulatory 

Commission, Seabrook Station Boral Spent Fuel Pool Test Coupons Report Pursuant to 

10 CFR Part 21.21. ADAMS Accession No. ML032880525. Washington, DC: U.S. Nuclear 

Regulatory Commission. October 2003.
XI.M41-1

XI.M41 BURIED AND UNDERGROUND PIPING AND TANKS

Program Description

This aging management program (AMP) manages the aging of the external surfaces of buried 

and underground piping and tanks. It addresses piping and tanks composed of any material, 

including metallic, polymeric, and cementitious materials. This program manages aging through 

preventive, mitigative, inspection, and in some cases, performance monitoring activities. It 

manages applicable aging effects such as loss of material and cracking.

Depending on the material, preventive and mitigative techniques may include external coatings, 

cathodic protection, and the quality of backfill. Also, depending on the material, inspection 

activities may include electrochemical verification of the effectiveness of cathodic protection, 

nondestructive evaluation of pipe or tank wall thicknesses, pressure testing of the pipe, 

performance monitoring of fire mains, and visual inspections of the pipe or tank from the exterior.

This program does not provide aging management of selective leaching. The Selective Leaching 

program of the Generic Aging Lessons Learned for Subsequent License Renewal (GALL-SLR)

Report AMP XI.M33 is applied in addition to this program for applicable materials and 

environments.

Evaluation and Technical Basis

1. Scope of Program: This program manages the effects of aging of the external surfaces 

of buried and underground piping and tanks constructed of any material including metallic, 

polymeric, and cementitious materials. The term “polymeric” material refers to plastics or 

other polymers that comprise the pressure boundary of the component. The program 

addresses aging effects such as loss of material and cracking. The program also 

manages loss of material due to corrosion of piping system bolting within the scope of this 

program. The Bolting Integrity program (GALL-SLR Report AMP XI.M18) manages other 

aging effects associated with piping system bolting. This program does not provide aging 

management of selective leaching. The Selective Leaching of Materials program 

(GALL-SLR Report AMP XI.M33) is applied in addition to this program for applicable 

materials and environments. 

2. Preventive Actions: Preventive actions utilized by this program vary with the material of 

the tank or pipe and the environment (e.g., air, soil, concrete) to which it is exposed. 

There are no recommended preventive actions for titanium alloy, super austenitic stainless 

steels, and nickel alloy materials. Preventive actions for buried and underground piping 

and tanks are conducted in accordance with Table XI.M41-1 and the following: 
XI.M41-2

Table XI.M41-1. Preventive Actions for Buried and Underground Piping and Tanks

Material Buried Underground

Stainless steel C, B None

Steel C, CP, B C

Copper alloy C, CP, B C

Aluminum alloy C, CP, B None

Cementitious C, CP, B None

Polymer B None

C: Coatings; CP: Cathodic Protection; B: Backfill

a. For buried stainless steel or cementitious piping or tanks, coatings are provided 

based on the environmental conditions (e.g., stainless steel in chloride containing 

environments). Applicants provide justification when coatings are not provided. 

Coatings are in accordance with Table 1 of National Association of Corrosion 

Engineers (NACE) SP0169-2007 or Section 3.4 of NACE RP0285-2002 as well 

as the following coating types: asphalt/coal tar enamel, concrete, elastomeric 

polychloroprene, mastic (asphaltic), epoxy polyethylene, polypropylene, 

polyurethane, and zinc.

b. For buried steel, copper alloy, and aluminum alloy piping and tanks and 

underground steel and copper alloy piping and tanks, coatings are in accordance 

with Table 1 of NACE SP0169-2007 or Section 3.4 of NACE RP0285-2002.

c. Cathodic protection is in accordance with NACE SP0169-2007 or NACE 

RP0285-2002. The system is operated so that the cathodic protection criteria 

and other considerations described in the standards are met at every location in 

the system for which cathodic protection is credited. System monitoring is 

conducted annually with a grace period of one to two months; however, in each 

calendar year, system monitoring is conducted at least once. The equipment 

used to implement cathodic protection need not be qualified in accordance with 

Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B.

d. Cathodic protection is supplied for reinforced concrete pipe and prestressed 

concrete cylinder pipe. Applicants provide justification when cathodic protection 

is not provided.

e. Critical potentials for cathodic protection:

i. To prevent damage to the coating or base metal (e.g., aluminum), the 

limiting critical potential should not be more negative than −1,200 mV.

ii. Where an impressed current cathodic protection system is utilized with 

prestressed concrete cylinder pipe, steps are taken to avoid an excessive 

level of potential that could damage the prestressing wire. Therefore, 

polarized potentials more negative than -1,000 mV relative to a 

copper/copper sulfate reference electrode (CSE) are avoided to prevent 

hydrogen generation and possible hydrogen embrittlement of the 

high-strength prestressing wire.
XI.M41-3

iii. Depending on the environment, steel (in a carbonate-bicarbonate 

environment) and stainless steel components can experience stress 

corrosion cracking dependent on the cathodic protection polarization 

level, temperature, pH, etc. If these conditions are applicable, the 

applicant describes the conditions and alternative cathodic protection 

levels in the subsequent license renewal application (SLRA).

iv. Any further over-protection limits are defined by the applicant and 

managed during surveillance activities. The use of excessive polarized 

potentials on externally coated pipelines should be avoided.

f. Backfill is consistent with NACE SP0169-2007 Section 5.2.3 or NACE 

RP0285-2002, Section 3.6. The staff considers backfill that is located within 

6 inches of the component that meets ASTM D 448-08 size number 67 

(size number 10 for polymeric materials) to meet the objectives of NACE 

SP0169-2007 and NACE RP0285-2002. For stainless steel and cementitious 

materials, backfill limits apply only if the component is coated. For materials 

other than aluminum alloy, the staff also considers the use of controlled low 

strength materials (flowable backfill) acceptable to meet the objectives of NACE 

SP0169-2007.

g. Alternatives to the preventive actions in Table XI.M41-1 are as follows:

i. A broader range of coatings may be used if justification is provided in 

the SLRA.

ii. Backfill quality may be demonstrated by plant records or by examining the 

backfill while conducting the inspections described in the “detection of 

aging effects” program element of this AMP.

iii. For fire mains installed in accordance with National Fire Protection 

Association (NFPA) NFPA® 24, preventive actions beyond those in 

NFPA 24 need not be provided if: (a) the system undergoes either a 

periodic flow test in accordance with NFPA 25; (b) the activity of the 

jockey pump (e.g., number of pump starts, run time) is monitored as 

described in “detection of aging effects” program element of this AMP; or 

(c) an annual system leakage rate test is conducted.

iv. Failure to provide cathodic protection in accordance with Table XI.M41-1 

may be acceptable if justified in the SLRA. The justification addresses 

soil sample locations, soil sample results, the methodology and results of 

how the overall soil corrosivity was determined, pipe to soil potential 

measurements and other relevant parameters. 

If cathodic protection is not provided for any reason, the applicant reviews 

the most recent 10 years of plant-specific operating experience (OE) to

determine if degraded conditions that would not have met the acceptance 

criteria of this AMP have occurred. This search includes components that 

are not in-scope for license renewal if, when compared to in-scope piping, 

they are similar materials and coating systems and are buried in a similar 
XI.M41-4

soil environment. The results of this expanded plant-specific OE search 

are included in the SLRA.

3. Parameters Monitored or Inspected:

a. Visual inspections of: (a) the external surface condition of buried or underground 

piping or tanks; (b) the external surface condition of associated coatings; or 

(c) external surfaces of controlled low strength material backfill are performed. 

Monitoring of the surface condition of the component is conducted to detect 

indications of aging effects described in 3.b. Monitoring of the surface condition of 

coatings is conducted to determine if the coatings are intact, well-adhered, and 

otherwise sound; such that aging effects would not be expected for the base 

material of the component. Monitoring of the external surfaces of controlled low 

strength material backfill is conducted to detect potential cracks that could admit

groundwater to the surface of the component.

b. Visual inspections of the external surface condition of the component 

should detect:

i. loss of material due to general, pitting, crevice, and microbiologically

influenced corrosion (MIC) for copper alloy and steel components;

ii. loss of material due to pitting and crevice corrosion for aluminum alloy 

and titanium alloy components;

iii. loss of material due to pitting and crevice corrosion, and MIC for stainless 

steel, super austenitic, and nickel alloy components; 

iv. loss of material due to wear for polymeric materials;

v. cracking due to chemical reaction, weathering, or settling for cementitious 

materials;

vi. cracking or blistering due to water absorption for high-density 

polyethylene and fiberglass components;

vii. cracking due to corrosion of reinforcement for reinforced concrete pipe; 

and

viii. loss of material due to delamination, exfoliation, spalling, popout, or 

scaling for cementitious materials.

c. Volumetric nondestructive examination techniques as well as pit depth gages or 

calipers may be used for measuring wall thickness as long as: (a) they have 

been determined to be effective for the material, environment, and conditions 

(e.g., remote methods) during the examination; and (b) they are capable of 

quantifying general wall thickness and the depth of pits. Wall thickness 

measurements are conducted to detect potential loss of material.
XI.M41-5

d. Inspections for cracking due to stress corrosion cracking for steel (in a 

carbonate-bicarbonate environment), stainless steel and susceptible aluminum 

alloy materials utilize a method that has been determined to be capable of 

detecting cracking. Coatings that: (a) are intact, well-adhered, and otherwise 

sound for the remaining inspection interval; and (b) exhibit small blisters that 

are few in number and completely surrounded by sound coating bonded to the 

substrate do not have to be removed. Inspections for cracking are conducted 

to assess the impact of cracks on the pressure boundary function of the 

component.

e. Pipe-to-soil potential and the cathodic protection current are monitored for steel, 

copper alloy, and aluminum alloy piping and tanks in contact with soil to 

determine the effectiveness of cathodic protection systems. 

f. When using alternatives to excavated direct visual examination of fire mains, 

appropriate inspection parameters are used in order to detect indications of fire 

main leakage. For example:

i. During periodic flow test, a reduction in available flow rate.

ii. For jockey pump monitoring, an increase in the number of pump starts or 

run time of the pump.

iii. During annual system leakage rate testing an increase in unaccounted flow 

leak rates (i.e., the leakage path could be through a valve disc and seat, 

which is not pertinent to this AMP).

4. Detection of Aging Effects: Methods and frequencies used for the detection of aging 

effects vary with the material and environment of the buried and underground piping and 

tanks. Inspections of buried and underground piping and tanks are conducted in 

accordance with Table XI.M41-2 and the following. There are no inspection 

recommendations for titanium alloy, super austenitic, or nickel alloy materials; however, 

these materials are opportunistically inspected when exposed. Table XI.M41-2 inspection 

quantities are for a single unit plant. For two-unit sites, the inspection quantities (i.e., not 

the percentage of pipe length) are increased by 50 percent. For a three-unit site, the 

inspection quantities are doubled. For multi-unit sites, the inspections are distributed 

evenly among the units. Additional inspections, beyond those in Table XI.M41-2 may be 

appropriate if exceptions are taken to program element 2, “preventive actions,” or in 

response to plant-specific OE. 

Inspections of buried and underground piping and tanks are conducted during each 

10-year period, commencing 10 years prior to the subsequent period of extended 

operation. Piping inspections are typically conducted by visual examination of the external 

surfaces of pipe or coatings. Tank inspections are conducted externally by visual 

examination of the surfaces of the tank or coating or internally by volumetric methods. 

Opportunistic inspections are conducted for in-scope piping whenever they become 

accessible. Visual inspections are supplemented with surface and/or volumetric 

nondestructive testing if evidence of wall loss beyond minor surface scale is observed.
XI.M41-6

Table XI.M41-2. Inspection of Buried and Underground Piping and Tanks

Inspections of Buried Piping

Material Preventive Action Categories 

Inspection

See Section 4.c. for

Extent of Inspections

Stainless steel 1 inspection

Polymeric

Backfill is in accordance with preventive 

actions program element

1 inspection

Backfill is not in accordance with preventive 

actions program element

The smaller of 1% of the 

length of pipe or 2 inspections

Cementitious 1 inspection

Steel

C The smaller of 0.5% of the 

piping length or 1 inspection

D The smaller of 1% of the 

piping length or 2 inspections

E The smaller of 5% of the 

piping length or 3 inspections

F The smaller of 10% of the 

piping length or 6 inspections

Copper alloy

C The smaller of 0.5% of the 

piping length or 1 inspection

D The smaller of 1% of the 

piping length or 2 inspections

E The smaller of 5% of the 

piping length or 3 inspections

F The smaller of 10% of the 

piping length or 6 inspections

Aluminum alloy

C The smaller of 0.5% of the 

piping length or 1 inspection

D The smaller of 1% of the 

piping length or 2 inspections

E The smaller of 5% of the 

piping length or 3 inspections

F The smaller of 10% of the 

piping length or 6 inspections

Inspections of Buried Tanks and Underground Piping and Tanks

Material Buried Tanks Underground Piping Underground Tanks

Stainless steel All tanks 1 inspection All tanks

Polymeric All tanks 1 inspection None

Cementitious All tanks 1 inspection None

Steel All tanks

The smaller of 2% of 

the piping length or 

2 inspections

All tanks

Copper alloy or 

Aluminum alloy All tanks

The smaller of 1% of 

the length of piping or 

1 inspection

All tanks
XI.M41-7

Table XI.M41-2. Inspection of Buried and Underground Piping and Tanks

The Preventive Action Categories are used as follows:

A: Category A no longer used.

B: Category B no longer used.

C: Category C applies when:

a. Cathodic protection was installed or refurbished 5 years prior to the end of the inspection period of 

interest; and

b. Cathodic protection has operated at least 85% of the time either since 10 years prior to the subsequent 

period of extended operation or since installation/refurbishment, whichever is shorter. Time periods in 

which the cathodic protection system is off-line for testing do not have to be included in the total 

non-operating hours; and

c. Cathodic protection has provided effective protection for buried piping as evidenced by meeting the 

acceptance criteria of Table XI.M41-3 of this AMP at least 80% of the time either since 10 years prior to 

the subsequent period of extended operation or since installation/refurbishment, whichever is shorter. As 

found results of annual surveys are to be used to determine locations within the plant’s population of 

buried pipe where cathodic protection acceptance criteria have, or have not, been met.

D: Inspection criteria provided for Category D piping may be used for those portions of in-scope buried piping 

where it has been determined, in accordance with the “preventive actions” program element of this AMP, that 

external corrosion control is not required.

E: Inspection criteria provided for Category E piping may be used for those portions of the population of buried 

piping where:

a. An analysis, conducted in accordance with the “preventive actions” program element of this AMP, has 

determined that installation or operation of a cathodic protection system is impractical; or

b. A cathodic protection system has been installed but all or portions of the piping covered by that system 

fail to meet any of the criteria of Category C piping above, provided:

i. Coatings and backfill are provided in accordance with the “preventive actions” program element of 

this AMP; and

ii. Plant-specific OE is acceptable (i.e., no leaks in buried piping due to external corrosion, no 

significant coating degradation or metal loss in more than 10% of inspections conducted); and

iii. Soil has been determined to not be corrosive for the material type (e.g., AWWA C105, 

“Polyethylene Encasement for Ductile-Iron Pipe Systems,” Table A.1, “Soil-Test Evaluation”). In 

order to determine that the soil is not corrosive, the applicant:

1) Obtains a minimum of three sets of soil samples in each soil environment (e.g., moisture 

content, soil composition) in the vicinity in which in-scope components are buried.

2) Tests the soil for soil resistivity, corrosion accelerating bacteria, pH, moisture, chlorides, 

sulfates, and redox potential.

3) Determines the potential soil corrosivity for each material type of buried in-scope piping. In 

addition to evaluating each individual parameter, the overall soil corrosivity is determined.

4) Conducts soil testing once in each 10-year period starting 10 years prior to the subsequent 

period of extended operation.

F: Inspection criteria provided for Category F piping is used for those portions of in-scope buried piping which cannot 

be classified as Category C, D, or E.

a. Transitioning to a Higher Number of Inspections: Plant-specific conditions can 

result in transitioning to a higher number of inspections than originally planned at 

the beginning of a 10-year interval. For example, degraded performance of the 

cathodic protection system could result in transitioning from Preventive Action 

Category C to Preventive Action Category E. Coating, backfill, or the condition of 

exposed piping that do not meet acceptance criteria could result in transitioning 

from Preventive Action Category E to Preventive Action Category F. If this 

transition occurs in the latter half of the current 10-year interval, the timing of the 

additional examinations is based on the severity of the degradation identified and 

is commensurate with the consequences of a leak or loss of function, but in all 
XI.M41-8

cases, the examinations are completed within 4 years after the end of the 

particular 10-year interval. These additional inspections conducted during the 

4 years following the end of an inspection interval cannot also be credited towards 

the number of inspections stated in Table XI.M41-2 for the following 10-year 

interval.

b. Exceptions to Table XI.M41-2 inspection quantities:

i. Where piping constructed of steel, copper alloy, or aluminum alloy has 

been coated with the same coating system and the backfill has the same 

requirements, the total inspections for this piping may be combined to 

satisfy the recommended inspection quantity. For example, for Preventive 

Action Category F, 10 percent of the total of the associated steel, copper 

alloy, or aluminum alloy is inspected; or six 10-foot segments of steel, 

copper alloy, or aluminum alloy piping are inspected.

ii. For buried piping or tanks, inspections may be reduced to one-half the 

number of inspections indicated in Table XI.M41-2 when performance of 

the indicated inspections necessitates excavation of piping or tanks that 

has been fully backfilled using controlled low strength material. The 

inspection quantity is rounded up (e.g., where three inspections are 

recommended in Table XI.M41-2, two inspections are conducted).

When conducting inspections of buried components embedded in concrete 

backfill, the backfill may be excavated and the pipe or tank examined, or 

the soil around the backfill may be excavated and the cementitious material 

examined. The inspection includes excavation of the top surfaces and at 

least 50 percent of the side surface to visually inspect for cracks in the 

backfill that could admit groundwater to the external surfaces of the 

component. When conducting inspection of backfill based on the number 

of inspections designated for that material type, 10 linear feet of the backfill 

is exposed for each inspection.

iii. No inspections are necessary if all the piping or tanks constructed from a 

specific material type is fully backfilled using controlled low strength 

material for: (a) polymeric and cementitious materials; (b) steel and copper 

alloy materials when Preventive Action Category C is met; and (c) stainless 

steel materials.

iv. If all of the in-scope polymeric material is nonsafety-related, no more than 

one inspection need be conducted.

v. Buried polymeric tanks are only inspected if backfill is not in accordance 

with the preventive actions.

vi. Stainless steel tanks are inspected when they are not coated and the 

underground environment is potentially exposed to in-leakage of 

groundwater or rain water.
XI.M41-9

vii. Steel, copper alloy, and aluminum alloy buried tanks are not inspected if 

the cathodic protection provided for the tank met the criteria for Preventive 

Action Category C.

c. Guidance related to the extent of inspections for piping is as follows:

i. When the inspections are based on the number of inspections in lieu 

of percentage of piping length, 10 feet of piping is exposed for 

each inspection.

ii. When the percentage of inspections for a given material type results in an 

inspection quantity of less than 10 feet, then 10 feet of piping is inspected. 

If the entire run of piping of that material type is less than 10 feet in total 

length, then the entire run of piping is inspected.

d. Piping inspection location selection: Piping inspection locations are selected 

based on risk (i.e., susceptibility to degradation and consequences of failure). 

Characteristics such as coating type (i.e., material type), coating condition, 

cathodic protection efficacy, backfill characteristics, soil resistivity, pipe contents, 

and pipe function are considered. Opportunistic examinations of nonleaking pipes 

may be credited toward examinations if the location selection criteria are met. The 

use of guided wave ultrasonic examinations may not be substituted for the 

inspections listed in the table.

e. Alternatives to visual examination of piping are as follows:

i. Aging effects associated with fire mains may be managed by either: (a) a 

flow test as described in Section 7.3 of NFPA 25 at a frequency of at least 

one test in each 1-year period; (b) monitoring the activity of the jockey 

pump (e.g., pump starts, run time) on an interval not to exceed 1 month; or 

(c) an annual system leak rate test. If the aging effects are not managed 

by one of these alternatives, and the extent of inspections is not based on 

the percentage of piping for that material type, then two additional 

inspections are added to the inspection quantity for that material type.

ii. At least 25 percent of the in-scope piping constructed from the material 

under consideration is pressure tested on an interval not to exceed 5 years. 

The piping is pressurized to 110 percent of the design pressure of any 

component within the boundary (not to exceed the maximum allowable test 

pressure of any nonisolated components) with test pressure being held for 

a continuous eight hour interval.

iii. At least 25 percent of the in-scope piping constructed from the material 

under consideration is internally inspected by a method capable of 

precisely determining pipe wall thickness. The inspection method has 

been determined to be capable of detecting both general and pitting 

corrosion on the external surface of the piping and is qualified by the 

applicant to identify loss of material that does not meet acceptance criteria. 

Ultrasonic examinations, in general, satisfy this criterion. As of the effective 

date of this document, guided wave ultrasonic examinations do not meet 

the intent of this paragraph. If internal inspections are to be conducted in 
XI.M41-10

lieu of direct visual examination, they are conducted at an interval not to 

exceed 10 years.

f. Examinations are conducted from the external surface of the tank using visual 

techniques or from the internal surface of the tank using volumetric techniques. A 

minimum of 25 percent coverage is obtained. This area includes at least some of 

both the top and bottom of the tank. If the tank is inspected internally by volumetric 

methods, the method is: capable of determining tank wall thickness, determined to 

be capable of detecting both general and pitting corrosion, and qualified by the 

applicant to identify loss of material that does not meet acceptance criteria. 

Double wall tanks may be examined by monitoring the annular space for leakage.

5. Monitoring and Trending: For piping and tanks protected by cathodic protection 

systems, potential difference and current measurements are trended to identify changes in 

the effectiveness of the systems and/or coatings. If aging of fire mains is managed 

through monitoring jockey pump activity (or a similar parameter), the jockey pump activity 

(or similar parameter) is trended to identify changes in pump activity that may be the result 

of increased leakage from buried fire main piping. Likewise, if leak rate testing is 

conducted, leak rates are trended. Where wall thickness measurements are conducted, 

the results are trended when follow up examinations are conducted.

Where practical, all other degradation (e.g., coating condition, cementitious piping 

degradation) is projected until the next scheduled inspection. Results are evaluated 

against acceptance criteria to confirm that the sampling bases (e.g., selection, size, 

frequency) will maintain the components’ intended functions throughout the subsequent 

period of extended operation based on the projected rate and extent of degradation.

6. Acceptance Criteria: The acceptance criteria associated with this AMP are: 

a. For coated piping or tanks, there is either no evidence of coating degradation, or 

the type and extent of coating degradation is evaluated as insignificant by an 

individual: (a) possessing a NACE Coating Inspector Program Level 2 or 3 

inspector qualification; (b) who has completed the Electric Power Research 

Institute Comprehensive Coatings Course and completed the EPRI Buried Pipe 

Condition Assessment and Repair Training Computer Based Training Course; or 

(c) a coatings specialist qualified in accordance with an ASTM standard endorsed 

in Regulatory Guide 1.54, Revision 2, “Service Level I, II, and III Protective 

Coatings Applied to Nuclear Power Plants.”

b. Cracking is absent in rigid polymeric components. Blisters, gouges, or wear of 

nonmetallic piping is evaluated.

c. The measured wall thickness projected to the end of the subsequent period of 

extended operation meets minimum wall thickness requirements.

d. Indications of cracking in metallic pipe are managed in accordance with the 

“corrective actions” program element.

e. Cementitious piping may exhibit minor cracking and loss of material provided there 

is no evidence of leakage exposed or rust staining from rebar or reinforcing “hoop”

bands.
XI.M41-11

f. Backfill is acceptable if the inspections do not reveal evidence that the backfill

caused damage to the component’s coatings or the surface of the component (if 

not coated).

g. Flow test results for fire mains are in accordance with NFPA 25, Section 7.3.

h. For pressure tests, the test acceptance criteria are that there are no visible 

indications of leakage, and no drop in pressure within the isolated portion of the 

piping that is not accounted for by a temperature change in the test media or by 

quantified leakage across test boundary valves.

i. Changes in jockey pump activity (or similar parameter) that cannot be attributed to 

causes other than leakage from buried piping, are not occurring.

j. When fire water system leak rate testing is conducted, leak rates are within 

acceptance limits of plant-specific documents.

k. Cracks in cementitious backfill that could admit groundwater to the surface of the 

component are not acceptable.

l. Criteria for pipe-to-soil potential when using a saturated CSE is as stated in 

Table XI.M41-3, or acceptable alternatives as stated below.

Table XI.M41-3. Cathodic Protection Acceptance Criteria

Material Criteria1,2

Steel −850 mV relative to a CSE, instant off

Copper alloy 100 mV minimum polarization

Aluminum alloy 100 mV minimum polarization

1

Plants with sacrificial anode systems state the test method and acceptance criteria and the basis for the method and 

criteria in the application.

2For steel piping, when: (a) active MIC has been identified or is probable; (b) temperatures greater than 60 °C 

(140 °F); or (c) in weak acid environments, a polarized potential of -950 mV or more negative is recommended.

m. Alternatives to the -850 mV criterion for steel piping in Table XI.M41-3 are 

as follows.

i. 100 mV minimum polarization

ii. -750 mV relative to a CSE, instant off where soil resistivity is greater than 

10,000 ohm-cm to less than 100,000 ohm-cm

iii. -650 mV relative to a CSE, instant off where soil resistivity is greater than 

100,000 ohm-cm

iv. Verify less than 1 mpy loss of material. Loss of material rates in excess of 

1 mpy may be acceptable if an engineering evaluation demonstrates that 

the corrosion rate would not result in a loss of intended function prior to the 

end of the subsequent period of extended operation. The engineering 

evaluation is cited and summarized in the SLRA.
XI.M41-12

When using the 100 mV, -750 mV, or -650 mV polarization criteria as an alternative to the 

-850 mV criterion for steel piping, means to verify the effectiveness of the protection of the 

most anodic metal is incorporated into the program. One acceptable means to verify the 

effectiveness of the cathodic protection system, or to demonstrate that the loss of material 

rate is acceptable, is to use installed electrical resistance corrosion rate probes. The 

external loss of material rate is verified:

• Every year when verifying the effectiveness of the cathodic protection system by 

measuring the loss of material rate.

• Every 2 years when using the 100 mV minimum polarization.

• Every 5 years when using the -750 or -650 criteria associated with higher resistivity 

soils. The soil resistivity is verified every 5 years.

As an alternative to verifying the effectiveness of the cathodic protection system every 

5 years, soil resistivity testing is conducted annually during a period of time when the 

soil resistivity would be expected to be at its lowest value (e.g., maximum rainfall 

periods). Upon completion of 10 annual consecutive soil samples, soil resistivity 

testing can be extended to every 5 years if the results of the soil sample tests 

consistently verified that the resistivity did not fall outside of the range being credited 

(e.g., for the -750 mV relative to a CSE, instant off criterion, all soil resistivity values 

were greater than 10,000 ohm-cm).

When electrical resistance corrosion rate probes will be used, the application identifies:

• The qualifications of the individuals that will determine the installation locations of the 

probes and the methods of use (e.g., NACE CP4, “Cathodic Protection Specialist”).

• How the impact of significant site features (e.g., large cathodic protection current 

collectors, shielding due to large objects located in the vicinity of the protected piping) 

and local soil conditions will be factored into placement of the probes and use of probe 

data.

7. Corrective Actions: Results that do not meet the acceptance criteria are addressed in 

the applicant’s corrective action program under those specific portions of the quality 

assurance (QA) program that are used to meet Criterion XVI, “Corrective Action,” of 

10 CFR Part 50, Appendix B. Appendix A of the GALL-SLR Report describes how an 

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the corrective 

actions element of this AMP for both safety-related and nonsafety-related structures and 

components (SCs) within the scope of this program.

a. Where damage to the coating has been evaluated as significant and the damage 

was caused by nonconforming backfill, an extent of condition evaluation is 

conducted to determine the extent of degraded backfill in the vicinity of the 

observed damage.

b. If coated or uncoated metallic piping or tanks show evidence of corrosion, the 

remaining wall thickness in the affected area is determined to ensure that the 

minimum wall thickness is maintained. This may include different values for large 

area minimum wall thickness and local area wall thickness. If the wall thickness 
XI.M41-13

extrapolated to the end of the subsequent period of extended operation meets 

minimum wall thickness requirements, recommendations for expansion of sample 

size below do not apply. 

c. Where the coatings, backfill, or the condition of exposed piping does not meet 

acceptance criteria, the degraded condition is repaired or the affected component 

is replaced. In addition, where the depth or extent of degradation of the base 

metal could have resulted in a loss of pressure boundary function when the loss of 

material is extrapolated to the end of the subsequent period of extended operation, 

an expansion of sample size is conducted. The number of inspections within the 

affected piping categories are doubled or increased by five, whichever is smaller. 

If the acceptance criteria are not met in any of the expanded samples, an analysis 

is conducted to determine the extent of condition and extent of cause. The number 

of follow-on inspections is determined based on the extent of condition and extent 

of cause.

The timing of the additional examinations is based on the severity of the 

degradation identified and is commensurate with the consequences of a leak or 

loss of function. However, in all cases, the expanded sample inspection is 

completed within the 10-year interval in which the original inspection was 

conducted or, if identified in the latter half of the current 10-year interval, within 

4 years after the end of the 10-year interval. These additional inspections 

conducted during the 4 years following the end of an inspection interval cannot 

also be credited towards the number of inspections in Table XI.M41-2 for the 

following 10-year interval. The number of inspections may be limited by the extent 

of piping or tanks subject to the observed degradation mechanism. 

The expansion of sample inspections may be halted in a piping system or portion 

of system that will be replaced within the 10-year interval in which the inspections 

were conducted or, if identified in the latter half of the current 10-year interval, 

within 4 years after the end of the 10-year interval.

d. Unacceptable cathodic protection survey results are entered into the plant 

corrective action program.

e. Sources of leakage detected during pressure tests are identified and corrected.

f. When using the option of monitoring the activity of a jockey pump instead of 

inspecting buried fire water system piping, a flow test or system leak rate test is 

conducted by the end of the next refueling outage or as directed by the current 

licensing basis, whichever is shorter, when unexplained changes in jockey pump 

activity (or equivalent equipment or parameter) are observed.

g. Indications of cracking are evaluated in accordance with applicable codes and 

plant-specific design criteria.
XI.M41-14

8. Confirmation Process: The confirmation process is addressed through those specific 

portions of the QA program that are used to meet Criterion XVI, “Corrective Action,” of 

10 CFR Part 50, Appendix B. Appendix A of the GALL-SLR Report describes how an 

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the confirmation 

process element of this AMP for both safety-related and nonsafety-related SCs within the 

scope of this program.

9. Administrative Controls: Administrative controls are addressed through the QA program 

that is used to meet the requirements of 10 CFR Part 50, Appendix B, associated with 

managing the effects of aging. Appendix A of the GALL-SLR Report describes how an 

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the 

administrative controls element of this AMP for both safety-related and nonsafety-related 

SCs within the scope of this program.

10. Operating Experience: Operating experience shows that buried and underground piping 

and tanks are subject to corrosion. Corrosion of buried oil, gas, and hazardous materials 

pipelines have been adequately managed through a combination of inspections and 

mitigative techniques, such as those prescribed in NACE SP0169-2007 and 

NACE RP0285-2002. Given the differences in piping and tank configurations between 

transmission pipelines and those in nuclear facilities, it is necessary for the applicant to 

evaluate both plant-specific and nuclear industry OE and to modify its AMP accordingly. 

The following examples of industry experience may be of significance to an applicant’s 

program:

a. In August 2009, a leak was discovered in a portion of buried aluminum pipe where 

it passed through a concrete wall. The piping is in the condensate transfer system. 

The failure was caused by vibration of the pipe within its steel support system. 

This vibration led to coating failure and eventual galvanic corrosion between the 

aluminum pipe and the steel supports. [Agencywide Documents Access and 

Management System (ADAMS) Accession No. ML093160004].

b. In June 2009, an active leak was discovered in buried piping associated with the 

condensate storage tank. The leak was discovered because elevated levels of 

tritium were detected. The cause of the through-wall leaks was determined to be 

the degradation of the protective moisture barrier wrap that allowed moisture 

to come in contact with the piping resulting in external corrosion. 

(ADAMS Accession No. ML093160004).

c. In April 2010, while performing inspections as part of its buried pipe program, a 

licensee discovered that major portions of their auxiliary feedwater piping were 

substantially degraded. The licensee’s cause determination attributes the cause of

the corrosion to the failure to properly coat the piping “as specified” during original 

construction. The affected piping was replaced during the next refueling outage. 

(ADAMS Accession No. ML103000405).

d. In November 2013, minor weepage was noted in a 10-inch service water supply 

line to the emergency diesel generators while performing a modification to a main 

transformer moat. Coating degradation was noted at approximately 10 locations 

along the exposed piping. The leaking and unacceptable portions of the degraded 

pipe were clamped and recoated until a permanent replacement could be 

implemented. (ADAMS Accession No. ML13329A422).
XI.M41-15

The program is informed and enhanced when necessary through the systematic and 

ongoing review of both plant-specific and industry OE including research and development 

such that the effectiveness of the AMP is evaluated consistent with the discussion in 

Appendix B of the GALL-SLR Report.

References

10 CFR Part 50, Appendix B, “Quality Assurance Criteria for Nuclear Power Plants and Fuel 

Reprocessing Plants.” Washington, DC: U.S. Nuclear Regulatory Commission. 2016.

ASTM. ASTM D 448-08, “Classification for Sizes of Aggregate for Road and Bridge 

Construction.” West Conshohocken, Pennsylvania: ASTM International. 2008.

AWWA. C105, “Polyethylene Encasement for Ductile-Iron Pipe Systems.” Denver, Colorado: 

American Water Works Association. 2010.

EPRI. EPRI 1021175, “Recommendations for an Effective Program to Control the Degradation of 

Buried and Underground Piping and Tanks,” (1016456 Revision 1). Palo Alto, California: Electric 

Power Research Institute. December 23, 2010.

ISO. ISO 15589-1, “Petroleum and Natural Gas Industries–Cathodic Protection of Pipeline 

Transportation Systems–Part 1: On Land Pipelines.” Vernier, Geneva, Switzerland: International 

Organization for Standardization. November 2003.

NACE. Recommended Practice RP0100-2004, “Standard Recommended Practice, Cathodic 

Protection of Prestressed Concrete Cylinder Pipelines.” Houston, Texas: NACE International. 

2004.

_____. Recommended Practice RP0285-2002, “Corrosion Control of Underground Storage Tank 

Systems by Cathodic Protection.” Houston, Texas: NACE International. April 2002.

_____. Standard Practice SP0169-2007, “Control of External Corrosion on Underground or 

Submerged Metallic Piping Systems.” Houston, Texas: NACE International. 2007.

NFPA. NFPA 24, “Standard for the Installation of Private Fire Service Mains and Their 

Appurtenances.” Quincy, Massachusetts: National Fire Protection Association. 2010.

_____. NFPA 25, “Inspection, Testing, and Maintenance of Water-Based Fire Protection 

Systems, 2011 Edition.” Quincy, Massachusetts: National Fire Protection Association. 2011.

NRC. Regulatory Guide 1.54, “Service Level I, II, and III Protective Coatings Applied to Nuclear 

Power Plants.” Revision 2. Washington, DC: U.S. Nuclear Regulatory Commission. 

October 2010.

XI.M42-1

XI.M42 INTERNAL COATINGS/LININGS FOR IN-SCOPE PIPING, PIPING

COMPONENTS, HEAT EXCHANGERS, AND TANKS 

Program Description

Proper maintenance of internal coatings/linings is essential to provide reasonable assurance that 

the intended functions of in-scope components are met. Degradation of coatings/linings can lead 

to loss of material or cracking of base materials and downstream effects such as reduction in flow, 

reduction in pressure, or reduction of heat transfer when coatings/linings become debris. The 

program consists of periodic visual inspections of internal coatings/linings exposed to closed-cycle 

cooling water (CCCW), raw water, treated water, treated borated water, waste water, fuel oil, and 

lubricating oil. Where the visual inspection of the coated/lined surfaces determines that the 

coating/lining is deficient or degraded, physical tests are performed, where physically possible, in 

conjunction with the visual inspection. Electric Power Research Institute (EPRI) Report 1019157, 

“Guideline on Nuclear Safety-Related Coatings,” provides information on the American Society for 

Testing and Materials (ASTM) standard guidelines and coatings. American Concrete Institute 

(ACI) Standard 201.1R, “Guide for Conducting a Visual Inspection of Concrete in Service,” 

provides guidelines for inspecting concrete. In addition, this program may be used to manage 

aging effects associated with coatings on external surfaces.

Evaluation and Technical Basis

1. Scope of Program: The scope of the program is internal coatings/linings for in-scope 

piping, piping components, heat exchangers, and tanks exposed to CCCW, raw water, 

treated water, treated borated water, waste water, fuel oil, and lubricating oil where loss of 

coating or lining integrity could prevent satisfactory accomplishment of any of the 

component’s or downstream component’s current licensing basis (CLB) intended functions 

identified under Title 10 of the Code of Federal Regulations (10 CFR) 54.4(a)(1), (a)(2), or 

(a)(3). The aging effects associated with fire water tank internal coatings/linings are 

managed by Generic Aging Lessons Learned for Subsequent License Renewal 

(GALL-SLR) Report aging management program (AMP) XI.M27, “Fire Water System,” 

instead of this AMP. However, where the fire water storage tank internals are coated, the 

Fire Water System Program and Final Safety Analysis Report (FSAR) Summary 

Description of the Program should be enhanced to include the recommendations 

associated with training and qualification of personnel and the “corrective actions” program 

element. The Fire Water System Program should also be enhanced to include the 

recommendations from the “acceptance criteria” program element.

If a coating/lining has a qualified life, and it will be replaced prior to the end of its qualified 

life without consideration of extending the life through condition monitoring, it would not be 

considered long lived and therefore, it would not be within the scope of this AMP.

Coatings/linings are an integral part of an in-scope component. The CLB-intended 

function(s) of the component dictates whether the component has an intended function(s) 

that meets the scoping criteria of 10 CFR 54.4(a). Internal coatings/linings for in-scope 

piping, piping components, heat exchangers, and tanks are not evaluated as standalone 

components to determine whether they meet the scoping criteria of 10 CFR 54.4(a). It is 

immaterial whether the coating/lining has an intended function identified in the CLB 

because it is the CLB-intended function of the component that dictates whether the 

component is in-scope and thereby the aging effects of the coating/lining integral to the 
XI.M42-2

component must be evaluated for potential impact on the component’s and downstream 

component’s intended function(s).

An applicant may elect to manage the aging effects for internal coatings/linings for 

in-scope piping, piping components, heat exchangers, and tanks in an alternative AMP 

that is specific to the component or system in which the coatings/linings are installed 

(e.g., GALL-SLR Report AMP XI.M20, “Open-Cycle Cooling Water System,” for service 

water coatings/linings) as long as the following are met:

• The recommendations of this AMP are incorporated into the alternative program.

• Exceptions or enhancements associated with the recommendations in this AMP 

are included in the alternative AMP.

• The FSAR supplement for this AMP as shown in the GALL-SLR Report

Table XI-01, “FSAR Supplement Summaries for GALL-SLR Report Chapter XI 

Aging Management Programs,” is included in the application with a reference to 

the alternative AMP.

For components where the aging effects of internally coated/lined surfaces are managed 

by this program, loss of material, cracking, and loss of material due to selective leaching 

need not be managed for these components by another program.

This program may be used to manage aging effects associated with external surfaces 

[e.g., Standard Review Plan for Review of Subsequent License Renewal Applications for 

Nuclear Power Plants (SRP-SLR) Section 3.2.2.2.2]. When the external coatings are 

credited to isolate the external surface of a component from the environment, the following 

recommendations are met as noted.

2. Preventive Actions: The program is a condition monitoring program and does not 

recommend any preventive actions. However, external coatings can be credited as a 

preventive action based on the coating isolating the external surfaces of a component from 

the environment.

3. Parameters Monitored or Inspected: Visual inspections are intended to identify 

coatings/linings that do not meet acceptance criteria, such as peeling and delamination. 

Aging mechanisms associated with coatings/linings are described as follows:

• Blistering–formation of bubbles in a coating/lining

• Cracking–formation of breaks in a coating/lining that extend through to the 

underlying surface

• Flaking–detachment of pieces of the coating/lining itself either from its substrate or 

from previously applied layers

• Peeling–separation of one or more coats or layers of a coating/lining from 

the substrate

• Delamination–separation of one coat or layer from another coat or layer, or from 

the substrate
XI.M42-3

• Rusting–corrosion of the substrate that occurs beneath or through the applied 

coating/lining

Loss of material and cracking is managed for cementitious materials. See the term 

“Cracking due to chemical reaction, weathering, settlement, or corrosion of reinforcement 

(reinforced concrete only); loss of material due to delamination, exfoliation, spalling, 

popout, scaling, or cavitation,” in the GALL-SLR Report Chapter IX.F.

Physical damage consists of removal or reduction of the thickness of coating/lining by 

mechanical damage. For the purposes of this AMP, this would include damage such as 

that which could occur downstream of a throttled valve as a result of cavitation or erosion. 

It does not include physical damage caused by actions such as installing scaffolding or 

assembly and disassembly of flanged joints.

Physical testing is intended to identify the extent of potential degradation of the 

coating/lining. 

4. Detection of Aging Effects: If a baseline has not been previously established, baseline 

coating/lining inspections occur in the 10-year period prior to the subsequent period of 

extended operation. Subsequent inspections are based on an evaluation of the effect of a 

coating/lining failure on the in-scope component’s intended function, potential problems 

identified during prior inspections, and known service life history. Subsequent inspection 

intervals are established by a coating specialist qualified in accordance with an ASTM 

International standard endorsed in Regulatory Guide (RG) 1.54. However, inspection 

intervals should not exceed those in Table XI.M42-1, “Inspection Intervals for Internal 

Coatings/Linings for Tanks, Piping, Piping Components, and Heat Exchangers.”

The extent of baseline and periodic inspections is based on an evaluation of the effect of a 

coating/lining failure on the in-scope component’s intended function(s), potential problems 

identified during prior inspections, and known service life history; however, the extent of 

inspection is not any less than the following for each coating/lining material and 

environment combination.

• All tanks–all accessible internal surfaces (and external surfaces when credited to 

isolate the external surfaces of a component from the environment).

• All heat exchangers–all accessible internal surfaces (and external surfaces when 

credited to isolate the external surfaces of a component from the environment.)

• Piping–either inspect a representative sample of seventy-three 1-foot axial length 

circumferential segments of piping or 50 percent of the total length of each 

coating/lining material and environment combination, whichever is less at each 

unit. The inspection surface includes the entire inside (or outside when applicable) 

surface of the 1-foot sample. If geometric limitations impede movement of remote 

or robotic inspection tools, the number of inspection segments is increased in order 

to cover an equivalent of seventy-three 1-foot axial length sections. For example, 

if the remote tool can only be maneuvered to view one-third of the inside surface, 

219 feet of pipe is inspected.
XI.M42-4

Table XI.M42-1. Inspection Intervals for Internal Coatings/Linings for Tanks, Piping, Piping 

Components, and Heat Exchangers1, 6

Inspection Category2 Inspection Interval

A 6 years3

B4,5 4 years

1. CLB requirements (e.g., Generic Letter 89-13) might require more frequent inspections.

2. Inspection Categories

A. No peeling, delamination, blisters, or rusting are observed during inspections. Any cracking and flaking has 

been found acceptable in accordance with the “acceptance criteria” program element of this AMP. No 

cracking or loss of material in cementitious coatings/linings.

B. Prior inspection results do not meet Category A. 

• As an alternative to conducting inspections at the intervals in inspection Category B, an extent of 

condition inspection is conducted prior to the end of the next refueling outage. The extent of condition 

inspects either double the number of components or an additional five piping inspections (i.e., five 1-foot 

segments of piping). If Inspection Category A criteria are satisfied for the other coatings in the initial sample 

and the expanded scope, Inspection Category A may be used for subsequent inspections.

3. If the following conditions are met, the inspection interval may be extended to 12 years:

a. The identical coating/lining material was installed with the same installation requirements in redundant 

trains (e.g., piping segments, tanks) with the same operating conditions and at least one of the trains is 

inspected every 6 years.

b. The coating/lining is not in a location subject to erosion that could result in damage to the coating/lining 

(e.g., certain heat exchanger end bells, piping downstream of certain control valves, wind—born erosive 

particles for external coatings).

4. Subsequent inspections for Inspection Category B are reinspections at the original location(s), when the 

coatings/linings have not been repaired, replaced, or removed, as well as inspections of new locations.

5. When conducting inspections for Inspection Category B, if two sequential subsequent inspections demonstrate no 

change in coating/lining condition (i.e., at least three consecutive inspections with no change in condition), 

subsequent inspections at those locations may be conducted to Inspection Category A. 

6. Internal inspection intervals for diesel fuel oil storage tanks may meet either Table XI.M42-1, or if the inspection 

results meet Inspection Category A, GALL-SLR Report AMP XI.M30, “Fuel Oil Chemistry.”

Where documentation exists that manufacturer recommendations and industry 

consensus documents (i.e., those recommended in RG 1.54, or earlier versions of 

those standards) were complied with during installation, the extent of piping 

inspections may be reduced to the lesser of twenty-five 1-foot axial length 

circumferential segments of piping or 20 percent of the total length of each 

coating/lining material and environment combination at each unit.

For multiunit sites where the piping sample size is not based on the percentage of the 

population, it is acceptable to reduce the total number of inspections at the site as follows: 

• For two-unit sites, fifty-five 1-foot axial length sections of piping (19 if manufacturer 

recommendations and industry consensus documents were complied with during 

installation) are inspected per unit.

• For a three-unit site, forty-nine 1-foot axial length sections of piping (17 if 

manufacturer recommendations and industry consensus documents were 

complied with during installation) are inspected per unit. 

In order to conduct the reduced number of inspections, the applicant states in the 

subsequent license renewal application the basis for why the operating conditions 

at each unit are similar enough (e.g., flowrate, temperature, excursions) to provide 

representative inspection results.

The coating/lining environment includes both the environment inside (and outside when 

applicable) the component and the metal to which the coating/lining is attached. 
XI.M42-5

Inspection locations are selected based on susceptibility to degradation and 

consequences of failure.

Coating/lining surfaces captured between interlocking surfaces (e.g., flange faces) are not 

required to be inspected unless the joint has been disassembled to allow access for an 

internal coating/lining inspection or other reasons. For areas not readily accessible for 

direct inspection, such as small pipelines, heat exchangers, and other equipment, 

consideration is given to the use of remote or robotic inspection tools.

Either of the following options [i.e., item (a) or (b)] is an acceptable alternative to the 

inspections recommended in this AMP for internal coatings when all of the following 

conditions exist: 

• Loss of coating or lining integrity cannot result in downstream effects such as 

reduction in flow, drop in pressure, or reduction of heat transfer for in-scope 

components,

• The component’s only CLB intended function is leakage boundary (spatial) or 

structural integrity (attached) as defined in SRP-SLR Table 2.1-4(b), 

• The internal environment does not contain chemical compounds that could cause 

accelerated corrosion of the base material if coating/lining degradation resulted in 

exposure of the base metal,

• The internal environment would not promote microbiologically influenced corrosion 

of the base metal,

• The coated/lined components are not located in the vicinity of uncoated 

components that could cause a galvanic couple to exist, and

• The design for the component did not credit the coating/lining (e.g., the corrosion 

allowance was not zero).

(a) A representative sample of external wall thickness measurements can be 

performed every 10 years commencing 10 years prior to the subsequent 

period of extended operation to confirm the acceptability of the corrosion 

rate of the base metal. For heat exchangers and tanks, a representative 

sample includes 25 percent coverage of the accessible external surfaces. 

For piping, a representative sample size is defined above. 

(b) In lieu of external wall thickness measurements, use GALL-SLR Report 

AMP XI.M36, “External Surfaces Monitoring of Mechanical Components,” 

and GALL-SLR Report AMP XI.M38, “Inspection of Internal Surfaces in 

Miscellaneous Piping and Ducting Components,” or other appropriate 

internal surfaces inspection program (e.g., GALL-SLR Report AMP XI.M20, 

AMP XI M21A) to manage loss of coating or lining integrity.
XI.M42-6

In addition, where loss of internal coating or lining integrity cannot result in downstream 

effects such as reduction in flow, drop in pressure, or reduction of heat transfer for 

in-scope components, a representative sample of external wall thickness measurements 

can be performed every 10 years commencing 10 years prior to the subsequent period of 

extended operation to confirm the acceptability of the corrosion rate of the base metal in 

lieu of visual inspections of the coatings/linings. For heat exchangers and tanks, a 

representative sample includes 25 percent coverage of the accessible external surfaces. 

For piping, a representative sample size is described above.

The training and qualification of individuals involved in coating/lining inspections and 

evaluating degraded conditions is conducted in accordance with an ASTM International 

standard endorsed in RG 1.54 including staff limitations associated with a particular 

standard, except for cementitious materials. For cementitious coatings/linings inspectors 

should have a minimum of 5 years of experience inspecting or testing concrete structures 

or cementitious coatings/linings or a degree in the civil/structural discipline and a minimum 

of 1 year of experience. 

5. Monitoring and Trending: A preinspection review of the previous two inspections, when 

available (i.e., two sets of inspection results may not be available to review for the baseline 

and first subsequent inspection of a particular coating/lining location), is conducted that 

includes reviewing the results of inspections and any subsequent repair activities. A 

coatings specialist prepares the post-inspection report to include: a list and location of all 

areas evidencing deterioration, a prioritization of the repair areas into areas that must be 

repaired before returning the system to service and areas where repair can be postponed 

to the next refueling outage, and where possible, photographic documentation indexed to 

inspection locations.

Where practical, (e.g., wall thickness measurements, blister size and frequency), 

degradation is projected until the next scheduled inspection. Results are evaluated 

against acceptance criteria to confirm that the sampling bases (e.g., selection, size, 

frequency) will maintain the components’ intended functions throughout the subsequent 

period of extended operation based on the projected rate and extent of degradation. 

6. Acceptance Criteria: Acceptance criteria are as follows:

a. There are no indications of peeling or delamination. 

b. Blisters are evaluated by a coatings specialist qualified in accordance with an 

ASTM International standard endorsed in RG 1.54 including staff limitations 

associated with use of a particular standard. Blisters should be limited to a few 

intact small blisters that are completely surrounded by sound coating/lining bonded 

to the substrate. Blister size or frequency should not be increasing between 

inspections (e.g., ASTM D714-02, “Standard Test Method for Evaluating Degree of 

Blistering of Paints”).

c. Indications such as cracking, flaking, and rusting are to be evaluated by a coatings 

specialist qualified in accordance with an ASTM International standard endorsed in 

RG 1.54 including staff limitations associated with use of a particular standard.

d. Minor cracking and spalling of cementitious coatings/linings is acceptable provided 

there is no evidence that the coating/lining is debonding from the base material.
XI.M42-7

e. As applicable, wall thickness measurements, projected to the next inspection, meet 

design minimum wall requirements.

f. Adhesion testing results, when conducted, meet or exceed the degree of adhesion 

recommended in plant-specific design requirements specific to the coating/lining 

and substrate.

7. Corrective Actions: Results that do not meet the acceptance criteria are addressed in 

the applicant’s corrective action program under those specific portions of the quality 

assurance (QA) program that are used to meet Criterion XVI, “Corrective Action,” of 

10 CFR Part 50, Appendix B. Appendix A of the GALL-SLR Report describes how an 

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the corrective 

actions element of this AMP for both safety-related and nonsafety-related structures and 

components (SCs) within the scope of this program.

Coatings/linings that do not meet acceptance criteria are repaired, replaced, or removed. 

Physical testing is performed where physically possible (i.e., sufficient room to conduct 

testing) or examination is conducted to ensure that the extent of repaired or replaced 

coatings/linings encompasses sound coating/lining material.

As an alternative, internal coatings exhibiting indications of peeling and delamination may 

be returned to service if: (a) physical testing is conducted to ensure that the remaining 

coating is tightly bonded to the base metal; (b) the potential for further degradation of the 

coating is minimized, (i.e., any loose coating is removed, the edge of the remaining 

coating is feathered); (c) adhesion testing using ASTM International standards endorsed in 

RG 1.54 (e.g., pull-off testing, knife adhesion testing) is conducted at a minimum of 

3 sample points adjacent to the defective area; (d) an evaluation is conducted of the 

potential impact on the system, including degraded performance of downstream 

components due to flow blockage and loss of material or cracking of the coated 

component; and (e) follow-up visual inspections of the degraded coating are conducted 

within 2 years from detection of the degraded condition, with a reinspection within an 

additional 2 years, or until the degraded coating is repaired or replaced.

If coatings/linings are credited for corrosion prevention (e.g., corrosion allowance in design 

calculations is zero, the “preventive actions” program element of a SLRA AMP credited the 

coating/lining) and the base metal has been exposed or it is beneath a blister, the 

component’s base material in the vicinity of the degraded coating/lining is examined to 

determine if the minimum wall thickness is met and will be met until the next inspection.

When a blister does not meet acceptance criteria, and it is not repaired, physical testing is 

conducted to ensure that the blister is completely surrounded by sound coating/lining 

bonded to the surface. Physical testing consists of adhesion testing using ASTM 

International standards endorsed in RG 1.54. Where adhesion testing is not possible due 

to physical constraints, another means of determining that the remaining coating/lining is 

tightly bonded to the base metal is conducted such as lightly tapping the coating/lining. 

Acceptance of a blister to remain inservice should be based both on the potential effects of 

flow blockage and degradation of the base material beneath the blister.

Additional inspections are conducted if one of the inspections does not meet acceptance 

criteria due to current or projected degradation (i.e., trending) unless the cause of the 

aging effect for each applicable material and environment is corrected by repair or 
XI.M42-8

replacement for all components constructed of the same material and exposed to the 

same environment. The number of increased inspections is determined in accordance 

with the site’s corrective action process; however, there are no fewer than five additional 

inspections for each inspection that did not meet acceptance criteria, or 20 percent of each 

applicable material, environment, and aging effect combination is inspected, whichever is 

less. When inspections are based on the percentage of piping length, an additional 

5 percent of the total length is inspected. The timing of the additional inspections is based 

on the severity of the degradation identified and is commensurate with the potential for 

loss of intended function. However, in all cases, the additional inspections are completed 

within the interval in which the original inspection was conducted, or if identified in the 

latter half of the current inspection interval, within the next refueling outage interval. These 

additional inspections conducted in the next inspection interval cannot also be credited 

towards the number of inspections in the latter interval. If subsequent inspections do not 

meet acceptance criteria, an extent of condition and extent of cause analysis is conducted 

to determine the further extent of inspections. Additional samples are inspected for any 

recurring degradation to provide reasonable assurance that corrective actions 

appropriately address the associated causes. At multi-unit sites, the additional inspections 

include inspections at all of the units with the same material, environment, and aging effect 

combination.

8. Confirmation Process: The confirmation process is addressed through those specific 

portions of the QA program that are used to meet Criterion XVI, “Corrective Action,” of 

10 CFR Part 50, Appendix B. Appendix A of the GALL-SLR Report describes how an 

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the confirmation 

process element of this AMP for both safety-related and nonsafety-related SCs within the 

scope of this program.

9. Administrative Controls: Administrative controls are addressed through the QA program 

that is used to meet the requirements of 10 CFR Part 50, Appendix B, associated with 

managing the effects of aging. Appendix A of the GALL-SLR Report describes how an

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the 

administrative controls element of this AMP for both safety-related and nonsafety-related 

SCs within the scope of this program.

10. Operating Experience: The inspection techniques and training of inspection personnel 

associated with this program are consistent with industry practice and have been 

demonstrated effective at detecting loss of coating or lining integrity. Not to exceed 

inspection intervals have been established that are dependent on the results of previous 

plant-specific inspection results. The following examples describe operating experience 

(OE) pertaining to loss of coating or lining integrity for coatings/linings installed on the 

internal surfaces of piping systems:

a. In 1982, a licensee experienced degradation of internal coatings in its spray pond 

piping system. This issue contains many key aspects related to coating 

degradation. These include installation details such as improper curing time, 

restricted availability of air flow leading to improper curing, installation layers that 

were too thick, and improper surface preparation (e.g., oils on surface, surface too 

smooth). The aging mechanisms included severe blistering, moisture entrapment 

between layers of the coating, delamination, peeling, and widespread rusting. The 

failure to install the coatings to manufacturer recommendations resulted in flow 

restrictions to the ultimate heat sink and blockage of an emergency diesel 
XI.M42-9

generator governor oil cooler. (Information Notice 85-24, “Failures of Protective 

Coatings in Pipes and Heat Exchangers.”)

b. During an U.S. Nuclear Regulatory Commission inspection, the staff found that 

coating degradation, which occurred as a result of weakening of the adhesive bond 

of the coating to the base metal due to turbulent flow, resulted in the coating 

eroding away and leaving the base metal subject to wall thinning and leakage. 

[Agencywide Documents Access and Management System (ADAMS) Accession 

No. ML12045A544].

c. In 1994, a licensee replaced a portion of its cement lined steel service water piping 

with piping lined with polyvinyl chloride material. The manufacturer stated that the 

lining material had an expected life of 15–20 years. An inspection in 1997 showed 

some bubbles and delamination in the coating material at a flange. A 2002 

inspection found some locations that had lack of adhesion to the base metal. In 

2011, diminished flow was observed downstream of this line. Inspections revealed 

that a majority of the lining in one spool piece was loose or missing. The missing 

material had clogged a downstream orifice. A sample of the lining was sent to a 

testing lab where it was determined that cracking was evident on both the base 

metal and water side of the lining and there was a noticeable increase in the 

hardness of the in service sample as compared to an unused sample. (ADAMS 

Accession No. ML12041A054).

d. A licensee has experienced multiple instances of coating degradation resulting in 

coating debris found downstream in heat exchanger end bells. None of the debris 

had been large enough to result in reduced heat exchanger performance. 

(ADAMS Accession No. ML12097A064).

e. A licensee experienced continuing flow reduction over a 14 day period, resulting in 

the service water room cooler being declared inoperable. The flow reduction 

occurred due to the rubber coating on a butterfly valve becoming detached. 

(ADAMS Accession No. ML073200779).

f. At an international plant, cavitation in the piping system damaged the coating of a 

piping system, which subsequently resulted in unanticipated corrosion through the 

pipe wall. (ADAMS Accession No. ML13063A135).

g. A licensee experienced degradation of the protective concrete lining which allowed 

brackish water to contact the unprotected carbon steel piping resulting in localized 

corrosion. The degradation of the concrete lining was likely caused by the high 

flow velocities and turbulence from the valve located just upstream of the degraded 

area. (ADAMS Accession No. ML072890132).

h. A licensee experienced through-wall corrosion when a localized area of coating 

degradation resulted in base metal corrosion. The cause of the coating 

degradation is thought to have been nonage related mechanical damage. 

(ADAMS Accession No. ML14087A210).

i. A licensee experienced through-wall corrosion when a localized polymeric repair of 

a rubber lined spool failed. (ADAMS Accession No. ML14073A059).
XI.M42-10

j. A licensee experienced accelerated galvanic corrosion when loss of coating 

integrity occurred in the vicinity of carbon steel components attached to AL6XN 

components. (ADAMS Accession No. ML12297A333).

The program is informed and enhanced when necessary through the systematic and 

ongoing review of both plant-specific and industry OE including research and development 

such that the effectiveness of the AMP is evaluated consistent with the discussion in 

Appendix B of the GALL-SLR Report.

References

10 CFR Part 50, Appendix B, “Quality Assurance Criteria for Nuclear Power Plants and Fuel 

Reprocessing Plants.” Washington, DC: U.S. Nuclear Regulatory Commission. 2016.

10 CFR 54.4(a), “Scope.” Washington, DC: U.S. Nuclear Regulatory Commission. 2016.

ACI. ACI Standard 201.1R-08, “Guide for Conducting a Visual Inspection of Concrete in Service.” 

Farmington Hills, Michigan: American Concrete Institute. 2008.

_____. ACI Standard 349.3R-02, “Evaluation of Existing Nuclear Safety-Related Concrete 

Structures.” Farmington Hills, Michigan: American Concrete Institute. 2002.

ASTM. ASTM 6677-07, “Standard Test Method for Evaluating Adhesion by Knife.” 

West Conshohocken, Pennsylvania: ASTM International. 2013.

_____. ASTM D714-02, “Standard Test Method for Evaluating Degree of Blistering of Paints.” 

West Conshohocken, Pennsylvania: ASTM International. 2009.

_____. ASTM D4538-05, “Standard Terminology Relating to Protective Coating and Lining Work 

for Power Generation Facilities.” West Conshohocken, Pennsylvania: ASTM International. 2006.

_____. ASTM D4541-09, “Standard Test Method for Pull-Off Strength of Coatings Using Portable 

Adhesion Testers.” West Conshohocken, Pennsylvania: ASTM International. 2011.

_____. ASTM D7167-12, “Standard Guide for Establishing Procedures to Monitor the 

Performance of Safety-Related Coating Service Level III Lining Systems in an Operating Nuclear 

Power Plant.” West Conshohocken, Pennsylvania: ASTM International. 2012.

EPRI. EPRI 1019157, “Guideline on Nuclear Safety-Related Coatings.” Revision 2. 

(Formerly TR-109937 and 1003102). Palo Alto, California: Electric Power Research Institute. 

December 2009.

NRC. Information Notice 85-24, “Failures of Protective Coatings in Pipes and Heat Exchangers.” 

Washington, DC: U.S. Nuclear Regulatory Commission. March 1985.

_____. Regulatory Guide 1.54, “Service Level I, II, and III Protective Coatings Applied to Nuclear 

Power Plants.” Revision 2. Washington, DC: U.S. Nuclear Regulatory Commission. 

October 2010.
XI.S1-1

XI.S1 ASME SECTION XI, SUBSECTION IWE

Program Description 

Title 10 of the Code of Federal Regulations (10 CFR) 50.55a imposes the inservice inspection 

(ISI) requirements of the American Society of Mechanical Engineers Boiler and Pressure Vessel 

Code (ASME Code)1

, Section XI, Subsection IWE, for steel containments (Class MC) and steel 

liners for concrete containments (Class CC). The scope of Subsection IWE includes steel 

containment shells and their integral attachments, steel liners for concrete containments and their 

integral attachments, containment penetrations, hatches, airlocks, moisture barriers, and 

pressure-retaining bolting. The requirements of ASME Code, Section XI, Subsection IWE, with 

the additional requirements specified in 10 CFR 50.55a(b)(2), are supplemented herein to 

augment an existing program applicable to managing aging of steel containments, steel liners of 

concrete containments, and other containment components for the subsequent period of 

extended operation.

The primary ISI method specified in IWE is visual examination (general visual, VT-3, VT-1). 

Limited volumetric examination (ultrasonic thickness measurement) and surface examination 

(e.g., liquid penetrant) may also be necessary in some instances to detect aging effects. IWE 

specifies acceptance criteria, corrective actions, and expansion of the inspection scope when 

degradation exceeding the acceptance criteria are found. 

Subsection IWE requires examination of coatings that are intended to prevent corrosion. Aging 

management program (AMP) XI.S8 is a protective coating monitoring and maintenance program 

that is recommended to provide reasonable assurance of emergency core cooling system (ECCS) 

operability, whether or not the Generic Aging Lessons Learned for Subsequent License Renewal 

(GALL-SLR) Report AMP XI.S8 is credited in the GALL-SLR Report AMP XI.S1.

The program attributes are supplemented to incorporate aging management activities, 

recommended in the Final License Renewal Interim Staff Guidance (LR-ISG)-2006-01, needed to 

address the potential loss of material due to corrosion in the inaccessible areas of the boiling 

water reactor (BWR) Mark I steel containment. 

The program attributes are supplemented to consider the operating experience (OE) of two-ply 

bellows for detection of cracking described in the U.S. Nuclear Regulatory Commission (NRC) 

Information Notice (IN) 92-20, “Inadequate Local Leak Rate Testing,” and to also include 

preventive actions to provide reasonable assurance that bolting integrity is maintained. The 

program is also supplemented to perform surface examination’ of pressure-retaining components 

that are subject to cyclic loading but have no current licensing basis (CLB) fatigue analysis; and, 

based on plant-specific OE, a one-time volumetric examination of metal shell or liner surfaces that 

are inaccessible from one side.

 

1GALL-SLR Report Chapter I, Table 1, identifies the ASME Code Section XI editions and addenda that are 

acceptable to use for this AMP.
XI.S1-2

Evaluation and Technical Basis

1. Scope of Program: The scope of this program addresses the pressure-retaining 

components of steel containments and steel liners of concrete containments specified in 

Subsection IWE-1000 and are supplemented to address aging management of potential 

corrosion in inaccessible areas of the drywell shell exterior of BWR Mark I steel 

containments. The components within the scope of Subsection IWE are Class Metal 

Containment (MC) pressure-retaining components (steel containments) and their integral 

attachments, metallic shell and penetration liners of Class CC containments and their 

integral attachments, containment moisture barriers, containment pressure-retaining 

bolting, and metal containment surface areas, including welds and base metal. The 

concrete portions of containments are inspected in accordance with Subsection IWL. 

Subsection IWE requires examination of coatings that are intended to prevent corrosion, 

including those inside BWR suppression chambers. The GALL-SLR Report AMP XI.S8 is 

a protective coating monitoring and maintenance program that is recommended to provide 

reasonable assurance of ECCS operability, whether or not the GALL-SLR Report 

AMP XI.S8 is credited in GALL-SLR Report AMP XI.S1. 

Subsection IWE exempts the following from examination:

(a) Components that are outside the boundaries of the containment, as 

defined in the plant-specific design specification;

(b) Embedded or inaccessible portions of containment components that met 

the requirements of the original construction code of record;

(c) Components that become embedded or inaccessible as a result of 

containment structure [i.e., steel containments (Class MC) and steel liners 

of concrete containments (Class CC)] repair or replacement, provided the 

requirements of IWE-1232 and IWE-5220 are met; and

(d) Piping, pumps, and valves that are part of the containment system or that 

penetrate or are attached to the containment vessel (governed by IWB 

or IWC).

10 CFR 50.55a(b)(2)(ix) and IWE-2420 (2006 and later editions/addenda) specify 

additional requirements for inaccessible areas. It states that the licensee is to evaluate the 

acceptability of inaccessible areas when conditions exist in accessible areas that could 

indicate the presence of or result in degradation to such inaccessible areas. Examination 

requirements for containment supports are not within the scope of Subsection IWE.

2. Preventive Action: This is a condition monitoring program. The program is 

supplemented to include preventive actions that provide reasonable assurance that 

moisture levels associated with an accelerated corrosion rate do not exist in the exterior 

portion of the BWR Mark I steel containment drywell shell. The actions consist of ensuring 

that the sand pocket area drains and/or the refueling seal drains are clear. The program is 

also supplemented to include preventive actions to provide reasonable assurance that

bolting integrity is maintained, as discussed in Electric Power Research Institute (EPRI) 

documents (such as EPRI NP-5067 and TR-104213), American Society for Testing and

Materials (ASTM) standards, and American Institute of Steel Construction specifications, 

as applicable. The preventive actions should emphasize proper selection of bolting 
XI.S1-3

material and lubricants, and appropriate installation torque or tension to prevent or 

minimize loss of bolting preload and cracking of high-strength bolting. If the structural 

bolting consists of ASTM A325 and/or ASTM A490 bolts (including respective equivalent 

twist-off type ASTM F1852 and/or ASTM F2280 bolts), the preventive actions for storage, 

lubricant selection, and bolting and coating material selection discussed in Section 2 of 

Research Council for Structural Connections publication “Specification for Structural Joints 

Using High-Strength Bolts,” need to be considered.

3. Parameters Monitored or Inspected: Table IWE-2500-1 references the applicable 

sections in IWE-2300 and IWE-3500 that identify the parameters examined or monitored. 

Noncoated surfaces are examined for evidence of cracking, discoloration, wear, pitting, 

excessive corrosion, arc strikes, gouges, surface discontinuities, dents, and other signs of 

surface irregularities including discernible liner plate bulges. Painted or coated surfaces, 

including those inside BWR suppression chambers, are examined for evidence of flaking, 

blistering, peeling, discoloration, and other signs of potential distress of the underlying 

metal shell or liner system, including discernible liner plate bulges. Steel, stainless steel

(SS), and dissimilar metal weld pressure-retaining components that are subject to cyclic 

loading but have no CLB fatigue analysis (i.e., components covered by Standard Review 

Plan for Review of Subsequent License Renewal Applications for Nuclear Power Plants

(SRP-SLR) Table 3.5-1, items 27 and 40, and corresponding GALL-SLR items; as 

applicable), are monitored for cracking. The moisture barriers are examined for wear, 

damage, erosion, tear, surface cracks, or other defects that permit intrusion of moisture in 

the inaccessible areas of the pressure retaining surfaces of the metal containment shell or 

liner. Pressure-retaining bolting is examined for loosening and material conditions that 

cause the bolted connection to affect either containment leak-tightness or structural 

integrity.

Subsequent license renewal applicants with BWR Mark I steel containments should 

periodically monitor the sand pocket area drains and/or the refueling seal drains for water 

leakage. The applicants should also ensure the drains are clear to prevent moisture levels 

associated with accelerated corrosion rates in the exterior portion of the drywell shell.

4. Detection of Aging Effects: The examination methods, frequency, and scope of 

examination specified in 10 CFR 50.55a and Subsection IWE provide reasonable 

assurance that aging effects are detected before they compromise the design-basis 

requirements. IWE-2500-1 and the requirements of 10 CFR 50.55a provide information 

regarding the examination categories, parts examined, and examination methods to be 

used to detect aging.

Regarding the extent of examination, all accessible surfaces receive at least a general 

visual examination as specified in Table IWE-2500-1 and the requirements of 

10 CFR 50.55a with results evaluated in accordance with IWE-3100. The acceptability of 

inaccessible areas of the steel containment shell or concrete containment steel liner is 

evaluated when conditions are found in accessible areas that could indicate the presence 

of, or could result in, flaws or degradation in such inaccessible areas. IWE-1240 requires 

augmented examinations (Examination Category E-C) of containment surface areas 

subject to accelerated degradation and aging. A VT-1 visual examination is performed for 

areas accessible from both sides, and volumetric (ultrasonic thickness measurement) 

examination is performed for areas accessible from only one side.
XI.S1-4

The requirements of ASME Code Section XI, Subsection IWE and 10 CFR 50.55a are 

supplemented to perform surface examination (or other applicable technique) in addition 

to visual examinations, to detect cracking in steel, SS, and dissimilar metal weld 

pressure-retaining components that are subject to cyclic loading but have no CLB fatigue 

analysis (i.e., components covered by SRP-SLR Table 3.5-1, items 27 and 40, and 

corresponding GALL-SLR items; as applicable to the plant). Where feasible, appropriate 

Appendix J leak rate tests (GALL-SLR Report AMP XI.S4) capable of detection of cracking 

may be performed or credited in lieu of the supplemental surface examination; the type of 

leak test determined to be appropriate is identified with the basis for components for which 

this option is used. 

The requirements of ASME Code Section XI, Subsection IWE and 10 CFR 50.55a are 

further supplemented to require a one-time volumetric examination of metal shell or liner 

surfaces that are inaccessible from one side, only if triggered by plant-specific OE. The 

trigger for this supplemental examination is plant-specific occurrence or recurrence of 

measurable metal shell or liner corrosion (base metal material loss exceeding 10 percent 

of nominal plate thickness) initiated on the inaccessible side or areas, identified since the 

date of issuance of the first renewed license. This supplemental volumetric examination 

consists of a sample of one-foot square locations that include both randomly-selected and 

focused areas most likely to experience degradation based on OE and/or other relevant 

considerations such as environment. Any identified degradation is addressed in 

accordance with the applicable provisions of the AMP. The sample size, locations, and 

any needed scope expansion (based on findings) for this one-time set of volumetric 

examinations should be determined on a plant-specific basis to demonstrate statistically 

with 95 percent confidence that 95 percent of the accessible portion of the containment 

liner is not experiencing corrosion degradation with greater than 10 percent loss of 

nominal thickness. Guidance provided in EPRI TR–107514 may be used for sampling 

considerations.

5. Monitoring and Trending: With the exception of inaccessible areas, all surfaces are 

monitored by virtue of the examination requirements on a scheduled basis. 

IWE-2420 specifies that: 

(a) The sequence of component examinations established during the first 

inspection interval shall be repeated during successive intervals, to the 

extent practical.

(b) When examination results require evaluation of flaws or areas of 

degradation in accordance with IWE-3000, and the component is 

acceptable for continued service, the areas containing such flaws or areas 

of degradation shall be reexamined during the next inspection period listed 

in the schedule of the inspection program of IWE-2411 or IWE-2412, in 

accordance with Table IWE-2500-1, Examination Category E-C.

(c) When the reexaminations required by IWE-2420(b) reveal that the flaws or 

areas of degradation remain essentially unchanged for the next inspection 

period, these areas no longer require augmented examination in 

accordance with Table IWE-2500-1 and the regular inspection schedule 

is continued. 
XI.S1-5

IWE-3120 requires examination results to be compared with recorded results of prior 

inservice examinations and evaluated for acceptance.

Applicants for subsequent license renewal (SLR) for plants with BWR Mark I containment 

should augment IWE monitoring and trending requirements to address inaccessible areas 

of the drywell. The applicant should consider the following recommended actions based 

on plant-specific design and OE.

(a) Develop a corrosion rate that can be inferred from past ultrasonic testing 

(UT) examinations or establish a corrosion rate using representative 

samples in similar operating conditions, materials, and environments. If 

degradation has occurred, provide a technical basis using the developed or 

established corrosion rate to demonstrate that the drywell shell will have 

sufficient wall thickness to perform its intended function through the 

subsequent period of extended operation.

(b) Demonstrate that UT measurements performed in response to NRC 

Generic Letter (GL) 87-05, “Request for Additional Information Assessment 

of Licensee Measures to Mitigate and/or Identify Potential Degradation of 

Mark I Drywells” did not show degradation inconsistent with the developed 

or established corrosion rate.

6. Acceptance Criteria: IWE-3000 provides acceptance standards for components of steel 

containments and liners of concrete containments. IWE-3410 refers to criteria to evaluate 

the acceptability of the containment components for service following the preservice 

examination and each inservice examination. Most of the acceptance standards rely on 

visual examinations. Areas identified with damage or degradation that exceed acceptance 

standards require an engineering evaluation or require correction by repair or 

replacement. For some examinations, such as augmented examinations, numerical 

values are specified for the acceptance standards. For the containment steel shell or liner, 

material loss locally exceeding 10 percent of the nominal containment wall thickness or 

material loss that is projected to locally exceed 10 percent of the nominal containment wall 

thickness before the next examination are documented. Such areas are corrected by 

repair or replacement in accordance with IWE-3122 or accepted by engineering 

evaluation. Cracking of steel, SS, and dissimilar metal weld pressure-retaining

components that are subject to cyclic loading but have no CLB fatigue analysis

(i.e., components covered by SRP-SLR Table 3.5-1, items 27 & 40, and corresponding 

GALL-SLR items; as applicable) is corrected by repair or replacement or accepted by 

engineering evaluation.

7. Corrective Actions: Results that do not meet the acceptance criteria are addressed in 

the applicant’s corrective action program under those specific portions of the quality 

assurance (QA) program that are used to meet Criterion XVI, “Corrective Action,” of 

10 CFR Part 50, Appendix B. Appendix A of the GALL-SLR Report describes how an 

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the corrective 

actions element of this AMP for both safety-related and nonsafety-related structures and 

components (SCs) within the scope of this program.

Subsection IWE states that components whose examination results indicate flaws or areas 

of degradation that do not meet the acceptance standards listed in IWE-3500 are 

acceptable if an engineering evaluation indicates that the flaw or area of degradation is 
XI.S1-6

nonstructural in nature or has no effect on the structural integrity of the containment. 

Components that do not meet the acceptance standards are subject to additional 

examination requirements, and the components are repaired or replaced to the extent 

necessary to meet the acceptance standards of IWE-3000. For repair of components 

within the scope of Subsection IWE, IWE-3124 states that repairs and re-examinations are 

to comply with IWA-4000. IWA-4000 provides repair specifications for pressure retaining 

components, including metal containments and metallic liners of concrete containments.

For BWR Mark I steel containments, if moisture has been detected or suspected in the 

inaccessible area on the exterior of the containment drywell shell or the source of moisture 

cannot be determined subsequent to root cause analysis, then:

(a) Include in the scope of SLR any components that are identified as a source 

of moisture, if applicable, such as the refueling seal or cracks in the SS 

liners of the refueling cavity pool walls, and perform an aging management 

review.

(b) Pursuant to Subsection IWE-1240, identify in the inspection program 

affected drywell surfaces requiring augmented examination for the 

subsequent period of extended operation in accordance with 

Table IWE-2500-1, Examination Category E-C.

(c) Conduct augmented inspections of the identified drywell surfaces using 

examination methods that are in accordance with Subsection IWE-2500.

(d) Demonstrate, through use of augmented inspections performed in 

accordance with Subsection IWE, that corrosion is not occurring or that 

corrosion is progressing so slowly that the age-related degradation will not 

jeopardize the intended function of the drywell shell through the 

subsequent period of extended operation.

8. Confirmation Process: The confirmation process is addressed through those specific 

portions of the QA program that are used to meet Criterion XVI, “Corrective Action,” of 

10 CFR Part 50, Appendix B. Appendix A of the GALL-SLR Report describes how an 

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the confirmation 

process element of this AMP for both safety-related and nonsafety-related SCs within the 

scope of this program.

When areas of degradation are identified, an evaluation is performed to determine whether 

repair or replacement is necessary. If the evaluation determines that repair or 

replacement is necessary, Subsection IWE specifies confirmation that appropriate 

corrective actions have been completed and are effective. Subsection IWE states that 

repairs and re-examinations are to comply with the requirements of IWA-4000. 

Re-examinations are conducted in accordance with the requirements of IWA-2200, and 

the recorded results are to demonstrate that the repair meets the acceptance standards 

set forth in IWE-3500.

9. Administrative Controls: Administrative controls are addressed through the QA program 

that is used to meet the requirements of 10 CFR Part 50, Appendix B, associated with 

managing the effects of aging. Appendix A of the GALL-SLR Report describes how an 

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the 
XI.S1-7

administrative controls element of this AMP for both safety-related and nonsafety-related 

SCs within the scope of this program.

IWA-6000 provides specifications for the preparation, submittal, and retention of records 

and reports.

10. Operating Experience: ASME Code Section XI, Subsection IWE, was incorporated into 

10 CFR 50.55a in 1996. Prior to this time, OE pertaining to degradation of steel 

components of containment was gained through the inspections required by 

10 CFR Part 50, Appendix J and adhoc inspections conducted by licensees and the NRC. 

NRC IN 86-99, IN 88-82, IN 89-79, IN 2004-09, IN 2010-12, NUREG–1522, and

NUREG/CR-7111 described occurrences of corrosion in steel containment shells,

containment liners, and tori. NRC GL 87-05 addressed the potential for corrosion of BWR 

Mark I steel drywells in the “sand pocket region.” IN 2011-15 described occurrences of 

corrosion in BWR Mark I steel containments, both inside the suppression chamber (torus) 

and outside the drywell. IN 2014-07 described OE concerning degradation of floor weld 

leak-chase channel systems of the steel containment shell and concrete containment steel 

liner that could affect leak tightness and aging management of containment structures.

NRC IN 97-10 identified specific locations where concrete containments are susceptible to 

liner plate corrosion; IN 92-20 described instances of two-ply containment bellows 

cracking for which leak rate testing was inadequate for detection, resulting in loss of 

leak tightness. Based on occurrences of transgranular stress corrosion cracking, 

NUREG–1611 (Tables 1 and 2) recommends augmented examination on the surfaces of 

two-ply bellow bodies using qualified enhanced techniques so that cracking can be 

detected. Other OE indicates that foreign objects embedded in concrete have caused 

through-wall corrosion of the liner plate at a few plants with reinforced concrete 

containments. NRC Technical Report, “Containment Liner Corrosion Operating 

Experience Summary” dated August 2, 2011, summarizes the industry OE related to 

containment liner corrosion and containment liner bulges. Some examples of OE related 

to liner bulges are noted in NUREG–1522 and Enclosure 2 to NRC Inspection Progress 

Report 05000302/2011009 dated May 12, 2011.

NRC IN 2006-01 described through-wall cracking and its probable cause in the torus 

of a BWR Mark I containment. The cracking was identified by the licensee in the 

heat-affected zone at the high-pressure coolant injection (HPCI) turbine exhaust pipe torus 

penetration. The licensee concluded that the cracking was most likely initiated by cyclic 

loading due to condensation oscillation during HPCI operation. These condensation 

oscillations induced on the torus shell may have been excessive due to a lack of an HPCI 

turbine exhaust pipe sparger that many licensees have installed. 

The program is to consider the liner plate and containment shell corrosion and cracking 

concerns described in these generic communications and technical report. 

Implementation of the ISI requirements of Subsection IWE, in accordance with 

10 CFR 50.55a, augmented to consider OE, and as recommended in LR-ISG-2006-01, is 

a necessary element of aging management for steel components of steel and concrete 

containments through the subsequent period of extended operation.

Degradation of threaded bolting and fasteners in closures for the reactor coolant pressure 

boundary has occurred from boric acid corrosion, stress corrosion cracking (SCC), and 

fatigue loading [NRC Inspection and Evaluation Bulletin (IEB) 82-02, NRC GL 91-17]. 
XI.S1-8

SCC has occurred in high strength bolts used for nuclear steam supply system component 

supports (EPRI NP-5769).

The program is informed and enhanced when necessary through the systematic and 

ongoing review of both plant-specific and industry OE including research and development 

such that the effectiveness of the AMP is evaluated consistent with the discussion in 

Appendix B of the GALL-SLR Report.

References

10 CFR Part 50, Appendix B, “Quality Assurance Criteria for Nuclear Power Plants and Fuel 

Reprocessing Plants.” Washington, DC: U.S. Nuclear Regulatory Commission. 2016.

10 CFR Part 50, Appendix J, “Primary Reactor Containment Leakage Testing for Water-Cooled 

Power Reactors.” Washington, DC: U.S. Nuclear Regulatory Commission. 2016.

10 CFR 50.55a, “Codes and Standards.” Washington, DC: U.S. Nuclear Regulatory 

Commission. 2016.

ASME. ASME Code Section XI, “Rules for Inservice Inspection of Nuclear Power Plant 

Components, Subsection IWA, General Requirements.” New York, New York: The American 

Society of Mechanical Engineers. 2008.

2

_____. ASME Code Section XI, “Rules for Inservice Inspection of Nuclear Power Plant 

Components, Subsection IWE, Requirements for Class MC and Metallic Liners of Class CC 

Components of Light-Water Cooled Power Plants.” New York, New York: The American Society 

of Mechanical Engineers. 2008. 

_____. ASME Code Section XI, “Rules for Inservice Inspection of Nuclear Power Plant 

Components, Subsection IWL, Requirements for Class CC Concrete Components of Light-Water 

Cooled Power Plants.” New York, New York: The American Society of Mechanical Engineers. 

2008. 

EPRI. EPRI NP-5067, “Good Bolting Practices, A Reference Manual for Nuclear Power Plant 

Maintenance Personnel.” Volume 1: Large Bolt Manual, 1987; Volume 2: Small Bolts and 

Threaded Fasteners. Palo Alto, California: Electric Power Research Institute. 1990.

_____. EPRI NP-5769, “Degradation and Failure of Bolting in Nuclear Power Plants.” Volumes 1 

and 2. Palo Alto, California: Electric Power Research Institute. April 1988.

_____. EPRI TR–104213, “Bolted Joint Maintenance & Application Guide.” Palo Alto, California:

Electric Power Research Institute. December 1995.

_____. EPRI TR–107514, “Age-Related Degradation Inspection Method and Demonstration.” In 

Behalf of Calvert Cliffs Nuclear Power Plant License Renewal Application. Palo Alto, California: 

Electric Power Research Institute. April 1998.

 

2GALL-SLR Report Chapter I, Table 1, identifies the ASME Code Section XI editions and addenda that are 

acceptable to use for this AMP.
XI.S1-9

NRC. Generic Letter 87-05, “Request for Additional Information Assessment of Licensee 

Measures to Mitigate and/or Identify Potential Degradation of Mark I Drywells.” Agencywide 

Documents Access and Management System (ADAMS) Accession No. ML031140335.

Washington, DC: U.S. Nuclear Regulatory Commission. March 1987.

_____. Generic Letter 91-17, “Generic Safety Issue 79, Bolting Degradation or Failure in Nuclear 

Power Plants.” ADAMS Accession No. ML0311140534. Washington, DC: U.S. Nuclear 

Regulatory Commission. October 1991.

_____. IE Bulletin 82-02, “Degradation of Threaded Fasteners in the Reactor Coolant Pressure 

Boundary of PWR Plants.” ADAMS Accession No. ML03120720. Washington, DC: U.S. Nuclear 

Regulatory Commission. June 1982.

_____. Information Notice 86-99, “Degradation of Steel Containments.” ADAMS Accession Nos.

ML031250248, ML 031250234. Washington, DC: U.S. Nuclear Regulatory Commission, 

December 8, 1986. Supplement 1 February 1991.

_____. Information Notice 88-82, “Torus Shells with Corrosion and Degraded Coatings in BWR 

Containments.” ADAMS Accession Nos. ML031150069, ML082910476. Washington, DC: 

U.S. Nuclear Regulatory Commission. October 1988. Supplement 1 May 1989.

_____. Information Notice 89-79, “Degraded Coatings and Corrosion of Steel Containment 

Vessels.” ADAMS Accession No. ML031190089. Washington, DC: U.S. Nuclear Regulatory 

Commission. December 1989. Supplement 1 June 1989.

_____. Information Notice 92-20, “Inadequate Local Leak Rate Testing.” Washington, DC: 

U.S. Nuclear Regulatory Commission. March 1992.

_____. Information Notice 97-10, “Liner Plate Corrosion in Concrete Containment.” ADAMS 

Accession No. ML031050365. Washington, DC: U.S. Nuclear Regulatory Commission. 

March 1997.

_____. Information Notice 2004-09, “Corrosion of Steel Containment and Containment Liner.” 

ADAMS Accession No. ML041170030. Washington DC: U.S. Nuclear Regulatory Commission. 

April 2004. 

_____. Information Notice 2006-01, “Torus Cracking in a BWR Mark I Containment.” ADAMS 

Accession No. ML053060311. Washington, DC: U.S. Nuclear Regulatory Commission. 

January 2006. 

_____. Information Notice 2010-12, “Containment Liner Corrosion.” Washington, DC: 

U.S. Nuclear Regulatory Commission. June 2010.

_____. Information Notice 2011-15, “Steel Containment Degradation and Associated License 

Renewal Aging Management Issues.” ADAMS Accession No. ML111460369. Washington, DC: 

U.S. Nuclear Regulatory Commission. August 2011.

_____. Information Notice 2014-07, “Degradation of leak-Chase Channel Systems for Floor 

Welds of Metal Containment Shell and Concrete Containment Metallic Liner.” ADAMS Accession 

No. ML14070A114. Washington, DC: U.S. Nuclear Regulatory Commission. May 2014.
XI.S1-10

_____. Inspection Report 05000302/2011009, Crystal River Nuclear Plant – Steam Generator 

Replacement Inspection Progress Report. ADAMS Accession No. ML111330350. 

Washington, DC: U.S. Nuclear Regulatory Commission. May 12, 2011.

_____. NUREG–1522, “Assessment of Inservice Conditions of Safety-Related Nuclear Plant 

Structures.” ADAMS Accession No. ML06510407. Washington, DC: U.S. Nuclear Regulatory 

Commission. June 1995.

_____. NUREG–1611, “Aging Management of Nuclear Power Plant Containments for License 

Renewal.” ADAMS Accession No. ML071650341. Washington, DC: U.S. Nuclear Regulatory 

Commission. September 1997.

_____. NUREG/CR–7111, “A Summary of Aging Effects and Their Management in Reactor 

Spent Fuel Pools, Refueling Cavities, Tori, and Safety-Related Concrete Structures.” ADAMS 

Accession No. ML12047A184. Washington, DC: U.S. Nuclear Regulatory Commission. 

January 2012.

_____. Staff Position and Rationale for the Final License Renewal Interim Staff Guidance 

LR-ISG-2006-01, “Plant-Specific Aging Management Program for Inaccessible Areas of 

Boiling Water Reactor (BWR) Mark I Steel Containments Drywell Shell.” ADAMS Accession 

No. ML063210074. Washington, DC: U.S. Nuclear Regulatory Commission. November 2006.

_____. Technical Report, “Containment Liner Corrosion Operating Experience Summary.” 

ADAMS Accession No. ML112070867. Revision 1. Washington, DC: U.S. Nuclear Regulatory 

Commission. August 2011.

RCSC. “Specification for Structural Joints Using High-Strength Bolts.” Chicago, Illinois: 

Research Council on Structural Connections. August 2014. 
XI.S2-1

XI.S2 ASME SECTION XI, SUBSECTION IWL

Program Description

Title 10 of the Code of Federal Regulations (10 CFR) 50.55a imposes the examination 

requirements of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code 

(ASME Code), Section XI, Subsection IWL, 1 for reinforced and prestressed concrete 

containments (Class CC). The scope of IWL includes reinforced concrete and unbonded 

post-tensioning systems. ASME Code, Section XI, Subsection IWL and the additional 

requirements specified in 10 CFR 50.55a(b)(2) constitute an existing mandated program 

applicable to managing aging of containment reinforced concrete and unbonded post-tensioning 

systems, and supplemented herein, for subsequent license renewal. Containments with grouted 

tendons may require an additional plant-specific aging management program (AMP), based on 

the guidance in U.S. Nuclear Regulatory Commission (NRC) Regulatory Guide (RG) 1.90, 

“Inservice Inspection of Prestressed Concrete Containment Structures with Grouted Tendons,” to 

address the adequacy of prestressing forces.

The primary inspection method specified in IWL-2500 is visual examination, supplemented by 

testing. For prestressed containments, tendon wires are tested for yield strength, ultimate tensile 

strength, and elongation. Tendon corrosion protection medium is analyzed for alkalinity, water 

content, and soluble ion concentrations. The quantity of free water contained in the anchorage 

end cap and any free water that drains from tendons during the examination is documented. 

Samples of free water are analyzed for pH. Prestressing forces are measured in selected sample 

tendons. IWL specifies acceptance criteria, corrective actions, and expansion of the inspection 

scope when degradation exceeding the acceptance criteria are found. 

The Code specifies augmented examination requirements following post-tensioning system 

repair/replacement activities.

Evaluation and Technical Basis

1. Scope of Program: Subsection IWL-1000 specifies the components of concrete 

containments within its scope. The components within the scope of Subsection IWL are 

reinforced concrete and unbonded post-tensioning systems of Class CC containments, as 

defined by CC-1000. The program also includes testing of the tendon corrosion protection 

medium and the pH of free water. Subsection IWL exempts from examination portions of 

the concrete containment that are inaccessible (e.g., concrete covered by liner, foundation 

material, or backfill or obstructed by adjacent structures or other components).

10 CFR 50.55a(b)(2)(viii) and the 2009 and later editions/addenda of the ASME Code 

specify additional requirements for inaccessible areas. The Code states that the licensee 

is to evaluate the acceptability of concrete in inaccessible areas when conditions exist in 

accessible areas that could indicate the presence of or result in degradation to such 

inaccessible areas. Steel liners for concrete containments and their integral attachments 

are not within the scope of Subsection IWL but are included within the scope of 

Subsection IWE. Subsection IWE is evaluated in Generic Aging Lessons Learned for 

 

1GALL-SLR Report Chapter I, Table 1, identifies the ASME Code Section XI editions and addenda that are 

acceptable to use for this AMP.
XI.S2-2

Subsequent License Renewal (GALL-SLR) Report AMP XI.S1, “ASME Section XI, 

Subsection IWE.”

2. Preventive Action: ASME Code Section XI, Subsection IWL is a condition monitoring 

program. However, the program includes actions to prevent or minimize corrosion of the 

prestressing tendons by maintaining corrosion protection medium chemistry within 

acceptable limits specified in Subsection IWL.

3. Parameters Monitored or Inspected: Table IWL-2500-1 specifies two categories for 

examination of concrete surfaces: (i) Category L-A for all accessible concrete surfaces 

and (ii) Category L-B for concrete surfaces surrounding anchorages of tendons selected 

for testing in accordance with IWL-2521. Both of these categories rely on visual 

examination methods. Concrete surfaces are examined for evidence of damage or 

degradation, such as concrete cracks. IWL-2510 specifies that concrete surfaces are 

examined for conditions indicative of degradation, such as those defined in American 

Concrete Institute (ACI) 201.1R and ACI 349.3R. Table IWL-2500-1 also specifies 

Category L-B for test and examination requirements for unbonded post tensioning 

systems. The number of tendons selected for examination is in accordance with 

Table IWL-2521-1. Additional augmented examination requirements for post-tensioning 

system repair/replacement activities are to be in accordance with Table IWL-2521-2. 

Tendon anchorage and wires or strands are visually examined for cracks, corrosion, and 

mechanical damage. Tendon wires or strands are also tested for yield strength, ultimate 

tensile strength, and elongation. The tendon corrosion protection medium is tested by 

analysis for alkalinity, water content, and soluble ion concentrations. The pH of free water 

samples is analyzed.

4. Detection of Aging Effects: The frequency and scope of examinations specified in 

10 CFR 50.55a and Subsection IWL provide reasonable assurance that aging effects 

would be detected before they would compromise the design-basis requirements. The 

frequency of inspection is specified in IWL-2400. Concrete inspections are performed in 

accordance with Examination Category L-A. Under Subsection IWL, inservice inspection 

(ISI) of concrete and unbonded post-tensioning systems is required at 1, 3, and 5 years 

following the initial structural integrity test. Thereafter, inspections are performed at 5-year 

intervals. For sites with multiple plants, the schedule for ISI is provided in IWL-2421. In 

the case of tendons, only a sample of the tendons of each tendon type requires 

examination during each inspection. 

The tendons to be examined during an inspection are selected on a random basis. 

Regarding detection methods for aging effects, all accessible concrete surfaces receive 

General Visual examination (as defined by the ASME Code). Selected areas, such as 

those that indicate suspect conditions and concrete surface areas surrounding tendon 

anchorages (Category L-B), receive a more rigorous Detailed Visual examination (as 

defined by the ASME Code). Prestressing forces in sample tendons are measured. In 

addition, one sample tendon of each type is detensioned. A single wire or strand is 

removed from each detensioned tendon for examination and testing. These visual 

examination methods and testing would identify the aging effects of accessible concrete 

components and prestressing systems in concrete containments. Examination of 

corrosion protection medium and free water is tested for each examined tendon as 

specified in Table IWL-2525-1.
XI.S2-3

5. Monitoring and Trending: Except in inaccessible areas, all concrete surfaces are 

monitored on a regular basis by virtue of the examination requirements. Inspection results 

are documented and compared to previous results to identify changes from prior 

inspections. Quantitative measurements and qualitative information are recorded and 

trended for findings exceeding the acceptance criteria described in Element 6 for all 

applicable parameters monitored or inspected. The use of photographs or surveys is 

recommended. Photography and its variations may be used to trend aging effects such as 

cracking, spalling, delamination, pop-outs, or other age-related concrete degradation as 

illustrated in ACI 201.1R. Photographic records may be used to document and trend the 

type, severity, extent and progression of degradation. 

For prestressed containments, trending of prestressing forces in tendons is required in 

accordance with the acceptance by examination criteria in IWL-3220. In addition to the 

random sampling used for tendon examination, one tendon of each type is selected from 

the first-year inspection sample and designated as a common tendon. Each common 

tendon is then examined during each inspection. Corrosion protection medium chemistry 

and free water pH are monitored for each examined tendon. This procedure provides 

monitoring and trending information over the life of the plant. 10 CFR 50.55a and 

Subsection IWL also require that prestressing forces in all inspection sample tendons be 

measured by lift-off or equivalent tests and compared with acceptance standards based 

on the predicted force for that type of tendon over its life.

6. Acceptance Criteria: IWL-3000 provides acceptance standards for concrete 

containments. Quantitative acceptance criteria for concrete surfaces based on the 

“second-tier” evaluation criteria provided in Chapter 5 of ACI 349.3R are acceptable.

Applicants who elect to use plant-specific criteria for concrete containment structures

should describe the criteria and provide a technical basis for deviations from those in

ACI 349.3R. Inspection results, based on the acceptance criteria selected, are

evaluated by the Responsible Engineer to ensure that the corrective action is 

implemented before loss of intended functions. 

The acceptance standards for the unbonded post-tensioning system are quantitative in 

nature. For the post-tensioning system, quantitative acceptance criteria are given for 

tendon force and elongation, tendon wire or strand samples, and corrosion protection 

medium. Free water in the tendon anchorage areas is not acceptable, as specified in 

IWL-3221.3. If free water is found, the recommendations in Table IWL-2525-1 are 

followed. 10 CFR 50.55a and Subsection IWL do not define the method for calculating 

predicted tendon prestressing forces for comparison to the measured tendon lift-off forces. 

The predicted tendon forces are calculated in accordance with RG 1.35.1, “Determining 

Prestressing Forces for Inspection of Prestressed Concrete Containments,” which 

provides an acceptable methodology for use through the subsequent period of extended 

operation. 

7. Corrective Actions: Results that do not meet the acceptance criteria are addressed in 

the applicant’s corrective action program under those specific portions of the quality 

assurance (QA) program that are used to meet Criterion XVI, “Corrective Action,” of 

10 CFR Part 50, Appendix B. Appendix A of the GALL-SLR Report describes how an 

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the corrective 

actions element of this AMP for both safety-related and nonsafety-related structures and 

components (SCs) within the scope of this program.
XI.S2-4

Subsection IWL specifies that items for which examination results do not meet the

acceptance standards are to be evaluated in accordance with IWL-3300,

“Evaluation,” and described in an engineering evaluation report. The report is to

include an evaluation of whether the concrete containment is acceptable without

repair of the item and, if repair is required, the extent, method, and completion date of

the repair or replacement. The report also identifies the cause of the condition and the

extent, nature, and frequency of additional examinations. Subsection IWL also

provides repair procedures to follow in IWL-4000. This includes requirements for the

concrete repair, repair of reinforcing steel, and repair of the post-tensioning system.

8. Confirmation Process: The confirmation process is addressed through those specific 

portions of the QA program that are used to meet Criterion XVI, “Corrective Action,” of 

10 CFR Part 50, Appendix B. Appendix A of the GALL-SLR Report describes how an 

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the confirmation 

process element of this AMP for both safety-related and nonsafety-related SCs within the 

scope of this program. 

9. Administrative Controls: Administrative controls are addressed through the QA program 

that is used to meet the requirements of 10 CFR Part 50, Appendix B, associated with 

managing the effects of aging. Appendix A of the GALL-SLR Report describes how an 

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the 

administrative controls element of this AMP for both safety-related and nonsafety-related 

SCs within the scope of this program.

IWA-1400 specifies the preparation of plans, schedules, and ISI summary reports. In

addition, written examination instructions and procedures, verification of qualification

level of personnel who perform the examinations, and documentation of a QA

program are specified. IWA-6000 specifically covers the preparation, submittal, and

retention of records and reports.

10. Operating Experience: ASME Code Section XI, Subsection IWL was incorporated into 

10 CFR 50.55a in 1996. Prior to this time, the prestressing tendon inspections were 

performed in accordance with the guidance provided in RG 1.35, “Inservice Inspection of 

Ungrouted Tendons in Prestressed Concrete Containments.” Operating experience 

pertaining to degradation of reinforced concrete in concrete containments was gained 

through the inspections required by 10 CFR 50.55a(g)(4) (i.e., Subsection IWL), 

10 CFR Part 50, Appendix J, and ad hoc inspections conducted by licensees and the 

NRC. NUREG–1522, “Assessment of Inservice Condition of Safety-Related Nuclear 

Power Plant Structures,” described instances of cracked, spalled, and degraded concrete 

for reinforced and prestressed concrete containments. The NUREG also described 

cracked anchor heads for the prestressing tendons at three prestressed concrete 

containments. NRC Information Notice (IN) 99-10, Revision 1, “Degradation of 

Prestressing Tendon Systems in Prestressed Concrete Containment,” described 

occurrences of degradation in prestressing systems. IN 2010-14, “Containment Concrete 

Surface Condition Examination Frequency and Acceptance Criteria,” describes issues 

concerning the containment concrete surface condition examination frequency and 

acceptance criteria. The program considers the degradation concerns described in these 

generic communications. Implementation of Subsection IWL, in accordance with 

10 CFR 50.55a, is a necessary element of aging management for concrete containments 

through the subsequent period of extended operation. 
XI.S2-5

NRC Inspection Report 05000302/2009007 documents operating experience (OE) of an 

unprecedented delamination event that occurred during a major containment modification 

of a post-tensioned concrete containment. Although the event is not considered 

attributable to an aging mechanism, aging characteristics of prestressed concrete 

containments and lessons learned should be an important consideration for major 

containment modification repair/replacement activities, especially those involving 

significant detensioning and retensioning of tendons, during the subsequent period of 

extended operation.

The program is informed and enhanced when necessary through the systematic and 

ongoing review of both plant-specific and industry OE including research and development 

such that the effectiveness of the AMP is evaluated consistent with the discussion in 

Appendix B of the GALL-SLR Report.

References

10 CFR Part 50, Appendix B, “Quality Assurance Criteria for Nuclear Power Plants and Fuel 

Reprocessing Plants.” Washington, DC: U.S. Nuclear Regulatory Commission. 2016.

10 CFR Part 50, Appendix J, “Primary Reactor Containment Leakage Testing for Water-Cooled 

Power Reactors.” Washington, DC: U.S. Nuclear Regulatory Commission. 2016.

10 CFR 50.55a, “Codes and Standards.” Washington, DC: U.S. Nuclear Regulatory 

Commission. 2016.

ACI. ACI Standard 201.1R-08, “Guide for Conducting a Visual Inspection of Concrete in Service.” 

Farmington Hills, Michigan: American Concrete Institute. 2008.

_____. ACI Standard 349.3R-02, “Evaluation of Existing Nuclear Safety-Related Concrete 

Structures.” Farmington Hills, Michigan: American Concrete Institute. 2002.

ASME. ASME Code Section XI, “Rules for Inservice Inspection of Nuclear Power Plant 

Components, Subsection IWA, General Requirements.” New York, New York: The American 

Society of Mechanical Engineers. 2008.

2

_____. ASME Code Section XI, “Rules for Inservice Inspection of Nuclear Power Plant 

Components, Subsection IWE, Requirements for Class MC and Metallic Liners of Class CC 

Components of Light-Water Cooled Power Plants.” New York, New York: The American Society 

of Mechanical Engineers. 2008. 

_____. ASME Code Section XI, “Rules for Inservice Inspection of Nuclear Power Plant 

Components, Subsection IWL, Requirements for Class CC Concrete Components of Light-Water 

Cooled Power Plants.” New York, New York: The American Society of Mechanical Engineers. 

2008. 

 

2GALL-SLR Report Chapter I, Table 1, identifies the ASME Code Section XI editions and addenda that are 

acceptable to use for this AMP.
XI.S2-6

NRC. Information Notice 99-10, Revision 1, “Degradation of Prestressing Tendon Systems in 

Prestressed Concrete Containment.” Revision 1. Agencywide Documents Access and 

Management System (ADAMS) Accession No. ML031500244. Washington DC: U.S. Nuclear 

Regulatory Commission. April 1999.

_____. Information Notice 2010-14, “Containment Concrete Surface Condition Examination 

Frequency and Acceptance Criteria.” ADAMS Accession No. ML101600151. Washington, DC: 

U.S. Nuclear Regulatory Commission. August 2010. 

_____. Inspection Report, Crystal River Nuclear Plant – Special Inspection Report 

05000302/2009007. ADAMS Accession No. ML102861026. Washington, DC: U.S. Nuclear 

Regulatory Commission. October 12, 2010.

_____. NUREG–1522, “Assessment of Inservice Condition of Safety-Related Nuclear Power 

Plant Structures.” Washington, DC: U.S. Nuclear Regulatory Commission. June 1995.

_____. Regulatory Guide 1.35.1, “Determining Prestressing Forces for Inspection of Prestressed 

Concrete Containments.” ADAMS Accession No. ML003740040. Washington, DC: U.S. Nuclear 

Regulatory Commission. July 1990.

_____. Regulatory Guide 1.90, “Inservice Inspection of Prestressed Concrete Containment 

Structures with Grouted Tendons.” ADAMS Accession No. ML11249A008. Washington, DC: 

U.S. Nuclear Regulatory Commission. November 2012. 
XI.S3-1

XI.S3 ASME SECTION XI, SUBSECTION IWF

Program Description 

Title 10 of the Code of Federal Regulations (10 CFR) 50.55a, imposes the inservice inspection 

(ISI) requirements of the American Society of Mechanical Engineers Boiler and Pressure Vessel 

Code (ASME Code),

1 Section XI, for Class 1, 2, 3, and metal containment (MC) piping and 

components and their associated supports. The ISI of supports for ASME piping and components 

is addressed in Section XI, Subsection IWF. This program supplements ASME Code, Section XI, 

Subsection IWF, which constitutes an existing mandated program applicable to managing aging 

of American Society of Mechanical Engineers (ASME) Class 1, 2, 3, and MC component supports 

for subsequent license renewal. 

The scope of inspection for supports is based on sampling of the total support population. The 

sample size varies depending on the ASME Class. The largest sample size is specified for the 

most critical supports (ASME Class 1). The sample size decreases for the less critical supports 

(ASME Class 2 and 3). Discovery of support deficiencies during regularly scheduled inspections 

triggers an increase of the inspection scope. The primary inspection method employed is visual 

examination. Degradation that potentially compromises support function or load capacity is 

identified for evaluation. ASME Code Section XI, Subsection IWF specifies acceptance criteria 

and corrective actions. Supports requiring corrective actions are reexamined during the next 

inspection period.

The requirements of Subsection IWF are supplemented to include monitoring of high-strength 

bolting (actual measured yield strength greater than or equal to 150 kilo-pounds per square inch 

(ksi) [1,034 megapascals (MPa)] for cracking. This program emphasizes proper selection of 

bolting material, lubricants, and installation torque or tension to prevent or minimize loss of bolting 

preload and cracking of high-strength bolting. This program includes a one-time inspection of

additional supports for each group of materials used and the environments to which they are 

exposed outside of the existing Subsection IWF sample population.

Evaluation and Technical Basis

1. Scope of Program: This program addresses ASME Class 1, 2, 3, and MC component 

supports. The scope of the program includes support members, structural bolting, 

high-strength structural bolting [actual measured yield strength greater than or equal to 

150 ksi (1,034 MPa)], anchor bolts, welds, support anchorage to the building structure, 

accessible sliding surfaces, constant and variable load spring hangers, guides, stops, and 

vibration isolation elements. The acceptability of inaccessible areas (e.g., portions of 

supports encased in concrete, buried underground, or encapsulated by guard pipe) is 

evaluated when conditions exist in accessible areas that could indicate the presence of, or 

result in, degradation to such inaccessible areas.

2. Preventive Action: Operating experience and laboratory examinations show that the use 

of molybdenum disulfide (MoS2) as a lubricant is a potential contributor to stress corrosion 

cracking (SCC), especially when applied to high-strength bolting. Thus, molybdenum 

disulfide and other lubricants containing sulfur should not be used. Preventive measures 

 

1GALL-SLR Report Chapter I, Table 1, identifies the ASME Code Section XI editions and addenda that are 

acceptable to use for this AMP.
XI.S3-2

also include using bolting material that has actual measured yield strength less than 

150 ksi (1,034 MPa). Bolting replacement and maintenance activities include proper 

selection of bolting material and lubricants, and appropriate installation torque or tension, 

as recommended in Electric Power Research Institute (EPRI) documents (e.g., EPRI 

NP-5067 and EPRI TR–104213), American Society for Testing and Materials (ASTM) 

standards, and American Institute of Steel Construction Specifications, as applicable. If 

bolting within the scope of the program consists of ASTM A325 and/or ASTM A490 bolts 

(including respective equivalent twist-off type ASTM F1852 and/or ASTM F2280 bolts), the 

preventive actions for storage, lubricant selection, and bolting and coating material 

selection discussed in Section 2 of Research Council for Structural Connections 

publication “Specification for Structural Joints Using High-Strength Bolts” need to be used. 

3. Parameters Monitored or Inspected: The parameters monitored or inspected include 

corrosion; cracking, deformation; misalignment of supports; missing, detached, or 

loosened support items; general structural condition of weld joints and weld connections to 

building structure for loss of integrity; improper clearances of guides and stops; and 

improper hot or cold settings of spring supports and constant load supports. Accessible 

areas of sliding surfaces are monitored for debris, dirt, or indications of excessive loss of 

material due to wear that could prevent or restrict sliding as intended in the design basis of 

the support. Elastomeric or polymeric vibration isolation elements are monitored for 

cracking, loss of material, and hardening. Bolting is monitored for corrosion, loss of 

integrity of bolted connections due to self-loosening, and material conditions that can 

affect structural integrity. Concrete around anchor bolts is monitored for degradation 

under the Structures Monitoring Program. High strength bolting (actual measured yield 

strength greater than or equal to 150 ksi (1,034 MPa) in sizes greater than 1 inch nominal 

diameter (including ASTM A490 bolts and ASTM F2280 bolts), should be monitored for

SCC. 

4. Detection of Aging Effects: The program requires that a sample of ASME Class 1, 2, 

and 3 piping supports that are not exempt from examination and 100 percent of supports 

other than piping supports (Class 1, 2, 3, and MC), be examined as specified in 

Table IWF-2500-1. The sample size examined for ASME Class 1, 2, and 3 component 

supports is as specified in Table IWF-2500-1. The provisions of ASME Code Section XI, 

Subsection IWF are supplemented to include a one-time inspection of an additional 

5 percent of the sample size specified in Table IWF-2500-1 for Class 1, 2, and 3 piping 

supports. The one-time inspection is conducted within 5 years prior to entering the 

subsequent period of extended operation. The additional supports are selected from the 

remaining population of IWF piping supports. However, the responsible engineer should 

ensure that the sample includes components that are most susceptible to age-related 

degradation (i.e., based on time in service, aggressive environment, etc.).

The extent, frequency, and examination methods are designed to detect, evaluate, or 

repair age-related degradation before there is a loss of component support intended 

function. The VT-3 examination method specified by the program can reveal loss of 

material due to corrosion and wear, cracks, verification of clearances, settings, physical 

displacements, loose or missing parts, debris or dirt in accessible areas of the sliding 

surfaces, or loss of integrity at bolted connections. The VT-3 examination can also detect 

loss of material and cracking of elastomeric or polymeric vibration isolation elements. 

Elastomeric or polymeric vibration isolation elements should be felt to detect hardening if 

the vibration isolation function is suspect. IWF-3200 specifies that visual examinations 
XI.S3-3

that detect surface flaws which exceed acceptance criteria may be supplemented by either 

surface or volumetric examinations to determine the character of the flaw.

For all high-strength bolting [actual measured yield strength greater than or equal to 

150 ksi (1,034 MPa)] in sizes greater than 1 inch nominal diameter (including ASTM A490 

and equivalent ASTM F2280), volumetric examination comparable to that of ASME Code 

Section XI, Table IWB-2500-1, Examination Category B-G-1 should be performed at least 

once per interval to detect cracking in addition to the VT-3 examination. The sample of 

high-strength bolts subject to volumetric examination should be determined on a 

plant-specific basis such that the program can provide reasonable assurance that SCC is 

not occurring for the entire population of high-strength bolts. This volumetric examination 

may be waived with plant-specific justification.

5. Monitoring and Trending: The ASME Class 1, 2, 3, and MC component supports are 

examined periodically, as specified in Table IWF-2500-1. As required by IWF-2420(a), the 

sequence of component support examinations established during the first inspection 

interval is repeated during each successive inspection interval, to the extent practical. 

Component supports whose examinations do not reveal unacceptable degradation are 

accepted for continued service. Verified changes of conditions from prior examination are 

recorded in accordance with IWA-6230. Component supports whose examinations reveal 

unacceptable conditions and are accepted for continued service by corrective measures or 

repair/replacement activity are reexamined during the next inspection period. When the 

reexamined component support no longer requires additional corrective measures during 

the next inspection period, the inspection schedule may revert to its regularly scheduled 

inspection. Examinations that reveal indications which exceed the acceptance standards 

and require corrective measures are extended to include additional examinations in 

accordance with IWF-2430. If a component support does not exceed the acceptance 

standards of IWF-3400 but is repaired to as-new condition, the sample is increased or 

modified to include another support that is representative of the remaining population of 

supports that were not repaired. 

6. Acceptance Criteria: The acceptance standards for visual examination are specified in 

IWF-3400. IWF-3410(a) identifies the following conditions as unacceptable:

(a) Deformations or structural degradations of fasteners, springs, clamps, or other 

support items;

(b) Missing, detached, or loosened support items, including bolts and nuts;

(c) Arc strikes, weld spatter, paint, scoring, roughness, or general corrosion on close 

tolerance machined or sliding surfaces;

(d) Improper hot or cold positions of spring supports and constant load supports;

(e) Misalignment of supports; and

(f) Improper clearances of guides and stops.
XI.S3-4

Other unacceptable conditions include:

(a) Loss of material due to corrosion or wear;

(b) Debris, dirt, or excessive wear that could prevent or restrict sliding of the sliding 

surfaces as intended in the design basis of the support;

(c) Cracked or sheared bolts, including high-strength bolts, and anchors; and

(d) Loss of material, cracking, and hardening of elastomeric or polymeric vibration 

isolation elements that could reduce the vibration isolation function;

(e) Cracks.

The above conditions may be accepted provided the technical basis for their acceptance is 

documented.

7. Corrective Actions: Results that do not meet the acceptance criteria are addressed in 

the applicant’s corrective action program under those specific portions of the quality 

assurance (QA) program that are used to meet Criterion XVI, “Corrective Action,” of 

10 CFR Part 50, Appendix B. Appendix A of the Generic Aging Lessons Learned for 

Subsequent License Renewal (GALL-SLR) Report describes how an applicant may apply 

its 10 CFR Part 50, Appendix B, QA program to fulfill the corrective actions element of this 

aging management program (AMP) for both safety-related and nonsafety-related 

structures and components (SCs) within the scope of this program.

Identification of unacceptable conditions triggers an expansion of the inspection scope, in 

accordance with IWF-2430, and reexamination of the supports requiring corrective actions 

during the next inspection period, in accordance with IWF-2420(b). In accordance with 

IWF-3122, supports containing unacceptable conditions are evaluated or tested or 

corrected before returning to service. Corrective actions are delineated in IWF-3122.2. 

IWF-3122.3 provides an alternative for evaluation or testing to substantiate structural 

integrity and/or functionality.

8. Confirmation Process: The confirmation process is addressed through those specific 

portions of the QA program that are used to meet Criterion XVI, “Corrective Action,” of 

10 CFR Part 50, Appendix B. Appendix A of the GALL-SLR Report describes how an 

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the confirmation 

process element of this AMP for both safety-related and nonsafety-related SCs within the 

scope of this program.

9. Administrative Controls: Administrative controls are addressed through the QA program 

that is used to meet the requirements of 10 CFR Part 50, Appendix B, associated with 

managing the effects of aging. Appendix A of the GALL-SLR Report describes how an 

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the 

administrative controls element of this AMP for both safety-related and nonsafety-related 

SCs within the scope of this program.

10. Operating Experience: Degradation of threaded bolting and fasteners has occurred from 

boric acid corrosion, SCC, and fatigue loading (U.S. Nuclear Regulatory Commission 

(NRC) Inspection and Enforcement Bulletin (IEB) 82-02, “Degradation of Threaded 
XI.S3-5

Fasteners In the Reactor Coolant Pressure Boundary of PWR Plants,” NRC Generic 

Letter 91-17, “Generic Safety Issue 79, Bolting Degradation of Failure in Nuclear Power 

Plants”). SCC has occurred in high-strength bolts used for nuclear steam supply system 

component supports (EPRI NP-5769). NRC Information Notice 2009-04 describes 

deviations in the supporting forces of mechanical constant supports, from code allowable 

load deviation, due to age-related wear on the linkages and increased friction between the 

various moving parts and joints within the constant support, which can adversely affect the 

analyzed stresses of connected piping systems. 

The program is informed and enhanced when necessary through the systematic and 

ongoing review of both plant-specific and industry operating experience including research

and development such that the effectiveness of the AMP is evaluated consistent with the

discussion in Appendix B of the GALL-SLR Report.

References

10 CFR Part 50, Appendix B, “Quality Assurance Criteria for Nuclear Power Plants and Fuel 

Reprocessing Plants.” Washington, DC: U.S. Nuclear Regulatory Commission. 2016.

10 CFR 50.55a, “Codes and Standards.” Washington, DC: U.S. Nuclear Regulatory 

Commission. 2016.

ASME. ASME Code Section XI, “Rules for Inservice Inspection of Nuclear Power Plant 

Components, Subsection IWB, Requirements for Class 1 Components of Light-Water Cooled 

Power Plants.” New York, New York: The American Society of Mechanical Engineers. 2008.

2

_____. ASME Code Section XI, “Rules for Inservice Inspection of Nuclear Power Plant 

Components, Subsection IWC, Requirements for Class 2 Components of Light-Water Cooled 

Power Plants.” New York, New York: The American Society of Mechanical Engineers. 2008.

_____. ASME Code Section XI, “Rules for Inservice Inspection of Nuclear Power Plant 

Components, Subsection IWD, Requirements for Class 3 Components of Light-Water Cooled 

Power Plants.” New York, New York: The American Society of Mechanical Engineers. 2008.

_____. ASME Code Section XI, “Rules for Inservice Inspection of Nuclear Power Plant 

Components, Subsection IWE, Requirements for Class MC and Metallic Liners of Class CC 

Components of Light-Water Cooled Power Plants.” New York, New York: The American Society 

of Mechanical Engineers. 2008.

_____. ASME Code Section XI, “Rules for Inservice Inspection of Nuclear Power Plant 

Components, Subsection IWF, Requirements for Class 1, 2, 3, and MC Component Supports of 

Light-Water Cooled Power Plants.” New York, New York: The American Society of Mechanical 

Engineers. 2008.

EPRI. EPRI NP-5067, “Good Bolting Practices, A Reference Manual for Nuclear Power Plant 

Maintenance Personnel.” Volume 1: Large Bolt Manual, 1987; Volume 2: Small Bolts and 

Threaded Fasteners. Palo Alto, California: Electric Power Research Institute. 1990.

 

2GALL-SLR Report Chapter I, Table 1, identifies the ASME Code Section XI editions and addenda that are 

acceptable to use for this AMP.
XI.S3-6

_____. EPRI NP-5769, “Degradation and Failure of Bolting in Nuclear Power Plants.” Volumes 1 

and 2. Palo Alto, California: Electric Power Research Institute. April 1988. 

_____. EPRI TR–104213, “Bolted Joint Maintenance & Application Guide.” 

Palo Alto, California: Electric Power Research Institute. December 1995.

NRC. Generic Letter 91-17, “Generic Safety Issue 79, Bolting Degradation or Failure in Nuclear 

Power Plants.” Agencywide Documents Access and Management System (ADAMS) Accession 

No. ML031140534. Washington, DC: U.S. Nuclear Regulatory Commission. October 1991.

_____. IE Bulletin 82-02, “Degradation of Threaded Fasteners in the Reactor Coolant Pressure 

Boundary of PWR Plants.” ADAMS Accession No. ML03120720. Washington, DC: U.S. Nuclear 

Regulatory Commission. June 1982.

_____. Information Notice 2009-04, “Age-Related Constant Support Degradation.” ADAMS 

Accession No. ML090340754. Washington, DC: U.S. Nuclear Regulatory Commission. 

February 2009. 

RCSC. “Specification for Structural Joints Using High-Strength Bolts.” Chicago, Illinois: 

Research Council on Structural Connections. August 2014.
XI.S4-1

XI.S4 10 CFR PART 50, APPENDIX J

Program Description 

A typical primary reactor containment system consists of a containment structure (containment), 

and a number of electrical, mechanical, equipment hatch, and personnel air lock penetrations. As 

described in Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix J, “Primary 

Reactor Containment Leakage Testing for Water-Cooled Power Reactors,” (Appendix J) periodic 

containment leak rate tests are required to assure that (a) leakage through these containments or 

systems and components penetrating these containments does not exceed allowable leakage 

rates specified in the Technical Specification (TS) and (b) integrity of the containment structure is 

maintained during its service life.

This aging management program (AMP) credits the existing program required by 10 CFR Part 50 

Appendix J, and augments it to ensure that all containment pressure-retaining components are 

managed for age-related degradation.

Appendix J provides two options, Option A and Option B, to meet the requirements of a 

containment leak rate test (LRT) program. Option A is prescriptive with all testing performed on 

specified periodic intervals. Option B is a performance-based approach. The U.S. Nuclear 

Regulatory Commission (NRC) Regulatory Guide 1.163, “Performance-Based Containment 

Leak-Test Program” and Nuclear Energy Institute (NEI) 94-01, Industry Guideline for 

Implementing Performance-Based Option for 10 CFR Part 50, Appendix J, as approved by the 

NRC final safety evaluation for NEI 94-01, Revision 2-A and Revision 3-A, provide additional 

information regarding Option B. Three types of tests are performed under either Option A or 

Option B, or a mix as adopted by licensees on a voluntary basis.

Type A integrated leak rate tests determine the overall containment integrated leakage rate, at the 

calculated peak containment internal pressure related to the design basis loss of coolant accident. 

Type B (containment penetration leak rate) tests detect local leaks and measure leakage across 

each pressure-containing or leakage-limiting boundary of containment penetrations. Type C 

(containment isolation valve leak rate) tests detect local leaks and measure leakage across 

containment isolation valves installed in containment penetrations or lines penetrating the 

containment.

Appendix J requires a general visual inspection of the accessible interior and exterior surfaces of 

the containment structures and components (SCs) to be performed prior to any Type A test and at 

periodic intervals between tests based on the performance of the containment system. The visual 

inspections required by American Society of Mechanical Engineers Boiler and Pressure Vessel 

Code (ASME Code) Section XI, Subsections IWE and IWL are acceptable substitutes for the 

general visual inspection. The purpose of the Appendix J general visual inspection is to uncover 

any evidence of structural deterioration that may affect the containment structure leakage integrity 

or the performance of the Type A test.

Evaluation and Technical Basis

1. Scope of Program: The scope of the containment LRT program includes the 

containment system and related systems and components penetrating the containment 

pressure-retaining or leakage-limiting boundary. The aging effects associated with 

containment pressure-retaining boundary components within the scope of subsequent 

license renewal and excluded from Type B or C Appendix J testing must still be managed. 
XI.S4-2

Other programs may be credited for managing the aging effects associated with these 

components; however, the component and the proposed AMP should be clearly identified. 

2. Preventive Action: The containment LRT program is a performance monitoring program 

with no specific preventive actions.

3. Parameters Monitored or Inspected: The monitored parameters are leakage rates 

through the containment shell, containment liner, penetrations, associated welds, access 

openings, and associated pressure boundary components.

4. Detection of Aging Effects: A containment LRT program is effective in detecting leakage 

rates of the containment pressure boundary components, including seals and gaskets, 

and in identifying and correcting sources of leakage. While the calculation of leakage 

rates and satisfactory performance of containment leak rate testing demonstrates the 

leakage integrity of the containment, it does not by itself provide information that would 

indicate that age-related degradation has initiated or that the capacity of the containment 

may have been reduced for other types of loading conditions. This would be achieved 

with the implementation of acceptable containment inservice inspection (ISI) programs 

such as ASME Code Section XI, Subsection IWE [Generic Aging Lessons Learned for 

Subsequent License Renewal (GALL-SLR) Report AMP XI.S1], and ASME Code 

Section XI, Subsection IWL (GALL-SLR Report AMP XI.S2).

5. Monitoring and Trending: Because the containment LRT program is repeated 

periodically throughout the operating license period, the entire containment pressure 

boundary is monitored over time. The frequency of these tests depends on which option 

(A or B) is selected. With Option A, testing is performed on a regular fixed time interval as 

defined in Appendix J. In the case of Option B, acceptable performance in prior tests 

meeting leakage rate limits serves as a basis to adjust the testing interval. For valves and 

penetrations administrative leakage rate limits may be set lower than the regulatory 

acceptance criteria for early detection of age-related degradation.

6. Acceptance Criteria: Plant TS define the regulatory acceptance criteria for leakage rate 

limits. The regulatory acceptance criteria meet the requirements as set forth in Appendix 

J, and are part of each plant’s licensing basis. 

7. Corrective Actions: Results that do not meet the acceptance criteria are addressed in 

the applicant’s corrective action program under those specific portions of the quality 

assurance (QA) program that are used to meet Criterion XVI, “Corrective Action,” of 

10 CFR Part 50, Appendix B. Appendix A of the GALL-SLR Report describes how an 

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the corrective 

actions element of this AMP for both safety-related and nonsafety-related SCs within the 

scope of this program.

Corrective actions are taken in accordance with Appendix J and NEI 94-01. When 

leakage rates do not meet the acceptance criteria, an evaluation is performed to identify 

the cause of the unacceptable performance and appropriate corrective actions are taken.

8. Confirmation Process: The confirmation process is addressed through those specific 

portions of the QA program that are used to meet Criterion XVI, “Corrective Action,” of 

10 CFR Part 50, Appendix B. Appendix A of the GALL-SLR Report describes how an 

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the confirmation 
XI.S4-3

process element of this AMP for both safety-related and nonsafety-related SCs within the 

scope of this program. 

9. Administrative Controls: Administrative controls are addressed through the QA program 

that is used to meet the requirements of 10 CFR Part 50, Appendix B, associated with 

managing the effects of aging. Appendix A of the GALL-SLR Report describes how an 

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the 

administrative controls element of this AMP for both safety-related and nonsafety-related 

SCs within the scope of this program.

10. Operating Experience: To date, Appendix J, containment LRT program, in conjunction 

with the containment ISI program, have been effective in preventing unacceptable leakage 

through the containment pressure boundary. Implementation of Option B for testing 

frequency must be consistent with plant-specific operating experience (OE).

NRC Information Notice 92-20, “Inadequate Local Leak Rate Testing,” describes OE of 

inadequate local leak rate testing of two-ply steel expansion bellows that were used on 

some piping penetrations.

The program is informed and enhanced when necessary through the systematic and 

ongoing review of both plant-specific and industry OE including research and development 

such that the effectiveness of the AMP is evaluated consistent with the discussion in 

Appendix B of the GALL-SLR Report.

References

10 CFR Part 50, Appendix B, “Quality Assurance Criteria for Nuclear Power Plants and Fuel 

Reprocessing Plants.” Washington, DC: U.S. Nuclear Regulatory Commission. 2016.

10 CFR Part 50, Appendix J, “Primary Reactor Containment Leakage Testing for Water-Cooled 

Power Reactors.” Washington, DC: U.S. Nuclear Regulatory Commission. 2016.

10 CFR 50.55a, “Codes and Standards.” Washington, DC: U.S. Nuclear Regulatory 

Commission. 2016.

10 CFR 50.72, “Immediate Notification Requirements for Operating Nuclear Power Reactors.” 

Washington, DC: U.S. Nuclear Regulatory Commission. 2016.

10 CFR 50.73, “Licensee Event Report System.” Washington, DC: U.S. Nuclear Regulatory 

Commission. 2016.

ASME. ASME Code Section XI, “Rules for Inservice Inspection of Nuclear Power Plant 

Components, Subsection IWE, Requirements for Class MC and Metallic Liners of Class CC 

Components of Light-Water Cooled Power Plants.” New York, New York: The American Society 

of Mechanical Engineers. 20081

.

_____. ASME Code Section XI, “Rules for Inservice Inspection of Nuclear Power Plant 

Components, Subsection IWL, Requirements for Class CC Concrete Components of Light-Water 

 

1GALL-SLR Report Chapter I, Table 1, identifies the ASME Code Section XI editions and addenda that are 

acceptable to use for this AMP.
XI.S4-4

Cooled Power Plants.” New York, New York: The American Society of Mechanical Engineers. 

2008.

NEI. NEI 94-01, “Industry Guideline for Implementing Performance-Based Option of 

10 CFR Part 50 Appendix J.” Revision 2-A. Washington, DC: Nuclear Energy Institute. 

October 2008.

_____. NEI 94-01, “Industry Guideline for Implementing Performance-Based Option of 

10 CFR Part 50 Appendix J.” Revision 3-A. Agencywide Documents Access and Management 

System (ADAMS) Accession No. ML12221A202. Washington, DC: Nuclear Energy Institute. 

July 2012.

NRC. “Final Safety Evaluation for Electric Power Research Institute (EPRI) Report No. 1009325, 

Revision 2, Risk Impact Assessment of Extended Integrated Leak Rate Testing Intervals.” 

ADAMS Accession ML072970208. Washington, DC: U.S. Nuclear Regulatory Commission. 

August 2007.

_____. “Final Safety Evaluation for Nuclear Energy Institute (NEI) Topical Report (TR) 94-01, 

Revision 2, Industry Guideline for Implementing Performance-Based Option of 10 CFR, Part 50, 

Appendix J.” ADAMS Accession No. ML081140105. Washington, DC: U.S. Nuclear Regulatory 

Commission. June 2008. 

_____. Information Notice 92-20, “Inadequate Local Leak Rate Testing.” ADAMS Accession 

No. ML031200473. Washington, DC: U.S. Nuclear Regulatory Commission. March 1992.

_____. Regulatory Guide 1.163, “Performance-Based Containment Leak-Test Program.” 

Revision 0. ADAMS Accession No. ML003740058. Washington, DC: U.S. Nuclear Regulatory 

Commission. September 1995.
XI.S5-1

XI.S5 MASONRY WALLS 

Program Description 

The U.S. Nuclear Regulatory Commission (NRC) Inspection and Enforcement Bulletin (IEB) 

80-11, “Masonry Wall Design,” and NRC Information Notice (IN) 87-67, “Lessons Learned from 

Regional Inspections of Licensee Actions in Response to IE Bulletin 80-11,” constitute an 

acceptable basis for a masonry wall aging management program (AMP). NRC IEB 80-11 

required (a) the identification of masonry walls in close proximity to or having attachments from 

safety-related systems or components and (b) the evaluation of design adequacy and 

construction practice. NRC IN 87-67 recommended plant-specific condition monitoring of 

masonry walls and administrative controls to ensure that the evaluation basis developed in 

response to NRC IEB 80-11 is not invalidated by: (a) deterioration of the masonry walls (e.g., new 

cracks not considered in the reevaluation), (b) physical plant changes such as installation of new 

safety related systems or components in close proximity to masonry walls, or (c) reclassification of 

systems or components from nonsafety-related to safety-related, provided appropriate evaluation 

is performed to account for such occurrences. 

Important elements in the evaluation of many masonry walls during the NRC IEB 80-11 program 

included: (a) installation of steel edge supports to provide a sound technical basis for boundary 

conditions used in seismic analysis and (b) installation of steel bracing to ensure stability or 

containment of unreinforced masonry walls during a seismic event. Consequently, in addition to 

the development of cracks in the masonry walls, loss of function of the structural steel supports 

and bracing would also invalidate the evaluation basis. The steel edge supports and steel 

bracings are considered component supports and aging effects are managed by the Structures 

Monitoring program [Generic Aging Lessons Learned for Subsequent License Renewal 

(GALL-SLR) Report AMP XI.S6].

The program consists of periodic visual inspection of masonry walls within the scope of 

subsequent license renewal (SLR) to detect loss of material and cracking of masonry units and 

mortar. The aging effects that could impact masonry wall intended function or potentially 

invalidate its evaluation basis are entered into the corrective action process for further analysis, 

repair, or replacement.

Since the issuance of NRC IEB 80-11 and NRC IN 87-67, the NRC promulgated Title 10 of the 

Code of Federal Regulations (10 CFR) 50.65, “Maintenance Rule.” For SLR, masonry walls may 

be inspected as part of GALL-SLR Report AMP XI.S6 conducted for the Maintenance Rule, 

provided the 10 attributes described below are incorporated in GALL-SLR Report AMP XI.S6. 

The aging effects on masonry walls that are considered fire barriers are managed by GALL-SLR 

Report AMP XI.M26, “Fire Protection.”

Evaluation and Technical Basis

1. Scope of Program: The scope includes all masonry walls identified as performing 

intended functions in accordance with 10 CFR 54.4. Masonry walls consist of solid or 

hollow concrete block, mortar, grout, steel bracing, reinforcing and supports. The aging 

effects on masonry walls that are considered fire barriers are also managed by GALL-SLR 

Report AMP XI.M26, Fire Protection, as well as being managed by this program. Aging 

effects on the steel elements of masonry walls are managed by GALL-SLR Report

AMP XI.S6. 
XI.S5-2

2. Preventive Action: This is a condition monitoring program and no specific preventive 

actions are required.

3. Parameters Monitored or Inspected: The primary parameters monitored are potential 

shrinkage and/or separation, cracking of masonry walls, cracking or loss of material at the 

mortar joints and gaps between the supports and masonry walls that could impact the 

intended function or potentially invalidate its evaluation basis. 

4. Detection of Aging Effects: Visual examination of the masonry walls by qualified 

inspection personnel is sufficient. In general, masonry walls are inspected every 5 years. 

Provisions exist for more frequent inspections in areas where significant loss of material, 

cracking, or other signs of degradation are observed to provide reasonable assurance that 

there is no loss of intended function between inspections. In addition, masonry walls that 

are fire barriers are visually inspected in accordance with GALL-SLR Report AMP XI.M26. 

Steel elements of masonry walls are visually inspected under the scope of GALL-SLR 

Report AMP XI.S6.

5. Monitoring and Trending: Condition monitoring for evidence of shrinkage and/or 

separation and cracking of masonry is achieved by periodic examination. Where practical, 

identified degradation is projected until the next scheduled inspection. Results are 

evaluated against acceptance criteria to confirm that the timing of subsequent inspections 

will maintain the components’ intended functions throughout the subsequent period of 

extended operation based on the projected rate of degradation. Inspection results are 

documented and compared to previous inspections to identify changes or trends in the 

condition of masonry walls. Crack widths and lengths, and gaps between supports and 

masonry walls, that approach or exceed acceptance criteria are measured and assessed 

for trends. Degradation detected from monitoring is evaluated. The use of photographs or 

surveys is encouraged and photographic records may be used to document and trend the 

type, severity, extent and progression of degradation.

6. Acceptance Criteria: For each masonry wall, observed degradation (e.g., shrinkage 

and/or separation, cracking of masonry walls, cracking or loss of material at the mortar 

joints and gaps between the supports and masonry walls) are assessed against the 

evaluation basis to confirm that the degradation has not invalidated the original evaluation 

assumptions or impacted the capability to perform the intended functions. Further 

evaluation is conducted to determine if corrective action is required when the degradation 

is determined to impact the intended function of the wall or invalidate its evaluation basis. 

Degraded conditions that exceed acceptance criteria and are accepted without repair or 

other corrective actions are technically justified or supported by engineering evaluation.

7. Corrective Actions: Results that do not meet the acceptance criteria are addressed in 

the applicant’s corrective action program under those specific portions of the quality 

assurance (QA) program that are used to meet Criterion XVI, “Corrective Action,” of 

10 CFR Part 50, Appendix B. Appendix A of the GALL-SLR Report describes how an 

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the corrective 

actions element of this AMP for both safety-related and nonsafety-related structures and 

components (SCs) within the scope of this program.

If any projected inspection results will not meet acceptance criteria prior to the next 

scheduled inspection, inspection frequencies are adjusted as determined by the site’s 

corrective action program.
XI.S5-3

A corrective action option is to develop a new analysis or evaluation basis that accounts 

for the degraded condition of the wall (i.e., acceptance by further evaluation). Other 

alternatives include repair or replacing the degraded wall.

8. Confirmation Process: The confirmation process is addressed through those specific 

portions of the QA program that are used to meet Criterion XVI, “Corrective Action,” of 

10 CFR Part 50, Appendix B. Appendix A of the GALL-SLR Report describes how an 

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the confirmation 

process element of this AMP for both safety-related and nonsafety-related SCs within the 

scope of this program. 

9. Administrative Controls: Administrative controls are addressed through the QA program 

that is used to meet the requirements of 10 CFR Part 50, Appendix B, associated with 

managing the effects of aging. Appendix A of the GALL-SLR Report describes how an 

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the 

administrative controls element of this AMP for both safety-related and nonsafety-related 

SCs within the scope of this program.

10. Operating Experience: Since 1980, masonry walls that perform an intended function 

have been systematically identified through licensee programs in response to NRC 

IEB 80-11, NRC Generic Letter 87-02, and 10 CFR 50.48. NRC IN 87-67 documented 

lessons learned from the NRC IEB 80-11 program and provided recommendations for 

administrative controls and periodic inspection to provide reasonable assurance that the 

evaluation basis for each safety-significant masonry wall is maintained. NUREG–1522 

documents instances of observed cracks and other deterioration of masonry-wall joints at 

nuclear power plants. Whether conducted as a stand-alone program or as a part of 

structures monitoring, a masonry wall AMP that incorporates the recommendations 

delineated in NRC IN 87-67 provides reasonable assurance that the intended functions of 

all masonry walls within the scope of license renewal are maintained for the subsequent 

period of extended operation.

The program is informed and enhanced when necessary through the systematic and 

ongoing review of both plant-specific and industry operating experience including research

and development such that the effectiveness of the AMP is evaluated consistent with the 

discussion in Appendix B of the GALL-SLR Report. 

References

10 CFR Part 50, Appendix B, “Quality Assurance Criteria for Nuclear Power Plants and Fuel 

Reprocessing Plants.” Washington, DC: U.S. Nuclear Regulatory Commission. 2016.

10 CFR 50.48, “Fire Protection.” Washington, DC: U.S. Nuclear Regulatory Commission. 2016. 

10 CFR 50.65, “Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power 

Plants.” Washington, DC: U.S. Nuclear Regulatory Commission. 2016.

10 CFR 54.4, “Scope.” Washington, DC: U.S. Nuclear Regulatory Commission. 2016. 
XI.S5-4

NRC. Generic Letter 87-02, “Verification of Seismic Adequacy of Mechanical and Electrical 

Equipment in Operating Reactors, Unresolved Safety Issue (USI) A-46.” Agencywide Documents

Access and Management System (ADAMS) Accession No. ML031150371. Washington, DC: 

U.S. Nuclear Regulatory Commission. February 1987.

_____. IE Bulletin 80-11, “Masonry Wall Design.” Washington, DC: U.S. Nuclear Regulatory 

Commission. May 1980.

_____. Information Notice 87-67, “Lessons Learned from Regional Inspections of Licensee 

Actions in Response to IE Bulletin 80-11.” Washington, DC: U.S. Nuclear Regulatory 

Commission. December 1987.

_____. NUREG–1522, “Assessment of Inservice Condition of Safety-Related Nuclear Power 

Plant Structures.” ADAMS Accession No. ML06510407. Washington, DC: U.S. Nuclear 

Regulatory Commission. June 1995.
XI.S6-1

XI.S6 STRUCTURES MONITORING 

Program Description 

Implementation of structures monitoring under Title 10 of the Code of Federal Regulations 

(10 CFR) 50.65 (the Maintenance Rule) is addressed in the U.S. Nuclear Regulatory Commission 

(NRC) Regulatory Guide (RG) 1.160, and Nuclear Management and Resources Council 93-01. 

These two documents and supplemental guidance herein provide guidance for development of 

licensee-specific programs to monitor the condition of structures and structural components within 

the scope of the license renewal rule, such that there is no loss of structure or structural 

component intended function. 

The structures monitoring program consists primarily of periodic visual inspections by personnel 

qualified to monitor structures and components (SCs) for applicable aging effects from 

degradation mechanisms, such as those described in the American Concrete Institute (ACI) 

Standards 349.3R, ACI 201.1R, and Structural Engineering Institute/American Society of Civil 

Engineers Standard (SEI/ASCE) 11. 

Identified aging effects are evaluated by qualified personnel using criteria derived from industry 

codes and standards contained in the plant current licensing bases, including ACI 349.3R, 

ACI 318, SEI/ASCE 11, and the American Institute of Steel Construction (AISC) specifications, as 

applicable.

The program includes preventive actions to ensure structural bolting integrity. The program also 

includes periodic sampling and testing of groundwater and the need to assess the impact of any 

changes in its chemistry on below grade concrete structures.

Evaluation and Technical Basis

1. Scope of Program: The scope of the program includes all SCs, component supports, 

and structural commodities in the scope of license renewal that are not covered by other 

structural aging management programs (AMPs) (i.e., “ASME Section XI, Subsection IWE” 

[Generic Aging Lessons Learned for Subsequent License Renewal (GALL-SLR) Report

AMP XI.S1]; “ASME Section XI, Subsection IWL” (GALL-SLR Report AMP XI.S2); “ASME 

Section XI, Subsection IWF” (GALL-SLR Report AMP XI.S3); “Masonry Walls” (GALL-SLR 

Report AMP XI.S5); and NRC RG 1.127, “Inspection of Water-Control Structures 

Associated with Nuclear Power Plants” (GALL-SLR Report AMP XI.S7). 

Examples of SCs and commodities in the scope of the program are concrete and steel 

structures, structural bolting, anchor bolts and embedments, component support 

members, steel edge supports and steel bracings associated with masonry walls, pipe 

whip restraints and jet impingement shields, transmission towers, panels and other 

enclosures, racks, sliding surfaces, sump and pool liners, electrical cable trays and 

conduits, trash racks associated with water control structures, electrical duct banks, 

manholes, doors, penetration seals, seismic joint filler and other elastomeric materials, 

and tube tracks.

If protective coatings are relied upon to manage the effects of aging for any structures 

included in the scope of this program, the program is to address protective coating 

monitoring and maintenance. Otherwise, coatings on structures within the scope of this 

program are inspected only as an indication of the condition of the underlying material. 
XI.S6-2 

The scope of this program includes periodic sampling and testing of groundwater. The 

scope may also include inspection of masonry walls and water-control structures provided 

all the attributes of “Masonry Walls” (GALL-SLR Report AMP XI.S5) and “Inspection of 

Water-Control Structures Associated with Nuclear Power Plants” (GALL-SLR Report

AMP XI.S7) are incorporated in the attributes of this program. 

2. Preventive Action: The Structures Monitoring program is primarily a condition monitoring

program; however, the program includes preventive actions to provide reasonable

assurance that structural bolting integrity is maintained, as discussed in Electric Power 

Research Institute (EPRI) documents (such as EPRI NP-5067 and TR-104213), American 

Society for Testing and Materials (ASTM) standards, and AISC specifications, as 

applicable. The preventive actions emphasize proper selection of bolting material and 

lubricants, and appropriate installation torque or tension to prevent or minimize loss of 

bolting preload and cracking of high-strength bolting. If the structural bolting consists of 

ASTM A325 and/or ASTM A490 bolts (including respective equivalent twist-off type ASTM 

F1852 and/or ASTM F2280 bolts), the preventive actions for storage, lubricant selection, 

and bolting and coating material selection discussed in Section 2 of Research Council for 

Structural Connection publication “Specification for Structural Joints Using High-Strength 

Bolts,” need to be used.

3. Parameters Monitored or Inspected: For each structure/aging effect combination, the

specific parameters monitored or inspected depend on the particular SC or commodity.

Parameters monitored or inspected are commensurate with industry codes, standards,

and guidelines and also consider industry and plant-specific operating experience (OE).

ACI 349.3R and SEI/ASCE 11 provide an acceptable basis for selection of parameters to

be monitored or inspected for concrete and steel structural elements and for steel liners,

joints, coatings, and waterproofing membranes (if applicable).

For concrete structures, parameters monitored include loss of material, cracking, increase 

in porosity and permeability, loss of strength, and reduction in concrete anchor capacity 

due to local concrete degradation. Steel SCs are monitored for loss of material due to 

corrosion. Structural steel bracing and edge supports associated with masonry walls are 

inspected for deflection or distortion, loose bolts, and loss of material due to corrosion. 

Painted or coated areas are examined for signs of distress that could indicate degradation 

of the underlying material. 

Bolting within the scope of the program is monitored for loss of material, loose bolts, 

missing or loose nuts, and other conditions indicative of loss of preload. In addition, 

concrete around anchor bolts is monitored for degradation. 

Accessible sliding surfaces are monitored for indication of significant loss of material due 

to wear or corrosion, and for accumulation of debris or dirt. Elastomeric vibration isolators, 

structural sealants, and seismic joint fillers are monitored for cracking, loss of material, and 

hardening. Groundwater chemistry (pH, chlorides, and sulfates) is monitored periodically 

to assess its impact, if any, on below-grade concrete structures. If through-wall leakage or 

groundwater infiltration is identified, leakage volumes and chemistry are monitored and 

trended for signs of concrete or steel reinforcement degradation. 

If necessary for managing settlement and erosion of porous concrete subfoundations, the 

continued functionality of a site dewatering system is monitored.
XI.S6-3 

4. Detection of Aging Effects: Structures are monitored under this program using periodic

visual inspection of each structure/aging effect combination by a qualified inspector to

ensure that aging degradation will be detected and quantified before there is loss of

intended function. It may be necessary to enhance or supplement visual inspections with

nondestructive examination, destructive testing and/or analytical methods, based on the

conditions observed or the parameter being monitored. Visual inspection of elastomeric

elements is supplemented by tactile inspection to detect hardening if the intended function

is suspect.

The inspection frequency depends on safety significance and the condition of the structure 

as specified in NRC RG 1.160. In general, all structures are monitored on an interval not 

to exceed 5 years. The program includes provisions for more frequent inspections based 

on an evaluation of the observed degradation. The responsible engineer for this program 

evaluates groundwater chemistry that is sampled from a location that is representative of 

the groundwater in contact with structures within the scope of subsequent license renewal. 

This can be done on an interval not to exceed 5 years as long as the evaluation accounts 

for seasonal variations (e.g., quarterly monitoring every 5th year). Inspector qualifications 

should be consistent with industry guidelines and standards and guidelines for 

implementing the requirements of 10 CFR 50.65. Qualifications of inspection and 

evaluation personnel specified in ACI 349.3R are acceptable for inspection of concrete 

structures. 

Indications of groundwater infiltration or through-concrete leakage are assessed for aging 

effects. This may include engineering evaluation, more frequent inspections, or 

destructive testing of affected concrete to validate existing concrete properties, including 

concrete pH levels. When leakage volumes allow, assessments may include analysis of 

the leakage pH, along with mineral, chloride, sulfate and iron content in the water. 

The structures monitoring program addresses detection of aging affects for inaccessible, 

below-grade concrete structural elements. For plants with nonaggressive groundwater/soil 

(pH > 5.5, chlorides < 500 ppm, and sulfates <1,500 ppm), the program recommends: 

(a) evaluating the acceptability of inaccessible areas when conditions exist in accessible 

areas that could indicate the presence of, or result in, degradation to such inaccessible 

areas and (b) examining representative samples of the exposed portions of the belowgrade concrete, when excavated for any reason.

For plants with aggressive groundwater/soil (pH < 5.5, chlorides > 500 ppm, or sulfates 

> 1,500 ppm) and/or where the concrete structural elements have experienced 

degradation, a plant-specific AMP accounting for the extent of the degradation 

experienced should be implemented to manage the concrete aging during the subsequent 

period of extended operation. The plant-specific AMP may include evaluations, 

destructive testing, and/or focused inspections of representative accessible (leading 

indicator) or below-grade, inaccessible concrete structural elements exposed to 

aggressive groundwater/soil, on an interval not to exceed 5 years.

5. Monitoring and Trending: Results of periodic inspections are documented and

compared to previous results to identify changes from prior inspections. Where practical,

identified degradation is projected until the next scheduled inspection. Results are

evaluated against acceptance criteria to confirm that the timing of subsequent inspections

will maintain the components’ intended functions throughout the subsequent period of

extended operation based on the projected rate of degradation. Quantitative
XI.S6-4

measurements and qualitative information are recorded and trended for findings that 

exceed the acceptance criteria described in Element 6 for all applicable parameters 

monitored or inspected. The use of photographs or surveys is encouraged and 

photographic records may be used to document and trend the type, severity, extent and 

progression of degradation.

Quantitative baseline inspection data should be established per the acceptance criteria 

described herein prior to the subsequent period of extended operation. Previously 

performed inspections that were conducted using comparable acceptance criteria 

specified herein are acceptable in lieu of performing a new baseline inspection.

6. Acceptance Criteria: Inspection results are evaluated by qualified engineering personnel 

based on acceptance criteria selected for each structure/aging effect to ensure that the 

need for corrective actions is identified before loss of intended functions. The criteria 

are derived from applicable codes and standards that include but are not limited to 

ACI 349.3R, ACI 318, SEI/ASCE 11, or the relevant AISC specifications and consider 

industry and plant OE. The criteria are directed at the identification and evaluation of 

degradation that may affect the ability of the structure or component to perform its 

intended function. Justified quantitative acceptance criteria are used whenever applicable. 

Acceptance criteria for concrete surfaces based on the “second-tier” evaluation criteria 

provided in Chapter 5 of ACI 349.3R are acceptable. Applicants who elect to use 

plant-specific criteria for concrete structures should describe the criteria and provide a 

technical basis for deviations from those in ACI 349.3R. Loose bolts and nuts are not 

acceptable unless accepted by engineering evaluation. Structural sealants are acceptable 

if the observed loss of material, cracking, and hardening will not result in loss of sealing. 

Elastomeric vibration isolation elements are acceptable if there is no loss of material, 

cracking, or hardening that could lead to the reduction or loss of isolation function. 

Acceptance criteria for sliding surfaces are (a) no indications of excessive loss of material 

due to corrosion or wear and (b) no debris or dirt that could restrict or prevent sliding of the 

surfaces as required by design. The structures monitoring program is to contain sufficient 

detail on acceptance criteria to conclude that this program attribute is satisfied.

7. Corrective Actions: Results that do not meet the acceptance criteria are addressed in 

the applicant’s corrective action program under those specific portions of the quality 

assurance (QA) program that are used to meet Criterion XVI, “Corrective Action,” of 

10 CFR Part 50, Appendix B. Appendix A of the GALL-SLR Report describes how an 

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the corrective 

actions element of this AMP for both safety-related and nonsafety-related SCs within the 

scope of this program. If any projected inspection results will not meet acceptance criteria 

prior to the next scheduled inspection, inspection frequencies are adjusted as determined 

by the site’s corrective action program.

8. Confirmation Process: The confirmation process is addressed through those specific 

portions of the QA program that are used to meet Criterion XVI, “Corrective Action,” of 

10 CFR Part 50, Appendix B. Appendix A of the GALL-SLR Report describes how an 

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the confirmation 

process element of this AMP for both safety-related and nonsafety-related SCs within the 

scope of this program. 
XI.S6-5

9. Administrative Controls: Administrative controls are addressed through the QA program 

that is used to meet the requirements of 10 CFR Part 50, Appendix B, associated with 

managing the effects of aging. Appendix A of the GALL-SLR Report describes how an 

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the 

administrative controls element of this AMP for both safety-related and nonsafety-related 

SCs within the scope of this program.

10. Operating Experience: NUREG–1522 documents the results of a survey sponsored in 

1992 by the Office of Nuclear Reactor Regulation to obtain information on the types of 

distress in the concrete and steel SCs, the type of repairs performed, and the durability of 

the repairs. Licensees who responded to the survey reported cracking, scaling, and 

leaching of concrete structures. The degradation was attributed to drying shrinkage, 

freeze-thaw, and abrasion. The NUREG also describes the results of NRC staff 

inspections at six plants. The staff observed concrete degradation, corrosion of 

component support members and anchor bolts, cracks and other deterioration of masonry 

walls, and groundwater leakage and seepage into underground structures. Information 

Notice (IN) 2011-20 discusses an instance of groundwater infiltration leading to alkali-silica 

reaction degradation in below-grade concrete structures, while IN 2004-05 and 

IN 2006-13 discusses instances of through-wall water leakage from spent fuel pools. 

NUREG/CR–7111 provides a summary of aging effects of safety-related concrete 

structures. Many license renewal applicants have found it necessary to enhance their 

Structures Monitoring program to ensure that the aging effects of SCs in the scope of 

10 CFR 54.4 are adequately managed during the subsequent period of extended 

operation. There is reasonable assurance that implementation of the structures 

monitoring program described above will be effective in managing the aging of the 

in-scope SC supports through the period of subsequent license renewal.

The program is informed and enhanced when necessary through the systematic and 

ongoing review of both plant-specific and industry OE including research and development 

such that the effectiveness of the AMP is evaluated consistent with the discussion in 

Appendix B of the GALL-SLR Report.

References

10 CFR Part 50, Appendix B, “Quality Assurance Criteria for Nuclear Power Plants and Fuel 

Reprocessing Plants.” Washington, DC: U.S. Nuclear Regulatory Commission. 2016.

10 CFR 50.65, “Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power 

Plants.” Washington, DC: U.S. Nuclear Regulatory Commission. 2016.

10 CFR 54.4, “Scope.” Washington, DC: U.S. Nuclear Regulatory Commission. 2016.

ACI. ACI Standard 201.1R-08, “Guide for Conducting a Visual Inspection of Concrete in Service.”

Farmington Hills, Michigan: American Concrete Institute. 2008.

_____. ACI Standard 318-95, “Building Code Requirements for Reinforced Concrete and 

Commentary.” Farmington Hills, Michigan: American Concrete Institute. 1995.

_____. ACI Standard 349.3R-02, “Evaluation of Existing Nuclear Safety-Related Concrete 

Structures.” Farmington Hills, Michigan: American Concrete Institute. 2002.
XI.S6-6

AISC. “AISC Specification for Steel Buildings.” Chicago, Illinois: American Institute of Steel 

Construction, Inc. 2005.

ASCE. SEI/ASCE 11-99, “Guideline for Structural Condition Assessment of Existing Buildings.” 

Reston, Virginia: American Society of Civil Engineers. 2000.

EPRI. EPRI NP-5067, “Good Bolting Practices, A Reference Manual for Nuclear Power Plant 

Maintenance Personnel.” Volume 1: Large Bolt Manual, 1987; Volume 2: Small Bolts and 

Threaded Fasteners. Palo Alto, California: Electric Power Research Institute. 1990.

_____. EPRI TR–104213, “Bolted Joint Maintenance & Application Guide.” 

Palo Alto, California: Electric Power Research Institute. December 1995.

NEI. NUMARC 93-01, “Industry Guideline for Monitoring the Effectiveness of Maintenance at 

Nuclear Power Plants.” Revision 4A. Agencywide Documents Access and Management System 

(ADAMS) Accession No. ML11116A198. Washington, DC: Nuclear Energy Institute. 2011.

NRC. Information Notice 2004-05, “Spent Fuel Pool Leakage to Onsite Groundwater.” 

Washington, DC: U.S. Nuclear Regulatory Commission. March 2004.

_____. Information Notice 2006-13, “Groundwater Contamination due to Undetected Leakage of 

Radioactive Water.” Washington, DC: U.S. Nuclear Regulatory Commission. July 2006.

_____. Information Notice 2011-20, “Concrete Degradation by Alkali-Silica Reaction.” 

Washington, DC: U.S. Nuclear Regulatory Commission. November 2011.

_____. NUREG–1522, “Assessment of Inservice Condition of Safety-Related Nuclear Power 

Plant Structures.” Washington, DC: U.S. Nuclear Regulatory Commission. June 1995.

_____. NUREG/CR–7111, “A Summary of Aging Effects and Their Management in Reactor 

Spent Fuel Pools, Refueling Cavities, Tori, and Safety-Related Concrete Structures.” ADAMS 

Accession No. ML12047A184. Washington, DC: U.S. Nuclear Regulatory Commission. 

January 2012.

_____. Regulatory Guide 1.127, “Inspection of Water-Control Structures Associated With Nuclear 

Power Plants.” Revision 1. ADAMS Accession No. ML003739392. Washington, DC: 

U.S. Nuclear Regulatory Commission. 1978.

_____. Regulatory Guide 1.142, “Safety-Related Concrete Structures for Nuclear Power Plants 

(Other than Reactor Vessels and Containments).” Revision 2. ADAMS Accession No.

ML013100274. Washington, DC: U.S. Nuclear Regulatory Commission. 1997.

_____. Regulatory Guide 1.160, “Monitoring the Effectiveness of Maintenance at Nuclear Power 

Plants.” ADAMS Accession No. ML1136100898. Revision 3. Washington, DC: U.S. Nuclear 

Regulatory Commission. 2012.

RCSC. “Specification for Structural Joints Using High-Strength Bolts.” Chicago, Illinois. 

Research Council on Structural Connections. August 2014.
XI.S7-1 

XI.S7 INSPECTION OF WATER-CONTROL STRUCTURES ASSOCIATED WITH 

NUCLEAR POWER PLANTS

Program Description

This program describes an acceptable basis for developing an inservice inspection (ISI) and 

surveillance program for dams, slopes, canals, and other raw water-control structures associated 

with emergency cooling water systems or flood protection of nuclear power plants (NPPs). The 

program addresses age-related deterioration, degradation due to environmental conditions, and 

the effects of natural phenomena that may affect water-control structures. The program 

recognizes the importance of periodic monitoring and maintenance of water-control structures so 

that the consequences of age-related deterioration and degradation can be prevented or mitigated 

in a timely manner.

The U.S. Nuclear Regulatory Commission (NRC) Regulatory Guide (RG) 1.127, “Inspection of 

Water-Control Structures Associated with Nuclear Power Plants,” provides additional detailed 

guidance for an inspection program for water-control structures, including guidance on

engineering data compilation, inspection activities, technical evaluation, inspection frequency, and 

the content of inspection reports. NRC RG 1.127 delineates current NRC practice in evaluating 

ISI programs for water-control structures.

An aging management program (AMP) addressing water-control structures, commensurate with 

the program elements described below, is expected regardless of whether a plant is committed to 

NRC RG 1.127. Aging management of water-control structures and components (SCs) may be

included in “Structures Monitoring” [Generic Aging Lessons Learned for Subsequent License 

Renewal (GALL-SLR) Report AMP XI.S6]; however, details pertaining to water-control structures, 

as described herein, should be explicitly incorporated and identified in GALL-SLR Report

AMP XI.S6 program attributes if this approach is taken.

Attributes evaluated below do not include inspection of dams. For dam inspection and 

maintenance, programs under the regulatory jurisdiction of the Federal Energy Regulatory 

Commission (FERC) or the U.S. Army Corps of Engineers (USACE), continued through the 

subsequent period of extended operation, are adequate for the purpose of aging management. 

For programs not falling under the regulatory jurisdiction of FERC or the USACE the staff 

evaluates the effectiveness of the AMP based on compatibility to the common practices of the 

FERC and USACE programs.

Evaluation and Technical Basis

1. Scope of Program: The scope includes raw water-control structures associated with

emergency cooling water systems or flood protection of NPPs. The water-control

structures included in the program are concrete structures, embankment structures,

spillway structures and outlet works, reservoirs, cooling water channels and canals, flood

protection walls and gates, and intake and discharge structures. The scope of the

program also includes structural steel, and structural bolting associated with water-control

structures, steel or wood piles and sheeting required for the stability of embankments and

channel slopes, and miscellaneous steel, such as sluice gates and trash racks.
XI.S7-2 

If protective coatings are relied upon to manage the effects of aging for any structures 

included in the scope of this program, the program is to address protective coating 

monitoring and maintenance. Otherwise, coatings on structures within the scope of this 

program are inspected only as an indication of the condition of the underlying material.

2. Preventive Action: This is a Condition Monitoring program. The program is augmented

to include preventive actions to provide reasonable assurance that structural bolting

integrity, as discussed in Electric Power Research Institute (EPRI) documents (such as

EPRI NP-5067 and TR-104213), American Society for Testing and Materials (ASTM)

standards, and American Institute of Steel Construction (AISC) specifications, as

applicable. The preventive actions emphasize proper selection of bolting material and

lubricants, and appropriate installation torque or tension to prevent or minimize loss of

bolting preload and cracking of high-strength bolting. If the structural bolting consists of

ASTM A325 and/or ASTM A490 bolts (including respective equivalent twist-off type

ASTM F1852 and/or ASTM F2280 bolts), the preventive actions for storage, lubricant

selection, and bolting and coating material selection discussed in Section 2 of Research

Council for Structural Connections (publication “Specification for Structural Joints Using

High-Strength Bolts” need to be used).

3. Parameters Monitored or Inspected: NRC RG 1.127 identifies parameters to be

monitored and inspected for water-control structures.

Parameters to be monitored and inspected for concrete structures are those described in

American Concrete Institute (ACI) 201.1R and ACI 349.3R. These include cracking,

movements (e.g., settlement, heaving, and deflection), conditions at junctions with

abutments and embankments, loss of material, increase in porosity and permeability,

seepage, and leakage.

Parameters to be monitored and inspected for earthen embankment structures include

settlement, depressions, sink holes, slope stability (e.g., irregularities in alignment and

variances from originally constructed slopes), seepage, proper functioning of drainage

systems, and degradation of slope protection features. Parameters monitored for

channels and canals include erosion or degradation that may impose constraints on the

function of the cooling system and present a potential hazard to the safety of the plant.

Submerged emergency canals (e.g., artificially dredged canals at the river bed or the

bottom of the reservoir) are monitored for sedimentation, debris, or instability of slopes that

may impair the function of the canals under extreme low flow conditions.

Further details of parameters to be monitored and inspected for these and other

water-control structures are specified in Section C of NRC RG 1.127.

Steel components are monitored for loss of material due to corrosion.

Painted or coated areas are examined for signs of distress that could indicate degradation

of the underlying material.

Bolting within the scope of the program is monitored for loss of material, loose bolts,

missing or loose nuts, and other conditions indicative of loss of preload. In addition,

concrete around anchor bolts is monitored for cracking.
XI.S7-3 

Accessible sliding surfaces are monitored for indication of loss of material due to wear or 

corrosion, and accumulation of debris or dirt. 

Wooden components are monitored for loss of material and change in material properties. 

4. Detection of Aging Effects: Inspection of water-control structures is conducted under

the direction of qualified engineers experienced in the investigation, design, construction,

and operation of these types of facilities. Qualifications of inspection and evaluation

personnel specified in ACI 349.3R are acceptable for reinforced concrete water control

structures. Visual inspections are primarily used to detect degradation of water-control

structures. In some cases, instruments have been installed to measure the behavior of

water-control structures. Available records and readings of installed instruments are to

be reviewed to detect any unusual performance or distress that may be indicative of

degradation. Periodic inspections are to be performed at least once every 5 years. This

interval has been shown to be adequate to detect degradation of water-control structures

before a loss of an intended function. The program includes provisions for increased

inspection frequency based on an evaluation of the observed degradation. The program

also includes provisions for special inspections immediately following the occurrence of

significant natural phenomena, such as large floods, earthquakes, hurricanes, tornadoes,

or intense local rainfalls. The responsible engineer for this program evaluates raw water

and groundwater chemistry that is sampled from a location that is representative of the

water in contact with structures within the scope of subsequent license renewal. This can

be done on an interval not to exceed 5 years as long as the evaluation accounts for

seasonal variations (e.g., quarterly monitoring every 5th year).

Indications of groundwater infiltration or through-concrete leakage are assessed for aging 

effects. This may include engineering evaluation, more frequent inspections, or 

destructive testing of affected concrete to validate existing concrete properties, including 

concrete pH levels. When leakage volumes allow, assessments may include analysis of 

the leakage pH, along with mineral, chloride, sulfate and iron content in the water.

The program addresses detection of aging affects for inaccessible, below-grade, and 

submerged concrete structural elements. For plants with nonaggressive raw water and 

groundwater/soil [pH > 5.5, chlorides < 500 parts per million (ppm), and sulfates 

< 1,500 ppm], the program includes (a) evaluation of the acceptability of inaccessible 

areas when conditions exist in accessible areas that could indicate the presence of, or 

result in, degradation to such inaccessible areas and (b) examination of representative 

samples of the exposed portions of the below-grade concrete when excavated for any 

reason. Submerged concrete structures may be inspected during periods of low tide or 

when dewatered. Plant-specific justification is provided in the subsequent license renewal 

application for the acceptability of submerged concrete if inspections do not occur within 

the 5 year interval. Areas covered by silt, vegetation, or marine growth are not considered 

inaccessible and are cleaned and inspected in accordance with the standard inspection 

frequency.

For plants with aggressive raw water (pH < 5.5, chlorides > 500 ppm, or sulfates 

> 1,500 ppm) or groundwater/soil and/or where the structural elements have experienced 

degradation, a plant-specific AMP accounting for the extent of the degradation 

experienced is implemented to manage aging during the subsequent period of extended 

operation. The plant-specific AMP may include evaluations, destructive testing, and/or 

focused inspections of accessible (leading indicator) or below-grade, inaccessible 
XI.S7-4

structural elements exposed to aggressive raw water or groundwater/soil on an interval 

not to exceed 5 years, and submerged structural elements are visually inspected 

(e.g., dewatering, divers) at least once every 5 years.

5. Monitoring and Trending: Results of periodic inspections are documented and 

compared to previous results to identify changes from prior inspections. Where practical, 

identified degradation is projected until the next scheduled inspection. Results are 

evaluated against acceptance criteria to confirm that the timing of subsequent inspections 

will maintain the components’ intended functions throughout the subsequent period of 

extended operation based on the projected rate of degradation. Quantitative 

measurements and qualitative information are recorded and trended for findings 

exceeding the acceptance criteria described in Element 6 for all applicable parameters 

monitored or inspected. The use of photographs or surveys is encouraged and

photographic records may be used to document and trend the type, severity, extent and 

progression of degradation. 

Quantitative baseline inspection data should be established per the acceptance criteria 

described herein prior to the subsequent period of extended operation. Previously 

performed inspections that were conducted using comparable acceptance criteria 

specified herein are acceptable in lieu of performing a new baseline inspection.

6. Acceptance Criteria: The quantitative “second-tier” evaluation criteria provided in 

Chapter 5 of ACI 349.3R are acceptable for concrete. Applicants who elect to use 

plant-specific criteria for concrete structures should describe the criteria and provide a 

technical basis for deviations from those in ACI 349.3R. Acceptance criteria for earthen 

structures, such as canals and embankments, are consistent with programs falling within 

the regulatory jurisdiction of the FERC or the USACE. Loose bolts and nuts, and 

degradation of piles and sheeting are accepted by engineering evaluation or subject to 

corrective actions. Engineering evaluation is documented and based on codes, 

specifications, and standards such as AISC specifications, Structural Engineering 

Institute/American Society of Civil Engineers Standard 11-99, “Guideline for Structural 

Condition Assessment of Existing Buildings,” and those referenced in the plant’s current 

licensing basis.

7. Corrective Actions: Results that do not meet the acceptance criteria are addressed in 

the applicant’s corrective action program under those specific portions of the quality 

assurance (QA) program that are used to meet Criterion XVI, “Corrective Action,” of 

10 CFR Part 50, Appendix B. Appendix A of the GALL-SLR Report describes how an 

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the corrective 

actions element of this AMP for both safety-related and nonsafety-related SCs within the 

scope of this program.

When inspection findings indicate that significant changes have occurred, the conditions 

are to be evaluated. This includes a technical assessment of the causes of distress or 

abnormal conditions, an evaluation of the behavior or movement of the structure, and 

recommendations for remedial or mitigating measures. If any projected inspection results 

will not meet acceptance criteria prior to the next scheduled inspection, inspection 

frequencies are adjusted as determined by the site’s corrective action program.
XI.S7-5

8. Confirmation Process: The confirmation process is addressed through those specific 

portions of the QA program that are used to meet Criterion XVI, “Corrective Action,” of 

10 CFR Part 50, Appendix B. Appendix A of the GALL-SLR Report describes how an 

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the confirmation 

process element of this AMP for both safety-related and nonsafety-related SCs within the 

scope of this program.

9. Administrative Controls: Administrative controls are addressed through the QA program 

that is used to meet the requirements of 10 CFR Part 50, Appendix B, associated with 

managing the effects of aging. Appendix A of the GALL-SLR Report describes how an 

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the 

administrative controls element of this AMP for both safety-related and nonsafety-related 

SCs within the scope of this program.

10. Operating Experience: Degradation of water-control structures has been detected, 

through NRC RG 1.127 programs, at a number of nuclear power plants, and, in some 

cases, it has required remedial action. NRC NUREG–1522, “Assessment of Inservice 

Conditions of Safety-Related Nuclear Plant Structures” described instances and corrective 

actions of severely degraded steel and concrete components at the intake structure and 

pump house of coastal plants. Other degradation described in the NUREG include 

appreciable leakage from the spillway gates, concrete cracking, corrosion of spillway 

bridge beam seats of a plant dam and cooling canal, and appreciable differential 

settlement of the outfall structure of another. No loss of intended functions has resulted 

from these occurrences. Therefore, it can be concluded that the inspections implemented 

in accordance with the guidance in NRC RG 1.127 have been successful in detecting 

significant degradation before loss of intended function occurs.

The program is informed and enhanced when necessary through the systematic and 

ongoing review of both plant-specific and industry operating experience including research

and development such that the effectiveness of the AMP is evaluated consistent with the 

discussion in Appendix B of the GALL-SLR Report.

References

10 CFR Part 50, Appendix B, “Quality Assurance Criteria for Nuclear Power Plants and Fuel 

Reprocessing Plants.” Washington, DC: U.S. Nuclear Regulatory Commission. 2016.

ACI. ACI Standard 201.1R-08, “Guide for Conducting a Visual Inspection of Concrete in Service.” 

Farmington Hills, Michigan: American Concrete Institute. 2008.

_____. ACI Standard 349.3R-02, “Evaluation of Existing Nuclear Safety-Related Concrete 

Structures.” Farmington Hills, Michigan: American Concrete Institute. 2002.

AISC. “AISC Specification for Steel Buildings.” Chicago, Illinois: American Institute of Steel 

Construction, Inc. 2010.

ASCE. SEI/ASCE 11-99, “Guideline for Structural Condition Assessment of Existing Buildings.” 

Reston, Virginia: American Society of Civil Engineers. 2000.
XI.S7-6

EPRI. EPRI NP-5067, “Good Bolting Practices, A Reference Manual for Nuclear Power Plant 

Maintenance Personnel.” Volume 1: Large Bolt Manual, 1987; Volume 2: Small Bolts and 

Threaded Fasteners. Palo Alto, California: Electric Power Research Institute. 1990.

____. EPRI TR–104213, “Bolted Joint Maintenance & Application Guide.” Palo Alto, California: 

Electric Power Research Institute. December 1995.

NRC. NUREG–1522, “Assessment of Inservice Conditions of Safety-Related Nuclear Plant 

Structures.” Agencywide Documents Access and Management System (ADAMS) Accession 

No. ML06510407. Washington, DC: U.S. Nuclear Regulatory Commission. June 1995.

_____. Regulatory Guide 1.127, “Inspection of Water-Control Structures Associated With Nuclear 

Power Plants.” ADAMS Accession No. ML003739392. Washington, DC: U.S. Nuclear 

Regulatory Commission. March 1978. 

_____. Regulatory Guide 1.160, “Monitoring the Effectiveness of Maintenance at Nuclear Power 

Plants.” ADAMS Accession No. ML12216A016. Washington, DC: U.S. Nuclear Regulatory 

Commission. 1993.

RCSC. “Specification for Structural Joints Using High-Strength Bolts.” Chicago, Illinois: 

Research Council on Structural Connections. August 2014.
XI.S8-1

XI.S8 PROTECTIVE COATING MONITORING AND MAINTENANCE 

Program Description

Proper maintenance of protective coatings inside containment (defined as Service Level I in the 

U.S. Nuclear Regulatory Commission (NRC) Regulatory Guide (RG) 1.54, Revision 1, or latest 

version) is essential to the operability of post-accident safety systems that rely on water recycled 

through the containment sump/drain system. Degradation of coatings can lead to clogging of 

Emergency Core Cooling System (ECCS) suction strainers, which reduces flow through the 

system and could cause unacceptable head loss for the pumps.

Maintenance of Service Level I coatings applied to carbon steel and concrete surfaces inside 

containment (e.g., steel liner, steel containment shell, structural steel, supports, penetrations, and 

concrete walls and floors) also serve to prevent or minimize loss of material due to corrosion of 

carbon steel components and aids in decontamination. Regulatory Position C4 in NRC RG 1.54, 

Revision 2, describes an acceptable technical basis for a Service Level I coatings monitoring and 

maintenance program that can be credited for managing the effects of corrosion for carbon steel 

elements inside containment. American Society for Testing and Materials (ASTM) D 5163-08 and 

endorsed years of the standard in NRC RG 1.54 are acceptable and considered consistent with 

the Generic Aging Lessons Learned for Subsequent License Renewal (GALL-SLR) Report. In 

addition, Electric Power Research Institute Report 1019157, “Guideline on Nuclear Safety-Related 

Coatings,” provides additional information on the ASTM standard guidelines.

A comparable program for monitoring and maintaining protective coatings inside containment, 

developed in accordance with NRC RG 1.54, Revision 2, is acceptable as an aging management 

program (AMP) for subsequent license renewal (SLR).

Service Level I coatings credited for preventing corrosion of steel containments and steel liners for 

concrete containments are subject to requirements specified by the American Society of 

Mechanical Engineers Boiler and Pressure Vessel Code, Section XI, Subsection IWE (GALL-SLR

Report AMP XI.S1). However, this program (GALL-SLR Report AMP XI.S8) reviews Service 

Level I coatings to ensure that the protective coating monitoring and maintenance program is

adequate for SLR.

Evaluation and Technical Basis

1. Scope of Program: The minimum scope of the program is Service Level I coatings 

applied to steel and concrete surfaces inside containment (e.g., steel liner, steel 

containment shell, structural steel, supports, penetrations, and concrete walls and floors),

defined in NRC RG 1.54, Revision 2, as follows: “Service Level I coatings are used in 

areas inside the reactor containment where the coating failure could adversely affect the 

operation of post-accident fluid systems and thereby impair safe shutdown.” The scope of 

the program also should include any Service Level I coatings that are credited by the 

licensee for preventing loss of material due to corrosion in accordance with GALL-SLR 

Report AMP XI.S1.

2. Preventive Action: The program is a condition monitoring program and does not 

recommend any preventive actions. However, for plants that credit coatings to minimize 

loss of material, this program is a preventive action.
XI.S8-2

3. Parameters Monitored or Inspected: ASTM D 5163-08 provides guidelines that are 

acceptable to the NRC staff for establishing an inservice coatings monitoring program for 

Service Level I coating systems in operating nuclear power plants, and identifies the 

parameters monitored or inspected to be “any visible defects, such as blistering, cracking, 

flaking, peeling, rusting, and physical damage.”

4. Detection of Aging Effects: ASTM D 5163-08, paragraph 6, defines the inspection 

frequency to be each refueling outage or during other major maintenance outages, as 

needed. ASTM D 5163-08, paragraph 9, discusses the qualifications for inspection 

personnel, the inspection coordinator, and the inspection results evaluator. 

ASTM D 5163-08, subparagraph 10.1, discusses development of the inspection plan and 

the inspection methods to be used. It states that a general visual inspection shall be 

conducted on all readily accessible coated surfaces during a walk-through. After a 

walk-through, or during the general visual inspection, thorough visual inspections shall be 

carried out on previously designated areas and on areas noted as deficient during the 

walk-through. A thorough visual inspection shall also be carried out on all coatings near 

sumps or screens associated with the ECCS. This subparagraph also addresses field 

documentation of inspection results. ASTM D 5163-08, subparagraph 10.5, identifies 

instruments and equipment needed for inspection. 

5. Monitoring and Trending: ASTM D 5163-08 identifies monitoring and trending activities 

in subparagraph 7.2, which specifies a pre-inspection review of the previous two 

monitoring reports, and in subparagraph 11.1.2, which specifies that the inspection report 

should prioritize repair areas as either needing repair during the same outage or as 

postponed to future outages, but under surveillance in the interim period. The assessment 

from periodic inspections and analysis of total amount of degraded coatings in the 

containment is compared with the total amount of permitted degraded coatings to provide 

reasonable assurance of post-accident operability of the ECCS.

6. Acceptance Criteria: ASTM D 5163-08, subparagraphs 10.2.1 through 10.2.6, 10.3, and 

10.4, contains one acceptable method for the characterization, documentation, and testing 

of defective or deficient coating surfaces. Additional ASTM and other recognized test 

methods are available for use in characterizing the severity of observed defects and 

deficiencies. The evaluation covers blistering, cracking, flaking, peeling, delamination, and 

rusting. ASTM D 5163-08, paragraph 11, addresses evaluation. It specifies that the 

inspection report is to be evaluated by the responsible evaluation personnel, who prepare 

a summary of findings and recommendations for future surveillance or repair, and 

prioritization of repairs.

7. Corrective Actions: Results that do not meet the acceptance criteria are addressed in 

the applicant’s corrective action program under those specific portions of the quality 

assurance (QA) program that are used to meet Criterion XVI, “Corrective Action,” of 

Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B. Appendix A of 

the GALL-SLR Report describes how an applicant may apply its 10 CFR Part 50, 

Appendix B, QA program to fulfill the corrective actions element of this AMP for both 

safety-related and nonsafety-related structures and components (SCs) within the scope of 

this program.

A recommended corrective action plan is required for major defective areas so that these 

areas can be repaired during the same outage, if appropriate. 
XI.S8-3

8. Confirmation Process: The confirmation process is addressed through those specific 

portions of the QA program that are used to meet Criterion XVI, “Corrective Action,” of 

10 CFR Part 50, Appendix B. Appendix A of the GALL-SLR Report describes how an 

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the confirmation 

process element of this AMP for both safety-related and nonsafety-related SCs within the 

scope of this program. 

9. Administrative Controls: Administrative controls are addressed through the QA program 

that is used to meet the requirements of 10 CFR Part 50, Appendix B, associated with 

managing the effects of aging. Appendix A of the GALL-SLR Report describes how an 

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the 

administrative controls element of this AMP for both safety-related and nonsafety-related 

SCs within the scope of this program.

10. Operating Experience: NRC Information Notice 88-82, NRC Bulletin 96-03, NRC 

Generic Letter (GL) 04-02, and NRC GL 98-04 describe industry experience pertaining to 

coatings degradation inside containment and the consequential clogging of sump 

strainers. NRC RG 1.54, Revision 1, was issued in July 2000. Monitoring and 

maintenance of Service Level I coatings conducted in accordance with Regulatory 

Position C4 is expected to be an effective program for managing degradation of Service 

Level I coatings and, consequently, an effective means to manage loss of material due to 

corrosion of carbon steel structural elements inside containment. 

The program is informed and enhanced when necessary through the systematic and 

ongoing review of both plant-specific and industry operating experience including research

and development such that the effectiveness of the AMP is evaluated consistent with the 

discussion in Appendix B of the GALL-SLR Report.

References

10 CFR Part 50, Appendix B, “Quality Assurance Criteria for Nuclear Power Plants and Fuel 

Reprocessing Plants.” Washington, DC: U.S. Nuclear Regulatory Commission. 2016.

ASTM. ASTM D 5163-05, “Guide for Establishing Procedures to Monitor the Performance of 

Coating Service Level I Coating Systems in an Operating Nuclear Power Plant.” 

West Conshohocken, Pennsylvania: American Society for Testing and Materials. 2005.

_____. ASTM D 5163-08, “Standard Guide for Establishing a Program for Condition Assessment 

of Coating Service Level I Coating Systems in Nuclear Power Plants.” West Conshohocken, 

Pennsylvania: American Society for Testing and Materials. 2008.

_____. ASTM D 5163-96, “Standard Guide for Establishing Procedures to Monitor the 

Performance of Safety Related Coatings in an Operating Nuclear Power Plant.” 

West Conshohocken, Pennsylvania: American Society for Testing and Materials. 1996.

EPRI. EPRI 1003102, “Guideline on Nuclear Safety-Related Coatings.” Revision 1. (Formerly 

TR-109937). Palo Alto, California: Electric Power Research Institute. November 2001.

_____. EPRI 1019157, “Guideline on Nuclear Safety-Related Coatings.” Revision 2. (Formerly 

TR-109937and 1003102). Palo Alto, California: Electric Power Research Institute. 

December 2009.
XI.S8-4

NRC. Bulletin 96-03, “Potential Plugging of Emergency Core Cooling Suction Strainers by Debris 

in Boiling-Water Reactors.” Washington, DC: U.S. Nuclear Regulatory Commission. May 1996.

_____. Generic Letter 04-02, “Potential Impact of Debris Blockage on Emergency Recirculation 

During Design Basis Accidents at Pressurized-Water Reactors.” Washington, DC: U.S. Nuclear 

Regulatory Commission. September 2004.

_____. Generic Letter 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.” Washington, DC: 

U.S. Nuclear Regulatory Commission. July 1998.

_____. Information Notice 88-82, “Torus Shells with Corrosion and Degraded Coatings in BWR 

Containments.” Washington, DC: U.S. Nuclear Regulatory Commission. November 1988.

_____. Information Notice 97-13, “Deficient Conditions Associated With Protective Coatings at 

Nuclear Power Plants.” Washington, DC: U.S. Nuclear Regulatory Commission. March 1997.

_____. Regulatory Guide 1.54, “Quality Assurance Requirements for Protective Coatings Applied 

to Water-Cooled Nuclear Power Plants.” Revision 0. Washington, DC: U.S. Nuclear Regulatory 

Commission. June 1973.

_____. Regulatory Guide 1.54, “Service Level I, II, and III Protective Coatings Applied to Nuclear 

Power Plants.” Revision 1. Washington, DC: U.S. Nuclear Regulatory Commission. July 2000.

_____. Regulatory Guide 1.54, “Service Level I, II, and III Protective Coatings Applied to Nuclear 

Power Plants.” Revision 2. Washington, DC: U.S. Nuclear Regulatory Commission. 

October 2010.
XI.E1-1

XI.E1 ELECTRICAL INSULATION FOR ELECTRICAL CABLES AND 

CONNECTIONS NOT SUBJECT TO 10 CFR 50.49 ENVIRONMENTAL 

QUALIFICATION REQUIREMENTS

Program Description

The purpose of this aging management program (AMP) is to provide reasonable assurance that 

the intended functions of electrical cable insulating material (e.g., power, control, and 

instrumentation) and connection insulating material that are not subject to the environmental 

qualification (EQ) requirements of Title 10 of the Code of Federal Regulations (10 CFR) 50.49 

are maintained consistent with the current licensing basis through the subsequent period of 

extended operation.

In most areas within a nuclear power plant, the actual operating environment (e.g., temperature, 

radiation, or moisture) is less severe than the plant design basis environment. However, in a 

limited number of localized areas, the actual environment may be more severe than the 

anticipated plant design basis environment. These localized areas are characterized as “adverse 

localized environments” that represent a limited plant area where the operating environment is 

significantly more severe than the plant design environment.

An adverse localized environment is an environment that exceeds the most limiting environment 

(e.g., temperature, radiation, or moisture) for the electrical insulation of cables and connectors. 

Electrical insulation used in electrical cables and connections may degrade more rapidly than 

expected when exposed to an adverse localized environment. Cable or connection electrical 

insulation subjected to an adverse localized environment may increase the rate of aging of a 

component or have an adverse effect on operability.

Adverse localized environments are identified through the use of an integrated approach. This 

approach includes, but is not limited to: (a) the review of EQ program radiation levels, 

temperatures, and moisture levels; (b) recorded information from equipment or plant 

instrumentation; (c) as-built and field walk down data (e.g., cable routing data base); (d) a plant 

spaces scoping and screening methodology; and (e) the review of relevant plant-specific and 

industry operating experience (OE). This OE includes, but is not limited to: 

• Identification of work practices that have the potential to subject in-scope cable and 

connection electrical insulation to an adverse localized environment (e.g., equipment 

thermal insulation removal and restoration);

• Corrective actions involving in-scope electrical cable and connection electrical insulation 

material service life (current operating term);

• Previous walk-downs including visual inspection of accessible cable and connection 

electrical insulation; and

• Environmental monitoring (e.g., long term periodic environmental monitoring–temperature, 

radiation, or moisture). 

Periodic environmental monitoring consists of a representative number of environmental 

measurements taken over a sufficient period of time and periodically evaluated to establish the 

environment for condition monitoring electrical insulation. Plant environmental data can be used 

in an aging evaluation in different ways, such as directly applying the plant data in the evaluation
XI.E1-2

or using the plant data to demonstrate conservatism. The methodology employed for monitoring, 

data collection, and the analysis of localized component environmental data (including 

temperature, radiation, and moisture) is documented in the record of the analysis. Documentation 

is provided, as needed, on the applicability of methodologies utilizing data that are collected and 

evaluated once, or are of limited duration.

Accessible in-scope cables and connections are visually inspected for degradation. Visual 

inspection findings may necessitate testing. Testing is comprised of one or more tests utilizing 

mechanical, electrical, or chemical means implemented on a sampling basis and represents with 

reasonable assurance, both accessible and inaccessible in-scope cable and connection electrical 

insulation degradation.

Accessible in-scope cable and connection inspection is considered a visual inspection performed 

from the floor, with the use of scaffolding as available, without the opening of junction boxes, pull 

boxes, or terminal boxes. The purpose of the visual inspection is to identify adverse localized 

environments (employing diagnostic tools such as thermography as applicable). These potential 

adverse localized environments are then evaluated, which may require further inspection using 

scaffolding or other means (e.g., opening of junction boxes, pull boxes, accessible pull points, 

panels, terminal boxes, and junction boxes) to assess cable and connector electrical insulation 

aging degradation.

The cable condition monitoring portion of the AMP utilizes component sampling for cable and 

connection electrical insulation testing, if deemed necessary. The following factors are 

considered in the development of the electrical insulation sample: the environment including 

identified adverse localized environments (high temperature, high humidity, vibration, etc.), 

voltage level, circuit loading, connection type, location (high temperature, high humidity, vibration, 

etc.) and the electrical insulation composition. The component sampling methodology utilizes a 

population that includes a representative sample of in-scope electrical cable and connection types 

regardless of whether or not the component was included in a previous aging management or 

maintenance program. The technical basis for the sample selection is documented.

Electrical insulation material for cables and connections previously identified and dispositioned 

during the first period of extended operation as subjected to an adverse localized environment are 

evaluated for cumulative aging effects during the subsequent period of extended operation. If an 

unacceptable condition or situation is identified for cable or connection electrical insulation by 

visual inspection or test, corrective actions are taken including a determination as to whether the 

same condition or situation is applicable to other in-scope accessible and inaccessible cable or 

connection electrical insulation (e.g., extent of condition). As such, this program does not apply to 

plants in which most cables are inaccessible.

As stated in NUREG/CR–5643, “the major concern is that failures of deteriorated cable systems 

(cables, connection electrical insulation) might be induced during accident conditions.” Since the 

cable and connection electrical insulation is not subject to the EQ requirements of 10 CFR 50.49, 

an AMP is needed to manage the aging mechanisms and effects for the subsequent period of 

extended operation. This AMP provides reasonable assurance that the insulation for electrical 

cables and connections will perform its intended function for the subsequent period of extended 

operation.
XI.E1-3 

Evaluation and Technical Basis

1. Scope of Program: This AMP applies to accessible cable and connection electrical

insulation within the scope of subsequent license renewal including in-scope cables and

connections subjected to an adverse localized environment.

2. Preventive Actions: This is a condition monitoring program and no actions are taken as

part of this program to prevent or mitigate aging degradation.

3. Parameters Monitored or Inspected: Accessible in-scope cable and connection

electrical insulation subject to an adverse localized environment are visually inspected for

surface anomalies. The cable insulation visual inspection portion of the AMP uses the

cable or connection jacket material as representative of the aging effects experienced by

the cable and connection electrical insulation. Cable and connection electrical insulation

material are evaluated for signs of reduced electrical insulation resistance due to an

adverse localized environment of temperature, moisture, radiation and oxygen that

includes radiolysis, photolysis (ultraviolet sensitive materials only) of organics, radiation

induced oxidation, moisture intrusion, indicated by signs of electrical insulation

embrittlement, discoloration, cracking, melting, swelling or surface contamination.

An adverse localized environment is a plant-specific condition; therefore, the applicant 

should clearly define the most limiting temperature, radiation, and moisture environments 

and their basis. For the subsequent period of extended operation, the applicant reviews 

plant-specific OE for previously identified and mitigated adverse localized environments 

cumulative aging effects applicable to in-scope cable and connection electrical insulation 

(i.e., service life). The applicant should also inspect for adverse localized environments for 

each of the most limiting cable and connection electrical insulation plant environments 

(e.g., caused by temperature, radiation, moisture, or contamination).

4. Detection of Aging Effects: Aging effects resulting from temperature, radiation, or

moisture cause surface abnormalities in the cable jacket, and connection material.

Accessible electrical cables and connections are visually inspected for cable jacket and

connection electrical insulation surface anomalies such as embrittlement, discoloration,

cracking, melting, swelling, or surface contamination. Cable and connection electrical

insulation are inspected to identify cable and connection insulation installed in an adverse

localized environment. Plant-specific OE is also evaluated to identify in-scope cable and

connection insulation previously subjected to adverse localized environment during the

period of extended operation. Cable and connection insulation are evaluated to confirm

that the dispositioned corrective actions continue to support in-scope cable and connection

intended functions during the subsequent period of extended operation.

The inspection of accessible cable and connection insulation material is used to evaluate 

the adequacy of inaccessible cable and connection electrical insulation. Accessible 

electrical cables and connections subjected to an adverse localized environment found in 

the performance of this AMP are visually inspected at least once every 10 years. This is 

an adequate period to preclude failures of the cables and connection electrical insulation 

since experience has shown that aging degradation is a slow process. If visual 

inspections identify degraded or damaged conditions as defined in Element 3 of this AMP, 

then testing may be performed for evaluation. For a large number of cables and 

connections identified as potentially degraded, a sample population is tested. The first 

inspection for subsequent license renewal is to be completed prior to the subsequent 
XI.E1-4

period of extended operation. Testing may include thermography and other proven 

condition monitoring test methods applicable to the cable and connection insulation. 

Testing as part of an existing maintenance, calibration or surveillance program may be 

credited in lieu of testing recommended in this AMP.

This AMP, as noted, is a cable and connection electrical insulation condition monitoring 

program that utilizes sampling. A sample of 20 percent of each cable and connection type 

with a maximum sample size of 25 is tested. The following factors are considered in the 

development of the cable and connection insulation test sample: environment including 

identified adverse localized environments (high temperature, high humidity, vibration, etc.), 

voltage level, circuit loading, connection type, location (high temperature, high humidity, 

vibration, etc.), and insulation material. The component sampling methodology utilizes a 

population that includes a representative sample of in-scope electrical cable and 

connection types regardless of whether or not the component was included in a previous 

aging management or maintenance program. The technical basis for the sample selection 

is documented.

5. Monitoring and Trending: Trending actions are not included as part of this AMP, 

because the ability to trend visual inspection and test results is dependent on the test or

visual inspection program selected. However, condition monitoring of cable and 

connection insulation utilizing visual inspection and test results that are trendable provide 

additional information on the rate of cable or connection insulation degradation.

6. Acceptance Criteria: Electrical cable and connection insulation material test results are 

to be within the acceptance criteria, as identified in the applicant’s procedures. Visual 

inspection results show that accessible cable and connection insulation material are free 

from unacceptable signs of surface abnormalities that indicate unusual cable or 

connection insulation aging effects exist. An unacceptable indication is defined as a 

noted condition or situation that, if left unmanaged, could potentially lead to a loss of the 

intended function.

7. Corrective Actions: Results that do not meet the acceptance criteria are addressed in 

the applicant’s corrective action program under those specific portions of the quality 

assurance (QA) program that are used to meet Criterion XVI, “Corrective Action,” of 

10 CFR Part 50, Appendix B. Appendix A of the Generic Aging Lessons Learned for 

Subsequent License Renewal (GALL-SLR) Report describes how an applicant may apply 

its 10 CFR Part 50, Appendix B, QA program to fulfill the corrective actions element of this 

AMP for both safety-related and nonsafety-related structures and components (SCs) 

within the scope of this program. 

Unacceptable test results and visual indications of cable and connection electrical 

insulation abnormalities are subject to an engineering evaluation. Such an evaluation 

considers the age and operating environment of the component, as well as the severity of 

the abnormality and whether such an abnormality has previously been correlated to 

degradation of cable or connection insulation. Corrective actions include, but are not 

limited to, testing, shielding, or otherwise mitigating the environment or relocation or 

replacement of the affected cables or connections. When an unacceptable condition or 

situation is identified, a determination is made as to whether the same condition or 

situation is applicable to additional in-scope accessible and inaccessible cables or 

connections (extent of condition).
XI.E1-5

8. Confirmation Process: The confirmation process is addressed through those specific 

portions of the QA program that are used to meet Criterion XVI, “Corrective Action,” of 

10 CFR Part 50, Appendix B. Appendix A of the GALL-SLR Report describes how an 

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the confirmation 

process element of this AMP for both safety-related and nonsafety-related SCs within the 

scope of this program.

9. Administrative Controls: Administrative controls are addressed through the QA program 

that is used to meet the requirements of 10 CFR Part 50, Appendix B, associated with 

managing the effects of aging. Appendix A of the GALL-SLR Report describes how an 

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the 

administrative controls element of this AMP for both safety-related and nonsafety-related 

SCs within the scope of this program.

10. Operating Experience: Industry OE has identified cable and connection insulation aging 

effects due to adverse localized environments caused by elevated temperature, radiation, 

or moisture. For example, cable and connection insulation located near steam generators, 

pressurizers, or process may be subjected to an adverse localized environment. These 

environments have been found to cause degradation of electrical cable and connection 

electrical insulation that are visually observable, such as color changes or surface 

abnormalities. These visual indications along with cable condition monitoring can be used 

as indicators of cable and connection insulation degradation.

The program is informed and enhanced when necessary through the systematic and 

ongoing review of both plant-specific and industry OE including research and development 

such that the effectiveness of the AMP is evaluated consistent with the discussion in 

Appendix B of the GALL-SLR Report.

References

10 CFR Part 50, Appendix B, “Quality Assurance Criteria for Nuclear Power Plants and Fuel 

Reprocessing Plants.” Washington, DC: U.S. Nuclear Regulatory Commission. 2016.

EPRI. EPRI TR–109619, “Guideline for the Management of Adverse Localized Equipment 

Environments.” Palo Alto, California: Electric Power Research Institute. June 1999.

IEEE. IEEE Standard 422-2012, “Guide for the Design of Cable Raceway Systems for Electric 

Generating Facilities.” New York, New York: Institute of Electrical and Electronic Engineers. 

2012.

_____. IEEE Standard 576-2000, “Recommended Practice for Installation, Termination, and 

Testing of Insulated Power Cable as Used in Industrial and Commercial Applications.” New York, 

New York: Institute of Electrical and Electronics Engineers. 2000.

_____. IEEE Standard 1205-2014, “IEEE Guide for Assessing, Monitoring and Mitigating Aging 

Effects on Class 1E Equipment Used in Nuclear Power Generating Stations.” New York, 

New York: Institute of Electrical and Electronics Engineers. 2014.
XI.E1-6 

NRC. Generic Letter 2007-01, “Inaccessible or Underground Power Cable Failures that Disable 

Accident Mitigation Systems or Cause Plant Transients.” Agencywide Documents Access and 

Management System (ADAMS) Accession No. ML070360665. Washington, DC: U.S. Nuclear 

Regulatory Commission. February 7, 2007.

_____. Information Notice 2010-2, “Construction Related Experience With Cables Connectors, 

and Junction Boxes.” ADAMS Accession No. ML090290185. Washington, DC: U.S. Nuclear 

Regulatory Commission. January 28, 2010.

_____. Information Notice 2010-25, “Inadequate Electrical Connections.” ADAMS Accession 

No. ML102530012. Washington, DC: U.S. Nuclear Regulatory Commission. 

November 17, 2010.

_____. Information Notice 2010-26, “Submerged Electrical Cables.” ADAMS Accession 

No. ML102800456. Washington, DC: U.S. Nuclear Regulatory Commission. December 2, 2010.

_____. NUREG/CR–5643, “Insights Gained From Aging Research.” ADAMS Accession 

No. ML04153026. Washington, DC: U.S. Nuclear Regulatory Commission. March 31, 1992.

_____. NUREG/CR–7000, “Essential Elements of an Electric Cable Condition Monitoring 

Program.” ADAMS Accession No. ML100540050. Washington, DC: U.S. Nuclear Regulatory 

Commission. January 31, 2010.

_____. Regulatory Guide 1.218, “Condition-Monitoring Techniques for Electric Cables Used In 

Nuclear Power Plants.” ADAMS Accession No. ML103510458. Washington, DC: U.S. Nuclear 

Regulatory Commission. April 30, 2012.

SNL. SAND96-0344, “Aging Management Guideline for Commercial Nuclear Power 

Plants-Electrical Cable and Terminations.” Albuquerque, New Mexico: Sandia National 

Laboratories. September 1996.
XI.E2-1

XI.E2 ELECTRICAL INSULATION FOR ELECTRICAL CABLES AND 

CONNECTIONS NOT SUBJECT TO 10 CFR 50.49 ENVIRONMENTAL 

QUALIFICATION REQUIREMENTS USED IN INSTRUMENTATION 

CIRCUITS 

Program Description

The purpose of this aging management program (AMP) is to provide reasonable assurance that 

the intended functions of electrical cables and connections (that are not subject to the 

environmental qualification requirements of Title 10 of the Code of Federal Regulations 

(10 CFR) 50.49 and are used in instrumentation circuits with sensitive, high voltage, low-level 

current signals) are maintained consistent with the current licensing basis through the subsequent 

period of extended operation. 

In most areas within a nuclear power plant the actual operating environment (e.g., temperature, 

radiation, or moisture) is less severe than the plant design bases environment. However, in a 

limited number of localized areas, the actual environment may be more severe than the plant 

design bases environment. These localized areas are characterized as “adverse localized 

environments” that represent a limited plant area where the operating environment is significantly 

more severe than the plant design basis environment. An adverse localized environment exceeds

the most limiting environment (e.g., temperature, radiation, or moisture) for the cable or 

connection insulation. A discussion of adverse localized environments and methods of identifying 

them can be found in Generic Aging Lessons Learned for Subsequent License Renewal 

(GALL-SLR) Report AMP XI.E1.

Exposure of electrical insulation to adverse localized environments caused by temperature, 

radiation, or moisture can cause age degradation resulting in reduced electrical insulation 

resistance, moisture intrusion related connection failures, or errors induced by thermal transients. 

Reduced electrical insulation resistance causes an increase in leakage currents between 

conductors and from individual conductors to ground. A reduction in electrical insulation 

resistance is a concern for all circuits, but especially those with sensitive, high-voltage, low-level 

current signals, such as radiation monitoring and nuclear instrumentation circuits, because a 

reduced insulation resistance may contribute to signal inaccuracies.

In this AMP, in addition to the evaluation and identification of adverse localized environments, 

either of two methods can be used to identify the existence of electrical insulation aging effects for 

cables and connections. In the first method, calibration results or findings of surveillance testing 

programs are evaluated to identify the existence of electrical cable and connection insulation

aging degradation. In the second method, direct testing of the cable system is performed.

This AMP applies to high-range-radiation and neutron flux monitoring instrumentation cables in 

addition to other cables used in high-voltage, low-level current signal applications that are 

sensitive to reduction in electrical insulation resistance. For these cables, GALL-SLR Report 

AMP XI.E1 does not apply.

As stated in NUREG/CR–5643, “the major concern is that failures of deteriorated cables might be 

induced during accident conditions.” Since the cable and connection electrical insulation is not 

subject to the environmental qualification requirements of 10 CFR 50.49, an AMP is needed to 

manage the aging mechanisms and effects for the subsequent period of extended operation. This 

AMP provides reasonable assurance that the electrical insulation for electrical cables and 

connections will perform its intended function for the subsequent period of extended operation.
XI.E2-2 

Evaluation and Technical Basis 

1. Scope of Program: This AMP applies to electrical cables and connections

(cable system) electrical insulation used in circuits with sensitive, high-voltage, low-level

current signals. Examples of these circuits include radiation monitoring and nuclear

instrumentation that are subject to aging management review and subjected to adverse

localized environments caused by temperature, radiation, or moisture.

2. Preventive Actions: This is a performance monitoring program and no actions are taken

as part of this program to prevent or mitigate aging degradation.

3. Parameters Monitored or Inspected: The parameters monitored are determined from

the specific calibration, surveillances, or testing performed and are based on the

specific instrumentation circuit under surveillance or calibration, as documented in

plant procedures.

4. Detection of Aging Effects: Review of calibration results or findings of surveillance

programs can provide an indication of the existence of aging effects based on acceptance

criteria related to instrumentation circuit performance. By reviewing the results obtained

during normal calibration or surveillance, an applicant may detect severe aging

degradation prior to the loss of the cable and connection intended function. The first

reviews are completed prior to the subsequent period of extended operation and at least

every 10 years thereafter. Calibration or surveillance results that do not meet acceptance

criteria are reviewed for aging effects when the results are available.

Cable system testing is conducted when the calibration or surveillance program does not

include the cabling system in the testing circuit, or as an alternative to the review of

calibration results described above. A cable system test for detecting deterioration of the

electrical insulation system is performed. This can be one or more of the following tests:

insulation resistance tests, time domain reflectometry tests, or other testing judged to be

effective in determining cable system insulation physical, mechanical, and chemical

properties, as applicable. The test frequency of the cable system is determined by the

applicant based on engineering evaluation, but the test frequency is at least once every

10 years. The first test is to be completed prior to the subsequent period of extended

operation.

5. Monitoring and Trending: Trending actions are not included as part of this AMP,

because the ability to trend visual inspection and test results is dependent on the test or

visual inspection program selected. However, inspection and test results that are

trendable provide additional information on the rate of cable or connection degradation.

6. Acceptance Criteria: An unacceptable indication is defined as a noted condition or

situation, if left unmanaged, could potentially lead to a loss of intended function.

Calibration results or findings of surveillance and cable system testing are to be within the

acceptance criteria, as set out in the applicant’s procedures.

7. Corrective Actions: Results that do not meet the acceptance criteria are addressed in

the applicant’s corrective action program under those specific portions of the quality

assurance (QA) program that are used to meet Criterion XVI, “Corrective Action,” of

10 CFR Part 50, Appendix B. Appendix A of the GALL-SLR Report describes how an
XI.E2-3 

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the corrective 

actions element of this AMP for both safety-related and nonsafety-related structures and 

components (SCs) within the scope of this program. 

Corrective actions, such as recalibration and circuit trouble-shooting, are implemented 

when calibration, surveillance, or cable system test results do not meet the acceptance 

criteria. An engineering evaluation is performed when the acceptance criteria are not met. 

Such an evaluation is to consider the significance of the calibration, surveillance, or cable 

system test results and whether the review of calibration and surveillance results or the 

cable system testing frequency needs to be increased.

8. Confirmation Process: The confirmation process is addressed through those specific

portions of the QA program that are used to meet Criterion XVI, “Corrective Action,” of

10 CFR Part 50, Appendix B. Appendix A of the GALL-SLR Report describes how an

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the confirmation

process element of this AMP for both safety-related and nonsafety-related SCs within the

scope of this program.

9. Administrative Controls: Administrative controls are addressed through the QA program

that is used to meet the requirements of 10 CFR Part 50, Appendix B, associated with

managing the effects of aging. Appendix A of the GALL-SLR Report describes how an

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the

administrative controls element of this AMP for both safety-related and nonsafety-related

SCs within the scope of this program.

10. Operating Experience: Operating experience has identified that a change in temperature

across a high range radiation monitor cable in containment resulted in a substantial

change in the reading of the monitor. Changes in instrument calibration can be caused by

degradation of the circuit cable or connection electrical insulation and represents a

possible indication of electrical cable degradation.

The program is informed and enhanced when necessary through the systematic and

ongoing review of both plant-specific and industry operating experience including research

and development such that the effectiveness of the AMP is evaluated consistent with the

discussion in Appendix B of the GALL-SLR Report.

References

10 CFR Part 50, Appendix B, “Quality Assurance Criteria for Nuclear Power Plants and Fuel 

Reprocessing Plants.” Washington, DC: U.S. Nuclear Regulatory Commission. 2016. 

EPRI. EPRI TR–109619, “Guideline for the Management of Adverse Localized Equipment 

Environments.” Palo Alto, California: Electric Power Research Institute. June 1999.

_____. EPRI TR–110379, “High Range Radiation Monitor Cable Study: Phase 1.” 

Palo Alto, California: Electric Power Research Institute. November 1998.

_____. EPRI TR–112582, “High Range Radiation Monitor Cable Study: Phase 2.” 

Palo Alto, California: Electric Power Research Institute. May 2000.
XI.E2-4

IEEE. IEEE Standard 1205-2014, “IEEE Guide for Assessing, Monitoring and Mitigating Aging 

Effects on Electrical Equipment Used in Nuclear Power Generating Stations and Other Nuclear 

Facilities.” New York, New York: Institute of Electrical and Electronics Engineers. 2014.

NRC. Information Notice 93-33: “Potential Deficiency of Certain Class IE Instrumentation and 

Control Cables.” Agencywide Documents Access and Management System (ADAMS) Accession 

No. ML031070494. Washington, DC: U.S. Nuclear Regulatory Commission. April 28, 1993.

_____. Information Notice 97-45, “Environmental Qualification Deficiency for Cables and 

Containment Penetration Pigtails.” ADAMS Accession No. ML031050410. Washington, DC: 

U.S. Nuclear Regulatory Commission. July 2, 1997.

_____. Information Notice 97-45, “Environmental Qualification Deficiency for Cables and 

Containment Penetration Pigtails.” Supplement 1. ADAMS Accession No. ML031050005. 

Washington, DC: U.S. Nuclear Regulatory Commission. February 17, 1998.

_____. NUREG/CR–5461, “Aging of Cables, Connections, and Electrical Penetrations 

Assemblies Used In Nuclear Power Plants.” ADAMS Accession No. ML041280192. 

Washington, DC: U.S. Nuclear Regulatory Commission. July 31, 1990.

_____. NUREG/CR–5643, “Insights Gained From Aging Research.” ADAMS Accession 

No. ML041530264. Washington, DC: U.S. Nuclear Regulatory Commission. March 31, 1992.

_____. NUREG/CR–5772, “Aging, Condition Monitoring and Loss-of-Coolant Accident (LOCA) 

Tests of Class IE Electrical Cables Vol. 1 and 2.” ADAMS Accession Nos. ML041270231, 

ML041280265. Washington, DC: U.S. Nuclear Regulatory Commission. August 31, 1992,

November 30, 1992.

_____. Regulatory Guide 1.218, “Condition Monitoring Techniques for Electric Cables Used in 

Nuclear Power Plants.” ADAMS Accession No. ML103510458. Washington, DC: U.S. Nuclear 

Regulatory Commission. April 30, 2012.

SNL. SAND96-0344, “Aging Management Guideline for Commercial Nuclear Power 

Plants-Electrical Cable and Terminations.” Albuquerque, New Mexico: Sandia National 

Laboratories. September 1996. 
XI.E3A-1

XI.E3A ELECTRICAL INSULATION FOR INACCESSIBLE MEDIUM-VOLTAGE 

POWER CABLES NOT SUBJECT TO 10 CFR 50.49 ENVIRONMENTAL 

QUALIFICATION REQUIREMENTS 

Program Description

The purpose of the aging management program (AMP) is to provide reasonable assurance that 

the intended functions of inaccessible medium-voltage power cables (operating voltages of 2 kV 

to 35 kV) that are not subject to the environmental qualification requirements of Title 10 of the 

Code of Federal Regulations (10 CFR) 50.49 are maintained consistent with the current licensing 

basis through the subsequent period of extended operation. This AMP applies to underground

(e.g., installed in buried conduit, embedded raceway, cable trenches, cable troughs, duct banks, 

vaults, manholes, or direct buried installations) medium-voltage cables within the scope of 

subsequent license renewal (SLR) exposed to wetting or submergence (i.e., significant moisture). 

Inaccessible medium-voltage cables designed for continuous wetting or submergence are also 

included in this AMP for a one-time inspection and test.

Most electrical cables in nuclear power plants are located in dry environments. However, some 

cables are inaccessible or underground, located in buried conduits, cable trenches, cable troughs, 

duct banks, vaults, or direct buried installations that may be exposed to water intrusion due to 

wetting or submergence. When an inaccessible medium-voltage power cable is exposed to wet, 

submerged, or other environments for which it was not designed, age related degradation of the 

electrical insulation may occur. Electrical insulation subjected to wetting or submergence could

have an adverse effect on performance of intended functions, or potentially lead to failure of the 

cable insulation system. Although variations exist in the aging mechanisms and effects 

depending on cable insulation material and manufacture, periodic actions are necessary to 

minimize the potential for insulation degradation.

Periodic actions are taken to prevent inaccessible medium-voltage cables from being exposed to 

significant moisture. Significant moisture is defined as exposure to moisture that lasts more than 

3 days (i.e., long term wetting or submergence over a continuous period) that if left unmanaged, 

could potentially lead to a loss of intended function. Cable wetting or submergence that occurs for 

a limited time as drainage occurs by either automatic or passive drains is not considered 

significant moisture for this AMP.

The inspection frequency for water accumulation is established and performed based on 

plant-specific operating experience (OE) over time with cable wetting or submergence. 

Inspections are performed periodically based on water accumulation over time. The periodic 

inspection occurs at least once annually with the first inspection for SLR completed prior to the 

subsequent period of extended operation. Inspection frequencies are adjusted based on 

inspection results including plant-specific OE but with a minimum inspection frequency of at least 

once annually. Inspections are also performed after event driven occurrences, such as heavy 

rain, rapid thawing of ice and snow, or flooding.

Examples of periodic actions to mitigate inaccessible medium-voltage cable exposure to 

significant moisture include inspection for water accumulation in cable manholes and conduits and 

removing water, as needed. However, these actions may not be sufficient to verify that water is 

not trapped elsewhere in the raceways. For example, water accumulation and submergence 

could occur from: (a) a duct bank conduit with low points in the routing, (b) concrete cracking due 

to soil settling over a long period of time, (c) manhole covers not being watertight, (d) routing

locations subject to a high water table (e.g., high seasonal cycles), and (e) wetting and 
XI.E3A-2

submergence potential even when duct banks are sloped with the intention to minimize 

water accumulation.

Therefore, in addition to the above periodic actions, in-scope inaccessible medium-voltage power 

cables exposed to significant moisture are tested to determine the condition of the electrical 

insulation. One or more tests may be required based on cable application, construction, and 

electrical insulation material to determine the age degradation of the cable. Cable testing as part 

of an existing maintenance or surveillance program, with justification, can be credited in lieu of, or 

in combination with, testing recommended in this AMP. A plant-specific inaccessible 

medium-voltage cable test matrix that documents inspection methods, test methods, and 

acceptance criteria for the applicant’s plant-specific in-scope inaccessible medium-voltage power 

cables is developed based on OE.

Note: inaccessible medium-voltage cables designed for continuous wetting or submergence are 

also included in this AMP for a one-time inspection and test with additional periodic tests and 

inspections determined by the test/inspection results and industry and plant-specific OE.

The first tests for license renewal are to be completed prior to the subsequent period of extended 

operation with subsequent tests performed at least once every 6 years thereafter. For 

inaccessible medium power cables exposed to significant moisture, test frequencies are adjusted 

based on test results (including trending of aging degradation where applicable) and plant-specific 

OE but with a minimum test frequency of at least once every 6 years.

As stated in NUREG/CR–5643, “the major concern is that failures of deteriorated cable systems 

(cables, connections, and penetrations) might be induced during accident conditions.” Because 

the cables are not subject to the environmental qualification requirements of 10 CFR 50.49, an 

AMP is required to manage the aging effects. This AMP provides reasonable assurance the 

insulation material for electrical cables will perform its intended function for the subsequent period 

of extended operation.

Evaluation and Technical Basis

1. Scope of Program: This AMP applies to underground medium-voltage (2kV to 35kV) 

power cable installations (e.g., direct buried, buried conduit, duct bank, embedded 

raceway, cable trench, vaults, or manholes) within the scope of subsequent license 

renewal exposed to significant moisture.

Significant moisture is defined as exposure to moisture that lasts more than 3 days (that if 

left unmanaged, could potentially lead to a loss of intended function. Cable wetting or 

submergence that occurs for a limited time as in the case of automatic or passive drainage 

is not considered significant moisture for this AMP.

In-scope inaccessible medium-voltage cable splices subjected to wetting or submergence 

are also included within the scope of this program. Submarine or other cables designed 

for continuous wetting or submergence are also included in this AMP as a one-time 

inspection and test with additional periodic tests and inspections determined by the 

one-time test/inspection results as well as industry and plant-specific OE.
XI.E3A-3

2. Preventive Actions: This is a condition monitoring program. However, periodic actions 

are taken to prevent inaccessible medium-voltage power cables from being exposed to 

significant moisture, such as identifying and inspecting conduit ends and cable 

manholes/vaults for water accumulation, and removing the water, as needed. 

The inspection frequency for water accumulation is established and performed based on 

plant-specific OE with cable wetting or submergence. The inspections are performed 

periodically based on water accumulation over time. The periodic inspection occurs at 

least once annually with the first inspection for SLR completed prior to the subsequent 

period of extended operation. The annual inspection frequency is consistent with 

U.S. Nuclear Regulatory Commission Inspection Manual, Attachment 71111.06, “Flood 

Protection Measures.”

Inspections for water accumulation are also performed after event driven occurrences, 

such as heavy rain, rapid thawing of ice and snow, or flooding. Plant-specific parameters 

are established for the initiation of an event driven inspection. Inspections include direct 

indication that cables are not wetted or submerged, and that cable/splices and cable 

support structures are intact. Dewatering systems (e.g., sump pumps and passive drains) 

and associated alarms are inspected and their operation verified periodically. The periodic 

inspection includes documentation that either automatic or passive drainage systems or 

manually pumping are effective in preventing cable exposure to significant moisture.

If water is found during inspection, corrective actions are taken per the applicant’s 

corrective action program to keep the cables free from significant moisture and to 

assess cable degradation. The aging management of the physical structures, including 

cable support structures of cable vaults/manholes is managed by Generic Aging Lessons 

Learned Subsequent License Renewal (GALL-SLR) Report AMP XI.S6, “Structures 

Monitoring.”

3. Parameters Monitored or Inspected: Inspection for water accumulation is performed 

based on plant-specific OE with water accumulation over time.

Inaccessible or underground medium-voltage power cables within the scope of license 

renewal exposed to significant moisture are tested to determine the age degradation of the 

electrical insulation.

4. Detection of Aging Effects: For inaccessible medium-voltage power cables exposed to 

significant moisture, test frequencies are adjusted based on test results (including trending 

of aging degradation where applicable) and plant-specific OE. Cable testing occurs at 

least once every 6 years. The first tests for license renewal are to be completed prior to 

the subsequent period of extended operation with additional tests performed at least once 

every 6 years thereafter. This is an adequate period to monitor performance of the cable 

and take appropriate corrective actions since experience has shown that although a slow 

process, aging degradation could be significant.

The specific type of test performed is determined prior to the initial test. Testing of 

installed inservice cables is comprised of one or more tests utilizing mechanical, electrical, 

or chemical means that determines, with reasonable assurance, in-scope inaccessible 

medium-voltage electrical insulation age degradation. One or more tests may be required 

due to cable application, construction, and electrical insulation material to determine the 

age degradation of the cables. Cable testing as part of an existing maintenance or 
XI.E3A-4

surveillance program, with justification, can be credited in lieu of, or in combination with, 

testing recommended in this AMP. A plant-specific inaccessible medium-voltage cable 

test matrix that documents inspection methods, test methods, and acceptance criteria for 

the applicant’s in-scope inaccessible medium-voltage power cables is developed based 

on OE.

5. Monitoring and Trending: Where practical, identified degradation is projected until the 

next scheduled inspection. Results are evaluated against acceptance criteria to confirm 

that the timing of subsequent inspections will maintain the components’ intended functions 

throughout the subsequent period of extended operation based on the projected rate of 

degradation. However, condition monitoring cable test and inspection results, utilizing the 

same visual inspection and test methods that are trendable and repeatable, provide 

additional information on the rate of cable or connection insulation degradation.

6. Acceptance Criteria: An unacceptable indication is defined as a noted condition or 

situation, if left unmanaged, could potentially lead to a loss of intended function.

The acceptance criteria for each test or inspection are determined by the specific type of 

test performed and the specific cable tested. Acceptance criteria for inspections for water 

accumulation are defined by the direct indication that cable support structures are intact 

and cables are not subject to significant moisture. Dewatering systems (e.g., sump pumps 

and drains) and associated alarms are inspected and their operation verified to prevent 

unacceptable exposure to significant moisture.

7. Corrective Actions: Results that do not meet the acceptance criteria are addressed in 

the applicant’s corrective action program under those specific portions of the quality 

assurance (QA) program that are used to meet Criterion XVI, “Corrective Action,” of 

10 CFR Part 50, Appendix B. Appendix A of the GALL-SLR Report describes how an 

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the corrective 

actions element of this AMP for both safety-related and nonsafety-related structures and 

components (SCs) within the scope of this program.

8. Confirmation Process: The confirmation process is addressed through those specific 

portions of the QA program that are used to meet Criterion XVI, “Corrective Action,” of 

10 CFR Part 50, Appendix B. Appendix A of the GALL-SLR Report describes how an 

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the confirmation 

process element of this AMP for both safety-related and nonsafety-related SCs within the 

scope of this program.

9. Administrative Controls: Administrative controls are addressed through the QA program 

that is used to meet the requirements of 10 CFR Part 50, Appendix B, associated with 

managing the effects of aging. Appendix A of the GALL-SLR Report describes how an 

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the 

administrative controls element of this AMP for both safety-related and nonsafety-related 

SCs within the scope of this program.

10. Operating Experience: Operating experience has shown that medium-voltage power 

cable electrical insulation materials undergo increased degradation either through water 

tree formation or other aging mechanisms when subjected to significant moisture. 

Inaccessible medium-voltage cables subjected to significant moisture may result in an 
XI.E3A-5

increased age degradation of electrical insulation. Minimizing exposure to significant 

moisture mitigates the potential for age related degradation.

The program is informed and enhanced when necessary through the systematic and 

ongoing review of both plant-specific and industry OE including research and development 

such that the effectiveness of the AMP is evaluated consistent with the discussion in 

Appendix B of the GALL-SLR Report.

References

10 CFR Part 50, Appendix B, “Quality Assurance Criteria for Nuclear Power Plants and Fuel 

Reprocessing Plants.” Washington, DC: U.S. Nuclear Regulatory Commission. 2016.

EPRI. EPRI TR–109619, “Guideline for the Management of Adverse Localized Equipment 

Environments.” Palo Alto, California: Electric Power Research Institute. June 1999.

IEEE. IEEE Standard 1205-2014, “IEEE Guide for Assessing, Monitoring, and Mitigating Aging 

Effects on Electrical Equipment Used in Nuclear Power Generating Stations and Other Nuclear 

Facilities.” New York, New York: Institute of Electrical and Electronics Engineers. 2014.

NRC. Generic Letter 2007-01, “Inaccessible or Underground Power Cable Failures that Disable 

Accident Mitigation Systems or Cause Plant Transients.” Agencywide Documents Access and 

Management System (ADAMS) Accession No. ML070360665. Washington, DC: U.S. Nuclear 

Regulatory Commission. February 7, 2007.

_____. Information Notice 1986-49, “Age/Environment Induces Electrical Cable Failures.” 

ADAMS Accession No. ML031220698. Washington, DC: U.S. Nuclear Regulatory Commission. 

June 16, 1986.

_____. Information Notice 2002-12, “Submerged Safety-Related Electrical Cables.” ADAMS 

Accession No. ML020790238. Washington, DC: U.S. Nuclear Regulatory Commission. 

March 31, 2002.

_____. Information Notice 2010-26, “Submerged Electrical Cables.” ADAMS Accession No. 

ML102800456. Washington, DC: U.S. Nuclear Regulatory Commission. December 2, 2010.

_____. Inspection Manual, Attachment 71111.01, “Adverse Weather Protection.” ADAMS 

Accession No. ML14334A684. Washington, DC: U.S. Nuclear Regulatory Commission. 

January 1, 2016.

_____. Inspection Manual, Attachment 71111.06, “Flood Protection Measures.” ADAMS 

Accession No. ML15140A133. Washington, DC: U.S. Nuclear Regulatory Commission. 

January 1, 2016.

_____. NUREG/CR–7000, “Essential Elements of an Electric Cable Condition Monitoring 

Program.” ADAMS Accession No. ML100540050. Washington, DC: U.S. Nuclear Regulatory 

Commission. January 31, 2010.

_____. Regulatory Guide 1.211, “Qualification of Safety-Related Cables and Field Splices for 

Nuclear Power Plants.” Revision 0. ADAMS Accession No. ML082530205. Washington, DC: 

U.S. Nuclear Regulatory Commission. April 1, 2009.
XI.E3A-6 

_____. Regulatory Guide 1.218, “Condition Monitoring Techniques for Electric Cables Used in 

Nuclear Power Plants.” Revision 0. ADAMS Accession No. ML1035310458. Washington, DC: 

U.S. Nuclear Regulatory Commission. April 30, 2012. 
XI.E3B-1 

XI.E3B ELECTRICAL INSULATION FOR INACCESSIBLE INSTRUMENT AND

CONTROL CABLES NOT SUBJECT TO 10 CFR 50.49 ENVIRONMENTAL 

QUALIFICATION REQUIREMENTS 

Program Description

The purpose of the aging management program (AMP) is to provide reasonable assurance that 

the intended functions of inaccessible or underground instrument and control cables that are not 

subject to the environmental qualification (EQ) requirements of Title 10 of the Code of Federal 

Regulations (10 CFR) 50.49 are maintained consistent with the current licensing basis through the 

subsequent period of extended operation.

This AMP applies to underground (e.g., installed in buried conduit, embedded raceway, cable 

trenches, cable troughs, duct banks, vaults, manholes, or direct buried installations) 

instrumentation and control cables, including those designed for continuous wetting or 

submergence within the scope of subsequent license renewal (SLR) exposed to significant 

moisture. Significant moisture is defined as exposure to moisture that lasts more than 3 days

that if left unmanaged, could potentially lead to a loss of intended function. Cable wetting or 

submergence that results from event driven occurrences and is mitigated by either automatic or 

passive drains is not considered significant moisture for the purposes of this AMP. 

When an inaccessible instrument and control cable is exposed to wet, submerged, or other 

environments for which it was not designed, accelerated age degradation of the electrical 

insulation may occur. The degradation of the cable shield due to water intrusion may introduce 

electrical ground issues and noise into the circuit. 

The risk contribution due to a failure of an inaccessible instrument and control cable may be 

limited due to system architecture. However, a common environmental aging stressor, such as 

submergence, represents an aging mechanism that if not anticipated in the design or mitigated in 

service, could have an adverse effect on performance of intended functions, or potentially lead to 

failure of the cable insulation system. 

In this AMP, periodic actions are taken to prevent inaccessible instrumentation and control cables 

from being exposed to significant moisture.

Examples of periodic actions include inspecting for water accumulation in cable manholes, vaults, 

conduits, and removing water, as needed. Instrumentation and control cables accessible from 

manholes, vaults, or other underground raceways are visually inspected for cable surface 

abnormalities. However, these periodic actions may not be sufficient due to the inability to 

remove accumulated water trapped in the raceways. For example, water accumulation or

submergence could occur from: (a) a duct bank conduit with low points in the routing, (b) raceway 

settling or cracking due to soil settling over a long period of time, (c) manholes and cable trench 

covers not being watertight, (d) raceway locations subject to a high water table (e.g., high 

seasonal cycles), and (e) potential wetting or submergence even when duct banks are sloped with 

the intention to minimize water accumulation. 

Therefore, in addition to the above periodic actions, in-scope inaccessible and underground 

instrumentation and control cables subject to significant moisture are evaluated to determine 

whether testing is required. If required, initial testing is performed once on a sample population to 

determine the condition of the electrical insulation. One or more tests may be required due to 

cable type, application, and electrical insulation to determine the age degradation of the cable. 
XI.E3B-2

Inaccessible instrumentation and control cables designed for continuous wetting or submergence 

are also included in this. The need for additional tests and inspections is determined by the 

test/inspection results as well as industry and plant-specific operating experience (OE).

Testing of installed inservice inaccessible and underground instrumentation and control cables as 

part of an existing maintenance, calibration or surveillance program, testing of coupons, 

abandoned or removed cables, or inaccessible medium- or low-voltage power cables subjected to 

the same or bounding environment, inservice application, cable routing, construction, 

manufacturing and insulation material may be credited in lieu of or in combination with testing of 

installed inservice inaccessible instrumentation and control cables when testing is recommended 

in this AMP.

As stated in NUREG/CR–5643, “the major concern is that failures of deteriorated cable systems 

(cables and penetrations) might be induced during accident conditions.” Because the cables are 

not subject to the EQ requirements of 10 CFR 50.49, an AMP is required to manage the aging 

effects. This AMP provides reasonable assurance that insulation material for electrical cables will 

perform its intended function for the subsequent period of extended operation.

Evaluation and Technical Basis

1. Scope of Program: This AMP applies to underground (e.g., installed in buried conduit, 

embedded raceway, cable trenches, cable troughs, duct banks, vaults, manholes, or direct 

buried installations) instrumentation and control cables, including those designed for 

continuous wetting or submergence within the scope of SLR, exposed to significant 

moisture. 

For this AMP, instrumentation cables are cables carrying either analog or digital signals 

such as coaxial cable, or cable comprised of twisted 16 or 18 American wire gauge (AWG)

conductor shielded pairs rated 300V with an overall shield. Examples of control cables 

included in this AMP are multi-conductor 600V 12 or 14 AWG cables used to monitor or 

initiate control functions through indication, switches, limit switches, relays, contacts, etc.

Significant moisture is defined as exposure to moisture that lasts more than 3 days that if 

left unmanaged, could potentially lead to a loss of intended function. Cable wetting or 

submergence that results from event driven occurrences and is mitigated by either 

automatic or passive drains is not considered significant moisture for the purposes of 

this AMP.

In-scope inaccessible and underground instrumentation and control cable splices 

subjected to wetting or submergence are included within the scope of this program. 

Cables designed for continuous wetting or submergence also are included in this AMP. 

Additional tests and periodic visual inspections are determined by the test/inspection 

results and industry and plant-specific aging degradation OE with the applicable cable 

electrical insulation. 

2. Preventive Actions: This is a condition monitoring program. However, periodic actions 

are taken to prevent inaccessible and underground instrumentation and control cables

from being exposed to significant moisture, such as identifying and inspecting in-scope 

accessible cable conduit ends and cable manholes/vaults for water accumulation, and 

removing the water, as needed.
XI.E3B-3

The inspection frequency for water accumulation in manholes/vaults is established and 

performed based on plant-specific OE with cable wetting or submergence. The 

inspections are performed periodically based on water accumulation over time. The 

periodic inspection occurs at least once annually with the first inspection for SLR 

completed prior to the subsequent period of extended operation. The annual inspection 

frequency is consistent with NRC Inspection Manual, Attachment 71111.06, “Flood 

Protection Measures.”

Inspections for water accumulation are also performed after event-driven occurrences, 

such as heavy rain, rapid thawing of ice and snow, or flooding. Plant-specific parameters 

are established for the initiation of an event-driven inspection. Inspections include direct 

indication that cables are not submerged, and that cable/splices and cable support 

structures are intact. Dewatering systems (e.g., sump pumps and passive drains) and 

associated alarms are inspected and their operation verified periodically. The periodic 

inspection includes documentation that either automatic or passive drainage systems, or 

manual pumping of manholes or vaults is effective in preventing inaccessible cable 

exposure to significant moisture.

The aging management of the physical structure, including cable support structures and

cable vaults or manholes, is managed by Generic Aging Lessons Learned for Subsequent 

License Renewal (GALL-SLR) Report AMP XI.S6, “Structures Monitoring.”

3. Parameters Monitored or Inspected: Inspection for water accumulation in 

manholes/vaults is performed periodically based on plant-specific OE with water 

accumulation over time.

Inaccessible and underground instrumentation and control cables within the scope of SLR 

are periodically visually inspected to assess age degradation of the electrical insulation. 

Inaccessible and underground instrumentation and control cables found to be exposed to 

significant moisture are evaluated (e.g., a determination is made as to whether a periodic 

or one-time test is needed for condition monitoring of the cable insulation system). Cable

installation systems that are known or subsequently found through either industry or 

plant-specific OE to degrade with continuous exposure to significant moisture 

(e.g., Vulkene and Raychem cross-linked polyethylene) are also tested to monitor cable 

electrical insulation degradation over time. The specific type of test(s) should be a proven 

technique capable of detecting reduced insulation resistance or degraded dielectric 

strength of the cable insulation system due to wetting or submergence.

Visual inspection of inaccessible and underground instrumentation and control cables also 

includes a determination as to whether other adverse environments exist. Cables 

subjected to these adverse environments are also evaluated for significant aging 

degradation of the cable insulation system.

4. Detection of Aging Effects: For inaccessible instrumentation and control cables 

exposed to significant moisture, visual inspection frequency is adjusted based on 

inspection and test results as well as plant-specific and industry OE. For inaccessible and 

underground instrumentation and control cables exposed to significant moisture where 

testing is required, a one-time test is performed. Visual inspection occurs at least once 

every 6 years and may be coordinated with the periodic inspection for water accumulation. 

This is an adequate period to monitor performance of instrumentation and control cables

and take appropriate corrective actions since industry OE has shown that although a slow 
XI.E3B-4

process, age degradation could be significant. Required testing and the initial visual 

inspection for SLR are to be completed prior to the subsequent period of extended 

operation.

Cables are periodically visually inspected for cable jacket surface abnormalities, such as:

embrittlement, discoloration, cracking, melting, swelling, or surface contamination due to 

the aging mechanism and effects of significant moisture. The cable insulation visual 

inspection portion of the AMP uses the cable jacket material as representative of the aging 

effects experienced by the instrumentation and control cable electrical insulation. Age 

degradation of the cable jacket may indicate accelerated age degradation of the electrical 

insulation due to significant moisture or other aging mechanisms.

The specific type of test(s) determines, with reasonable assurance, in-scope inaccessible 

instrumentation, and control cable insulation age degradation. One or more tests may be 

required based on cable application, and electrical insulation material to determine the age 

degradation of the cable insulation. 

Testing of installed inservice inaccessible instrumentation and control cables as part of an 

existing maintenance, calibration or surveillance program, testing of coupons, abandoned 

or removed cables, or inaccessible medium- or low-voltage power cables subjected to the 

same or bounding environment, inservice application, cable routing, manufacturing and 

insulation material may be credited in lieu of or in combination with testing of installed 

inservice inaccessible instrumentation and control cables when testing is required in 

this AMP.

The cable testing portion of the AMP utilizes sampling. The following factors are 

considered in the development of the electrical insulation sample: temperature, voltage, 

cable type, and construction including the electrical insulation composition. A sample of 

20 percent with a maximum sample of 25 constitutes a representative cable sample size. 

The basis for the methodology and sample used is documented. If an unacceptable 

condition or situation is identified in the selected sample, a determination is made as to 

whether the same condition or situation is applicable to other inaccessible instrumentation 

and control cables not tested and whether the tested sample population should be 

expanded. The applicant’s corrective action program is used to evaluate test or visual 

inspection results that did not meet acceptance criteria and determine appropriate 

corrective action (e.g., additional visual inspections or testing).

5. Monitoring and Trending: Where practical, identified degradation is projected until the 

next scheduled inspection. Results are evaluated against acceptance criteria to confirm 

that the timing of subsequent inspections will maintain the components’ intended functions 

throughout the subsequent period of extended operation based on the projected rate of 

degradation. However, condition monitoring cable tests and inspection results that utilize 

the same visual or test methods that are trendable and repeatable provide additional 

information on the rate of cable insulation degradation.

6. Acceptance Criteria: An unacceptable indication is defined as a noted condition or 

situation that, if left unmanaged, could potentially lead to a loss of intended function.

The acceptance criteria for each test or inspection are determined by the specific type of 

test performed and the specific cable tested. Acceptance criteria for water accumulation 

inspections are defined by the direct indication that cable support structures are intact and 
XI.E3B-5 

cables are not subject to significant moisture. Dewatering systems (e.g., sump pumps and 

drains) and associated alarms are inspected and their operation verified.

Visual inspection results show that instrumentation and control cable jacket material are 

free from unacceptable surface abnormalities that indicate excessive cable insulation 

aging degradation.

7. Corrective Actions: Results that do not meet the acceptance criteria are addressed in

the applicant’s corrective action program under those specific portions of the quality

assurance (QA) program that are used to meet Criterion XVI, “Corrective Action,” of

10 CFR Part 50, Appendix B. Appendix A of the GALL-SLR Report describes how an

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the corrective

actions element of this AMP for both safety-related and nonsafety-related structures and

components (SCs) within the scope of this program.

8. Confirmation Process: The confirmation process is addressed through those specific

portions of the QA program that are used to meet Criterion XVI, “Corrective Action,” of

10 CFR Part 50, Appendix B. Appendix A of the GALL-SLR Report describes how an

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the confirmation

process element of this AMP for both safety-related and nonsafety-related SCs within the

scope of this program.

9. Administrative Controls: Administrative controls are addressed through the QA program

that is used to meet the requirements of 10 CFR Part 50, Appendix B, associated with

managing the effects of aging. Appendix A of the GALL-SLR Report describes how an

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the

administrative controls element of this AMP for both safety-related and nonsafety-related

SCs within the scope of this program.

10. Operating Experience: The program is informed and enhanced when necessary through

the systematic and ongoing review of both plant-specific and industry OE including

research and development such that the effectiveness of the AMP is evaluated consistent

with the discussion in Appendix B of the GALL-SLR Report.

References

10 CFR Part 50, Appendix B, “Quality Assurance Criteria for Nuclear Power Plants and Fuel 

Reprocessing Plants.” Washington, DC: U.S. Nuclear Regulatory Commission. 2016. 

EPRI. EPRI TR–109619, “Guideline for the Management of Adverse Localized Equipment 

Environments.” Palo Alto, California: Electric Power Research Institute. June 1999.

IEEE. IEEE Standard 1205-2014, “IEEE Guide for Assessing, Monitoring, and Mitigating Aging 

Effects on Electrical Equipment Used in Nuclear Power Generating Stations and Other Nuclear 

Facilities.” New York, New York: Institute of Electrical and Electronics Engineers. 2014.

NRC. Generic Letter 2007-01, “Inaccessible or Underground Power Cable Failures that Disable 

Accident Mitigation Systems or Cause Plant Transients.” Agencywide Documents Access and 

Management System (ADAMS) Accession No. ML070360665. Washington, DC: U.S. Nuclear 

Regulatory Commission. February 7, 2007. 
XI.E3B-6

_____. Information Notice 1986-49, “Age/Environment Induces Electrical Cable Failures.” 

ADAMS Accession No. ML031220698. Washington, DC: U.S. Nuclear Regulatory Commission. 

June 16, 1986.

_____. Information Notice 2002-12, “Submerged Safety-Related Electrical Cables.” ADAMS 

Accession No. ML020790238. Washington, DC: U.S. Nuclear Regulatory Commission. 

March 31, 2002.

_____. Information Notice 2010-26, “Submerged Electrical Cables.” ADAMS Accession 

No. ML102800456. Washington, DC: U.S. Nuclear Regulatory Commission. 

December 2, 2010.

_____. Inspection Manual, Attachment 71111.01, “Adverse Weather Protection.” ADAMS 

Accession No. ML14334A684. Washington, DC: U.S. Nuclear Regulatory Commission. 

January 1, 2016.

_____. Inspection Manual, Attachment 71111.06, “Flood Protection Measures.” ADAMS 

Accession No. ML15140A133. Washington, DC: U.S. Nuclear Regulatory Commission. 

January 1, 2016.

_____. NUREG/CR–7000, “Essential Elements of an Electric Cable Condition Monitoring 

Program.” ADAMS Accession No. ML100540050. Washington, DC: U.S. Nuclear Regulatory 

Commission. January 31, 2010.

_____. Regulatory Guide 1.211, “Qualification of Safety-Related Cables and Field Splices for 

Nuclear Power Plants.” Revision 0. ADAMS Accession No. ML082530205. Washington, DC: 

U.S. Nuclear Regulatory Commission. April 1, 2009.

_____. Regulatory Guide 1.218, “Condition Monitoring Techniques for Electric Cables Used in 

Nuclear Power Plants.” Revision 0. ADAMS Accession No. ML103510458. Washington, DC: 

U.S. Nuclear Regulatory Commission. April 30, 2012.
XI.E3C-1

XI.E3C ELECTRICAL INSULATION FOR INACCESSIBLE LOW-VOLTAGE POWER 

CABLES NOT SUBJECT TO 10 CFR 50.49 ENVIRONMENTAL 

QUALIFICATION REQUIREMENTS 

Program Description

The purpose of the aging management program (AMP) is to provide reasonable assurance that 

the intended functions of inaccessible or underground low-voltage ac and dc power cables 

(i.e., typical operating voltage of less than 1,000 V, but no greater than 2 kV) that are not subject 

to the environmental qualification (EQ) requirements of Title 10 of the Code of Federal 

Regulations (10 CFR) 50.49 are maintained consistent with the current licensing basis through the 

subsequent period of extended operation.

This AMP applies to all underground (e.g., installed in buried conduit, embedded raceway, cable 

trenches, cable troughs, duct banks, vaults, manholes, or direct buried installations) low-voltage 

power cables, including those designed for continuous wetting or submergence, within the scope 

of subsequent license renewal (SLR) exposed to significant moisture. Significant moisture is 

defined as exposure to moisture that lasts more than three days that if left unmanaged, could 

potentially lead to a loss of intended function. Cable wetting or submergence that results from 

event driven occurrences and is mitigated by either automatic or passive drains is not considered 

significant moisture for the purposes of this AMP.

When an inaccessible low-voltage power cable is exposed to wet, submerged, or other 

environments for which it was not designed, accelerated age degradation of the electrical 

insulation may occur. The risk contribution due to a failure of a low-voltage power cable may be 

limited due to system architecture. However, a common environmental aging stressor such as 

submergence represents an aging mechanism that if not anticipated in the design or mitigated in 

service, could have an adverse effect on performance of intended functions or potentially lead to 

failure of the cable insulation system.

Periodic actions are taken to prevent inaccessible low-voltage power cables from being exposed 

to significant moisture. Examples of periodic actions include inspecting for water accumulation in 

cable manholes, vaults, conduits, and removing water, as needed. Low-voltage power cables 

accessible from manholes, vaults, or other underground raceways are visually inspected for cable 

surface abnormalities. However, these periodic actions may not be sufficient due to the inability to 

remove accumulated water trapped in the raceways. For example, water accumulation or

submergence could occur from: (a) a duct bank conduit with low points in the routing, (b) raceway 

settling or cracking due to soil settling over a long period of time, (c) manholes and cable trench 

covers not being watertight, (d) raceway locations subject to a high water table (e.g., high 

seasonal cycles), and (e) potential wetting or submergence even when duct banks are sloped with 

the intention to minimize water accumulation.

In addition to the above periodic actions, in-scope inaccessible and underground low-voltage 

power cables subject to significant moisture are evaluated to determine whether testing is 

required. If required, initial testing is performed once on a sample population to determine the 

condition of the electrical insulation. One or more tests may be required due to cable type, 

application, and electrical insulation to determine the age degradation of the cable. Inaccessible

low-voltage power cables designed for continuous wetting or submergence are also included in 

this AMP. The need for additional periodic tests and inspections is determined by the test and 

inspection results, as well as, industry and plant-specific operating experience (OE).
XI.E3C-2 

Testing of installed inservice inaccessible and underground low-voltage power cables as part of 

an existing maintenance, calibration or surveillance program, testing of coupons, abandoned or 

removed cables, or inaccessible low-voltage power cables subjected to the same or bounding 

environment, inservice application, cable routing, construction, manufacturing and insulation 

material may be credited in lieu of or in combination with testing of installed inservice inaccessible 

low-voltage power cables when testing is recommended in this AMP. 

As stated in NUREG/CR–5643, “the major concern is that failures of deteriorated cable systems 

(cables, connections, and penetrations) might be induced during accident conditions.” Because 

the cables are not subject to the EQ requirements of 10 CFR 50.49, an AMP is required to 

manage the aging effects. This AMP provides reasonable assurance that insulation material 

for electrical cables will perform its intended function for the subsequent period of extended 

operation.

Evaluation and Technical Basis

1. Scope of Program: This AMP applies to underground (e.g., installed in buried conduit,

embedded raceway, cable trenches, cable troughs, duct banks, vaults, manholes, or direct

buried installations) low-voltage power cables, including those designed for continuous

wetting or submergence, within the scope of SLR exposed to significant moisture. For this

AMP, low-voltage ac and dc power cables are considered in-scope cables with typical

operating voltage of less than 1,000 V, but no greater than 2 kV.

Significant moisture is defined as exposure to moisture that lasts more than 3 days that if 

left unmanaged, could potentially lead to a loss of intended function. Cable wetting or 

submergence that results from event-driven occurrences and is mitigated by either 

automatic or passive drains is not considered significant moisture for the purposes of 

this AMP. 

In-scope inaccessible and underground low-voltage power cable splices subjected to 

wetting or submergence are included within the scope of this program. Cables designed 

for continuous wetting or submergence also are included in this AMP. Additional tests and 

periodic visual inspections are determined by the test/inspection results and industry and 

plant-specific aging degradation OE with the applicable cable electrical insulation.

2. Preventive Actions: This is a condition monitoring program. However, periodic actions

are taken to prevent inaccessible and underground low-voltage power cables from being

exposed to significant moisture, such as identifying and inspecting in-scope accessible

cable conduit ends and cable manholes/vaults for water accumulation, and removing the

water, as needed.

The inspection frequency for water accumulation in manholes/vaults is established and 

performed based on plant-specific OE with cable wetting or submergence. The 

inspections are performed periodically based on water accumulation over time. The 

periodic inspection occurs at least once annually with the first inspection for SLR 

completed prior to the subsequent period of extended operation. The annual inspection 

frequency is consistent with U.S. Nuclear Regulatory Commission Inspection Manual, 

Attachment 71111.06, “Flood Protection Measures.”
XI.E3C-3

Inspections for water accumulation are also performed after event-driven occurrences, 

such as heavy rain, rapid thawing of ice and snow, or flooding. Plant-specific parameters 

are established for the initiation of an event-driven inspection. Inspections include direct 

indication that cables are not wetted or submerged, and that cable/splices and cable 

support structures are intact. Dewatering systems (e.g., sump pumps and passive drains) 

and associated alarms are inspected and their operation verified periodically. The periodic 

inspection includes documentation that either automatic or passive drainage systems, or 

manually pumping of manholes or vaults is effective in preventing inaccessible cable 

exposure to significant moisture.

The aging management of the physical structure, including cable support structures, of 

cable vaults/manholes is managed by Generic Aging Lessons Learned for Subsequent 

License Renewal (GALL-SLR) Report AMP XI.S6, “Structures Monitoring.”

3. Parameters Monitored or Inspected: Inspection for water accumulation in 

manholes/vaults is performed based on plant-specific OE with water accumulation 

over time.

Inaccessible and underground low-voltage power cables within the scope of SLR are 

periodically visually inspected to assess age degradation of the electrical insulation. 

Inaccessible and underground low-voltage power cables found to be exposed to 

significant moisture are evaluated (e.g., a determination is made as to whether a periodic 

or one-time test is needed for condition monitoring of the cable insulation system). Cable 

installation systems that are known or subsequently found through either industry or 

plant-specific OE to degrade with continuous exposure to significant moisture 

(e.g., Vulkene and Raychem cross-linked polyethylene) are also tested to monitor cable 

electrical insulation degradation over time. The specific type of test(s) should be a proven 

technique capable of detecting reduced insulation resistance or degraded dielectric 

strength of the cable insulation system due to wetting or submergence.

Visual inspection of inaccessible and underground low-voltage power cables also includes 

a determination as to whether other adverse environments may exist. Cables subjected to 

these adverse environments are also evaluated for significant aging degradation of the 

cable insulation system.

4. Detection of Aging Effects: For inaccessible low-voltage power cables exposed to 

significant moisture, visual inspection frequency is determined based on inspection and 

test results as well as plant-specific and industry OE. For inaccessible and underground 

low-voltage power cables exposed to significant moisture where testing is required, a 

one-time test is performed. Visual inspection occurs at least once every 6 years and may 

be coordinated with the periodic inspection for water accumulation. This is an adequate 

period to monitor performance of low-voltage power cables and take appropriate corrective 

actions since industry OE has shown that although a slow process, age degradation could 

be significant. Required testing and the initial visual inspection for SLR are to be 

completed prior to the subsequent period of extended operation.

Cables are periodically visually inspected for cable jacket surface abnormalities such as:

embrittlement, discoloration, cracking, melting, swelling, or surface contamination due to 

the aging mechanism and effects of significant moisture. The cable insulation visual 

inspection portion of the AMP uses the cable jacket material as representative of the aging 

effects experienced by the low-voltage power cable electrical insulation. Age degradation 
XI.E3C-4 

of the cable jacket may indicate accelerated age degradation of the electrical insulation 

due to significant moisture or other aging mechanisms. 

The specific type of test(s) determines, with reasonable assurance, in-scope inaccessible 

low-voltage power cable insulation age degradation. One or more tests may be required 

based on cable application, and electrical insulation material to determine the age 

degradation of the cable insulation.

Testing of installed inservice low-voltage power cables as part of an existing maintenance, 

calibration or surveillance program, testing of coupons, abandoned or removed cables, or 

inaccessible medium voltage power cables or instrumentation and control cables

subjected to the same or bounding environment, inservice application, cable routing, 

manufacturing and insulation material may be credited in lieu of or in combination with 

testing of installed inservice inaccessible low-voltage power cables when testing is 

required in this AMP. 

The cable testing portion of the AMP utilizes sampling. The following factors are 

considered in the development of the electrical insulation sample: temperature, voltage, 

cable type, and construction including the electrical insulation composition. A sample of 

20 percent with a maximum sample of 25 constitutes a representative cable sample size. 

The basis for the methodology and sample used is documented. If an unacceptable 

condition or situation is identified in the selected sample, a determination is made as to 

whether the same condition or situation is applicable to other inaccessible low-voltage 

power cables not tested and whether the tested sample population should be expanded. 

The applicant’s corrective action program is used to evaluate test or visual inspection 

results that did not meet acceptance criteria and determine appropriate corrective action

(e.g., additional visual inspections or testing). 

5. Monitoring and Trending: Where practical, degradation is projected until the next

scheduled inspection. Results are evaluated against acceptance criteria to confirm that

the sampling bases (e.g., selection, size, frequency) will maintain the components’

intended functions throughout the subsequent period of extended operation based on the

projected rate and extent of degradation. However, condition monitoring cable tests and

visual inspection results that utilize the same visual or test methods that are trendable and

repeatable provide additional information on the rate of cable insulation degradation.

6. Acceptance Criteria: An unacceptable indication is defined as a noted condition or

situation that if left unmanaged, could potentially lead to a loss of intended function.

The acceptance criteria for each test or inspection are determined by the specific type of 

test performed and the specific cable tested. Acceptance criteria for water accumulation 

inspections are defined by the direct indication that cables/splices and cable support 

structures are intact and cables are not subject to significant moisture. Dewatering 

systems (e.g., sump pumps and drains) and associated alarms are inspected and their 

operation verified.

Visual inspection results show that low-voltage power cable jacket material is free 

from unacceptable surface abnormalities that indicate excessive cable insulation 

aging degradation.
XI.E3C-5

7. Corrective Actions: Results that do not meet the acceptance criteria are addressed in 

the applicant’s corrective action program under those specific portions of the quality 

assurance (QA) program that are used to meet Criterion XVI, “Corrective Action,” of 

10 CFR Part 50, Appendix B. Appendix A of the GALL-SLR Report describes how an 

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the corrective 

actions element of this AMP for both safety-related and nonsafety-related structures and 

components (SCs) within the scope of this program.

8. Confirmation Process: The confirmation process is addressed through those specific 

portions of the QA program that are used to meet Criterion XVI, “Corrective Action,” of 

10 CFR Part 50, Appendix B. Appendix A of the GALL-SLR Report describes how an 

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the confirmation 

process element of this AMP for both safety-related and nonsafety-related SCs within the 

scope of this program.

9. Administrative Controls: Administrative controls are addressed through the QA program 

that is used to meet the requirements of 10 CFR Part 50, Appendix B, associated with 

managing the effects of aging. Appendix A of the GALL-SLR Report describes how an 

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the 

administrative controls element of this AMP for both safety-related and nonsafety-related 

SCs within the scope of this program.

10. Operating Experience: The program is informed and enhanced when necessary through 

the systematic and ongoing review of both plant-specific and industry OE including 

research and development such that the effectiveness of the AMP is evaluated consistent 

with the discussion in Appendix B of the GALL-SLR Report.

References

10 CFR Part 50, Appendix B, “Quality Assurance Criteria for Nuclear Power Plants and Fuel 

Reprocessing Plants.” Washington, DC: U.S. Nuclear Regulatory Commission. 2016.

EPRI. EPRI TR–109619, “Guideline for the Management of Adverse Localized Equipment 

Environments.” Palo Alto, California: Electric Power Research Institute. June 1999.

IEEE. IEEE Standard 1205-2014, “IEEE Guide for Assessing, Monitoring, and Mitigating Aging 

Effects on Electrical Equipment Used in Nuclear Power Generating Stations and Other Nuclear 

Facilities.” New York, New York: Institute of Electrical and Electronics Engineers. 2014.

NRC. Generic Letter 2007-01, “Inaccessible or Underground Power Cable Failures that Disable 

Accident Mitigation Systems or Cause Plant Transients.” Agencywide Documents Access and 

Management System (ADAMS) Accession No. ML070360665. Washington, DC: U.S. Nuclear 

Regulatory Commission. February 7, 2007.

_____. Information Notice 1986-49, “Age/Environment Induces Electrical Cable Failures.” 

ADAMS Accession No. ML031220698. Washington, DC: U.S. Nuclear Regulatory Commission. 

June 16, 1986.

_____. Information Notice 2002-12, “Submerged Safety-Related Electrical Cables.” ADAMS 

Accession No. ML020790238. Washington, DC: U.S. Nuclear Regulatory Commission. 

March 31, 2002.
XI.E3C-6

_____. Information Notice 2010-26, “Submerged Electrical Cables.” ADAMS Accession 

No. ML102800456. Washington, DC: U.S. Nuclear Regulatory Commission. December 2, 2010.

_____. Inspection Manual, Attachment 71111.01, “Adverse Weather Protection.” ADAMS 

Accession No. ML14334A684. Washington, DC: U.S. Nuclear Regulatory Commission. 

January 1, 2016.

_____. Inspection Manual, Attachment 71111.06, “Flood Protection Measures.” ADAMS 

Accession No. ML15140A133. Washington, DC: U.S. Nuclear Regulatory Commission. 

January 1, 2016.

_____. NUREG/CR–7000, “Essential Elements of an Electric Cable Condition Monitoring 

Program.” ADAMS Accession No. ML100540050. Washington, DC: U.S. Nuclear Regulatory 

Commission. January 31, 2010.

_____. Regulatory Guide 1.211, “Qualification of Safety-Related Cables and Field Splices for 

Nuclear Power Plants.” Revision 0. ADAMS Accession No. ML082530205. Washington, DC: 

U.S. Nuclear Regulatory Commission. April 1, 2009.

_____. Regulatory Guide 1.218, “Condition Monitoring Techniques for Electric Cables Used in 

Nuclear Power Plants.” Revision 0. ADAMS Accession No. ML103510458. Washington, DC: 

U.S. Nuclear Regulatory Commission. April 30, 2012.

SNL. SAND96-0344, “Aging Management Guideline for Commercial Nuclear Power 

Plants-Electrical Cable and Terminations.” Albuquerque, New Mexico: Sandia National 

Laboratories. September 1996.
XI.E4-1 

XI.E4 METAL ENCLOSED BUS

Program Description

The purpose of this aging management program (AMP) is to provide an internal and external 

inspection of metal enclosed buses (MEBs) within the scope of subsequent license renewal (SLR) 

to identify age-related degradation of electrical insulating material (i.e., porcelain, xenoy, 

thermoplastic organic polymers), and metallic and elastomer components (e.g., gaskets, 

boots, and sealants). This AMP provides reasonable assurance that in-scope MEBs will be 

maintained consistent with the current licensing basis (CLB) through the subsequent period of 

extended operation.

MEBs are electrical buses installed on electrically insulated supports that are constructed with 

each phase conductor enclosed in a separate metal enclosure (isolated phase bus), all 

conductors enclosed in a common metal enclosure (nonsegregated bus), or all phase conductors 

in a common metal enclosure, but separated by metal barriers between phases (segregated bus). 

The conductors are adequately separated and insulated from ground by insulating supports or 

bus electrical insulation. The MEBs are used in power systems to connect various elements in 

electric power circuits, such as switchgear, transformers, main generators, and diesel generators.

Industry operating experience (OE) indicates that the primary failure modes of MEBs have been 

caused by cracked electrical insulation, moisture, debris, loose connections, corrosion, or 

excessive dust buildup internal to the bus housing. Cracked insulation has resulted from high 

ambient temperature and contamination from bus bar joint compounds. Cracked electrical 

insulation in the presence of moisture or debris has caused phase-to-phase or phase-to-ground 

electrical paths, which has resulted in catastrophic failure of the buses. Significant ohmic heating 

of the bus may result in loosening of bolted connections associated with repeated cycling of 

connected loads. Bus failure has led to loss of power to electrical loads connected to the buses, 

causing subsequent reactor trips and initiating unnecessary challenges to plant systems 

and operators.

MEBs may experience increased resistance of connection due to loosening of bolted bus duct 

connections caused by repeated thermal cycling of connected loads. This phenomenon can 

occur in heavily loaded circuits (i.e., those exposed to appreciable ohmic heating). For example, 

SAND96-0344 identified instances of termination loosening at several plants due to thermal 

cycling and U.S. Nuclear Regulatory Commission Information Notice 2000-14 identified torque 

relaxation of splice plate connecting bolts as one potential cause of MEB failures. 

This AMP includes the inspection of accessible bus ducts and a sample of MEB bolted 

connections within the scope of license renewal for increased resistance of connections. 

Evaluation and Technical Basis

1. Scope of Program: This AMP manages the age-related degradation effects for electrical

bus bar bolted connections, bus bar electrical insulation, bus bar insulating supports, bus

enclosure assemblies (internal and external), and elastomers. This program does not

manage the aging effects on external bus structural supports, which are managed under

Generic Aging Lessons Learned for Subsequent License Renewal (GALL-SLR) Report

AMP XI.S6, “Structures Monitoring.” Alternatively, the aging effects on elastomers can be

managed under GALL-SLR Report AMP XI.M38, “Inspection of Internal Surfaces in

Miscellaneous Piping and Ducting Components,” and the external surfaces of MEB
XI.E4-2

enclosure assemblies can be managed under GALL-SLR Report AMP XI.S6, “Structures 

Monitoring.” Cable bus arrangements as described in GALL-SLR Chapter VI Table A, 

“Electrical Components – Equipment Not Subject to 10 CFR 50.49 Environmental 

Qualification Requirements” are excluded from this AMP and are evaluated as a 

site-specific further evaluation item per Section 3.6.2.2.2 of the Standard Review Plan for 

Review of Subsequent License Renewal Applications for Nuclear Power Plants.

2. Preventive Actions: This is a condition monitoring program and no actions are taken as 

part of this program to prevent or mitigate aging degradation.

3. Parameters Monitored or Inspected: This AMP provides for the inspection of the 

internal and external portions of the MEB. Internal portions (bus enclosure assemblies) of 

the MEB are inspected for cracks, corrosion, foreign debris, excessive dust buildup, and 

evidence of water intrusion. The bus electrical insulation material is inspected for signs of 

reduced insulation resistance due to thermal/thermoxidative degradation of 

organics/thermoplastics, radiation-induced oxidation, moisture/debris intrusion, or ohmic 

heating, as indicated by embrittlement, cracking, chipping, melting, discoloration, or 

swelling, which may indicate overheating or aging degradation. The internal bus insulating 

supports are inspected for structural integrity and signs of cracks. A sample of bolted

connections is inspected for increased resistance of connection (e.g., loose or corroded 

MEB bolted connections and hardware including cracked or split washers). Alternatively, 

a sample of bolted connections covered with heat shrink tape, sleeving, insulating boots, 

etc., may be visually inspected for electrical insulation material surface abnormalities. The 

external portions of the MEB, including accessible gaskets, boots, and sealants, are 

inspected for hardening or loss of strength due to elastomer degradation that could permit 

water or foreign debris to enter the bus. MEB external surfaces are inspected for loss of 

material due to general, pitting, and crevice corrosion.

MEBs are generally accessible structures and as such are inspected and tested in their 

entirety. However, depending on particular plant configurations, some segments of the 

MEB may be considered inaccessible due to close proximity to other permanent structures 

(e.g., nearby walls, ducts, cable trays, equipment or other structural elements). For 

inaccessible MEB internal or external segments, the applicant demonstrates (e.g., through 

alternative analysis, inspection, test or plant OE) that the inaccessible MEB segments 

evaluation, together with the accessible MEB inspection and test program, will continue to 

maintain the MEB consistent with the current licensing basis during the subsequent period 

of extended operation.

4. Detection of Aging Effects: MEB internal surfaces are visually inspected for aging 

degradation including cracks, corrosion, foreign materials debris, excessive dust buildup, 

and evidence of moisture intrusion. MEB insulating material is visually inspected for signs 

of embrittlement, cracking, chipping, melting, discoloration, swelling, or surface 

contamination. Internal bus insulating supports are visually inspected for structural 

integrity and signs of cracks. MEB external surfaces are visually inspected for loss of 

material due to general, pitting, and crevice corrosion. Accessible elastomers 

(e.g., gaskets, boots, and sealants) are inspected for degradation including surface 

cracking, crazing, scuffing, dimensional change (e.g., “ballooning” and “necking”), 

shrinkage, discoloration, hardening or loss of strength.
XI.E4-3 

A sample of accessible bolted connections is inspected for increased resistance of 

connection by using thermography or by measuring connection resistance using a micro 

ohmmeter. Twenty percent of the population with a maximum sample size of 

25 constitutes a representative sample size. When thermography is employed by the 

applicant, the applicant demonstrates with a documented evaluation that thermography is 

effective in identifying MEB increased resistance of connection (e.g., infrared viewing 

windows installed, or demonstrated test equipment capability). In addition to 

thermography or resistance measurement, bolted connections not covered with heat 

shrink tape or boots are visually inspected for increased resistance of connection 

(e.g., loose or corroded bolted connections and hardware including cracked or 

split washers). 

The first inspection for measuring connection resistance or thermography is completed 

prior to the subsequent period of extended operation and every 10 years thereafter. This 

is an adequate period to preclude failures of the MEBs since experience has shown that 

MEB aging degradation is a slow process.

As an alternative to thermography or measuring connection resistance of bolted 

connections, for accessible bolted connections covered with heat shrink tape, sleeving, 

insulating boots, etc., the applicant may use visual inspection of insulation material to 

detect surface anomalies, such as embrittlement, cracking, chipping, melting, 

discoloration, swelling, or surface contamination. When an alternative visual inspection is 

used to check MEB bolted connections, the first inspection is completed prior to the 

subsequent period of extended operation and every 5 years thereafter.

5. Monitoring and Trending: Trending actions are not included as part of this AMP

because the ability to trend inspection results is limited. However, results that are

trendable provide additional information on the rate of degradation.

6. Acceptance Criteria: An unacceptable condition is defined as a noted condition or

situation that, if left unmanaged, could potentially lead to a loss of the intended function.

MEB electrical insulation materials are free from unacceptable regional indications of 

surface anomalies such as embrittlement, cracking, chipping, melting, discoloration, 

swelling, or surface contamination. MEB internal surfaces show no indications of 

unacceptable corrosion, cracks, foreign debris, excessive dust buildup, or evidence of 

moisture intrusion. Accessible elastomers (e.g., gaskets, boots, and sealants) show no 

indications of unacceptable surface cracking, crazing, scuffing, dimensional change 

(e.g., “ballooning” and “necking”), shrinkage, discoloration, hardening, and loss of strength. 

MEB external surfaces are free from unacceptable loss of material due to general, pitting, 

and crevice corrosion.

MEB bolted connections are below the maximum allowed temperature (e.g., comparison 

of compartment temperatures, trending of temperature over time, or comparison to a 

baseline thermography signature) for the application when thermography is used or a low 

resistance value appropriate for the application when resistance measurement is used.

When the visual inspection alternative for MEB bolted connections is used, the absence of 

embrittlement, cracking, chipping, melting, discoloration, swelling, surface contamination 

of the electrical insulation material provides positive indication that the bolted connections 

are not loose. Visual inspection of bolted connections not covered with heat shrink tape, 
XI.E4-4

sleeving, insulating boots, etc. are free from corrosion, loose connections and hardware 

including cracked or split washers.

7. Corrective Actions: Results that do not meet the acceptance criteria are addressed in 

the applicant’s corrective action program under those specific portions of the quality 

assurance (QA) program that are used to meet Criterion XVI, “Corrective Action,” of 

Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B. Appendix A of 

the GALL-SLR Report describes how an applicant may apply its 10 CFR Part 50, 

Appendix B, QA program to fulfill the corrective actions element of this AMP for both 

safety-related and nonsafety-related structures and components (SCs) within the scope of 

this program.

Corrective actions are taken and an engineering evaluation is 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 

MEB components. An engineering evaluation is performed when the acceptance criteria 

are not met to demonstrate that the MEB intended function can be maintained consistent 

with the CLB. The engineering evaluation considers the significance of the surveillance, 

inspection or test results on the performance of intended functions, the extent of the 

concern, the potential root causes for not meeting the acceptance criteria, the corrective 

actions required, and the likelihood of recurrence. If an unacceptable condition or situation 

is identified, (e.g., internal surface degradation including cracks, corrosion, foreign debris, 

excessive dust buildup, moisture intrusion, insulating material embrittlement, cracking, 

chipping, melting, discoloration, swelling, or surface contamination) a determination is 

made as to whether the same condition or situation is applicable to MEB bolted 

connections not inspected or tested. Further, when acceptance criteria are not met, a 

determination is made as to whether the surveillance, inspection, or test, including 

frequency intervals, needs to be modified.

8. Confirmation Process: The confirmation process is addressed through those specific 

portions of the QA program that are used to meet Criterion XVI, “Corrective Action,” of 

10 CFR Part 50, Appendix B. Appendix A of the GALL-SLR Report describes how an 

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the confirmation 

process element of this AMP for both safety-related and nonsafety-related SCs within the 

scope of this program.

9. Administrative Controls: Administrative controls are addressed through the QA program 

that is used to meet the requirements of 10 CFR Part 50, Appendix B, associated with 

managing the effects of aging. Appendix A of the GALL-SLR Report describes how an 

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the 

administrative controls element of this AMP for both safety-related and nonsafety-related 

SCs within the scope of this program.

10. Operating Experience: Industry experience has shown that failures have occurred on 

MEBs caused by cracked electrical insulation and moisture or debris buildup internal to the 

MEB. Experience also has shown that bus connections in the MEBs exposed to 

appreciable ohmic heating during operation may experience loosening due to repeated 

cycling of connected loads.
XI.E4-5 

The program is informed and enhanced when necessary through the systematic and 

ongoing review of both plant-specific and industry OE including research and development 

such that the effectiveness of the AMP is evaluated consistent with the discussion in 

Appendix B of the GALL-SLR Report.

References

10 CFR Part 50, Appendix B, “Quality Assurance Criteria for Nuclear Power Plants and Fuel 

Reprocessing Plants.” Washington, DC: U.S. Nuclear Regulatory Commission. 2016. 

EPRI. “Switchgear and Bus Maintenance Guide.” Palo Alto, California: Electric Power Research 

Institute, Nuclear Maintenance Application Center. December 2006.

_____. “Cable System Management.” Palo Alto, California: Electric Power Research Institute. 

2002.

_____. “Electrical Connector Application Guidelines.” Palo Alto, California: Electric Power 

Research Institute. December 2002. 

_____. “Infrared Thermography Guide.” Palo Alto, California: Electric Power Research Institute. 

2002.

_____. “Plant Support Engineering: License Renewal Electrical Handbook.” 

Palo Alto, California: Electric Power Research Institute. 2001.

IAEA. Safety Guide No. NS-G-2.12, “Ageing Management for Nuclear Power Plants.” IAEA. 

Vienna: International Atomic Energy Agency. February 2009.

IEEE. IEEE Standard 1205-2014, “IEEE Guide for Assessing, Monitoring and Mitigating Aging 

Effects on Electrical Equipment Used in Nuclear Power Generating Stations and Other Nuclear 

Facilities.” New York, New York: Institute of Electrical and Electronics Engineers. 2014.

NRC. Information Notice 89-64, “Electrical Bus Bar Failures.” Agencywide Documents Access 

and Management System (ADAMS) Accession No. ML013180735. Washington, DC: 

U.S. Nuclear Regulatory Commission. September 7, 1989.

_____. Information Notice 98-36, “Inadequate or Poorly Controlled, Non-Safety-Related 

Maintenance Activities Unnecessary Challenged Safety Systems.” ADAMS Accession No. 

ML031040558. Washington, DC: U.S. Nuclear Regulatory Commission. September 18, 1998.

_____. Information Notice 2000-14, “Non-Vital Bus Fault Leads to Fire and Loss of Offsite 

Power.” ADAMS Accession No. ML003748744. Washington, DC: U.S. Nuclear Regulatory 

Commission. September 27, 2000.

_____. Information Notice 2010-25, “Inadequate Electrical Connections.” ADAMS Accession No. 

ML102530012. Washington, DC: U.S. Nuclear Regulatory Commission. November 17, 2010.

_____. NUREG/CR–5461, “Aging of Cables, Connections, and Electrical Penetration Assemblies 

Used in Nuclear Power Plants.” ADAMS Accession No. ML041280192. Washington, DC: 

U.S. Nuclear Regulatory Commission. July 31, 1990.
XI.E4-6 

SNL. SAND96-0344, “Aging Management Guideline for Commercial Nuclear Power 

Plants-Electrical Cable and Terminations.” Albuquerque, New Mexico: Sandia National 

Laboratories. September 1996.
XI.E5-1 

XI.E5 FUSE HOLDERS 

Program Description

The purpose of this aging management program (AMP) is to provide reasonable assurance that 

the intended functions of fuse holders within the scope of subsequent license renewal (SLR) and 

subject to aging management are maintained consistent with the current licensing basis. The fuse 

holder program was developed specifically to address aging management of fuse holder 

insulation material and fuse holder metallic clamp aging mechanisms and effects. This AMP 

utilizes visual inspection and testing to identify age-related degradation for both fuse holder 

electrical insulation material and fuse holder metallic clamps. Visual inspection and testing 

provides reasonable assurance that the applicable aging effects are identified and fuse holder 

insulators and metallic clamps are age managed. 

Fuse holders (fuse blocks) are classified as a specialized type of terminal block because of the 

similarity in fuse holder design and construction to that of a terminal block. Fuse holders are 

typically constructed of blocks of rigid insulating material, such as phenolic resins. Metallic clamps 

(clips) are attached to the blocks to hold each end of the fuse. The clamps, which are typically 

made of copper, can be spring-loaded clips or bolt lugs to which the fuse ends are connected. 

Industry operating experience (OE) has shown that repetitive removal and reinsertion of fuses 

during maintenance or surveillance activities can lead to degradation of the fuse holders. Fuse 

holders, located outside of active equipment, where fuses are removed and replaced frequently 

for maintenance or surveillance activities are also included in this AMP to manage these 

repetitive activities. 

The metallic portion of fuse holders that are within the scope of SLR and subject to aging 

management are tested for the following aging stressors: increased resistance of connection due 

to chemical contamination, corrosion, and oxidation or fatigue caused by ohmic heating, thermal 

cycling, electrical transients, frequent removal and insertion, or vibration. The specific type of test 

is determined prior to the initial test and detects increased resistance of fuse holder metallic clamp

connections. Tests may include thermography, contact resistance testing, or other appropriate 

testing justified in the application. 

Fuse holders within the scope of SLR and subject to aging management are visually inspected to 

provide an indication of the condition of the electrical insulation portion of the fuse holders. Fuse 

holders are visually inspected for electrical insulation surface anomalies indicating signs of 

reduced insulation resistance due to thermal/thermoxidative degradation of organics, radiolysis 

and photolysis [ultraviolet (UV) sensitive materials only] of organics, radiation-induced oxidation, 

and moisture intrusion as indicated by signs of embrittlement, discoloration, cracking, melting, 

swelling, or surface contamination. 

As stated in NUREG–1760, “Aging Assessment of Safety-Related Fuses Used in Low and 

Medium-Voltage Applications in Nuclear Power Plants,” licensees have experienced a number of 

age-related failures. The major concern is that failures of a deteriorated cable system (cables, 

connections including fuse holders, and penetrations) might be induced during accident 

conditions. Since they are not subject to the environmental qualification requirements of Title 10 

of the Code of Federal Regulations (10 CFR) 50.49, an AMP is required to manage the aging 

effects. This AMP demonstrates that fuse holders, including both the insulation and metallic 

components will maintain the ability to perform their intended function for the subsequent period of 

extended operation. 
XI.E5-2 

Evaluation and Technical Basis

1. Scope of Program: This AMP manages in-scope fuse holders outside of active devices

that are considered susceptible to the following aging effects: increased resistance of

connection due to chemical contamination, corrosion, and oxidation or fatigue caused by

ohmic heating, thermal cycling, electrical transients, frequent removal and replacement, or

vibration. It also manages degradation of electrical insulation for the fuse holders with

metallic clamps susceptible to the aging effects identified. Fuse holders inside an active

device (e.g. switchgears, power supplies, inverters, battery chargers, and circuit boards)

and not subject to the aging effects identified, are not within the scope of this AMP.

2. Preventive Actions: This is a condition monitoring program and no actions are taken as

part of this program to prevent or mitigate aging degradation.

3. Parameters Monitored or Inspected: The metallic clamp portion of the fuse holder is

tested to detect increased resistance of connection due to chemical contamination,

corrosion, and oxidation or fatigue caused by ohmic heating, thermal cycling, electrical

transients, frequent removal and replacement or vibration. The electrical insulation

material portion of the fuse holder is visually inspected to identify insulation surface

anomalies indicating signs of reduced insulation resistance due to thermal/thermoxidative

degradation of organics, radiolysis and photolysis (UV sensitive materials only) of

organics, radiation-induced oxidation, and moisture intrusion as indicated by signs of

embrittlement, discoloration, cracking, melting, swelling, or surface contamination.

4. Detection of Aging Effects: Fuse holders within the scope of this AMP are visually

inspected and tested at least once every 10 years to provide an indication of the condition

of the metallic clamp of the fuse holder. Testing may include thermography, contact

resistance testing, or other appropriate testing methods. Visual inspection includes

inspection for electrical insulation surface anomalies indicating signs of reduced insulation

resistance. Visual inspection and testing at least once every 10 years is an adequate

period to preclude failures of the fuse holders since experience has shown that aging

degradation is a slow process. The first visual inspections and tests for SLR are to be

completed prior to the subsequent period of extended operation.

5. Monitoring and Trending: Trending actions are not included as part of this AMP

because the ability to trend visual inspection and test results is dependent on the

inspection and specific type of test chosen. However, results that are trendable provide

additional information on the rate of degradation.

6. Acceptance Criteria: An unacceptable indication is defined as a noted condition or

situation that, if left unmanaged, could potentially lead to a loss of intended function.

The acceptance criteria for each visual inspection and test are defined by the specific type 

of inspection or test performed and the specific type of fuse holder tested. When 

thermography is used, the metallic clamp of the fuse holder needs to be below the 

maximum allowed temperature for the application; otherwise, a low resistance value 

appropriate for the application is applicable when resistance measurement is used. Test 

acceptance criteria show that fuse holders are free from the unacceptable aging effects of 

increased resistance of connection due to chemical contamination, corrosion, and 

oxidation or fatigue caused by ohmic heating, thermal cycling, electrical transients, 

frequent removal and replacement, or vibration. Visual inspection acceptance 
XI.E5-3 

criteria show that fuse holders are free from unacceptable electrical insulation 

surface anomalies indicating signs of reduced insulation resistance due to 

thermal/thermoxidative degradation of organics, radiolysis and photolysis (UV sensitive 

materials only) of organics; radiation-induced oxidation, and moisture intrusion as 

indicated by signs of embrittlement, discoloration, cracking, melting, swelling, or 

surface contamination.

7. Corrective Actions: Results that do not meet the acceptance criteria are addressed in

the applicant’s corrective action program under those specific portions of the quality

assurance (QA) program that are used to meet Criterion XVI, “Corrective Action,” of

10 CFR Part 50, Appendix B. Appendix A of the Generic Aging Lessons Learned for

Subsequent License Renewal (GALL-SLR) Report describes how an applicant may apply

its 10 CFR Part 50, Appendix B, QA program to fulfill the corrective actions element of this

AMP for both safety-related and nonsafety-related structures and components (SCs)

within the scope of this program.

8. Confirmation Process: The confirmation process is addressed through those specific

portions of the QA program that are used to meet Criterion XVI, “Corrective Action,” of

10 CFR Part 50, Appendix B. Appendix A of the GALL-SLR Report describes how an

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the confirmation

process element of this AMP for both safety-related and nonsafety-related SCs within the

scope of this program.

9. Administrative Controls: Administrative controls are addressed through the QA program

that is used to meet the requirements of 10 CFR Part 50, Appendix B, associated with

managing the effects of aging. Appendix A of the GALL-SLR Report describes how an

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the

administrative controls element of this AMP for both safety-related and nonsafety-related

SCs within the scope of this program.

10. Operating Experience: Operating experience has shown that loosening of fuse holder

metallic clamps due to chemical contamination, corrosion, oxidation or fatigue caused by

ohmic heating, thermal cycling, electrical transients, frequent removal and replacement,

vibration, and electrical insulation surface (i.e., fuse blocks) abnormalities, are aging

mechanisms indicating signs of reduced insulation resistance. If left unmanaged, these

aging mechanisms can lead to a loss of function. NUREG–1760 documents fuse holder

failures due to fatigue and recommends the review of maintenance procedures (e.g., fuse

control programs) to minimize removal and reinsertion of fuses to de-energize

components (as this can lead to degradation of the fuse holder assembly).

The program is informed and enhanced when necessary through the systematic and 

ongoing review of both plant-specific and industry OE including research and development 

such that the effectiveness of the AMP is evaluated consistent with the discussion in 

Appendix B of the GALL-SLR Report. 

References

10 CFR Part 50, Appendix B, “Quality Assurance Criteria for Nuclear Power Plants and Fuel 

Reprocessing Plants.” Washington, DC: U.S. Nuclear Regulatory Commission. 2016. 
XI.E5-4

IEEE. IEEE Standard 1205-2014, “IEEE Guide for Assessing, Monitoring, and Mitigating Aging 

Effects on Electrical Equipment Used in Nuclear Power Generating Stations and Other Nuclear 

Facilities.” New York, New York: Institute of Electrical and Electronics Engineers. 2014.

NRC. Information Notice 86-87, “Loss of Offsite Power Upon an Automatic Bus Transfer.” 

Agencywide Documents Access and Management System (ADAMS) Accession No. 

ML031250328. Washington, DC: U.S. Nuclear Regulatory Commission. October 10, 1986.

_____. Information Notice 87-42, “Diesel Generator Fuse Contacts.” ADAMS Accession 

No. ML031130353. Washington, DC: U.S. Nuclear Regulatory Commission. September 4, 1987.

_____. Information Notice 91-78, “Status Indication of Control Power for Circuit Breakers Used in 

Safety-Related Applications.” ADAMS Accession No. ML082380373. Washington, DC: 

U.S. Nuclear Regulatory Commission. November 28, 1991.

_____. NUREG–1760, “Aging Assessment of Safety-Related Fuses Used in Low- and 

Medium-Voltage Applications in Nuclear Power Plants.” ADAMS Accession No. ML021360517. 

Washington, DC: U.S. Nuclear Regulatory Commission. May 31, 2002.
XI.E6-1 

XI.E6 ELECTRICAL CABLE CONNECTIONS NOT SUBJECT TO 10 CFR 50.49 

ENVIRONMENTAL QUALIFICATION REQUIREMENTS

Program Description

The purpose of the this aging management program (AMP) is to provide reasonable assurance 

that the intended functions of the metallic parts of electrical cable connections that are not subject 

to the environmental qualification (EQ) requirements of Title 10 of the Code of Federal 

Regulations (10 CFR) 50.49 and susceptible to age-related degradation resulting in increased 

resistance of the connection are maintained consistent with the current licensing basis through the 

subsequent period of extended operation. This AMP manages the aging mechanisms and effects 

associated with the metallic portion of electrical connections that result in increased resistance of 

connection due to thermal cycling, ohmic heating, electrical transients, vibration, chemical 

contamination, corrosion, or oxidation such that the metallic portions of the electrical cable 

connections are maintained consistent with the current licensing basis through the subsequent 

period of extended operation. 

Cable connections are used to connect cable conductors to other cable conductors or electrical 

devices. Connections associated with cables within the scope of license renewal are part of this 

AMP. Examples of connections used in nuclear power plants include bolted connectors, 

coaxial/triaxial connections, compression/crimped connectors, splices (butt or bolted), stress 

cones, and terminal blocks. Most connections involve insulating material and metallic parts. This 

AMP focuses on the metallic parts of the electrical cable connections. This AMP provides testing, 

on a sampling basis, to demonstrate that either aging of metallic cable connections is not 

occurring and/or that the existing preventive maintenance program is effective. Testing confirms 

the absence of age-related degradation of cable connections resulting in increased resistance of 

connection due to thermal cycling, ohmic heating, electrical transients, vibration, chemical 

contamination, corrosion, or oxidation. 

The Generic Aging Lessons Learned for Subsequent License Renewal (GALL-SLR) Report

AMP XI.E1, “Electrical Insulation Material for Electrical Cables and Connections Not Subject to 

10 CFR 50.49 Environmental Qualification Requirements,” manages the aging of insulating 

material but not the metallic parts of the electrical connections. The GALL-SLR Report 

AMP X1.E1 is based on a visual inspection of accessible cables and connections. However, 

visual inspection alone may not be sufficient to detect the aging effects from thermal cycling, 

ohmic heating, electrical transients, vibration, chemical contamination, corrosion, or oxidation on 

the metallic parts of cable connections. 

Electrical cable connections exposed to appreciable ohmic or ambient heating during operation 

may experience increased resistance of connection caused by repeated cycling of connected 

loads or by the ambient temperature environment. Different materials used in various cable 

system components can produce situations where stresses between these components change 

with repeated thermal cycling. For example, under loaded conditions, ohmic heating may raise 

the temperature of a compression terminal and cable conductor well above the ambient 

temperature, thereby causing thermal expansion of both components. Thermal expansion 

coefficients of different materials may alter mechanical stresses between the components and 

may adversely impact the termination. When the current is reduced, the affected components 

cool and contract. Repeated cycling in this fashion can cause loosening of the termination and 

may lead to increased resistance of connection or eventual separation of compression type 

terminations. Threaded connectors may also loosen if subjected to significant thermally induced 

stress and cycling. 
XI.E6-2 

A sample of cable connections within the scope of license renewal are tested on a one-time test 

basis or periodically once every 5 years, if only visual inspection is used to provide an indication 

of the integrity of the cable connections. Depending on the findings of the one-time test, 

subsequent testing may have to be performed within 10 years of initial testing. The first visual 

inspections or tests for license renewal are to be completed prior to the subsequent period of 

extended operation. 

The specific type of test to be performed is a proven test for detecting increased resistance of 

connection, such as thermography, contact resistance testing, or another appropriate test. As an 

alternative to measurement of cable connections, for the accessible cable connections that are 

covered with insulation materials such as tape, the applicant may perform visual inspection of 

insulation material to detect aging effects. The basis for performing only a periodic visual 

inspection is documented. 

This AMP is a sampling program. The following factors are considered for sampling: voltage 

level (medium and low-voltage), circuit loading (high loading), connection type, and location (high 

temperature, high humidity, vibration, etc.). The technical basis for the sample selections should 

be documented. If an unacceptable condition or situation is identified in the selected sample, a 

determination is made as to whether the same condition or situation is applicable to other 

connections not tested. The corrective action program is used to evaluate the condition and 

determine appropriate corrective action. 

This AMP is not applicable to cable connections in harsh environments since they are already 

addressed by the requirements of 10 CFR 50.49. Even though cable connections may not be 

exposed to harsh environments, increased resistance of connection is a concern due to the cable 

connection aging mechanisms and effects discussed above. 

Evaluation and Technical Basis

1. Scope of Program: Cable connections associated with cables within the scope of license

renewal that are external connections terminating at active or passive devices, are in the

scope of this AMP. Wiring connections internal to an active assembly are considered part

of the active assembly and, therefore, are not within the scope of this AMP. This AMP

does not include high voltage (>35 kilo-volts) switchyard connections. The cable

connections covered under the EQ program are not included in the scope of this program.

2. Preventive Actions: This is a condition monitoring program, and no actions are taken as

part of this program to prevent or mitigate aging degradation.

3. Parameters Monitored or Inspected: This AMP focuses on the metallic parts of the

connection. One-time testing provides an indication of increased resistance of connection

due to thermal cycling, ohmic heating, electrical transients, vibration, chemical

contamination, corrosion, or oxidation. Representative samples of each type of electrical

cable connection are tested. The following factors are considered for sampling: voltage

level (medium and low-voltage), circuit loading (high load), connection type, and location

(high temperature, high humidity, vibration, etc.). The technical basis for the sample

selection is documented.

4. Detection of Aging Effects: A representative sample of electrical connections within the

scope of license renewal is tested prior to the subsequent period of extended operation.

The findings of the initial one-time test are evaluated to determine whether periodic testing
XI.E6-3 

of the cable connections is warranted. This finding forms the basis of site-specific 

operating experience (OE) for age-related degradation and informs the need for 

subsequent testing on a 10-year periodic basis. The justification and technical basis for 

not performing subsequent periodic testing is documented. This includes a discussion of 

the types of unacceptable conditions or degradation identified and whether they were 

determined to be age-related, requiring periodic maintenance. 

Testing of in-scope connections manages the aging mechanisms and effects requiring 

management during the subsequent period of extended operation. Testing may include 

thermography, contact resistance testing, or other appropriate testing methods without 

removing the connection insulation. One-time testing provides additional confirmation to 

support industry OE that shows that electrical connections have not experienced a high 

degree of failures, and that existing installation and maintenance practices are effective. 

Twenty percent of a connector type population with a maximum sample of 25 constitutes a 

representative connector sample size. Otherwise a technical justification of the 

methodology and sample size used for selecting components under test should be 

included as part of the applicant’s AMP’s documentation.

The first tests for license renewal are to be completed prior to the subsequent period of 

extended operation.

As an alternative to measurement testing for accessible cable connections that are 

covered with heat shrink tape, sleeving, insulating boots, etc., the applicant may use a 

visual inspection of insulation materials to detect surface anomalies, such as 

embrittlement, cracking, chipping, melting, discoloration, swelling or surface 

contamination. When this alternative visual inspection is used to check cable connections, 

the first inspection is completed prior to the subsequent period of extended operation 

and at least every 5 years thereafter. The basis for performing only the alternative 

periodic visual inspection to monitor age-related degradation of cable connections 

is documented.

5. Monitoring and Trending: Trending actions are not included as part of this AMP

because the ability to trend visual inspection and test results is dependent on the specific

test or visual inspection program selected. However, condition monitoring inspection or

test results that are trendable provide additional information on the rate of electrical

connection degradation.

6. Acceptance Criteria: Cable connections should not indicate abnormal temperatures for

the application when thermography is used. Alternatively, connections should exhibit a

low resistance value appropriate for the application when resistance measurement is

used. When the visual inspection alternative for covered cable connections is used, the

absence of embrittlement, cracking, chipping, melting, discoloration, swelling, or surface

contamination indicates that the covered cable connection components are not loose. An

unacceptable indication is defined as a noted condition or situation that, if left unmanaged,

could potentially lead to a loss of intended function.

7. Corrective Actions: Results that do not meet the acceptance criteria are addressed in

the applicant’s corrective action program under those specific portions of the quality

assurance (QA) program that are used to meet Criterion XVI, “Corrective Action,” of

10 CFR Part 50, Appendix B. Appendix A of the GALL-SLR Report describes how an

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the corrective
XI.E6-4 

actions element of this AMP for both safety-related and nonsafety-related structures and 

components (SCs) within the scope of this program.

8. Confirmation Process: The confirmation process is addressed through those specific

portions of the QA program that are used to meet Criterion XVI, “Corrective Action,” of

10 CFR Part 50, Appendix B. Appendix A of the GALL-SLR Report describes how an

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the confirmation

process element of this AMP for both safety-related and nonsafety-related SCs within the

scope of this program.

9. Administrative Controls: Administrative controls are addressed through the QA program

that is used to meet the requirements of 10 CFR Part 50, Appendix B, associated with

managing the effects of aging. Appendix A of the GALL-SLR Report describes how an

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the

administrative controls element of this AMP for both safety-related and nonsafety-related

SCs within the scope of this program.

10. Operating Experience: Electrical cable connections exposed to thermal cycling, ohmic

heating, electrical transients, vibration, chemical contamination, corrosion, or oxidation

during operation may experience increased resistance of connection. There have been

limited numbers of age-related failures of cable connections reported. An applicant’s OE

with connection reliability and aging effects should be adequate to demonstrate the AMP

effectiveness of GALL-SLR Report AMP XI.E6, “Electrical Cable Connections Not Subject

To 10 CFR 50.49 Environmental Qualification Requirements,” including the program’s

capability to detect the presence or noting the absence of aging effects for electrical

cable connections.

The program is informed and enhanced when necessary through the systematic and

ongoing review of both plant-specific and industry OE including research and development

such that the effectiveness of the AMP is evaluated consistent with the discussion in

Appendix B of the GALL-SLR Report.

References

10 CFR Part 50, Appendix B, “Quality Assurance Criteria for Nuclear Power Plants and Fuel 

Reprocessing Plants.” Washington, DC: U.S. Nuclear Regulatory Commission. 2016. 

EPRI. EPRI 104213, “Bolted Joint Maintenance & Application Guide.” Palo Alto, California: 

Electric Power Research Institute. December 1995.

_____. EPRI 109619, “Guideline for the Management of Adverse Localized Equipment 

Environments.” Palo Alto, California: Electric Power Research Institute. June 1999.

_____. EPRI 1003471, “Electrical Connector Application Guidelines.” Palo Alto, California: 

Electric Power Research Institute. December 2002.

IEEE. IEEE Standard 1205-2014, “IEEE Guide for Assessing, Monitoring and Mitigating Aging 

Effects on Class 1E Equipment Used in Nuclear Power Generating Stations.” New York, 

New York: Institute of Electrical and Electronics Engineers. 2014.
XI.E6-5 

Licensee Event Report 361/2007-005, “San Onofre Unit 2, Loose Electrical Connection Results in 

Inoperable Pump Room Cooler.” https://lersearch.inl.gov/LERSearchCriteria.aspx. 2009.

Licensee Event Report 361/2007-006, “San Onofre Units 2 and 3, Loose Electrical Connection 

Results in One Train of Emergency Chilled Water (ECW) System Inoperable.” 

https://lersearch.inl.gov/LERSearchCriteria.aspx. 2009.

Licensee Event Report 361/2008-006, “San Onofre 2, Loose Connection Bolting Results in 

Inoperable Battery and TS Violation.” https://lersearch.inl.gov/LERSearchCriteria.aspx. 2009.

NEI. White Paper, “GALL-SLR AMP XI.E6 (Electrical Cables).” Agencywide Documents Access 

and Management System (ADAMS) Accession No. ML062770105. Washington, DC: 

Nuclear Energy Institute. September 5, 2006.

NRC. NUREG/CR–5643, “Insights Gained From Aging Research.” ADAMS Accession 

No. ML041530264. Washington, DC: U.S. Nuclear Regulatory Commission. March 31, 1992.

_____. Staff’s Response to the NEI White Paper on Generic Aging Lessons Learned (GALL) 

Report Aging Management Program (AMP) XI.E6, “Electrical Cable Connections Not Subject to 

10 CFR 50.49 Environmental Qualification Requirements.” ADAMS Accession No.

ML070400349. Washington, DC: U.S. Nuclear Regulatory Commission. March 16, 2007.

XI.E7-1

XI.E7 HIGH-VOLTAGE INSULATORS

Program Description

The purpose of the aging management program (AMP) is to provide reasonable assurance 

that the intended functions of high-voltage insulators within the scope of subsequent license 

renewal (SLR) are maintained consistent with the current licensing basis through the subsequent 

period of extended operation. The high-voltage insulator program was developed specifically 

to age manage high-voltage insulators susceptible to aging degradation due to local 

environmental conditions. 

The high-voltage insulators program includes visual inspections to identify degradation of 

high-voltage insulator sub-component parts, namely; insulation and metallic elements. Visual 

inspection provides reasonable assurance that the applicable aging effects are identified and 

high-voltage insulator age degradation is managed. Insulation materials used in high-voltage 

insulators may degrade more rapidly than expected when installed in an environment conducive 

to accelerated aging. The insulation and metallic elements of high-voltage insulators are made of 

porcelain, cement, malleable iron, aluminum, and galvanized steel. Significant loss of metallic 

material can occur due to mechanical wear caused by oscillating movement of insulators due to 

wind. Surface corrosion in metallic parts may appear due to contamination or where galvanized 

or other protective coatings are worn. With substantial airborne contamination such as salt, 

surface corrosion in metallic parts may become significant such that the insulator no longer will 

support the conductor. Various airborne contaminates such as dust, salt, fog, cooling tower 

plume, or industrial effluent can contaminate the insulator surface leading to reduced insulation 

resistance. Excessive surface contaminants or loss of material can lead to insulator flashover

and failure.

The high voltage insulators within the scope of this program are to be visually inspected at 

a frequency, determined prior to subsequent period of extended operation, based on plant-specific 

operating experience (OE). The first inspections for the subsequent period of extended operation 

are to be completed prior to the subsequent period of extended operation. The high-voltage 

insulator program provides reasonable assurance that high-voltage insulators will perform its 

intended function during the subsequent period of extended operation.

Evaluation and Technical Basis

1. Scope of Program: This AMP manages the age related degradation effects of 

high-voltage insulators within the scope of subsequent license renewal, susceptible to 

airborne contaminants including dust, salt, fog, cooling tower plume, industrial effluent or 

loss of material.

2. Preventive Actions: The high-voltage insulators AMP is a condition monitoring program 

that relies on visual inspections and high-voltage insulator coating and cleaning to manage 

high-voltage insulator aging effects. High-voltage insulator periodic visual inspections are 

performed to monitor the buildup of contaminants on the insulator surface. The periodic 

coating or cleaning of high-voltage insulators limits high-voltage insulator surface 

contamination.
XI.E7-2

3. Parameters Monitored or Inspected: The high voltage insulators within the scope of this 

program are visually inspected at a frequency based on plant-specific OE. High-voltage 

insulator surfaces are visually inspected to detect reduced insulation resistance aging 

effects including cracks, foreign debris, salt, dust, cooling tower plume and industrial 

effluent contamination. Metallic parts of the insulator are visually inspected to detect loss 

of material due to mechanical wear or corrosion.

4. Detection of Aging Effects: Visual inspection is used to detect the following two aging 

degradations: (a) loss of material in the metallic parts and (b) reduced insulation 

resistance. The loss of material in the metallic parts is due to corrosion caused by 

contaminants, where galvanized or other protective coatings are worn, and mechanical 

wear due to wind-induced movement. Reduced insulation resistance can be caused by 

the presence of insulator surface contamination. Visual inspections may be supplemented 

with infrared thermography inspections to detect high-voltage insulator reduced insulation 

resistance. The first inspection for SLR is to be completed prior to the subsequent period 

of extended operation.

5. Monitoring and Trending: Trending actions are not included as part of this AMP, 

because the ability to trend visual inspection results is limited. However, inspection results 

that are trendable provide additional information on the rate of insulator degradation 

including optimization of inspection frequencies. 

6. Acceptance Criteria: An unacceptable indication is defined as a noted condition or 

situation, if left unmanaged, could potentially lead to a loss of intended function.

High-voltage insulator surfaces are free from unacceptable accumulation of foreign 

material such as significant salt or dust buildup as well as other contaminants. Metallic 

parts must be free from significant loss of materials due to pitting, fatigue, crevice, and 

general corrosion. Acceptance criteria will be based on temperature rise above a 

reference temperature for the application when thermography is used. The reference 

temperature will be ambient temperature or a baseline temperature based on data from 

the same type of high-voltage insulator being inspected.

7. Corrective Actions: Results that do not meet the acceptance criteria are addressed in 

the applicant’s corrective action program under those specific portions of the quality 

assurance (QA) program that are used to meet Criterion XVI, “Corrective Action,” of 

10 CFR Part 50, Appendix B. Appendix A of the Generic Aging Lessons Learned for 

Subsequent License Renewal (GALL-SLR) Report describes how an applicant may apply 

its 10 CFR Part 50, Appendix B, QA program to fulfill the corrective actions element of this 

AMP for both safety-related and nonsafety-related structures and components (SCs) 

within the scope of this program. 

Corrective actions are taken and an engineering evaluation is performed when the 

acceptance criteria are not met. Corrective actions will be based on the observed 

degradation. The evaluation will consider the significance of the inspection results, the 

extent of the concern, the potential root causes, and the corrective actions required. If an 

unacceptable condition is identified, a determination is made as to whether the same 

condition or situation is applicable to other high-voltage insulators. Corrective actions will 

be implemented when inspection results do not meet the acceptance criteria.
XI.E7-3 

8. Confirmation Process: The confirmation process is addressed through those specific

portions of the QA program that are used to meet Criterion XVI, “Corrective Action,” of

10 CFR Part 50, Appendix B. Appendix A of the GALL-SLR Report describes how an

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the confirmation

process element of this AMP for both safety-related and nonsafety-related SCs within the

scope of this program.

9. Administrative Controls: Administrative controls are addressed through the QA program

that is used to meet the requirements of 10 CFR Part 50, Appendix B, associated with

managing the effects of aging. Appendix A of the GALL-SLR Report describes how an

applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the

administrative controls element of this AMP for both safety-related and nonsafety-related

SCs within the scope of this program.

10. Operating Experience: The program is informed and enhanced when necessary through

the systematic and ongoing review of both plant-specific and industry OE including

research and development such that the effectiveness of the AMP is evaluated consistent

with the discussion in Appendix B of the GALL-SLR Report.

References

10 CFR Part 50, Appendix B, “Quality Assurance Criteria for Nuclear Power Plants and Fuel 

Reprocessing Plants.” Washington, DC: U.S. Nuclear Regulatory Commission. 2016. 

EPRI. EPRI 1001997, “Parameters that Influence the Aging and Degradation of Overhead 

Conductors.” Palo Alto, California: Electric Power Research Institute. December 2003.

_____. EPRI 1013475, “Plant Support Engineering: License Renewal Electrical Handbook.” 

Revision 1. Palo Alto, California: Electric Power Research Institute. February 2007.

IEEE. IEEE Standard 1205-2014, “IEEE Guide for Assessing, Monitoring, and Mitigating Aging 

Effects on Electrical Equipment Used in Nuclear Power Generating Stations and Other Nuclear 

Facilities,” New York, New York: Institute of Electrical and Electronics Engineers. 2014.

NRC. NUREG/CR–5643, “Insights Gained From Aging Research.” Agencywide Documents 

Access and Management System (ADAMS) Accession No. ML041530264. Washington, DC: 

U.S. Nuclear Regulatory Commission. March 31, 1992.

_____. Information Notice 93-95: “Storm-Related Loss of Offsite Power Events Due to Salt 

Buildup on Switchyard Insulators.” ADAMS Accession No. ML031070158. Washington, DC: 

U.S. Nuclear Regulatory Commission. December 13, 1993.

XI 01-1 

Table XI-01. FSAR Supplement Summaries for GALL-SLR Report Chapter XI Aging 

 Management Programs 

AMP

GALL-SLR 

Program Description of Program

Implementation 

Schedule*

XI.E1

Electrical 

Insulation for 

Electrical 

Cables and 

Connections 

Not Subject to 

10 CFR 50.49 

Environmental 

Qualification 

Requirements

The program applies to accessible electrical cable 

and connection electrical insulation material within 

the scope of license renewal subjected to an 

adverse localized environment. Accessible inscope electrical cable and connection electrical 

insulation material is visually inspected and tested 

for cable and connection insulation surface 

anomalies indicating signs of reduced electrical 

insulation resistance. If visual inspections identify 

degraded or damaged conditions, then testing is 

performed for evaluation. 

Visual Inspection and testing may include 

thermography and one or more proven condition 

monitoring test methods applicable to the cable 

and connection insulation material. Electrical 

cable and connection insulation material test 

results are to be within the acceptance criteria, as 

identified in the applicant’s procedures. 

Program and 

SLR 

enhancements, 

when 

applicable, are 

implemented 

6 months prior 

to the 

subsequent 

period of 

extended 

operation.

XI.E2

Electrical 

Insulation for 

Electrical 

Cables and 

Connections 

Not Subject to 

10 CFR 50.49 

Environmental 

Qualification 

Requirements 

Used in 

Instrumentation 

Circuits

The program applies to electrical cables and 

connections (cable system) electrical insulation 

material used in circuits with sensitive, 

high-voltage, low-level current signals within the 

scope of subsequent license renewal. Examples 

of these circuits include radiation monitoring and 

nuclear instrumentation that are subject to aging 

management review and subjected to adverse 

localized environments caused by temperature, 

radiation, or moisture. 

The program evaluates electrical insulation 

material for cables and connections subjected to 

an adverse localized environment at least once 

every 10 years.

Program and 

SLR 

enhancements, 

when 

applicable, are 

implemented 

6 months prior 

to the 

subsequent 

period of 

extended 

operation.
XI 01-2 

Table XI-01. FSAR Supplement Summaries for GALL-SLR Report Chapter XI Aging 

 Management Programs 

AMP

GALL-SLR 

Program Description of Program

Implementation 

Schedule*

XI.E3A

Electrical 

Insulation for 

Inaccessible 

Medium-Voltage 

Power Cables 

Not Subject To 

10 CFR 50.49 

Environmental 

Qualification 

Requirements

The program applies to inaccessible or 

underground (e.g., installed in buried conduits, 

cable trenches, cable troughs, duct banks, 

underground vaults, or direct buried installations) 

medium-voltage power cable (operating voltage; 2 

kV to 35 kV) within the scope of license renewal 

exposed to significant moisture. 

This is a condition monitoring program. However, 

periodic actions are performed to prevent 

inaccessible cable from being exposed to 

significant moisture such as identifying and 

inspecting in-scope accessible cable conduit ends 

and cable manholes/vaults for water accumulation, 

and draining the water, as needed.

Significant moisture is defined as exposure to 

moisture that lasts more than 3 days (i.e., long 

term wetting or submergence over a continuous 

period) that if left unmanaged, could potentially 

lead to a loss of intended function.

Submarine or other cables designed for 

continuous wetting or submergence are also 

included in this AMP as a one-time inspection and 

test with additional periodic tests and inspections 

determined by one-time inspection results and 

industry and plant specific operating experience.

Program and

SLR 

enhancements, 

when 

applicable, are 

implemented 

6 months prior 

to the 

subsequent 

period of 

extended 

operation.

XI.E3B

Electrical 

Insulation for 

Inaccessible 

Instrument and 

Control Cables 

Not Subject To 

10 CFR 50.49 

Environmental 

Qualification 

Requirements

The program applies to inaccessible or 

underground (e.g., installed in buried conduits, 

cable trenches, cable troughs, duct banks, 

underground vaults, or direct buried installations) 

instrument and control cable, within the scope of 

license renewal exposed to significant moisture.

This is a condition monitoring program. However, 

periodic actions are taken to prevent inaccessible 

instrumentation and control cable from being 

exposed to significant moisture, such as identifying 

and inspecting in-scope accessible cable conduit 

ends and cable manholes/vaults for water 

accumulation, and draining the water, as needed.

Significant moisture is defined as exposure to 

moisture that lasts more than three days (i.e., long 

term wetting or submergence over a continuous 

period) that if left unmanaged, could potentially 

lead to a loss of intended function. 

Program and 

SLR 

enhancements, 

when 

applicable, are 

implemented 

6 months prior 

to the 

subsequent 

period of 

extended 

operation.
XI 01-3 

Table XI-01. FSAR Supplement Summaries for GALL-SLR Report Chapter XI Aging 

 Management Programs 

AMP

GALL-SLR 

Program Description of Program

Implementation 

Schedule*

XI.E3C

Electrical 

Insulation for 

Inaccessible 

Low-Voltage 

Power Cables 

Not Subject To 

10 CFR 50.49 

Environmental 

Qualification 

Requirements

The program applies to inaccessible or 

underground (e.g., installed in buried conduits, 

cable trenches, cable troughs, duct banks, 

underground vaults, or direct buried installations) 

low-voltage power cable (operating voltage less 

than 2 kV) within the scope of license renewal 

exposed to significant moisture. 

This is a condition monitoring program. However, 

periodic actions are taken to prevent inaccessible 

low-voltage power cable from being exposed to 

significant moisture, such as identifying and 

inspecting in-scope accessible cable conduit ends 

and cable manholes/vaults for water accumulation, 

and draining the water, as needed. 

Significant moisture is defined as exposure to 

moisture that lasts more than 3 days (i.e., long 

term wetting or submergence over a continuous 

period) that if left unmanaged, could potentially 

lead to a loss of intended function.

Program and 

SLR 

enhancements, 

when 

applicable, are 

implemented 

6 months prior 

to the 

subsequent 

period of 

extended 

operation.

XI.E4 Metal Enclosed 

Bus 

The program applies to metal enclosed bus (MEB) 

within the scope of subsequent license renewal. 

The program is a condition monitoring program 

that utilizes sampling. 

The program requires the visual inspection of MEB 

internal surfaces to detect age-related degradation, 

including cracks, corrosion, foreign debris, 

excessive dust buildup, and evidence of moisture 

intrusion. MEB insulating material is visually 

inspected for signs of embrittlement, cracking, 

chipping, melting, swelling, discoloration, or 

surface contamination, which may indicate 

overheating or aging degradation. The internal 

bus insulating supports are visually inspected for 

structural integrity and signs of cracks. MEB 

external surfaces are visually inspected for loss of 

material due to general, pitting, and crevice 

corrosion. Accessible elastomers (e.g., gaskets, 

bolts, and sealants) are inspected for degradation, 

including surface cracking, crazing, scuffing, and 

changes in dimensions (e.g., ballooning and 

necking), shrinkage, discoloration, hardening, and 

loss of strength. 

A sample of accessible bolted connections is 

inspected for increased resistance of connection 

by using thermography or by measuring 

connection resistance using a micro-ohmmeter. 

These inspections are performed at least once 

every 10 years. 

Program and 

SLR 

enhancements, 

when 

applicable, are 

implemented 

6 months prior 

to the 

subsequent 

period of 

extended 

operation.
XI 01-4 

Table XI-01. FSAR Supplement Summaries for GALL-SLR Report Chapter XI Aging 

 Management Programs 

AMP

GALL-SLR 

Program Description of Program

Implementation 

Schedule*

XI.E5 Fuse Holders 

The program applies to fuse holders outside of 

active equipment within the scope of subsequent 

license renewal and require age management 

activities. 

This is a condition monitoring program. The 

program utilizes visual inspection and testing to 

identify age-related degradation for both fuse 

holder electrical insulation material and fuse holder 

metallic clamps. The specific type of test 

performed is determined prior to the initial test and 

is to be a proven test for detecting increased 

resistance of connection of fuse holder metallic 

clamps, or other appropriate testing justified in the 

applicant’s aging management program. 

Program and 

SLR 

enhancements, 

when 

applicable, are 

implemented 

6 months prior 

to the 

subsequent 

period of 

extended 

operation.

XI.E6

Electrical Cable 

Connections 

Not Subject to 

10 CFR 50.49 

Environmental 

Qualification 

Requirements

The program applies to electrical connections 

within the scope of subsequent license renewal. 

The program is a condition monitoring program 

that consists of a representative sample of 

electrical connections tested prior to the 

subsequent period of extended operation, and the 

results are evaluated to determine the need for 

subsequent testing on a 10 year basis. 

The following factors are considered for sampling: 

voltage level (medium and low-voltage), circuit 

loading (high loading), connection type, and 

location (high temperature, high humidity, 

vibration, etc.). Twenty percent of a connector 

type population with a maximum sample of 25 

constitutes a representative connector sample 

size. Otherwise a technical justification of the 

methodology and sample size used for selecting 

components under test should be included as part 

of the applicant’s AMP documentation. The 

specific type of test to be performed is a proven 

test for detecting increased resistance of 

connection.

As an alternative to thermography or resistance 

measurement of cable connections for the 

accessible cable connections that are covered with 

electrical insulation materials such as tape, the 

applicant may perform visual inspection of the 

electrical insulation material to detect aging effects 

for covered cable connections. The basis for 

performing only a periodic visual inspection is 

documented. 

Program and 

SLR 

enhancements, 

when 

applicable, are

implemented 

6 months prior 

to the 

subsequent 

period of 

extended 

operation.
XI 01-5 

Table XI-01. FSAR Supplement Summaries for GALL-SLR Report Chapter XI Aging 

 Management Programs 

AMP

GALL-SLR 

Program Description of Program

Implementation 

Schedule*

XI.E7

High-Voltage 

Insulators

New AMP

The program was developed specifically to 

address aging management of in-scope

high-voltage insulator aging mechanisms and 

effects. This is a condition monitoring program 

and manages the age related degradation effects 

of within scope high-voltage insulators susceptible 

to airborne contaminates including dust, salt, fog, 

cooling tower plume, industrial effluent or loss of 

material. 

Program is 

implemented 

6 months prior 

to the 

subsequent 

period of 

extended 

operation. 

Inspections that 

are to be 

completed prior 

to the 

subsequent 

period of 

extended 

operation are 

completed 6 

months prior to 

the subsequent 

period of 

extended 

operation or no 

later than the 

last refueling 

outage prior to 

the subsequent 

period of 

extended 

operation.

XI.M1

ASME Section 

XI Inservice 

Inspection, 

Subsections 

IWB, IWC, and 

IWD 

The program consists of periodic volumetric, 

surface, and/or visual examination of ASME Class 

1, 2, and 3 pressure-retaining components, 

including welds, pump casings, valve bodies, 

integral attachments, and pressure-retaining 

bolting for assessment, signs of degradation, and 

corrective actions. This program is in accordance 

with the ASME Code Section XI edition and 

addenda approved in accordance with provisions 

of 10 CFR 50.55a during the subsequent period of 

extended operation. 

Program and 

SLR 

enhancements, 

when 

applicable, are 

implemented 

6 months prior 

to the 

subsequent 

period of 

extended 

operation.
XI 01-6 

Table XI-01. FSAR Supplement Summaries for GALL-SLR Report Chapter XI Aging 

 Management Programs 

AMP

GALL-SLR 

Program Description of Program

Implementation 

Schedule*

XI.M2 Water 

Chemistry

This program mitigates aging effects of loss of 

material due to corrosion, cracking due to SCC, 

and related mechanisms, and reduction of heat 

transfer due to fouling in components exposed to a 

treated water environment. Chemistry programs 

are used to control water chemistry for impurities 

(e.g., chloride, fluoride, and sulfate) that accelerate 

corrosion. This program relies on monitoring and 

control of water chemistry to keep peak levels of 

various contaminants below the system-specific 

limits, based on EPRI guidelines (a) BWRVIP-190 

(EPRI 1016579, BWR Water Chemistry Guidelines 

– 2008 Revision) for BWRs or (b) EPRI 1014986

(PWR Primary Water Chemistry – Revision 7) and 

EPRI 1016555 (PWR Secondary Water Chemistry 

– Revision 7) for PWRs.

Program is 

implemented 

6 months prior 

to the 

subsequent 

period of 

extended 

operation

XI.M3

Reactor Head 

Closure Stud 

Bolting

The program includes (a) ISI in conformance with 

the requirements of the ASME Code, Section XI, 

Subsection IWB, Table IWB-2500-1, and 

(b) preventive measures to mitigate cracking. The 

program also relies on recommendations to 

address reactor head stud bolting degradation as 

delineated in NRC RG 1.65, Revision 1. 

Program is 

implemented 

6 months prior 

to the 

subsequent 

period of 

extended 

operation
XI 01-7 

Table XI-01. FSAR Supplement Summaries for GALL-SLR Report Chapter XI Aging 

 Management Programs 

AMP

GALL-SLR 

Program Description of Program

Implementation 

Schedule*

XI.M4

BWR Vessel ID 

Attachment 

Welds

The program is a condition monitoring program 

that manages cracking in the reactor vessel inside 

diameter attachment welds. This program relies 

on visual examinations to detect cracking. The 

examination scope, frequencies, and methods are 

in accordance with ASME Code, Section XI, 

Table-IWB-2500-1, Examination Category B-N-2, 

and BWRVIP-48-A, “Vessel ID Attachment Weld 

Inspection and Flaw Evaluation Guidelines,” dated 

November 2004. The scope of the examinations 

is expanded when flaws are detected.

Any indications are evaluated in accordance with 

ASME Code, Section XI, or the guidance in 

BWRVIP 48-A. Crack growth evaluations follow 

the guidance in BWRVIP-14-A, “Evaluation of 

Crack Growth in BWR Stainless Steel RPV 

Internals, dated September 2008; BWRVIP-59-A, 

“Evaluation of Crack Growth in BWR Nickel-Base 

Austenitic Alloys in RPV Internals,” dated 

May 2007; or 

BWRVIP-60-A, “BWR Vessel and Internals 

Project, Evaluation of Crack Growth in BWR Low 

Alloy Steel RPV Internals,” dated June 2003; as 

appropriate. The acceptance criteria are in 

BWRVIP-48-A and ASME Code, Section XI, 

Subarticle IWB-3520. Repair and replacement 

activities are conducted in accordance with 

BWRVIP-52-A, “Shroud Support and Vessel 

Bracket Repair Design Criteria,” dated September 

2005.

Program is 

implemented 

6 months prior 

to the 

subsequent 

period of 

extended 

operation
XI 01-8 

Table XI-01. FSAR Supplement Summaries for GALL-SLR Report Chapter XI Aging 

 Management Programs 

AMP

GALL-SLR 

Program Description of Program

Implementation 

Schedule*

XI.M7

BWR Stress 

Corrosion 

Cracking

The program manages cracking due to IGSCC for 

all BWR piping and piping welds made of 

austenitic stainless steel and nickel alloy that are 

4 inches or larger in nominal diameter containing 

reactor coolant at a temperature above 93 °C 

(200 °F) during power operation, regardless of 

code classification.

The program performs volumetric examinations to 

detect and manage IGSCC in accordance with 

NRC GL 88-01. Modifications to the extent and 

schedule of inspection in GL 88-01 are allowed in 

accordance with the inspection guidance in staffapproved BWRVIP-75-A. This program relies on 

the staff-approved positions that are described in 

NUREG–0313, Revision 2, and GL 88-01 and its 

Supplement 1 regarding selection of IGSCCresistant materials, solution heat treatment and 

stress improvement processes, water chemistry, 

weld overlay reinforcement, partial replacement, 

clamping devices, crack characterization and 

repair criteria, inspection methods and personnel, 

inspection schedules, sample expansion, leakage 

detection, and reporting requirements.

Program is 

implemented 

6 months prior 

to the 

subsequent 

period of 

extended 

operation

XI.M8 BWR 

Penetrations

The program includes BWR instrumentation 

penetrations, CRD housing and ICMH 

penetrations, and standby liquid control 

nozzles/Core ΔP nozzles. The program manages 

cracking due to cyclic loading or stress corrosion 

cracking by performing inspection and flaw 

evaluation in accordance with the guidelines of 

staff-approved BWRVIP-49-A, BWRVIP-47-A and 

BWRVIP-27-A and the requirements in the ASME 

Code, Section XI. The examination categories 

include volumetric examination methods 

(ultrasonic testing or radiography testing), surface 

examination methods (liquid penetrant testing or 

magnetic particle testing), and visual examination 

methods.

Program is 

implemented 

6 months prior 

to the 

subsequent 

period of 

extended 

operation
XI 01-9 

Table XI-01. FSAR Supplement Summaries for GALL-SLR Report Chapter XI Aging 

 Management Programs 

AMP

GALL-SLR 

Program Description of Program

Implementation 

Schedule*

XI.M9 BWR Vessel 

Internals

The program includes inspections and flaw 

evaluations in conformance with the guidelines of 

applicable staff-approved BWRVIP documents, 

and provides reasonable assurance of the longterm integrity and safe operation of BWR vessel 

internal components that are fabricated of nickel 

alloy and stainless steel (including martensitic 

stainless steel, cast stainless steel and 

associated welds).

The program manages the effects of cracking due 

to SCC, IGSCC, or IASCC, cracking due to cyclic 

loading (including flow-induced vibration), loss of 

material due to wear, loss of fracture toughness 

due to neutron or thermal embrittlement, and loss 

of preload due to thermal or irradiation-enhanced 

stress relaxation.

The program performs inspections for cracking 

and loss of material in accordance with the 

guidelines of applicable staff-approved BWRVIP 

documents and the requirements of ASME Code, 

Section XI, Table IWB 2500-1. The impact of loss 

of fracture toughness on component integrity is 

indirectly managed by using visual or volumetric 

examination techniques to monitor for cracking in 

the components. This program also manages loss 

of preload for core plate rim holddown bolts and jet 

pump assembly holddown beam bolts by 

performing visual inspections or stress analyses 

for adequate structural integrity.

This program performs evaluations to determine 

whether supplemental inspections in addition to 

the existing BWRVIP examination guidelines are 

necessary to adequately manage loss of fracture 

toughness due to thermal or neutron embrittlement 

and cracking due to IASCC for the subsequent 

period of extended operation. If the evaluations 

determine that supplemental inspections are 

necessary for certain components based on 

neutron fluence, cracking susceptibility and 

fracture toughness, the program conducts the 

supplemental inspections for adequate aging

management. 

Program is 

implemented 

6 months prior 

to the 

subsequent 

period of 

extended 

operation
XI 01-10

Table XI-01. FSAR Supplement Summaries for GALL-SLR Report Chapter XI Aging 

 Management Programs 

AMP

GALL-SLR 

Program Description of Program

Implementation 

Schedule*

XI.M10 Boric Acid 

Corrosion

This program relies, in part, on the response to 

NRC GL 88-05, “Boric Acid Corrosion of Carbon 

Steel Reactor Pressure Boundary Components in 

PWR Plants,” to identify, evaluate, and correct 

borated water leaks that could cause corrosion

damage to reactor coolant pressure boundary 

components. The program also includes 

inspections, evaluations, and corrective actions for 

all components subject to aging management 

review that may be adversely affected by some 

form of borated water leakage. 

This program includes provisions to initiate 

evaluations and assessments when leakage is 

discovered by activities not associated with the 

program. This program follows the guidance 

described in Section 7 of WCAP-15988-NP, 

Revision 2, “Generic Guidance for an Effective 

Boric Inspection Program for Pressurized Water 

Reactors.”

Program is 

implemented 

6 months prior 

to the 

subsequent 

period of 

extended 

operation

XI.M11B

Cracking of 

Nickel-Alloy 

Components 

and Loss of 

Material due to 

Boric AcidInduced 

Corrosion in 

Reactor Coolant 

Pressure 

Boundary 

Components 

(PWRs Only)

This program addresses operating experience of 

degradation due to PWSCC of components or 

welds constructed from certain nickel alloys 

(e.g., Alloy 600/82/182) and exposed to 

pressurized water reactor primary coolant at 

elevated temperature. The scope of this program 

includes the following groups of components and 

materials: (a) all nickel alloy components and 

welds which are identified in EPRI MRP-126; (b) 

nickel alloy components and welds identified in 

ASME Code Cases N-770, N-729, and N-722, as 

incorporated by reference in 10 CFR 50.55a; and 

(c) components that are susceptible to corrosion 

by boric acid and may be impacted by leakage of 

boric acid from nearby or adjacent nickel alloy 

components previously described. This program is 

used in conjunction with GALL-SLR Report AMP 

XI.M2, “Water Chemistry” because water 

chemistry can affect the cracking of nickel alloys. 

The completeness of the plant’s EPRI MRP-126 

program is also verified prior to entering the 

subsequent period of extended operation.

For nickel alloy components and welds addressed 

by the regulatory requirements of 10 CFR 50.55a, 

inspections are conducted in accordance with 

10 CFR 50.55a. Other nickel alloy components 

and welds within the scope of this program are 

inspected in accordance with EPRI MRP-126.

Program is 

implemented 

6 months prior 

to the 

subsequent 

period of 

extended 

operation 
XI 01-11

Table XI-01. FSAR Supplement Summaries for GALL-SLR Report Chapter XI Aging 

 Management Programs 

AMP

GALL-SLR 

Program Description of Program

Implementation 

Schedule*

XI.M12

Thermal Aging 

Embrittlement of 

Cast Austenitic 

Stainless Steel 

(CASS) 

The program consists of the determination of the 

susceptibility potential significance of loss of 

fracture toughness due to thermal aging 

embrittlement of CASS piping and piping 

components in both the BWR and PWR reactor 

coolant pressure boundaries ECCS systems, 

including interfacing pipe lines to the chemical and 

volume control system and to the spent fuel pool; 

and in BWR ECCS systems, including interfacing 

pipe lines to the suppression chamber and to the 

drywell and suppression chamber spray system in 

regard to thermal aging embrittlement based on 

the casting method, molybdenum content, and 

ferrite percentage. For potentially susceptible 

piping and piping components aging management 

is accomplished either through enhanced 

volumetric examination, enhanced visual 

examination, or a component-specific flaw 

tolerance evaluation.

Program is 

implemented 

6 months prior 

to the 

subsequent 

period of 

extended 

operation

XI.M16A PWR Vessel 

Internals

The program relies on implementation of the 

inspection and evaluation guidelines in EPRI 

Technical Report No. 1022863 (MRP-227-A) and 

EPRI Technical Report No. 1016609 (MRP-228) to 

manage the aging effects on the reactor vessel 

internal components, as supplemented by a gap 

analysis. This program is used to manage: 

(a) cracking, including stress corrosion cracking, 

primary water stress corrosion cracking, 

irradiation-assisted stress corrosion cracking, and 

cracking due to fatigue/cyclical loading; (b) loss of 

material induced by wear; (c) loss of fracture 

toughness due to either thermal aging, neutron 

irradiation embrittlement, or void swelling; (d) 

dimensional changes due to void swelling or 

distortion; and (e) loss of preload due to thermal 

and irradiation enhanced stress relaxation 

or creep.

[The applicant is to provide additional details to 

describe the gap analysis associated with the 

AMP.]

Program, 

accounting for 

the impacts of a 

gap analysis, is 

implemented 

6 months prior 

to the 

subsequent 

period of 

extended 

operation, or 

alternatively, a 

plant-specific 

program may be 

implemented 

6 months prior 

to the 

subsequent 

period of 

extended 

operation.
XI 01-12

Table XI-01. FSAR Supplement Summaries for GALL-SLR Report Chapter XI Aging 

 Management Programs 

AMP

GALL-SLR 

Program Description of Program

Implementation 

Schedule*

XI.M17

FlowAccelerated 

Corrosion (FAC) 

The program is based on the response to NRC 

GL 89-08, “Erosion/Corrosion-Induced Pipe Wall 

Thinning,” and relies on implementation of the 

EPRI guidelines in the Nuclear Safety Analysis 

Center 202L [(as applicable) Revision 2, 3, or 4], 

“Recommendations for an Effective Flow 

Accelerated Corrosion Program.”

The program includes the use of predictive 

analytical software [(as applicable) 

CHECWORKSTM, BRT CICEROTM, COMSY]. [(If 

applicable) This program also manages wall 

thinning caused by mechanisms other than FAC,

in situations where periodic monitoring is used in 

lieu of eliminating the cause of various

erosion mechanisms.]

This program includes: (a) identifying all 

susceptible piping systems and components; (b) 

developing FAC predictive models to reflect 

component geometries, materials, and operating 

parameters; (c) performing analyses of FAC 

models and, with consideration of operating 

experience, selecting a sample of components for 

inspections; (d) inspecting components; 

(e) evaluating inspection data to determine the 

need for inspection sample expansion, repairs, or 

replacements, and to schedule future inspections; 

and (f) incorporating inspection data to refine FAC 

models.

Program and 

SLR 

enhancements, 

when 

applicable, are 

implemented 

6 months prior 

to the 

subsequent 

period of 

extended 

operation.
XI 01-13

Table XI-01. FSAR Supplement Summaries for GALL-SLR Report Chapter XI Aging 

 Management Programs 

AMP

GALL-SLR 

Program Description of Program

Implementation 

Schedule*

XI.M18 Bolting Integrity 

This program focuses on closure bolting for 

pressure-retaining components and relies on 

recommendations for a comprehensive bolting 

integrity program, as delineated in NUREG–1339 

and EPRI NP–5769, with the exceptions noted in 

NUREG–1339 for safety-related bolting. The 

program also relies on industry recommendations 

for comprehensive bolting maintenance, as 

delineated in the EPRI 1015336 and 1015337.

The program includes periodic visual inspection of 

closure bolting for indications of loss of preload, 

cracking, and loss of material due to general, 

pitting, and crevice corrosion, MIC, and wear as 

evidenced by leakage. Closure bolting that is 

submerged or where the piping systems contains 

air or gas for which leakage is difficult to detect are 

inspected or tested by alternative means. The 

program also includes sampling-based volumetric 

examinations of high-strength closure bolting to 

detect indications of cracking. The program also 

includes preventive measures to preclude or 

minimize loss of preload and cracking.

A related aging management program (AMP) 

XI.M1, “ASME Section XI Inservice Inspection (ISI) 

Subsections IWB, IWC, and IWD,” includes 

inspections of safety-related and nonsafety-related 

closure bolting and supplements this bolting 

integrity program. Other related programs, 

AMPs XI.S1, “ASME Section XI, Subsection IWE”; 

XI.S3, “ASME Section XI Subsection IWF”; 

XI.S6, “Structures Monitoring”; XI.S7, “Inspection 

of Water-Control Structures Associated with 

Nuclear Power Plant”; and XI.M23, “Inspection of 

Overhead Heavy Load and Light Load (Related to 

Refueling) Handling Systems,” manage the 

inspection of safety related and nonsafety related 

structural bolting.

Program and 

SLR 

enhancements, 

when 

applicable, are 

implemented 

6 months prior 

to the 

subsequent 

period of 

extended 

operation.
XI 01-14

Table XI-01. FSAR Supplement Summaries for GALL-SLR Report Chapter XI Aging 

 Management Programs 

AMP

GALL-SLR 

Program Description of Program

Implementation 

Schedule*

XI.M19 Steam 

Generators

This program manages the aging of steam 

generator tubes, plugs, sleeves, divider plate 

assemblies (as applicable), tube-to-tubesheet 

welds, heads (interior surfaces of channel or 

lower/upper heads), tubesheets (primary side), 

and secondary side components that are 

contained within the steam generator. This 

program consists of aging management activities 

for the steam generator tubes, plugs, sleeves, and 

secondary side components that are contained 

within the steam generator in accordance with the 

plant technical specifications and includes 

commitments to NEI 97-06, Revision 3 and the 

associated EPRI guidelines. This program also 

performs general visual inspections of the steam 

generator heads (internal surfaces) looking for 

evidence of cracking or loss of material (e.g., rust 

stains) at least every 72 effective full power 

months or every third refueling outage, whichever 

results in more frequent inspections. The program 

includes foreign material exclusion as a means to 

inhibit wear degradation, and secondary side 

maintenance activities, such as sludge lancing, for 

removing deposits that may contribute to 

component degradation. The program performs 

volumetric examination on steam generator tubes 

in accordance with the requirements in the 

technical specifications to detect aging effects, if 

they should occur. The technical specifications 

require condition monitoring (explicitly) and 

operational assessments (implicitly) to be 

performed to ensure that the tube integrity will be 

maintained until the next inspection.

Program and 

SLR 

enhancements, 

when 

applicable, are 

implemented 

6 months prior 

to the 

subsequent 

period of 

extended 

operation.

XI.M20

Open-Cycle 

Cooling Water 

System 

The program relies, in part, on implementing the 

response to NRC GL 89-13, “Service Water 

System Problems Affecting Safety-Related 

Equipment,” [(if applicable) and includes 

nonsafety-related portions of the open-cycle 

cooling water system]. The program includes: (a) 

surveillance and control to significantly reduce the 

incidence of flow blockage problems as a result of 

biofouling, (b) tests to verify heat transfer of heat 

exchangers, (c) routine inspection and 

maintenance so that corrosion, erosion, protective 

coating failure, fouling, and biofouling cannot 

degrade the performance of systems serviced by 

the open-cycle cooling water system. This 

program includes enhancements to the guidance 

in NRC GL 89-13 that address operating 

experience such that aging effects are adequately 

managed.

Program and 

SLR 

enhancements, 

when 

applicable, are 

implemented 

6 months prior 

to the 

subsequent 

period of 

extended 

operation.
XI 01-15

Table XI-01. FSAR Supplement Summaries for GALL-SLR Report Chapter XI Aging 

 Management Programs 

AMP

GALL-SLR 

Program Description of Program

Implementation 

Schedule*

XI.M21A Closed Treated 

Water Systems

This is a mitigation program that also includes a 

condition monitoring program to verify the 

effectiveness of the mitigation activities. The 

program consists of: (a) water treatment, including 

the use of corrosion inhibitors, to modify the 

chemical composition of the water such that the 

effects of corrosion are minimized; (b) chemical 

testing of the water so that the water treatment 

program maintains the water chemistry within

acceptable guidelines; and (c) inspections to 

determine the presence or extent of degradation. 

The program uses as applicable, EPRI 1007820, 

Closed Cooling Water Chemistry Guideline, and 

includes corrosion coupon testing and 

microbiological testing.

Program and 

SLR 

enhancements, 

when 

applicable, are 

implemented 

6 months prior 

to the 

subsequent 

period of 

extended 

operation.

XI.M22 Boraflex 

Monitoring

The program consists of: (a) neutron attenuation 

testing (“blackness testing”) to determine gap 

formation, (b) sampling for the presence of silica in 

the spent fuel pool along with boron loss, and 

(c) monitoring and analysis of criticality to assure 

that the required 5% subcriticality margin is 

maintained. This program is implemented in 

response to NRC GL 96-04.

Program and 

SLR 

enhancements, 

when 

applicable, are 

implemented 

6 months prior 

to the 

subsequent 

period of 

extended 

operation.

XI.M23

Inspection of 

Overhead 

Heavy Load and 

Light Load 

Handling 

Related to 

Refueling) 

Handling 

Systems 

The program evaluates the effectiveness of 

maintenance monitoring activities for cranes and 

hoists. The program includes periodic visual 

inspections to detect loss of material due to 

corrosion, wear, cracking, and indications of loss of 

preload for load handling bridges, structural 

members, structural components and bolted 

connections. This program relies on the guidance 

in NUREG–0612, ASME B30.2, and other 

appropriate standards in the ASME B30 series. 

These cranes must also comply with the 

maintenance rule requirements provided in 10 

CFR 50.65.

Program and 

SLR 

enhancements, 

when 

applicable, are 

implemented 

6 months prior 

to the 

subsequent 

period of 

extended 

operation.
XI 01-16

Table XI-01. FSAR Supplement Summaries for GALL-SLR Report Chapter XI Aging 

 Management Programs 

AMP

GALL-SLR 

Program Description of Program

Implementation 

Schedule*

XI.M24 Compressed Air 

Monitoring 

The program consists of monitoring moisture 

content and corrosion, and performance of the 

compressed air system, including (a) preventive 

monitoring of water (moisture), and other 

contaminants to keep within the specified limits 

and (b) inspection of components for indications of 

loss of material due to corrosion. This program is 

in response to NRC GL 88-14 and INPO’s SOER 

88-01. It also relies on the guidance from the 

ASME operations and maintenance standards and 

guides (ASME 

OM-S/G-2012, Division 2, Part 28) and 

ANSI/ISA-S7.0.1-1996, and EPRI TR–10847 for 

testing and monitoring air quality and moisture. 

Additionally, periodic opportunistic visual 

inspections of component internal surfaces are 

performed for signs of loss of material due to 

corrosion.

Program and 

SLR 

enhancements, 

when 

applicable, are 

implemented 

6 months prior 

to the 

subsequent 

period of 

extended 

operation.

XI.M25

BWR Reactor 

Water Cleanup 

System

This program includes ISI and monitoring and 

control of reactor coolant water chemistry. Related 

to the inspection guidelines for the RWCU 

inspections of RWCU piping welds that are located 

outboard of the second containment isolation 

valve, the program includes measures delineated 

in per the guidelines of NUREG–0313, Revision 2, 

and NRC GL 88-01, GL 88-01 Supplement 1, and 

any applicable NRC-approved alternatives to these 

guidelines and ISI in conformance with the ASME 

Code Section XI.

Program and 

SLR 

enhancements, 

when 

applicable, are 

implemented 

6 months prior 

to the 

subsequent 

period of 

extended 

operation.

XI.M26 Fire Protection

This program includes fire barrier inspections. The 

fire barrier inspection program requires periodic 

visual inspection of fire barrier penetration seals, 

fire barrier walls, ceilings, and floors, fire damper 

assemblies, and periodic visual inspection and 

functional tests of fire-rated doors to so that their 

operability is maintained. The program also 

includes periodic inspection and testing of 

halon/carbon dioxide or clean agent fire 

suppression systems.

Program and 

SLR 

enhancements, 

when 

applicable, are 

implemented 

6 months prior 

to the 

subsequent 

period of 

extended 

operation.
XI 01-17

Table XI-01. FSAR Supplement Summaries for GALL-SLR Report Chapter XI Aging 

 Management Programs 

AMP

GALL-SLR 

Program Description of Program

Implementation 

Schedule*

XI.M27 Fire Water 

System

This program is a condition monitoring program 

that manages aging effects associated with 

water-based fire protection system components. 

This program manages loss of material, cracking, 

and flow blockage due to fouling by conducting 

periodic visual inspections, tests, and flushes 

performed in accordance with the 2011 Edition of 

NFPA 25. Testing or replacement of sprinklers 

that have been in place for 50 years is performed 

in accordance with NFPA 25. In addition to NFPA 

codes and standards, portions of the water-based 

fire protection system that are: (a) normally dry but 

periodically subjected to flow and (b) cannot be 

drained or allow water to collect are subjected to 

augmented testing beyond that specified in 

NFPA 25, including: (a) periodic system full flow 

tests at the design pressure and flow rate or 

internal visual inspections and (b) piping volumetric 

wall-thickness examinations.

The water-based fire protection system is normally 

maintained at required operating pressure and is 

monitored such that loss of system pressure is 

immediately detected and corrective actions 

initiated. Piping wall thickness measurements are 

conducted when visual inspections detect surface 

irregularities indicative of unexpected levels of 

degradation. When the presence of sufficient 

organic or inorganic material sufficient to obstruct 

piping or sprinklers is detected, the material is 

removed and the source is detected and corrected. 

Inspections and tests follow site procedures that 

include inspection parameters for items such as 

lighting, distance, offset, presence of protective 

coatings, and cleaning processes for an adequate 

examination.

Program is 

implemented 

and inspections 

or tests begin 

5 years before 

the subsequent 

period of 

extended 

operation. 

Inspections or 

tests that are to 

be completed 

prior to the 

subsequent 

period of 

extended 

operation are 

completed 

6 months prior 

to the 

subsequent 

period of 

extended 

operation or no 

later than the 

last refueling 

outage prior to 

the subsequent 

period of 

extended 

operation.
XI 01-18

Table XI-01. FSAR Supplement Summaries for GALL-SLR Report Chapter XI Aging 

 Management Programs 

AMP

GALL-SLR 

Program Description of Program

Implementation 

Schedule*

XI.M29

Outdoor and 

Large 

Atmospheric 

Metallic Storage 

Tanks

This program is a condition monitoring program 

that manages aging effects associated with 

outdoor tanks sited on soil or concrete, indoor 

large-volume tanks containing water designed with 

internal pressures approximating atmospheric 

pressure that are sited on concrete or soil, and 

other indoor tanks that sit on, or are embedded in 

concrete, where plant-specific operating 

experience indicates that the tank surfaces are 

periodically exposed to moisture, including the 

[applicant to list the specific tanks that are in the 

program scope]. The program includes preventive 

measures to mitigate corrosion by protecting the 

external surfaces of steel components per 

standard industry practice. Sealant or caulking is 

used for outdoor tanks at the concrete-component 

interface.

This program manages loss of material and 

cracking by conducting periodic internal and 

external visual and surface examinations. 

Inspections of caulking or sealant are 

supplemented with physical manipulation. Surface 

exams are conducted to detect cracking when 

susceptible materials are used. [The applicant can 

modify this sentence if it is demonstrated that any 

in-scope stainless steel or aluminum tanks are not 

susceptible to SCC or loss of material based on 

the results of SRP-SLR Sections 3.1.2.2.16, 

3.2.2.2.4, 3.3.2.2.3, 3.4.2.2.2, 3.2.2.2.2, 3.3.2.2.4, 

3.4.2.2.3, 3.2.2.2.8, 3.3.2.2.8, 3.4.2.2.7, 3.2.2.2.10, 

3.3.2.2.10, and 3.4.2.2.9.] Thickness 

measurements of tank bottoms are conducted to 

detect degradation. The external surfaces of 

insulated tanks are periodically sampling-based 

inspected. Inspections not conducted in 

accordance with ASME Code Section XI 

requirements are conducted in accordance with 

plant-specific procedures including inspection 

parameters such as lighting, distance, offset, and 

surface conditions. 

Program is 

implemented 

and inspections 

or tests begin 

10 years before 

the subsequent 

period of 

extended 

operation. 

Inspections or 

tests that are to 

be completed 

prior to the 

subsequent 

period of 

extended 

operation are 

completed 

6 months prior 

to the 

subsequent 

period of 

extended 

operation or no 

later than the 

last refueling 

outage prior to 

the subsequent 

period of 

extended 

operation. 
XI 01-19

Table XI-01. FSAR Supplement Summaries for GALL-SLR Report Chapter XI Aging 

 Management Programs 

AMP

GALL-SLR 

Program Description of Program

Implementation 

Schedule*

XI.M30 Fuel Oil 

Chemistry

This program relies on a combination of 

surveillance and maintenance procedures. Fuel oil

quality is maintained by monitoring and controlling

fuel oil contamination in accordance with the

plant’s technical specifications. Guidelines of the

ASTM Standards, such as ASTM D 0975, D 1796,

D 2276, D 2709, D 6217, and D 4057, also may be 

used. Exposure to fuel oil contaminants, such as 

water and microbiological organisms, is minimized 

by periodic cleaning/draining of tanks and by 

verifying the quality of new oil before its 

introduction into the storage tanks.

Program is 

implemented

and inspections 

begin 10 years 

before the 

subsequent 

period of 

extended 

operation. 

Inspections that 

are to be 

completed prior 

to the 

subsequent 

period of 

extended 

operation are 

completed 

6 months prior 

to the 

subsequent 

period of 

extended 

operation or no

later than the 

last refueling 

outage prior to 

the subsequent 

period of 

extended 

operation.

XI.M31

Reactor Vessel 

Material 

Surveillance

This program requires implementation of a reactor 

vessel material surveillance program to monitor 

the changes in fracture toughness to the ferritic 

reactor vessel beltline materials which are 

projected to receive a peak neutron fluence at the 

end of the design life of the vessel exceeding 1017

n/cm2 (E >1MeV). The surveillance capsules must 

be located near the inside vessel wall in the 

beltline region so that the material specimens 

duplicate, to the greatest degree possible, the 

neutron spectrum, temperature history, and 

maximum neutron fluence experienced at the 

reactor vessel’s inner surface. Because of the 

resulting lead factors, surveillance capsules 

receive equivalent neutron fluence exposures 

earlier than the inner surface of the reactor vessel. 

This allows surveillance capsules to be withdrawn 

prior to the inner surface receiving an equivalent 

neutron fluence and therefore test results may 

Program and 

SLR 

enhancements, 

when 

applicable, are 

implemented 

6 months prior 

to the 

subsequent 

period of 

extended 

operation. This 

program 

includes 

removal and 

testing of at 

least one 

capsule during 

the subsequent 

period of 

extended 
XI 01-20

Table XI-01. FSAR Supplement Summaries for GALL-SLR Report Chapter XI Aging 

 Management Programs 

AMP

GALL-SLR 

Program Description of Program

Implementation 

Schedule*

bound the corresponding operating period in the 

capsule withdrawal schedule.

This surveillance program must comply with ASTM 

International (formerly American Society for 

Testing and Materials) Standard Practice E 185-

82, as incorporated by reference in 10 CFR Part 

50, Appendix H. Because the withdrawal schedule 

in Table 1 of ASTM E 185-82 is based on plant 

operation during the original 40-year initial license 

term, standby capsules may need to be 

incorporated into the Appendix H program for 

appropriate monitoring during the subsequent 

period of extended operation. Surveillance 

capsules are designed and located to permit 

insertion of replacement capsules. If standby 

capsules will be incorporated into the Appendix H 

program for the subsequent period of extended 

operation and have been removed from the reactor 

vessel, these should be reinserted so that 

appropriate lead factors are maintained and test 

results will bound the corresponding operating 

period. This program includes removal and testing 

of at least one capsule during the subsequent 

period of extended operation, with a neutron 

fluence of the capsule between one and two times 

the projected peak vessel neutron fluence at the 

end of the subsequent period of extended 

operation.

As an alternative to a plant-specific surveillance 

program complying with ASTM E 185-82, an ISP 

may be considered for a set of reactors that have 

similar design and operating features, in 

accordance with 10 CFR Part 50, Appendix H, 

Paragraph III.C. The plant-specific implementation 

of the ISP is consistent with the latest version of 

the ISP plan that has received approval by the 

NRC for the subsequent period of extended 

operation. 

The objective of this Reactor Vessel Material 

Surveillance program is to provide sufficient 

material data and dosimetry to (a) monitor 

irradiation embrittlement to neutron fluences 

greater than the projected neutron fluence at the 

end of the subsequent period of operation, and (b) 

provide adequate dosimetry monitoring during the 

operational period. If surveillance capsules are not 

withdrawn during the subsequent period of 

operation, with a 

neutron fluence 

of the capsule 

between one 

and two times 

the projected 

peak vessel 

neutron fluence 

at the end of the 

subsequent 

period of 

extended 

operation.
XI 01-21

Table XI-01. FSAR Supplement Summaries for GALL-SLR Report Chapter XI Aging 

 Management Programs 

AMP

GALL-SLR 

Program Description of Program

Implementation 

Schedule*

extended operation, provisions are made to 

perform dosimetry monitoring.

This program is a condition monitoring program 

that measures the increase in Charpy V-notch 30 

ft-lb transition temperature and the drop in the 

upper-shelf energy as a function of neutron fluence 

and irradiation temperature. The data from this 

surveillance program are used to monitor neutron 

irradiation embrittlement of the reactor vessel, and 

are inputs to the neutron embrittlement TLAAs 

described in Section 4.2 of the SRP-SLR. The 

Reactor Vessel Material Surveillance program is 

also used in conjunction with AMP X.M2, “Neutron 

Fluence Monitoring,” which monitors neutron 

fluence for reactor vessel components and reactor 

vessel internal components.

In accordance with 10 CFR Part 50, Appendix H, 

all surveillance capsules, including those 

previously removed from the reactor vessel, must 

meet the test procedures and reporting 

requirements of ASTM E 185-82, to the extent 

practicable, for the configuration of the specimens 

in the capsule. Any changes to the capsule 

withdrawal schedule, including the conversion of 

standby capsules into the Appendix H program 

and extension of the surveillance program for the 

subsequent period of extended operation, must be 

approved by the NRC prior to implementation, in 

accordance with 10 CFR Part 50, Appendix H, 

Paragraph III.B.3. Standby capsules placed in 

storage (e.g., removed from the reactor vessel) 

are maintained for possible future insertion.
XI 01-22

Table XI-01. FSAR Supplement Summaries for GALL-SLR Report Chapter XI Aging 

 Management Programs 

AMP

GALL-SLR 

Program Description of Program

Implementation 

Schedule*

XI.M32 One-Time 

Inspection 

The program is a condition monitoring program 

consisting of a one-time inspection of selected 

components to verify: (a) the system-wide 

effectiveness of an AMP that is designed to 

prevent or minimize aging to the extent that it will 

not cause the loss of intended function during the 

subsequent period of extended operation; (b) the 

insignificance of an aging effect; and (c) that 

long-term loss of material will not cause a loss of 

intended function for steel components exposed to 

environments that do not include corrosion 

inhibitors as a preventive action. 

The elements of the program include: 

(a) determination of the sample size of 

components to be inspected based on an 

assessment of materials of fabrication, 

environment, plausible aging effects, and 

operating experience, (b) identification of the 

inspection locations in the system or component 

based on the potential for the aging effect to occur, 

(c) determination of the examination technique, 

including acceptance criteria that would be 

effective in managing the aging effect for which the

component is examined, and (d) an evaluation of 

the need for follow-up examinations to monitor the 

progression of aging if age-related degradation is 

found that could jeopardize an intended function 

before the end of the subsequent period of 

extended operation.

Periodic inspections instead of this program are 

used for structures or components with known 

age-related degradation mechanisms or when the 

environment in the subsequent period of extended 

operation is not expected to be equivalent to that in 

the prior operating period. Inspections not 

conducted in accordance with ASME Code 

Section XI requirements are conducted in 

accordance with plant-specific procedures 

including inspection parameters such as lighting, 

distance, offset, and surface conditions.

Program is 

implemented 

and inspections 

begin 10 years 

before the 

subsequent 

period of 

extended 

operation. 

Inspections that 

are to be 

completed prior 

to the 

subsequent 

period of 

extended 

operation are 

completed 

6 months prior 

to the 

subsequent 

period of 

extended 

operation or no 

later than the 

last refueling 

outage prior to 

the subsequent 

period of 

extended 

operation.
XI 01-23

Table XI-01. FSAR Supplement Summaries for GALL-SLR Report Chapter XI Aging 

 Management Programs 

AMP

GALL-SLR 

Program Description of Program

Implementation 

Schedule*

XI.M33 Selective 

Leaching 

This program is a condition monitoring program 

that includes a one-time inspection for components 

exposed to a closed-cycle cooling water or treated 

water environment when plant-specific operating 

experience has not revealed selective leaching in 

these environments. Opportunistic and periodic 

inspections are conducted for raw water, waste 

water, soil, and groundwater environments, and for 

closed-cycle cooling water and treated water 

environments when plant-specific operating 

experience has revealed selective leaching in 

these environments. Visual inspections coupled 

with mechanical examination techniques such as 

chipping or scraping are conducted. Periodic 

destructive examinations of components for 

physical properties (i.e., degree of dealloying, 

depth of dealloying, through-wall thickness, and 

chemical composition) are conducted for 

components exposed to raw water, waste water, 

soil, and groundwater environments, or for 

closed-cycle cooling water and treated water 

environments when plant-specific operating 

experience has revealed selective leaching in 

these environments. Inspections and tests are 

conducted to determine whether loss of material 

will affect the ability of the components to perform 

their intended function for the subsequent period of 

extended operation. Inspections are conducted in 

accordance with plant-specific procedures 

including inspection parameters such as lighting, 

distance, offset and surface conditions. When the 

acceptance criteria are not met such that it is 

determined that the affected component should be 

replaced prior to the end of the subsequent period 

of extended operation, additional inspections are 

performed.

Program is 

implemented 

and inspections 

begin 10 years 

before the 

subsequent 

period of 

extended 

operation. 

Inspections that 

are to be 

completed prior 

to the 

subsequent 

period of 

extended 

operation are 

completed 

6 months prior 

to the 

subsequent 

period of 

extended 

operation or no 

later than the 

last refueling 

outage prior to 

the subsequent 

period of 

extended 

operation. 
XI 01-24

Table XI-01. FSAR Supplement Summaries for GALL-SLR Report Chapter XI Aging 

 Management Programs 

AMP

GALL-SLR 

Program Description of Program

Implementation 

Schedule*

XI.M35

ASME Code 

Class 1 Small 

Bore-Piping

This program augments the existing ASME Code, 

Section XI requirements and is applicable to 

small-bore ASME Code Class 1 piping and 

systems with a NPS diameter less than 4 inches 

and greater than or equal to 1 inch (1 ≤ NPS <4). 

This program provides a one-time volumetric 

inspection of a sample of this Class 1 piping. This 

program includes pipes, full and partial penetration 

(socket) welds. The program includes measures 

to verify that degradation is not occurring, thereby 

either confirming that there is no need to manage 

aging-related degradation or validating the 

effectiveness of any existing program for the 

subsequent period of extended operation. The 

one-time inspection program for ASME Code 

Class 1 small-bore piping includes locations that 

are susceptible to cracking. This program is 

applicable to systems that have not experienced 

cracking of ASME Code Class 1 small-bore piping. 

This program can also be used for systems that 

experienced cracking but have implemented 

design changes to effectively mitigate cracking. 

[Measure of effectiveness includes: (1) the 

one-time inspection sampling is statistically 

significant; (2) samples will be selected as 

described in Element 5; and (3) no repeated 

failures over an extended period of time.] For 

systems that have experienced cracking and 

operating experience indicates design changes 

have not been implemented to effectively mitigate 

cracking, periodic inspection is proposed, as 

managed by a plant-specific AMP. Should 

evidence of cracking be revealed by a one-time 

inspection, a periodic inspection is also proposed, 

as managed by a plant-specific AMP.

Program is 

implemented 

and inspections 

are completed 

within 6 years 

before the 

subsequent 

period of 

extended 

operation. 

Inspections that 

are to be 

completed prior 

to the 

subsequent 

period of 

extended 

operation are 

completed 

6 months prior 

to the 

subsequent 

period of 

extended 

operation or no 

later than the 

last refueling 

outage prior to 

the subsequent 

period of 

extended 

operation. 
XI 01-25

Table XI-01. FSAR Supplement Summaries for GALL-SLR Report Chapter XI Aging 

 Management Programs 

AMP

GALL-SLR 

Program Description of Program

Implementation 

Schedule*

XI.M36

External 

Surfaces 

Monitoring of 

Mechanical 

Components

This program is a condition monitoring program 

that manages loss of material, cracking, changes 

in material properties (of cementitious 

components), hardening or loss of strength (of 

elastomeric components), and reduced thermal 

insulation resistance. Periodic visual inspections, 

not to exceed a refueling outage interval, of 

metallic, polymeric, insulation jacketing (insulation 

when not jacketed), and cementitious components 

are conducted. Surface examinations or ASME 

Code Section XI VT-1 examinations are conducted 

to detect cracking of stainless steel and aluminum 

components. 

For certain materials, such as flexible polymers, 

physical manipulation or pressurization to detect 

hardening or loss of strength is used to augment 

the visual examinations conducted under this 

program. A sample of outdoor component 

surfaces that are insulated and a sample of indoor 

insulated components exposed to condensation 

(due to the in-scope component being operated 

below the dew point), are periodically inspected 

every 10 years during the subsequent period of 

extended operation. [The applicant can modify 

this sentence if it is demonstrated that any 

in-scope stainless steel or aluminum components

are not susceptible to SCC or loss of material 

based on the results of SRP-SLR 

Sections 3.1.2.2.16, 3.2.2.2.4, 3.3.2.2.3, 3.4.2.2.2, 

3.2.2.2.2, 3.3.2.2.4, 3.4.2.2.3, 3.2.2.2.8, 3.3.2.2.8, 

3.4.2.2.7, 3.2.2.2.10, 3.3.2.2.10, and 3.4.2.2.9.] 

Inspections not conducted in accordance with 

ASME Code Section XI requirements are 

conducted in accordance with plant-specific 

procedures including inspection parameters such 

as lighting, distance, offset, and surface conditions. 

Acceptance criteria are such that the component 

will meet its intended function until the next 

inspection or the end of the subsequent period of 

extended operation. Qualitative acceptance 

criteria are clear enough to reasonably assure a 

singular decision is derived based on observed

conditions.

Program and 

SLR 

enhancements, 

when 

applicable, are 

implemented 

6 months prior 

to the 

subsequent 

period of 

extended 

operation.
XI 01-26

Table XI-01. FSAR Supplement Summaries for GALL-SLR Report Chapter XI Aging 

 Management Programs 

AMP

GALL-SLR 

Program Description of Program

Implementation 

Schedule*

XI.M37 Flux Thimble 

Tube Inspection

The program inspects for the thinning of flux 

thimble tube walls, which provides a path for the 

in-core neutron flux monitoring system detectors 

and forms part of the reactor coolant system 

pressure boundary. Flux thimble tubes are subject 

to loss of material at certain locations in the reactor 

vessel where flow-induced fretting causes wear at 

discontinuities in the path from the reactor vessel 

instrument nozzle to the fuel assembly instrument 

guide tube. A periodic nondestructive examination 

methodology, such as eddy current testing or other 

applicant-justified and US NRC-accepted 

inspection methods is used to monitor flux thimble 

tube wear. This program implements the 

recommendations of NRC Bulletin 88-09, “Thimble 

Tube Thinning in Westinghouse Reactors.”

Program and 

SLR 

enhancements, 

when 

applicable, are 

implemented 

6 months prior 

to the 

subsequent 

period of 

extended 

operation.

XI.M38

Inspection of 

Internal 

Surfaces in 

Miscellaneous 

Piping and 

Ducting 

Components 

This program is a condition monitoring program 

that manages loss of material and cracking, as 

well as hardening or loss of strength of polymeric 

materials. This program consists of visual 

inspections of all accessible internal surfaces of 

piping, piping components, ducting, heat 

exchanger components, polymeric and elastomeric 

components, and other components. Surface 

examinations or ASME Code Section XI VT-1 

examinations are conducted to detect cracking of 

stainless steel and aluminum components. Aging 

effects associated with items (except for 

elastomers) within the scope of AMP XI.M20 

(open-cycle cooling water), AMP XI.M21A (closed 

treated water system), and XI.M27 (fire water 

system) are not managed by this program. 

Applicable environments include air, gas, 

condensation, diesel exhaust, water, fuel oil, and 

lubricating oil.

These internal inspections are performed during 

the periodic system and component surveillances 

or during the performance of maintenance 

activities when the surfaces are made accessible 

for visual inspection. At a minimum, in each 

10-year period during the subsequent period of 

extended operation a representative sample of 

20% of the population (defined as components 

having the same combination of material, 

environment, and aging effect) or a maximum of 

25 components per population is inspected. 

Where practical, the inspections focus on the 

bounding or lead components most susceptible to 

aging because of time in service, and severity of 

operating conditions. Opportunistic inspections 

continue in each period despite meeting the 

Program and 

SLR 

enhancements, 

when 

applicable, are 

implemented 

6 months prior 

to the 

subsequent 

period of 

extended 

operation.
XI 01-27

Table XI-01. FSAR Supplement Summaries for GALL-SLR Report Chapter XI Aging 

 Management Programs 

AMP

GALL-SLR 

Program Description of Program

Implementation 

Schedule*

sampling limit. For certain materials, such as 

flexible polymers, physical manipulation or 

pressurization to detect hardening or loss of 

strength is used to augment the visual 

examinations conducted under this program. If 

visual inspection of internal surfaces is not 

possible, a plant-specific program is used. 

Inspections not conducted in accordance with 

ASME Code Section XI requirements are 

conducted in accordance with plant-specific 

procedures including inspection parameters such 

as lighting, distance, offset and surface conditions. 

Acceptance criteria are such that the component 

will meet its intended function until the next 

inspection or the end of the subsequent period of 

extended operation. Qualitative acceptance 

criteria are clear enough to reasonably assure a 

singular decision is derived based on 

observed conditions.

XI.M39 Lubricating Oil 

Analysis

This program provides reasonable assurance that 

the oil environment in the mechanical systems is 

maintained to the required quality, and the oil 

systems are maintained free of contaminants 

(primarily water and particulates), thereby 

preserving an environment that is not conducive to 

loss of material or reduction of heat transfer. 

Testing activities include sampling and analysis of 

lubricating oil for detrimental contaminants. The 

presence of water or particulates may also indicate 

in-leakage and corrosion product buildup.

Program and 

SLR 

enhancements, 

when 

applicable, are 

implemented 

6 months prior 

to the 

subsequent 

period of 

extended

operation.

XI.M40

Monitoring of 

NeutronAbsorbing 

Materials other 

than Boraflex

This program relies on periodic inspection, testing, 

monitoring, and analysis of the criticality design to 

assure that the required 5% subcriticality margin is 

maintained. This program consists of inspecting 

the physical condition of the neutron-absorbing 

material, such as visual appearance, dimensional 

measurements, weight, geometric changes 

(e.g., formation of blisters, pits, and bulges), and 

boron areal density as observed from coupons or 

in situ.

Program and 

SLR 

enhancements, 

when 

applicable, are 

implemented 

6 months prior 

to the 

subsequent 

period of 

extended 

operation.
XI 01-28

Table XI-01. FSAR Supplement Summaries for GALL-SLR Report Chapter XI Aging 

 Management Programs 

AMP

GALL-SLR 

Program Description of Program

Implementation 

Schedule*

XI.M41

Buried and 

Underground 

Piping and 

Tanks

This program is a condition monitoring program 

that manages the aging effects associated with the 

external surfaces of buried and underground 

piping and tanks such as loss of material and

cracking. It addresses piping and tanks composed 

of any material, including metallic, polymeric, and 

cementitious materials. 

The program also manages aging through 

preventive and mitigative actions (i.e., coatings, 

backfill quality, and cathodic protection). The 

number of inspections is based on the 

effectiveness of the preventive and mitigative 

actions. Annual cathodic protection surveys are 

conducted. For steel components, where the 

acceptance criteria for the effectiveness of the 

cathodic protection is other than -850 mV instant 

off, loss of material rates are measured.

Inspections are conducted by qualified individuals. 

Where the coatings, backfill or the condition of 

exposed piping does not meet acceptance criteria 

such that the depth or extent of degradation of the 

base metal could have resulted in a loss of 

pressure boundary function when the loss of 

material rate is extrapolated to the end of the 

subsequent period of extended operation, an 

increase in the sample size is conducted. If a 

reduction in the number of inspections 

recommended in GALL-SLR Report, AMP XI.M41, 

Table XI.M41-2 is claimed based on a lack of soil 

corrosivity as determined by soil testing, then soil 

testing is conducted once in each 10-year period 

starting 10 years prior to the subsequent period of 

extended operation.

Program is 

implemented 

and inspections 

begin 10 years 

before the 

subsequent 

period of 

extended 

operation. 

Inspections that 

are to be 

completed prior 

to the 

subsequent 

period of 

extended 

operation are 

completed 

6 months prior 

to the 

subsequent 

period of 

extended 

operation or no 

later than the 

last refueling 

outage prior to 

the subsequent 

period of 

extended 

operation.
XI 01-29

Table XI-01. FSAR Supplement Summaries for GALL-SLR Report Chapter XI Aging 

 Management Programs 

AMP

GALL-SLR 

Program Description of Program

Implementation 

Schedule*

XI.M42

Internal 

Coatings/Linings 

for In-Scope 

Piping, Piping 

Components, 

Heat 

Exchangers, 

and Tanks

This program is a condition monitoring program 

that manages degradation of internal 

coatings/linings exposed to closed-cycle cooling 

water, raw water, treated water, treated borated 

water, waste water, lubricating oil or fuel oil that 

can lead to loss of material of base materials or

downstream effects such as reduction in flow, 

reduction in pressure or reduction of heat transfer 

when coatings/linings become debris. This 

program can also be used to manage loss of 

coating integrity for external coatings exposed to 

any air environment or condensation credited with 

isolating the external surface of a component from 

the environment (e.g., SRP-SLR 

Section 3.2.2.2.2). 

This program manages these aging effects for 

internal coatings by conducting periodic visual 

inspections of all coatings/linings applied to the 

internal surfaces of in-scope components where 

loss of coating or lining integrity could impact the 

component’s or downstream component’s current 

licensing basis intended function(s). Visual 

inspections are conducted on external surfaces 

when applicable.

For tanks and heat exchangers, all accessible 

surfaces are inspected. Piping inspections are 

sampling-based. The training and qualification of 

individuals involved in coating/lining inspections of 

non-cementitious coatings/linings are conducted in 

accordance with ASTM International Standards 

endorsed in RG 1.54 including guidance from the 

staff associated with a particular standard. For 

cementitious coatings, training and qualifications 

are based on an appropriate combination of 

education and experience related to inspecting 

concrete surfaces. Peeling and delamination is 

not acceptable. Blisters are evaluated by a 

coatings specialist with the blisters being 

surrounded by sound material and with the size 

and frequency not increasing. Minor cracks in 

cementitious coatings are acceptable provided 

there is no evidence of debonding. All other 

degraded conditions are evaluated by a coatings 

specialist. For coated/lined surfaces determined to 

not meet the acceptance criteria, physical testing is 

performed where physically possible (i.e., sufficient 

room to conduct testing) in conjunction with repair 

or replacement of the coating/lining.

Program is 

implemented 

and inspections 

begin 10 years 

before the 

subsequent 

period of 

extended 

operation. 

Inspections that 

are to be 

completed prior 

to the 

subsequent 

period of 

extended 

operation are 

completed 

6 months prior 

to the 

subsequent 

period of 

extended 

operation or no 

later than the 

last refueling 

outage prior to 

the subsequent 

period of 

extended 

operation.
XI 01-30

Table XI-01. FSAR Supplement Summaries for GALL-SLR Report Chapter XI Aging 

 Management Programs 

AMP

GALL-SLR 

Program Description of Program

Implementation 

Schedule*

XI.S1

ASME Section 

XI, Subsection 

IWE Inservice 

Inspection (IWE)

This program is in accordance with ASME Code 

Section XI, Subsection IWE, consistent with 

10 CFR 50.55a “Codes and standards,” with 

supplemental recommendations. The AMP 

includes periodic visual, surface, and volumetric 

examinations, where applicable, of metallic 

pressure-retaining components of steel 

containments and concrete containments for signs 

of degradation, damage, irregularities including 

discernable liner plate bulges, and for coated 

areas distress of the underlying metal shell or liner, 

and corrective actions. Acceptability of 

inaccessible areas of steel containment shell or 

concrete containment steel liner is evaluated when 

conditions found in accessible areas indicate the 

presence of, or could result in, flaws or 

degradation in inaccessible areas. 

This program also includes aging management for 

the potential loss of material due to corrosion in the 

inaccessible areas of the BWR Mark I steel 

containment. In addition, the program includes 

supplemental surface examination to detect 

cracking for specific pressure-retaining 

components [identify components] subject to cyclic 

loading but have no CLB fatigue analysis; and if 

triggered by plant-specific operating experience, a 

one-time supplemental volumetric examination by 

sampling randomly-selected as well as focused 

locations susceptible to loss of thickness due to 

corrosion of containment shell or liner that is 

inaccessible from one side. Inspection results are 

compared with prior recorded results in 

acceptance of components for continued service.

Program and 

SLR 

enhancements, 

when 

applicable, are 

implemented 

6 months prior 

to the 

subsequent 

period of 

extended 

operation and if 

triggered by 

plant-specific 

operating 

experience, a 

one-time 

supplemental 

volumetric 

examination by 

sampling 

randomlyselected as well 

as focused 

locations 

susceptible to 

loss of thickness 

due to corrosion 

of containment 

shell or liner that 

is inaccessible 

from one side is 

completed 

6 months prior 

to the 

subsequent 

period of 

extended 

operation or no 

later than the 

last refueling 

outage prior to 

the subsequent 

period of 

extended 

operation.
XI 01-31

Table XI-01. FSAR Supplement Summaries for GALL-SLR Report Chapter XI Aging 

 Management Programs 

AMP

GALL-SLR 

Program Description of Program

Implementation 

Schedule*

XI.S2

ASME Section 

XI, Subsection 

IWL Inservice 

Inspection (IWL)

This program consists of: (a) periodic visual 

inspection of concrete surfaces for reinforced and 

pre-stressed concrete containments, (b) periodic 

visual inspection and sample tendon testing of 

un-bonded post-tensioning systems for prestressed concrete containments for signs of 

degradation, assessment of damage, and 

corrective actions, and testing of the tendon 

corrosion protection medium and free water. 

Measured tendon lift-off forces are compared to 

predicted tendon forces calculated in accordance 

with RG 1.35.1. The Subsection IWL requirements 

are supplemented to include quantitative 

acceptance criteria for evaluation of concrete 

surfaces based on the “Evaluation Criteria” 

provided in Chapter 5 of ACI 349.3R.

Program and 

SLR 

enhancements, 

when 

applicable, are 

implemented 

6 months prior 

to the 

subsequent 

period of 

extended 

operation.
XI 01-32

Table XI-01. FSAR Supplement Summaries for GALL-SLR Report Chapter XI Aging 

 Management Programs 

AMP

GALL-SLR 

Program Description of Program

Implementation 

Schedule*

XI.S3

ASME Section 

XI, Subsection 

IWF Inservice 

inspection (IWF) 

This program consists of periodic visual 

examination of piping and component supports for 

signs of degradation, evaluation, and corrective 

actions. This program recommends additional 

inspections beyond the inspections required by the 

10 CFR 50.55a ASME Code Section XI, 

Subsection IWF program. This consists of a onetime inspection of an additional 5% of the sample 

size specified in Table IWF-2500-1 for Class 1, 2, 

and 3 piping supports. This one-time inspection is 

conducted within 5 years prior to entering the 

subsequent period of extended operation. For 

high-strength bolting in sizes greater than 1 inch 

nominal diameter, volumetric examination 

comparable to that of ASME Code Section XI, 

Table IWB-2500-1, Examination Category B-G-1 

should be performed to detect cracking in addition 

to the VT-3 examination.

If a component support does not exceed the 

acceptance standards of IWF-3400 but is 

electively repaired to as-new condition, the sample 

is increased or modified to include another support 

that is representative of the remaining population 

of supports that were not repaired.

Program is 

implemented 

and a one-time 

inspection of an 

additional 5% of 

the sample size 

specified in 

Table IWF2500-1 for 

Class 1, 2, and 

3 piping 

supports is 

conducted 

within 5 years 

prior to the 

subsequent 

period of 

extended 

operation, and 

are to be 

completed prior 

to the 

subsequent 

period of 

extended 

operation, are 

completed 

6 months prior 

to the 

subsequent 

period of 

extended 

operation or no 

later than the 

last refueling 

outage prior to 

the subsequent 

period of 

extended 

operation.

XI.S4 10 CFR Part 50, 

Appendix J 

This program consists of monitoring leakage rates 

through the containment system, its shell or liner, 

associated welds, penetrations, isolation valves, 

fittings, and other access openings to detect 

degradation of the containment pressure 

boundary. Corrective actions are taken if leakage 

rates exceed acceptance criteria. This program is 

implemented in accordance with 10 CFR Part 50 

Appendix J, RG 1.163 and/or NEI 94-01, and 

subject to the requirements of 10 CFR Part 54. 

Program and 

SLR 

enhancements, 

when 

applicable, are 

implemented 

6 months prior 

to the 

subsequent 

period of 

extended 

operation.
XI 01-33

Table XI-01. FSAR Supplement Summaries for GALL-SLR Report Chapter XI Aging 

 Management Programs 

AMP

GALL-SLR 

Program Description of Program

Implementation 

Schedule*

XI.S5 Masonry Walls

This program consists of inspections, based on 

IEB 80-11 and plant-specific monitoring proposed 

by IN 87-67, for managing shrinkage, separation, 

gaps, loss of material and cracking of masonry 

walls such that the evaluation basis is not 

invalidated and intended functions are maintained.

Program and 

SLR 

enhancements, 

when 

applicable, are 

implemented 

6 months prior 

to the 

subsequent 

period of 

extended 

operation.

XI.S6 Structures 

Monitoring

This program consists of periodic visual inspection 

and monitoring the condition of concrete and steel 

structures, structural components, component 

supports, and structural commodities to ensure 

that aging degradation (such as those described in 

ACI 349.3R, ACI 201.1R, SEI/ASCE 11, and other 

documents) will be detected, the extent of 

degradation determined and evaluated, and 

corrective actions taken prior to loss of intended 

functions. Inspections also include seismic joint 

fillers, elastomeric materials; and steel edge 

supports and steel bracings associated with 

masonry walls, and periodic evaluation of 

groundwater chemistry and opportunistic 

inspections for the condition of below grade 

concrete. Quantitative results (measurements) 

and qualitative information from periodic 

inspections are trended with photographs and 

surveys for the type, severity, extent, and 

progression of degradation. The acceptance 

criteria are derived from applicable consensus 

codes and standards. For concrete structures, the 

program includes personnel qualifications and 

quantitative acceptance criteria of ACI 349.3R. 

Program and 

SLR 

enhancements, 

when 

applicable, are 

implemented 

6 months prior 

to the 

subsequent 

period of 

extended 

operation.

XI.S7

Inspection of 

Water-Control 

Structures 

Associated with 

Nuclear Power 

Plants

This program consists of inspection and 

surveillance of raw-water control structures 

associated with emergency cooling systems or 

flood protection. The program also includes 

structural steel and structural bolting associated 

with water-control structures. In general, 

parameters monitored are in accordance with 

Section C.2 of RG 1.127 and quantitative 

measurements should be recorded for findings that 

exceed the acceptance criteria for applicable 

parameters monitored or inspected. Inspections 

should occur at least once every 5 years. 

Structures exposed to aggressive water require 

additional plant-specific investigation.

Program and 

SLR 

enhancements, 

when 

applicable, are 

implemented 

6 months prior 

to the 

subsequent 

period of 

extended 

operation.
XI 01-34

Table XI-01. FSAR Supplement Summaries for GALL-SLR Report Chapter XI Aging 

 Management Programs 

AMP

GALL-SLR 

Program Description of Program

Implementation 

Schedule*

XI.S8

Protective 

Coating 

Monitoring and 

Maintenance 

This program ensures that a monitoring and 

maintenance program implemented in accordance 

with RG 1.54 is adequate for the subsequent 

period of extended operation. The program 

consists of guidance for selection, application, 

inspection, and maintenance of protective 

coatings. Maintenance of Service Level I coatings 

applied to carbon steel and concrete surfaces 

inside containment (e.g., steel liner, steel 

containment shell, structural steel, supports, 

penetrations, and concrete walls and floors) serve 

to prevent or minimize loss of material due to 

corrosion of carbon steel components and aids in 

decontamination. Degraded coatings in the 

containment are assessed periodically to ensure 

post-accident operability of the ECCS.

Program and 

SLR 

enhancements, 

when 

applicable, are 

implemented 

6 months prior 

to the 

subsequent 

period of 

extended 

operation.

SRPSLR 

Appendix 

A 

Plant-Specific 

AMP

The [fill in name of program] Program is a 

[prevention, mitigation, condition monitoring, 

performance monitoring] program that manages 

aging effects associated with [list component type 

or system as applicable that are in the scope of the 

program]. Preventive or mitigative actions include 

[fill in key actions when applicable]. The program 

manages [list the AERM] by conducting [periodic, 

one-time] [describe inspection methods and tests] 

of [all components or a representative sample of 

components] within the scope of the 

program. [When applicable, periodic inspections 

are conducted every XX years commencing prior 

to or during the subsequent period of extended 

operation.] [Describe how inspection and test 

implementing procedures are controlled (e.g., nonASME Code inspections and tests follow site 

procedures that include inspection parameters for 

items such as lighting, distance, offset, presence of 

protective coatings, and cleaning processes that 

ensure an adequate examination).] Qualitative 

acceptance criteria are clear enough to reasonably 

ensure a singular decision is derived based on 

observed conditions. When the acceptance 

criteria are not met such that it is determined that 

the affected component should be replaced prior to 

the end of the subsequent period of extended 

operation, additional inspections are performed.

Program is

implemented 

6 months prior 

to the 

subsequent 

period of 

extended 

operation.
APPENDIX A 

QUALITY ASSURANCE FOR AGING MANAGEMENT PROGRAMS

A–1

QUALITY ASSURANCE FOR AGING MANAGEMENT PROGRAMS

The subsequent license renewal (SLR) applicant must demonstrate that the effects of aging on 

structures and components (SCs) subject to an aging management review (AMR) will be 

managed in a manner that is consistent with the current licensing basis (CLB) of the facility for the 

subsequent period of extended operation. Therefore, those aspects of the AMR process that 

affect the quality of safety-related SCs are subject to the quality assurance (QA) requirements 

of Appendix B of Title 10 of the Code of Federal Regulations (10 CFR) Part 50. For 

nonsafety-related SCs subject to an AMR, the existing 10 CFR Part 50, Appendix B, QA program 

may be used to address the elements of corrective actions, confirmation process, and 

administrative controls. Criterion XVI of 10 CFR Part 50, Appendix B, requires that 

measures be established to ensure that conditions adverse to quality, such as 

failures, malfunctions, deviations, defective material and equipment, and 

nonconformances are promptly identified and corrected. In the case of significant 

conditions adverse to quality, measures must be implemented to ensure that the 

cause of the condition is determined and that corrective action is taken to preclude 

repetition. In addition, the cause of the significant condition adverse to quality and 

the corrective action implemented must be documented and reported to appropriate 

levels of management.

To preclude repetition of significant conditions adverse to quality, the confirmation process 

element (Element 8) for SLR aging management programs (AMPs) consists of follow-up actions 

to verify that the corrective actions implemented are effective in preventing a recurrence. As an 

example, for the management of internal piping corrosion, the Generic Aging Lessons Learned for 

Subsequent License Renewal (GALL-SLR) Report AMP XI.M2, “Water Chemistry,” may be used 

to minimize the piping’s susceptibility to corrosion. However, it also may be necessary to institute 

a condition monitoring program that uses ultrasonic inspection to verify that corrosion is indeed 

insignificant. 

As required by 10 CFR 50.34(b)(6)(i), the final safety analysis report (FSAR) submitted by a 

nuclear power plant license applicant includes “information on the applicant’s organizational 

structure, allocations of responsibilities and authorities, and personnel qualification requirements.” 

10 CFR 50.34(b)(6)(ii) also notes that Appendix B of 10 CFR Part 50 sets forth the requirements 

for “managerial and administrative controls used for safe operation.” Pursuant to 

10 CFR 50.36(c)(5), administrative controls related to organization and management, procedures, 

record keeping, review and audit, and reporting ensure the safe operation of the facility. 

Programs that are consistent with the requirements of 10 CFR Part 50, Appendix B, also satisfy 

the administrative controls element necessary for AMPs for SLR.

Notwithstanding the suitability of its provisions to address quality-related aspects of the AMR 

process for SLR, 10 CFR Part 50, Appendix B, covers only safety-related SCs. Therefore, absent 

a commitment by the applicant to expand the scope of its 10 CFR Part 50, Appendix B, QA 

program to include nonsafety-related SCs subject to an AMR for SLR, the AMPs applicable to 

nonsafety-related SCs include alternative means to address corrective actions, confirmation 

processes, and administrative controls. Such alternate means are subject to review by the NRC 

on a case-by-case basis.

An example summary program description of the QA program for the FSAR supplement is shown 

in Table A-01 below.
A–2

Table A-01. FSAR Supplement Summary for Quality Assurance Programs for Aging 

Management Programs

GALLSLR AMPGALL-SLR 

Program Description of Program

Implementation

Schedule

GALLSLR 

Appendix 

A

Quality 

Assurance

The QA program, developed in accordance with 

the requirements of 10 CFR Part 50, Appendix B, 

provides the basis for the corrective actions, 

confirmation process, and administrative controls 

elements of AMPs. The scope of this existing 

QA program is expanded to also include 

nonsafety-related SCs subject to AMPs.

Existing 

program
APPENDIX B

OPERATING EXPERIENCE FOR AGING MANAGEMENT PROGRAMS

B–1

OPERATING EXPERIENCE FOR AGING MANAGEMENT PROGRAMS

Operating experience (OE) is a crucial element of an effective aging management program 

(AMP). It provides the basis to support all other elements of the AMP and, as a continuous 

feedback mechanism, drives changes to these elements to maintain the overall effectiveness of 

the AMP. OE should provide objective evidence to support the conclusion that the effects of 

aging are managed adequately so that the structure- and component-intended function(s) will be 

maintained during the subsequent period of extended operation. Pursuant to Part 54, 

“Requirements for Renewal of Operating Licenses for Nuclear Power Plants,” Section 21(a)(3), of 

Title 10 of the Code of Federal Regulations [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 

aging management review (AMR) are adequately managed so that the intended function(s) will be 

maintained consistent with the current licensing basis (CLB) for the period of extended operation.

The systematic review of plant-specific and industry OE concerning aging management and 

age-related degradation confirms that the subsequent license renewal (SLR) AMPs are, and will 

continue to be, effective in managing the aging effects for which they are credited. The AMPs 

should either be enhanced or new AMPs developed, as appropriate, when it is determined 

through the evaluation of OE that the effects of aging may not be adequately managed. AMPs 

should be informed by the review of OE on an ongoing basis, regardless of the AMP’s 

implementation schedule.

Acceptable Use of Existing Programs

Programs and procedures relied upon to meet the requirements of 10 CFR Part 50, Appendix B, 

and provisions in NUREG–0737, Item I.C.5, may be used for the capture, processing, and 

evaluation of OE concerning age-related degradation and aging management during the term of a 

renewed operating license. As part of meeting the provisions of NUREG–0737, Item I.C.5, the 

applicant should actively participate in the Institute of Nuclear Power Operations’ (INPOs’) OE

program (formerly the Significant Event Evaluation and Information Network (SEE-IN) program 

endorsed in U.S. Nuclear Regulatory Commission (NRC) Generic Letter 82-04, “Use of INPO 

SEE-IN Program”). These programs and procedures may also be used for the translation of 

recommendations from the OE evaluations into plant actions (e.g., enhancement of AMPs and 

development of new AMPs). While these programs and procedures establish a majority of the 

functions necessary for the ongoing review of OE, they are also subject to further review as 

discussed below.

Areas of Further Review

To ensure that the programmatic activities for the ongoing review of OE are adequate for SLR, the 

following points should be addressed:

• The programs and procedures relied upon to meet the requirements of 10 CFR Part 50, 

Appendix B, and provisions in NUREG–0737, Item I.C.5, explicitly apply to and otherwise 

would not preclude the consideration of OE on age-related degradation and aging 

management. Such OE can constitute information on the structures and components 

(SCs) identified in the integrated plant assessment; their materials, environments, aging 

effects, and aging mechanisms; the AMPs credited for managing the effects of aging; and 

the activities, criteria, and evaluations integral to the elements of the AMPs. To satisfy this 

criterion, the applicant should use the option described in the “Standard Review Plan 

for Review of Subsequent License Renewal Applications for Nuclear Power Plants,” 
B–2

Section A.2, “Quality Assurance for Aging Management Programs (Branch Technical 

Position IQMB-1),” Position 2, to expand the scope of its 10 CFR Part 50, Appendix B, 

program to include nonsafety-related SCs.

• All final license renewal interim staff guidance documents and revisions to the Generic 

Aging Lessons Learned for Subsequent License Renewal (GALL-SLR) Report should be 

considered as sources of industry OE and evaluated accordingly. There should be a 

process to identify such documents and process them as OE.

• All incoming plant-specific and industry OE should be screened to determine whether it 

may involve age-related degradation or impacts to aging management activities.

• Relevant research and development information should be reviewed to determine whether 

it might involve age-related degradation or impacts to aging management activities. 

Relevant foreign and domestic research and development would generally be subject to a 

consensus process, and would have used materials and test conditions typical of 

operating power reactors, including actual operating and environmental conditions. 

Examples of relevant research and development sources are: (a) industry consensus 

standards development organizations (e.g., ASME, IEEE, ACI, API, NACE, International 

Organization for Standardization); (b) Electric Power Research Institute (EPRI); (c) generic 

communications issued by the staff based on research conducted by national labs used by 

the NRC; and (d) nuclear steam supply system vendor and owner’s groups.

• A means should be established within the corrective action program to identify, track, and 

trend OE that specifically involves age-related degradation. There should also be a 

process to identify adverse trends and to enter them into the corrective action program 

for evaluation.

• Operating experience, including relevant research and development items identified as 

potentially involving aging should receive further evaluation. This evaluation should 

specifically take into account the following: (a) systems, structures, and components, 

(b) materials, (c) environments, (d) aging effects, (e) aging mechanisms, (f) AMPs, and 

(g) the activities, criteria, and evaluations integral to the elements of the AMPs. The 

assessment of this information should be recorded with the OE evaluation. If it is found 

through evaluation that any effects of aging may not be adequately managed, then a 

corrective action should be entered into the 10 CFR Part 50, Appendix B, program to 

either enhance the AMPs or develop and implement new AMPs.

• Assessments should be conducted on the effectiveness of the AMPs and activities. These 

assessments should be conducted on a periodic basis that is not to exceed once every 

5 years. They should be conducted regardless of whether the acceptance criteria of the 

particular AMPs have been met. The assessments should also include evaluation of the 

aging management program or activity against the latest NRC and industry guidance 

documents and standards that are relevant to the particular program or activity. If there is 

an indication that the effects of aging are not being adequately managed, then a corrective 

action is entered into the 10 CFR Part 50, Appendix B, program to either enhance the 

AMPs or develop and implement new AMPs, as appropriate.
B–3

• Training on age-related degradation and aging management should be provided to those 

personnel responsible for implementing the AMPs and those personnel who may submit, 

screen, assign, evaluate, or otherwise process plant-specific and industry OE. The scope 

of training should be linked to the responsibilities for processing OE. This training should 

occur on a periodic basis and include provisions to accommodate the turnover of plant 

personnel.

• Guidelines should be established for reporting plant-specific OE on age-related 

degradation and aging management to the industry. This reporting should be 

accomplished through participation in the INPOs’ OE program.

• Any enhancements necessary to fulfill the above criteria should be put in place no later 

than the date the subsequently renewed operating license is issued and implemented on 

an ongoing basis throughout the term of the subsequently renewed license.

The programmatic activities for the ongoing review of plant-specific and industry experience, 

including relevant research and development concerning age-related degradation and aging 

management should be described in the subsequent license renewal application, including the 

Final Safety Analysis Report (FSAR) supplement. Alternate approaches for the future 

consideration of OE are subject to NRC review on a case-by-case basis.

An example summary program description of the OE program for the FSAR supplement is shown

in Table B-01 below.
B–4

Table B-01. FSAR Supplement Summary for Operating Experience Programs for Aging 

Management Programs

GALL-SLR 

AMP

GALL-SLR 

Program Description of Program

Implementation 

Schedule

GALL-SLR 

Appendix B

Operating

Experience

This program captures the OE from 

plant-specific and industry sources and is 

systematically reviewed on an ongoing 

basis in accordance with the QA program, 

which meets the requirements of 

10 CFR Part 50, Appendix B, and the OE 

program, which meets the provisions of 

NUREG–0737, “Clarification of TMI Action 

Plan Requirements,” Item I.C.5, 

“Procedures for Feedback of Operating 

Experience to Plant Staff.”

This program interfaces with and relies on 

active participation in the INPO OE 

program, as endorsed by the NRC. In 

accordance with these programs, all 

incoming OE items are screened to 

determine whether they may involve 

age-related degradation or aging 

management impacts. Research and 

development is also reviewed. Items so 

identified are further evaluated and the 

AMPs are either enhanced or new AMPs 

are developed, as appropriate, when it is 

determined through these evaluations that 

the effects of aging may not be 

adequately managed. Training on agerelated degradation and aging 

management is provided to those 

personnel responsible for implementing 

the AMPs and to those who may submit, 

screen, assign, evaluate, or otherwise 

process plant-specific and industry OE. 

Plant-specific OE associated with aging 

management and age-related degradation 

is reported to the industry in accordance 

with guidelines established in the OE 

program.

The Program 

and necessary 

enhancements 

are 

implemented 

no later than 

the date the 

subsequently 

renewed 

operating 

license is 

issued.