ML070570237

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FAC Program, EN-DC-315, Rev. 0, 05000271-07-006
ML070570237
Person / Time
Site: Vermont Yankee File:NorthStar Vermont Yankee icon.png
Issue date: 05/09/2006
From: Eaton W
Entergy Corp
To:
NRC Region 1
DeFrancisco, A, (610) 337-5078
References
EN-DC-315, Rev 0 IR-07-006
Download: ML070570237 (34)


Text

QUALITYRELATEDEN-DC-315REV. 0NUCLEARMANAGEMENTMANUALINFORMATIONALUSEPAGE 1 OF 34Flow Accelerated Corrosion ProgramProcedure Contains NMM REFLIB Forms: YES NOEffectiveDate12/1/2006Procedure Owner:Title:Site:W. A. EatonVP EngineeringEchelonExecutive Sponsor:Title:Site:W. A. EatonVP EngineeringEchelonExceptionDate*SiteSite Procedure ChampionTitleANOWilliam G. SmithTechnical Specialist IIIGGNSBruce LeeTechnical Specialist IVIPECRichard BurroniManager, P&CEJAFJoe PechacekManager, P&CEPNPSGearld BechenSenior EngineerRBSReggie JacksonTechnical Specialist IVVYLarry LukensEngineering SupervisorW3Paul StantonEngineering SupervisorECHCharles TurkManager, Design EngineeringWPORobert PennyManager, Engineering ProgramsSite and NMM Procedures Canceled or Superseded By This Revision*ENN DC-315*ENS-DC-315Process Applicability Exclusion)All Sites: Specific Sites: ANO GGNS IPEC JAF PNPS RBS VY W3Change StatementInitial issue of fleet procedure which replaces ENN-DC-315 and ENS-DC-315.*Requires justification for the exception QUALITYRELATEDEN-DC-315REV. 0NUCLEARMANAGEMENTMANUALINFORMATIONALUSEPAGE 2 OF 34Flow Accelerated Corrosion Program__________________________________________________________________________TABLE OF CONTENTSSection TitlePage1.0PURPOSE ............................................................................................

32.0REFERENCES

......................................................................................33.0DEFINITIONS........................................................................................64.0RESPONSIBILITIES...........................................................................105.0DETAILS ..........................................................................................156.0INTERFACES.....................................................................................287.0RECORDS ..........................................................................................288.0OBLIGATIONSANDCOMMITMENTSIMPLEMENTEDBYTHEPROCEDURE.....................................................................................289.0ATTACHMENTS.................................................................................29ATTACHMENT9.1 GUIDANCE ONPARAMETERSAFFECTINGFAC...........................30ATTACHMENT9.2FLOWACCELERATEDCORROSIONPROGRAMATTRIBUTES..........33ATTACHMENT9.3WALL THINNING EVALUATION PROCESS MAP...............................34__________________________________________________________________________

QUALITYRELATEDEN-DC-315REV. 0NUCLEARMANAGEMENTMANUALINFORMATIONALUSEPAGE 3 OF 34Flow Accelerated Corrosion Program1.0 PURPOSE[P-33641 - P-33643], [P-33645], [P-33714 - P-33719], [P-33730], [P-35351], [JAFP-87-0737], [JPN-89-051], [IP3-87-055Z], [IPN-89-044], [BECo-89-107], [FVY-89-66], [FVY-87-94], [FVY-87-121], [P-1079],[P-35269], [P-24444], [P-15802], [P-15803], [P-16557], [P-20303], [P-22888][1] The purpose of this procedure is to provide requirements for establishing andmaintaining an effective Flow Accelerated Corrosion (FAC) Program that willstandardize Entergy Nuclear Fleet's approach towards mitigating FAC damage.[2] This procedure uses a systematic approach forlong term monitoring to enhance thereliability of the affected FAC components by reducing the probability of failures andreduces maintenance costs associated with unplanned or unnecessary repairs.[3] This procedure provides criteria and methodology for selecting components forinspection, performing inspections, evaluating inspection data, disposition of results,sample expansion requirements, piping repair /replacement criteria, programresponsibilities and documentation requirements.[4] This program is applicable to carbon steel plant piping systems and includes feedwater heater and moisture separator re-heater (MSR) shells susceptible to FAC. Itincludes inspections of single-phase and two-phase piping components for both safetyand non-safety related systems.[5] This procedure may be used as a guide for evaluating systems and components thatare not included in the FAC program.

2.0 REFERENCES

[1] NRC Generic Letter 89-08, Erosion/Corrosion Induced Pipe Wall Thinning.[2] NUREG-1344, "Erosion/Corrosion-Induced Pipe Wall Thinning in U.S. Nuclear PowerPlants."[3] NSAC 202L, latest revision, EPRI Document, "Recommendations for an EffectiveFlow Accelerated Corrosion Program"[4] EPRI Technical Report, TR-106611, "Flow-Accelerated Corrosion in Power Plants"[5] NRC Bulletin No. 87-01, "Pipe Wall Thinning."[6] EN-LI-102, "Corrective Action Process."[7] Erosion/Corrosion in Nuclear Power Plant Steam Piping: Causes and inspectionProgram Guidelines. EPRI, April 1985. NP-3944.

QUALITYRELATEDEN-DC-315REV. 0NUCLEARMANAGEMENTMANUALINFORMATIONALUSEPAGE 4 OF 34Flow Accelerated Corrosion Program2.0 cont.[8] ENN-NDE-9.05,"Ultrasonic Thickness Examination"[9] ANSI B31.1 "Power Piping", (For applicable code year see individual plant FSAR).[10] ENN-DC-126, "Calculations".[11] ENS-DC-126, "Engineering Calculation Process".[12] ENS-DC-126-01, "Engineering Calculation Process".[13] ENN-CS-S-008, "Pipe Wall Thinning Structural Evaluation".[14] ENS-PS-S-001, "Pipe Wall Thinning and Crack-like Flaw Evaluation Standard".[15] Site ASME XI Repair / Replacement Program as applicable.[16] ENN-EP-S-005 "Flow Accelerated Corrosion Component Scanning and GriddingStandard".[17] EPRI Paper, "Single-Phase Erosion/Corrosion of Carbon Steel Piping", February1987.[18] EPRI Paper - "Practical Consideration for the Repair of Piping Systems Damaged byErosion/Corrosion", dated 10/5/87[19] Acceptance Criteria for Structural Evaluation of Erosion/Corrosion Thinning in CarbonSteel Piping. EPRI, April 1988. NP-5911.[20] NRC Generic Letter 90-05, "Guidance for Performing Temporary Non-Code Repairs ofASME Code Class 1, 2 &3 Piping".[21] INPO SOER 87-3, "Piping Failures in High-Energy Systems Due toErosion/Corrosion", March 1987.[22] INPO Significant Operating Experience Report (SOER) 82-11, "Erosion of SteamPiping and Resulting Failure", February 1982.[23] IN 93-21, Summary of NRC Staff Observations compiled during Engineering Audits oninspections of Licensee E/C Programs", dated March 25, 1993.[24] EPRI CHUG Position Paper #3, "A Summary of Tasks and Resources Required toImplement an Effective Flow Accelerated Corrosion Program."

QUALITYRELATEDEN-DC-315REV. 0NUCLEARMANAGEMENTMANUALINFORMATIONALUSEPAGE 5 OF 34Flow Accelerated Corrosion Program2.0 cont.[25] EPRI CHUG Position Paper #4,"Recommendations for inspecting Feedwater HeaterShells for Flow-Accelerated Corrosion Damage", February 2000.[26] CHECWORKS Steam /Feedwater Application, "Guidelines for Plant Modeling andEvaluation of Component Inspection Data", EPRI No. 1009599, Final Report,September 2004.[27] Entergy Quality Assurance Manual[28] ENN FAC Qualification Card ENN-TK-ESPG-042, "Implementing the FlowAccelerated Corrosion Program ".[29] ENN/ENS-DC-115, "Engineering Response Development".[30] EN-DC-115, Engineering Change Development"[31] EOI-C-QC-ESPP-PFAC- "Qualification card for Flow Accelerated CorrosionEngineers".[32] EN-DC-202, "NEI 03-08 Materials Initiative".[33] JAF-SPEC-MISC-03290 Rev.0, "Specification for Evaluation and Acceptance of LocalAreas of material, parts and components that are less than the specified thickness."By REEDY Engineering.[34] IP3-SPEC-UNSPEC-02996 Rev.0, "Specification for Evaluation and Acceptance ofLocal Areas of material, parts and components that are less than the specifiedthickness." By REEDY Engineering.[35] CHECWORKS Steam /Feedwater Application, Version 2.1, EPRI No. 1009600, FinalReport, October 2004.[36] CHECWORKS Steam /Feedwater Application, latest version.[37] Institute of Nuclear Plant Operations, "Engineering Program Guide, Flow AcceleratedCorrosion", EPG-06 (Pending).

QUALITYRELATEDEN-DC-315REV. 0NUCLEARMANAGEMENTMANUALINFORMATIONALUSEPAGE 6 OF 34Flow Accelerated Corrosion Program3.0 DEFINITIONS[1] Base Line Inspection - An initial wall thickness measurement of a component takenprior to being placed in service.[2] Basis Document - Program documents that define the scope, attributes, commitments,evaluation reports and predictive models that forms the basis of the FAC program(i.e., System Susceptibility Evaluation reports). These documents contain the basis forthe plant piping in the CHECWORKS model, the susceptible-not-modeled (SNM)piping and those that are non-susceptible.[3] Code Minimum Thickness (tmin, tcodemin) - The minimum required global wallthickness based on hoop stress.[4] Critical Thickness (tcrit,) -The minimum required wall thickness per code ofconstruction required to meet all design-loading conditions.[5] Deficient Component - A component identified by examination to be belowtaccpt wallthickness or projected to be belowtaccpt wall thickness by the next refueling outage.[6] Degraded component - A component identified as being below the screening criteriathat is acceptable for continued operation.[7] EPRI CHUG - EPRICHECWORKS USERS GROUP.[8] Examination - Denotes the performance of all visual observation and nondestructivetesting, such as radiography, ultrasonic, eddy current, liquid penetrant and magneticparticle methods.[9] Examination Checklist/ Traveler - A data sheet developed for the components beinginspected and may contain but is not limited to the following:tnom,tmeas, Tmin,Screening criteria, components name, system number, previous data, inspectiondatasheet number, grid size, examination extent, work order and affiliated minimumwall calculation.[10] Flow Accelerated Corrosion (FAC) - Degradation and consequent wall thinning of acomponent by a dissolution phenomenon, which is affected by variables such astemperature, steam quality, steam/fluid velocity, water chemistry, component materialcomposition and component geometry. Previously known as Erosion/Corrosion.

QUALITYRELATEDEN-DC-315REV. 0NUCLEARMANAGEMENTMANUALINFORMATIONALUSEPAGE 7 OF 34Flow Accelerated Corrosion Program3.0 cont.[11] Grid - A patternof points or lines on a piping component, where UT thicknessmeasurements will be made. Grid may be permanently marked with circumferentialand longitudinal grid lines.[12] Grid Point - A Specific location on a piping component, where aUT thicknessmeasurement will be made. Grid points are at the intersections of the circumferentialand longitudinal grid lines.[13] Grid Point Reading - UT reading taken at the intersection of the grid location.[14] Grid Scan- 100% scans of the area between the grid lines. The lowest measurementin each area to be recorded as the measured thickness.[15] Full Scan - scans of 100% of an area, circumference, nozzle, heater segments etc,measuring minimum, maximum and averages thicknesses and approximate locationof minimum measured thickness.[16] Grid Size - The distance between grid points in the circumferential or longitudinaldirection. Also called grid space or grid spacing.[17] Initial Thickness (tinit): The thickness determined by ultrasonic examination prior to thecomponent being placed into service (baseline) or the first ultrasonic examinationduring its service life. If an examination has not previously been performed on thecomponent, the initial thickness shall be determined by reviewing the initial ultrasonicdata for that component. The area of maximum wall thickness within the same regionas the worn area (based on the method selected for evaluating wear) shall beidentified and compared totnom. If the thickness is greater thantnom, the maximumwall thickness within that region shall be used astinit. If that thickness is less thantnom, tnom shall be used astinit.[18] Inspection Location - A specific component (i.e., elbow, tee, reducer, straight pipesection).[19] Inspection Outage - the outage during which the component was inspected.[20] Large-bore Piping - Piping generally greater than 2" nominal pipe size with butt-weldfittings.[21] Line Scans- piping segments broken into one-foot lengths (Small-Bore pipe).

QUALITYRELATEDEN-DC-315REV. 0NUCLEARMANAGEMENTMANUALINFORMATIONALUSEPAGE 8 OF 34Flow Accelerated Corrosion Program3.0 cont.[22] Minimum acceptable wall thickness (taccpt) - Maximum value of axial stress,hoop stress, and or critical thickness and the piping replacement values of 0.3tnom forClass1 piping or 0.2 tnom for Class 2, Class 3 and non-safety related piping.[23] Minimum Measured Thickness - (tmeas ortmm) as identified by ultrasonic thicknessexamination, the present thickness at the thinnest point on a component.[24] Local minimum required thickness - (taloc) Minimum acceptable local wall thicknessas calculated by ENN-CS-S-008 or ENS-PS-S-001.[25] Minimum required thickness - (tamin) Minimum required pipe wall thickness based onaxial stress (See ENN-CS-S-008) .[26] Next Scheduled Inspection (NSI) -The outage at which an inspection will be performedon a given component.[27] Nominal Thickness (tnom) - Wall thickness equal to ANSI standard thickness.[28] PASS 1 Analysis - Runs modeled in CHECWORKS that either have no inspectiondata, an insufficient number of inspections to provide a proper calibration, or wherethere is no expectation of ever developing a proper calibration.[29] PASS 2 Analysis - The process of utilizing UT inspection data thicknessmeasurements in CHECWORKS to predict wear and wear rates for components.[30] Piping Segment - A runof piping that consists of inspection locations which havecommon operating parameters (i.e., temperature, pressure, flowrate,Oxygencontentand pH level).[31] Predicted /Projected Thickness (tp, tpred) -The calculated thickness of a componentbased upon a rate of wear to some point in time (e.g., next refueling, next scheduledexamination).[32] Quadrant Scan- Piping segments divided in quadrants A, B, C, D that are 90 degreesapart and broken into one-foot lengths, or as specified by the FAC engineer.

QUALITYRELATEDEN-DC-315REV. 0NUCLEARMANAGEMENTMANUALINFORMATIONALUSEPAGE 9 OF 34Flow Accelerated Corrosion Program3.0 cont.[33] Qualified FAC Engineer- Individual who has completed the FAC Qualification Card,who participates in the Engineering Support Personnel (ESP) training program anddemonstrates knowledge required for the use of the CHECWORKS computerprogram.[34] Reference Point - The point on a piping component where the longitudinal andcircumferential grid lines originate.[35] Remaining Service Life (RSL) - The amount of time remaining based upon anestablished rate of wear at which the component is anticipated to thin totaccpt.[36] Safety Factor - A Margin of Safety used to account for inaccuracies in wear rateevaluation.[37] Sample Expansion - The addition of inspection locations based on significant orunexpected wall thinning during planned inspection(s).[38] Significant wall thinning - Wall thinning to a thickness which is the largest of:(a) a thickness less than 60% of pipe nominal wall thickness(b) Wall thinning to a thickness that is half the remaining margin of the piping/component which is abovetaccpt. [1/2 (0.875tnom +taccpt)](c) (taccpt+ 0.020) inch.[39] Small-bore Piping - Piping that is generally2" or less nominal diameter and thattypically uses socket welded fittings.[40] Subsequent Inspection - Inspection of components that have had a baselineinspection and/or an initial operational inspection.[41] Susceptible Line - Piping determined to be susceptible to FAC using the EPRIsusceptibility criteria in NSAC 202L, industry experience and as documented in theSystem Susceptible Evaluation.[42] Susceptible Non-Modeled (SNM) Piping- A subset of the FAC susceptible lines thatcannot be modeled using the EPRI CHECWORKS software.[43] Time - Time in service shall be actual hours on line or of operation and/ or hourscritical. Calendar hours may be used for conservatism.

QUALITYRELATEDEN-DC-315REV. 0NUCLEARMANAGEMENTMANUALINFORMATIONALUSEPAGE 10 OF 34Flow Accelerated Corrosion Program3.0 cont.[44] Train - Loops within subsystems that have similar geometries, flow rates andtemperatures and which have similar FAC risk.[45] UT Datasheets - Paperwork that documentsthe results of the ultrasonic thicknessinspections.[46] Wear (W) - The amount of material removed or lost from a components wall thicknesssince baseline or subsequent to being placed in service.[47] Wear Rate (WR) - Wall loss per unit time.4.0 RESPONSIBILITIES4.1 MANAGER, ENGINEERING PROGRAMS[1] Providing a single point of accountability and is responsible for the overall health anddirection of the FAC programs.[2] Ensuring that the FAC programs are effectively developed and implemented.[3] Providing oversight for implementing the FAC programs.[4] Co-ordinate ENN or ENS FAC working group meetings.[5] Co-ordinate ENN or ENS FAC Self-Assessments.4.2 SUPERVISOR,CODE PROGRAMS[1] Designate responsible engineer/Personnel from the Code Programs EngineeringGroup for the implementation and maintenance of the Flow Accelerated CorrosionProgram.[2] Ensure that the Flow Accelerated Corrosion Program activities are conducted inaccordance with this procedure.[3] Shall ensure that repair procedures are in place to support any planned repairs orreplacements.[4] Ensureaudits and surveillance of selected Flow Accelerated Corrosion (FAC)activities isperformedto verify compliance with applicable codes, procedures anddrawings.

QUALITYRELATEDEN-DC-315REV. 0NUCLEARMANAGEMENTMANUALINFORMATIONALUSEPAGE 11 OF 34Flow Accelerated Corrosion Program4.2 cont.[5] Provides personnel to perform NDE during normal plant operation and unscheduledoutages.[6] Shall provide qualified Non-Destructive Examination personnel to perform flowaccelerated corrosion inspections during scheduled refueling and maintenanceoutages.[7] Provides personnel to perform reviews of all final FAC UT data sheets.[8] Provides personnel to review vendor procedures, personnel certifications andequipment certifications.[9] Assuring adequate technical personnel are available to provide required supportservices prior to the outage.[10] Allocation of resources to execute the requirements of the program.[11] Provide funding and resources to address control and configuration requirements forFAC drawings.[12] Having bench strength and back up personnel for the FAC program.4.3 NDE LEVEL III OR DESIGNEE[1] Reviews and approves FAC personnel and equipment certifications, and NDEprocedures including revisions.[2] NDE Level II or Level III reviews and signs all final NDE/UT data sheets to ensureappropriate NDE examinations have been completed in accordance with the FACprogram. The NDE level III review of Risk Informed examination shall be performed inaccordance with the site ISI program requirements.[3] Resolution of anomalies found in inspection data.[4] Identify discrepancies or deficiencies and initiates condition report in accordance withFAC program or site protocols as appropriate.[5] Performs oversight of selected FAC examinations to verify vendor procedurecompliance.[6] Performs functions in accordance with applicable procedures including the EntergyQuality Assurance Program.

QUALITYRELATEDEN-DC-315REV. 0NUCLEARMANAGEMENTMANUALINFORMATIONALUSEPAGE 12 OF 34Flow Accelerated Corrosion Program4.4 FLOW ACCELERATED CORROSION ENGINEER[1] Shall determine scope of inspections. The FAC Engineer shall develop a list ofcomponents/piping segments to be inspected prior to each outage using the criteria ofNSAC-202L and CHECWORKS Pass1 and Pass 2 output as a guide. Previousoutage inspection results shall be reviewed prior to development of the inspection list.This list shall be based on the susceptibility to flow accelerated corrosion and theseverities of wear identified from previous inspection results.[2] Review and/or perform an engineering evaluation for all Flow Accelerated Corrosioninspections where pipe wall thinning has been identified and concur on anyrecommended action. Calculations shall be done in accordance with applicableprocedures.[3] Shall ensure that appropriate inspections are performed in accordance with the scopeof the Flow Accelerated Corrosion Program.[4] Shall review and may sign all inspection data and make recommendations forrepair/replacement of piping materials in accordance withapplicable site protocols.[5] Shall provide NDE data for review and signature to the ANII, if requested by the ANII.[6] Shall provide Risk Informed Inspection data sheet (s) to the ANII for review andsignature, if applicable.[7] Develops or reviews program basis documents.[8] Shall revise and/or expand the scope of the Flow Accelerated Corrosion inspectionprogram to incorporate industry and in-house operating experiences and track/trendinspection results.[9] Shall maintain records of all inspection results and inspection database.[10] Develop a FAC examination checklist/traveler that containstnom, screening criteria,taccpt, line number, etc. for the components being inspected.[11] Shall initiate request for engineering services in accordance with the MAXIMO/IndusAsset Suite or site specific work control system for piping replacement or engineeringevaluations as required. This request should include recommended materials forreplacement and configuration changes, if applicable, to reduce the effects of flowaccelerated corrosion.[12] Shall periodically review completed plant modifications to assess their effect on thescope of the flow accelerated corrosion program.

QUALITYRELATEDEN-DC-315REV. 0NUCLEARMANAGEMENTMANUALINFORMATIONALUSEPAGE 13 OF 34Flow Accelerated Corrosion Program4.4 cont.[13] Shall assist in vendor oversight as required.[14] Maintaining control of the predictive models (e.g. CHECWORKS), which includes anydevelopment, updates or revisions to the models.[15] Developing, revising, and issuing FAC program documents.[16] Initiating and/or responding to Condition Reports and Engineering Requests forevaluating degraded and deficient components or other discrepancies or deficiencieswithin the scope of the FAC program.[17] Developing post outage inspection summary reports.[18] Review and disposition Operating Event (OE) notices for applicability to the FACprogram.[19] Analyzing inspection data to determine component acceptability for continued serviceand to determine the need for sample expansion.[20] Prioritizing and ranking inspection in terms of susceptibility and consequence offailure.[21] Develop and maintain the System Susceptibility Evaluation report.4.5 DESIGN ENGINEERING/RESPONSIBLE ENGINEER[1] Provide minimum acceptable wall thickness (taccpt) to the FAC Engineer.Responsibility may be delegated to another department or qualified personnel.[2] Perform local wall thinning evaluations for components having UT measurements thatare below or are projected to go below the minimum acceptable wall thickness (taccpt)or administrative wall thickness requirement. Responsibility may be delegated toanother department or qualified personnel.[3] Prepare and issue engineering response packages for component requiringreplacement. Responsibility may be delegated to another department or qualifiedpersonnel.[4] Perform remaining service life evaluation for components in the FAC program asrequired. Responsibility may be delegated to another department or qualifiedpersonnel.

QUALITYRELATEDEN-DC-315REV. 0NUCLEARMANAGEMENTMANUALINFORMATIONALUSEPAGE 14 OF 34Flow Accelerated Corrosion Program4.6 MAINTENANCE SUPERVISOR/DESIGNEE[1] The maintenance supervisor or designee will ensure that adequate craft personnel areavailable to support the FAC program. The supervisor shall ensure that scaffolding iserected, when needed, and insulation removed from components/piping segmentsthat will be inspected and that the piping is prepared for inspection. Scaffoldingerection in safety related areas should be in accordance with site procedures.[2] The maintenance supervisor or designee shall inform the FAC engineer when it isnecessary to remove a pipe support for inspection. An engineering evaluation isrequired if a pipe support requires removal.[3] The maintenance supervisor must ensure that surfaces to be inspected are free fromall foreign materials that would interfere with the inspections,i.e., dirt, rust, paint, etc.If cleaning is required, this may be accomplished by power sanding, flapper wheelonly) hand wire brushing, or hand sanding in accordance with siteprocedures/protocols.[4] The maintenance supervisor shall ensure restoration of lines, i.e. insulation replaced,scaffolding removed, upon completion of the FAC inspection.4.7 FAC/ISI PROJECT COORDINATOR[1] A FAC/ISI project coordinator may be chosen to Implement the activities of theinspection plan, the duties, if applicable, may include but is not limited to the followingactivities:(a) Performing component walk downs(b) Generating NDE inspection packages(c) Defining NDE staffing as required(d) Scheduling of inspections(e) Acquiring data as required(f)Providing field coordination to ensure timely inspection are accomplished(g) Tracking progress of the FAC inspection project(h) Transmitting inspection results to the FAC Engineer QUALITYRELATEDEN-DC-315REV. 0NUCLEARMANAGEMENTMANUALINFORMATIONALUSEPAGE 15 OF 34Flow Accelerated Corrosion Program5.0 DETAILS5.1 PRECAUTIONS AND LIMITATIONSNone.5.2 ANALYSIS/PRE-EXAMINATION[1] The criteria contained in NSAC-202L, latest revision, shall be used to perform theSystem Susceptibility Evaluation (SSE).[2] The System Susceptibility Evaluation report shall be developed and peer checked inaccordance with ENN or ENS procedures.[3] Non-typical operation of systems should be taken into consideration and if necessaryfactored into the FAC program.[4] The susceptible small-bore piping inspection priority ranking should considerpersonnel safety, consequence of failure and plant unavailability.[5] Industry and plant experiences relating to FAC will be factored into the program.[6] The CHECWORKS model should be used for guidance in determining inspectionpriority based on relative ranking for specific locations to be examined for FACdamage.5.3 PREPARATION OF OUTAGE INSPECTION PLAN[1] The FAC Program Engineer shall prepare an Outage Inspection Plan prior to theoutage to meet site milestones.[2] The Outage Inspection Plan should consider the cost of repair/replacement versusinspection.[3] The Outage Inspection Plan should consider inspection priority based on relativeranking for specific locations to be examined for FAC damage.[4] Each identified location shall be documented in the inspection plan, along with thecomponent number and reason for selection.[5] The inspection plan shall be reviewed by qualified FAC personnel.

QUALITYRELATEDEN-DC-315REV. 0NUCLEARMANAGEMENTMANUALINFORMATIONALUSEPAGE 16 OF 34Flow Accelerated Corrosion Program5.3 cont.[6] Component Selection(a) The FAC engineer shall prepare a FAC Outage Inspection scope as directed byplant milestones or as directed by Station management.(b) Inspection selections shall be made in accordance with the requirements of thisprocedure and shall be identified based on CHECWORKS results,industry/station/utility experience, required re-inspections, the non- modeledprogram piping and engineering judgment.(c) If a selected inspection location is determined to be excessively difficult,impractical or costly to examine due to inaccessibility, temperature, ALARAconcerns, scaffolding requirements, or other factors, then an equivalentalternate inspection location may be selected.(d) Components selected shall be formally documented.(e) The criteria for component selection should consider the following:(1) Components selected from measured or apparent wear found inprevious inspection results.(2) Components ranked high for susceptibility from current CHECWORKSevaluation.(3) Components identified by industry events/experience via the NuclearNetwork or through the EPRI CHUG.(4) Components selected to calibrate the CHECWORKS models.(5) Components subjected to off normal flow conditions. Primarily isolatedlines to the condenser in which leakage is indicated from the turbineperformance monitoring system.(6) Engineering judgment / Other(7) Piping identified from Work Orders (malfunctioning equipment,downstream of leaking valves, etc.).(8) Susceptible piping locations (groups of components) contained in theSmall Bore Piping database, which have not received an initialinspection.

QUALITYRELATEDEN-DC-315REV. 0NUCLEARMANAGEMENTMANUALINFORMATIONALUSEPAGE 17 OF 34Flow Accelerated Corrosion Program5.3[6](e) cont.(9) Piping identified from Condition Reports/ Corrective action, Work Orders(malfunctioning equip, downstream of leaking valves, etc.).(10) Vessel Shells - Feed-water heaters, moisture separator re-heaters,drain tanks etc.[7] Inspection schedule(a) Inspection sequence and schedule should be developed based on priorityestablished by the FAC engineer considering repair/scope expansion potential.Consideration will also be incorporated based on other outage work priorities,job conflict and system window duration.(b) The FAC outage schedule should contain sufficient time for analysis andevaluations of the components being inspected.[8] Drawing Preparation(a) For each component scheduled for inspection, an isometric or other acceptablelocation drawing should be prepared prior to the outage that identifies thecomponent to be examined. When applicable ensure the component number isshown on the drawing.[9] Obtain Minimum Acceptable WallThickness (taccpt)(a) Obtaintaccpt values for each component to be inspected.(b) The minimum acceptable wall thickness,taccpt, values should be obtained fromENN-CS-S-008 or ENS-PS-S-001 as applicable or from an approved sitemethod (e.g. FAC Manager).(c) Values fortaccpt should be obtained from design engineering or it may bedelegated to another department or qualified personnel. These values may beascertained prior to or during an outage.

QUALITYRELATEDEN-DC-315REV. 0NUCLEARMANAGEMENTMANUALINFORMATIONALUSEPAGE 18 OF 34Flow Accelerated Corrosion Program5.3 cont.[10] Component Identification(a) Inspected components should have a unique identifier to allow for the trackingof inspection data.(b) Component identifiers may allow for the identification of the Unit, system,sub-system, line number and corresponding location of that component within asub-system.(c) Components in the CHECWORKS non-modeled piping may be identified byusing line numbers.[11] Pre-inspection Activities(a) Review inspection schedule, inspection requirements and sequence withappropriate plant personnel to ensure requirements for the completion of theFAC inspection are understood.(b) The FAC engineer should participate in the preparation of FAC inspection workpackages as required.5.4 GRIDDING[1] Gridding of components shall be performed in accordance with recommendation ofNSAC 202L, ENN-EP-S-005 (for ENN plants only), and applicable site approvedprocedures or as specified by the FAC engineer.[2] Gridding information shall be documented on the appropriate NDE UT data sheeteither by a sketch or digital photo.5.5 NDE TEST METHODS AND DOCUMENTATION[1] Components can be inspected for FAC wear using ultrasonic testing (UT),radiography testing (RT), visual observation or other approved methods. Theinspection technique used shall be at the discretion of the FAC engineer.

QUALITYRELATEDEN-DC-315REV. 0NUCLEARMANAGEMENTMANUALINFORMATIONALUSEPAGE 19 OF 34Flow Accelerated Corrosion Program5.5 cont.[2] UT thickness measurement is the primary method of determining pipe wall thickness.(a) Inspections will be performed by using one of the following techniques:(1) Grid Point Reading(2) Grid Scan(3) Quadrant Scan(4) Line Scan(5) Full Scan(b) Ultrasonic Thickness measurement shall be performed in accordance withapproved NDE, site or vendor procedures.(c) A data sheet for components inspected shall be prepared. The informationincluded in the sheet should contain but is not limited to the following:(1) Plant's name/unit(2) Components name(3) Component sketch(4) NDE technician signature/ date(5) Grid size(6) Axial and radial grid boundaries(7) Calibration information(8) Level II or Level III signature/date(9) Work order information(10) Nominal & Measured thickness(11) 87.5% nominal thickness screening criteria(12) Scanning method QUALITYRELATEDEN-DC-315REV. 0NUCLEARMANAGEMENTMANUALINFORMATIONALUSEPAGE 20 OF 34Flow Accelerated Corrosion Program5.5 cont.[3] Radiograph Testing(a) RT (digital or conventional) is the preferred method for inspecting socketwelded fittings. The method used is at the discretion of the FAC engineer.(b) RT can be performed during plant operations without removing insulation[4] Visual Observation(a) Visual observation/techniques may be used for examination of largecomponents such as tanks, cross-around piping, cross-under piping, pumpcasings, shell walls, valves etc. (visual techniques is only applicable to twophase flow).(b) Follow-up UT examinations, at the discretion of the FAC engineer, may berequired of areas where significant damage is observed or suspected.5.6 EVALUATION OF UT INSPECTION DATANOTEHistorically, typical manufacturing practice has been to supply fittings (especially tees,elbows and reducers) with wall thickness significantly larger than the piping nominalthickness.[1] The data review should consider screening for further evaluation. Factors that shouldbe considered when reviewing the inspection data include unknown initial thickness(especially fittings), counter-bore, obstructions, and manufacturing wall thicknessvariations.[2] For each component that is examined and is below the screening criteria of 87.5% ofnominal wall, the wear, wear rate, remaining service life shall be calculated.[3] The FAC Program Engineer or designee shall review the UT data to ensure that thedata is complete and corresponds to the requirements specified on the inspection datasheet (i.e., grid size, spacing, flow direction, starting and ending locations,obstructions, missing data, suspect readings and orientation).[4] If low readings are encountered from repeat inspections that are due to counter-bore,then those areas shall be noted and additional inspections are not required.

QUALITYRELATEDEN-DC-315REV. 0NUCLEARMANAGEMENTMANUALINFORMATIONALUSEPAGE 21 OF 34Flow Accelerated Corrosion Program5.6 cont.[5] Grid Refinement(a) A grid reduction / refinement may be used if the minimum measured thicknessis less than the minimum required wall thickness, severe wall thinning isdetected, engineering judgment, or the projected thickness is less than theminimum required wall thickness or as directed by the FAC engineer.(b) The results of the grid refinement or scan shall be documented on aninspection data sheet.[6] Grid Extension(a) If measurement indicates wall loss at anyedge of the grid, then the grid shouldbe extended until the entire wear pattern is mapped.[7] Determination of Initial Wall Thickness(a) Initial Thickness (tinit): The thickness determined by ultrasonic examination priorto the component being placed into service (baseline) or the first ultrasonicexamination during its service life. If an examination has not previously beenperformed on the component, the initial thickness shall be determined byreviewing the initial ultrasonic data for that component. The area of maximumwall thickness within the same region as the worn area (based on the methodselected for evaluating wear) shall be identified and compared totnom. If thethickness is greater thantnom, the maximum wall thickness within that regionshall be used astinit. If that thickness is less thantnom,tnom shall be used astinit.[8] Determination of Wear(a) Wear of piping components may be evaluated using the band, area, andblanket or point-to-point method as defined in NSAC-202 L, latest revision orany other approved method.(b) Evaluation of inspection data that is determined to require wear evaluation shallbe documented and reviewed.

QUALITYRELATEDEN-DC-315REV. 0NUCLEARMANAGEMENTMANUALINFORMATIONALUSEPAGE 22 OF 34Flow Accelerated Corrosion Program5.6 cont.[9] Wear rate Determination(a) Wear rate is determined by wear/ unit time (Units to be consistent withthickness evaluation).(b) A reasonable safety factor should be applied to the wear rates to account forinaccuracies in the FAC wear rate calculations.(c) Wear rate evaluation should be evaluated on a component evaluation sheet.[10] Predicted Thickness (tp ,tpred)(a) The projected or predicted thickness to the next schedule refueling outage.tpred =tmeas - Safety factor x Wear Rate x TimeA safety factor of 1.1 should be applied to all Entergy nuclear plants. If a valueless than 1.1 is used the reason shall be documented.[11] Determination of Remaining Service Life (RSL)(a) Remaining service life (RSL) shall be evaluated as follows, units to beconsistent with thickness evaluation:RSL = (tmeas -taccpt) / (Safety Factor x Wear Rate)5.7 EVALUATION OF RT INSPECTION DATA[1] Qualified NDE personnel shall interpret the film and report the examination result tothe FAC engineer.[2] Appropriate conservatism should be used to determine if a component requiresreplacement or re-inspection as a consequence of qualitative nature of RT.[3] RT inspection shall be recorded on a data sheet.

QUALITYRELATEDEN-DC-315REV. 0NUCLEARMANAGEMENTMANUALINFORMATIONALUSEPAGE 23 OF 34Flow Accelerated Corrosion Program5.8 EVALUATION OF VISUAL INSPECTION DATA[1] Where accessible, visual inspections may be performed on two-phase flow lines.[2] Follow-up UT inspection is required for locations where significant damage isobserved or suspected.[3] Due to the qualitative nature of visual inspections, appropriate conservatism should beused when determining whether a component is acceptable to return to service andwhen establishing a re-inspection frequency.5.9 DISPOSITION OF INSPECTION RESULTS[1] The following are used to disposition component inspection results. Referenceattachment 9.3 for logic diagramNOTECertain components may have very little margin remaining as a consequence ofhigh stresses in the line even thoughtpred 0.875tnom and therefore may requireevaluation, for example Feedwater, Condensate, RHR, etc.[2] Iftpredis 0.875 tnom, the component is acceptable as is and may be returned toservice.[3] Iftpredis < 0.875tnom, evaluate for sample expansion (Reference section 5.12).[4] Iftpredis 0.3tnom, for ISI Class 1 piping repair or replacement is required inaccordance with the requirements of ASME Section XI Repair and ReplacementProgram.[5] Iftpredis 0.2tnom, for ISI Class 2, Class 3 and non-safety related, repair, replace orevaluate as warranted in accordance with applicable site programs or as directed bythe FAC engineer.[6] Iftpredis taccpt, the component is acceptable for continued operations, howevermonitoring is required in accordance with program requirements.

QUALITYRELATEDEN-DC-315REV. 0NUCLEARMANAGEMENTMANUALINFORMATIONALUSEPAGE 24 OF 34Flow Accelerated Corrosion Program5.9 cont.[7] Iftpredis <taccpt, a structural evaluation is required in accordance with site approvedprocedures or engineering standards. Also a sample expansion evaluation is required.Repair or replacement in accordance with the requirements of ASME Section XIRepair and Replacement Program or other site approved process may also berequired.[8] Iftmeas is < taccpt,generate a condition report. A structural evaluation is alsorequired in accordance with applicable site procedures or engineering standards.5.10 RE-INSPECTION REQUIREMENT[1] If the remaining service life (RSL) of a component is greater than or equal to thenumber of hours in the next operating cycle, then the component may be returned toservice.[2] If the component's remaining service life (RSL) is greater than the number of hours inthe next operating cycle but is less than the number of hours in the next two operatingcycles, then the component should be considered for re-inspection, repair orreplacement during the next scheduled outage.[3] If the component is acceptable for continued service, then it shall be re-examinedbefore or during the outage immediately prior to the cycle during which it is projectedto wear to the minimum allowable wall thickness.5.11 COMPONENTS FAILING TO MEET INITIAL SCREENING CRITERIA[1] If the results of the remaining life evaluationare shorter than the amount of time untilthe next scheduled inspection, there are several options for disposition of thecomponent, as follows:(a) Shorten the inspection interval (for components that can be inspected online)(b) Refine thetaccpt value through a detailed stress analysis, which should beprovided by Design Engineering or designee.(c) Repair or replace the component(d) ISI Class1 components that are less than or equal to 0.3 tnom must be repairedor replaced unless further structural evaluation permits continued service.[2] Wall thinning resulting in less thantaccpt shall be reported immediately to the FACengineer by verbal or written communications.

QUALITYRELATEDEN-DC-315REV. 0NUCLEARMANAGEMENTMANUALINFORMATIONALUSEPAGE 25 OF 34Flow Accelerated Corrosion Program5.11 cont.[3] A condition report shall be generated when significant wall thinning or unexpectedwear is detected in a system or component.[4] A condition report shall be generated for wall thinning belowtaccpt or other siteestablished limit and a subsequent structural evaluation performed to disposition theline for continued service.[5] If a previous condition report was generated for a component with wall thinning thenno new condition report is required provided that the associated structural evaluationis current and applicable.5.12 SAMPLE EXPANSION[1] If a component is discovered that has a current or projected wall thickness less thanthe minimum acceptable wall thickness (taccpt), then additional inspections of identicalor similar piping components in a parallel or alternate train shall be performed tobound the extent of thinning except as provided below. Reference section 5.12.2.[2] When inspections of components detects significant wall thinning and it is determinedthat sample expansion is required, the sample size for that line should be increased toinclude the following:(a) Components within two diameters downstream of the component displayingsignificant wear or within two diameters upstream if the component is anexpander or expanding elbow.(b) A minimum of the next two most susceptible components from the relative wearranking in the same train as the piping component displaying significant wallthinning.(c) Corresponding components in each other train of a multi-train line with aconfiguration similar to that of the piping component displaying significant wallthinning.[3] If the expanded inspection scope detects additional degradation, the sampleexpansion should continue until no additional components with significant wear aredetected.[4] Sample expansion is not required if the thinning was expected or if the thinning isunique to that component (e.g., degradation downstream of a leaking valve).

QUALITYRELATEDEN-DC-315REV. 0NUCLEARMANAGEMENTMANUALINFORMATIONALUSEPAGE 26 OF 34Flow Accelerated Corrosion Program5.12 cont.[5] Inspections of components from the current or past outages may satisfy the sampleexpansion criteria, therefore, some of the sample expansion requirements can be metwithout performing additional inspections.[6] Sample expansion is not required for components that are being re-inspected ifnormal or expected wear is detected or wear unique to that component. All other wearpatterns encountered shall be evaluated by the FAC Engineer to determine if sampleexpansion is required.5.13 REPAIR / REPLACEMENT OF DEGRADED COMPONENTS[NRC Generic Letter 90-05][1] The FAC engineer shall generate applicable documents to facilitate repair orreplacement of degraded or deficientcomponents.[2] Components experiencing severe or unacceptable wear should be replaced withcorrosion resistant material. However like in kind replacement may be appropriate ifprocurement of a resistant material would delay plant restart.[3] Replacing components or fitting-by-fitting that have experienced significant wear is asatisfactory approach to reducing wear if the wear is very localized (i.e., wear isconcentrated downstream of a flow control valve or orifice).[4] Repairs and replacements to piping and components within the scope of Class 1, 2, 3shall be performed in accordance with the requirements of ASME Section XI Repairand Replacement Program.[5] All temporary non-code repairs to ISI Class 1, 2, 3 shall comply with NRC GenericLetter 90-05.5.14 COMPONENT EVALUATION PACKAGES[1] The FAC Engineer or designee shall assemble a component evaluation package foreach examined component which may contain some of, but is not limited to thefollowing:(a) UT DATA Sheet(b) Isometric drawing(s), sketches, flow diagram and digital photo.(c) Reference to Structural /Minimum wall evaluation(d) Component evaluation data sheet.

QUALITYRELATEDEN-DC-315REV. 0NUCLEARMANAGEMENTMANUALINFORMATIONALUSEPAGE 27 OF 34Flow Accelerated Corrosion Program5.15 POST- INSPECTION ACTIVITIES[1] The FAC Program Engineer shall prepare an Outage Summary report to documentthe outage FAC activities and submit to Records for retention in accordance withapplicable procedures.[2] Update CHECWORKS models with inspection data.[3] Update small bore susceptible report as applicable[4] Update all applicable FAC reports.[5] Update FAC System Susceptible Report as required.5.16 LONG TERM STRATEGY[1] Entergy's fleet long-term strategy shall focus on reducing the plants FACsusceptibility. Optimization of the inspection planning process is an important factor.However, the reduction of FAC wear rates is necessary if both the number ofinspections and the probability of failure are to be reduced. Subsequently the fleet'slong term strategy will include the following elements:(a) The use of improved materials for replaced components or proactivereplacement of piping with corrosion resistant material.(b) Utilization of improved water chemistry(c) Incorporation of local design changes.(d) Optimization of the inspection planning process,(e) Industry participation in meetings for technology and information transfer (e.g.EPRI CHUG).(f)Maintaining up-to-date predictive software and incorporating the latestinspection data in the models.5.17 METHODS OF DETERMINING PLANT PERFORMANCE[1] Program performance indicators, self- assessments and bench marking are utilized asmethods for monitoring program and plant performance.

QUALITYRELATEDEN-DC-315REV. 0NUCLEARMANAGEMENTMANUALINFORMATIONALUSEPAGE 28 OF 34Flow Accelerated Corrosion Program6.0 INTERFACES[1] ENN-CS-S-008, "Pipe Wall Thinning Structural Evaluation".[2] ENN-EP-S-005 "Flow Accelerated Corrosion Component Scanning and GriddingStandard".[3] ENS-PS-S-001, "Pipe Wall Thinning and Crack-like Flaw Evaluation Standard".[4] EN-DC-202, "NEI 03-08 Materials Initiative".7.0 RECORDS[1] Record retention shall be in accordance with site procedures.8.0 OBLIGATION AND COMMITMENTS IMPLEMENTED BY THIS PROCEDURE8.1 OBLIGATIONS AND COMMITMENTS IMPLEMENTED OVERALLNone8.2 SECTION/STEP SPECIFIC OBLIGATIONS AND COMMITMENTSStepDocumentDocument Section/StepCommitment Number[1]QAPMA.6a, A.6b, A.6c, A.6eP33641-P33643, P-33645[2]QAPMB.12a, B.12b, B.12c,B.12d, B.12e, B12fP-33714 - P-33719[3]QAPMB.15a, B.15cP-33730, P-35351[4]NRC Generic Letter 90-05None8.3 SITE SPECIFIC COMMITMENTSStepSiteDocumentCommitment Number or Reference[1]JAFResponse to NRC IEBulletin 87-01JAFP 87-0737[2]JAFResponse to NRC GenericLetter 89-08JPN-89-051[3]IPEC Unit 3 Response to NRC IEBulletin 87-01IP3-87-055Z[4]IPEC Unit 3 Response to NRC GenericLetter 89-08IPN-89-044[5]IPEC Unit 2 Response to NRC IEBulletin 87-01Mr. Murray Selman (Con Edison) to Mr.William Russell (NRC), Letter datedSeptember 11, 1987.

QUALITYRELATEDEN-DC-315REV. 0NUCLEARMANAGEMENTMANUALINFORMATIONALUSEPAGE 29 OF 34Flow Accelerated Corrosion Program8.3 cont.[6]PilgrimResponse to NRC GenericLetter 89-08BECo 89-107[7]VYResponse to NRC GenericLetter 89-08Vermont Yankee letter to USNRC, FVY-89-66[8]VYResponse to NRC IEBulletin 87-01Vermont Yankee letter to USNRC, FVY-87-94[9]VYSupplemental Responseto NRC IE Bulletin 87-01Vermont Yankee letter to USNRC, FVY-87-121[10]ANOOCAN108914P-1079[11]GGNSGGNS Appendix K, PowerUprateP-35269[12]GGNSResponse to NRC GenericLetter 89-08P-24444[13]RBSResponse to NRC IEBulletin 93-02P-15802[14]RBSResponse to NRC IEBulletin 93-02, Supp. 1P-15803[15]WF3Response to INPO SOER87-03P-16557[16]WF3Response to IEN 89-001 P-20303[17]WF3Response to IEN 93-021 P-22888(a)9.0 ATTACHMENTS9.1 Guidance on Parameters affecting FAC.9.2 Flow Accelerated Corrosion Program Attributes.9.3 Wall Thinning Evaluation Process Map.

QUALITYRELATEDEN-DC-315REV. 0NUCLEARMANAGEMENTMANUALINFORMATIONALUSEPAGE 30 OF 34Flow Accelerated Corrosion ProgramATTACHMENT9.1GUIDANCE ONPARAMETERSAFFECTINGFACSheet 1 of 3GUIDANCE ON PARAMETERS AFFECTING FACListed below are factors to be considered when reviewing work requests, component replacements andmodification packages for possible impact on the content of the FAC Program governed by DC-315. AllDesign Change Packages (DCP's) are required to be evaluated for impact to the FAC Program. Thislist is not intended to be all-inclusive or to limit the number of items an individual would consider whenperforming this impact assessment. It is intended as a reasonable list of items to consider for potentialprogram content updates.1. Water Chemistry. Many water chemistry parameters have been shown to contribute to FAC.a. pH Control Amine - pH is the primary chemistry parameter affecting FAC rates in PWRs.However, the amine used to control pH also plays an important role. Amines such asammonia tend to separate more into the steam phase in two-phase flow conditions, andtherefore provide less protection in the drains. Amines such as morpholine and especiallyethanolamine have better partitioning characteristics for FAC.b. In a BWR, pH has much less of a role since the pH is stable and there are no amine'sadded to control the pH. FAC rates decrease as pH level increases. FAC rates seem todrop considerably at pH values of greater than 9.3 - 9.5.c. Oxygen Content - FAC rates decrease as oxygen concentration increases. Values thattypically result in minimum FAC rates are approximately 15 to 20 ppb.d. Hydrogen Water Chemistry - BWR Plants that do not have hydrogen addition normallyhave a main steam oxygen content near 18 ppm. Plants with hydrogen water chemistrytypically have an oxygen content from 3 to 12 ppm. This has a potential to impact thecorrosion rates in the LP steam systems; mainly the first and second stage reheater drainsbased on industry experience.e. Hydrazine Injection - Hydrazine is added to the feed train of PWRs as an oxygenscavenger and to maintain a reducing environment in the steam generators. From zero toapproximately 150 ppb,an increase in hydrazine concentrations seems to increase rates ofFAC. Higher concentrations seem to result in no further increase in FAC rates. EPRIrecommends the use of high levels of hydrazine (>100 ppb) to protect steam generatortubes; however, this can result in accelerated rates of FAC in the feed train. AlthoughCHECWORKS does not currently model high hydrazine conditions, any model updatesperformed after the release of version 1.0F should carefully consider hydrazineconcentrations.f.Zinc Injection - Industry experience has shown that zinc injection decreases corrosion andFAC wear rates due to the concentration of zinc at the oxide surface. The amount ofreduction depends on the amount of zinc at the surface.

QUALITYRELATEDEN-DC-315REV. 0NUCLEARMANAGEMENTMANUALINFORMATIONALUSEPAGE 31 OF 34Flow Accelerated Corrosion ProgramATTACHMENT9.1GUIDANCE ONPARAMETERSAFFECTINGFACSheet 2 of 32. Piping Geometry - Piping geometry is one of the most important factors in FAC. Generally,geometries that produce the greatest turbulence also produce the highest FAC rates. Listedbelow are examples of obvious items that should be considered in any assessment:a. Addition or replacement of fittings, bends and branch connections.b. Like for like replacement of any fitting in a system that is susceptible to FAC damage or ispart of system that is already part of the FAC Program.c. Alterations or repairs encountered in the nozzles or walls of FW heaters, MSR, DrainTanks, FW Pumps, HD Pumps or CD/CB Pumps.d. Throttled Valves.3. Piping Material Composition - Alloying elements improve the resistance of piping systems toFAC. In ascending order of resistance, the following table presents the degree of improvementover carbon steel:MaterialNominal CompositionRate (carbon steel) /Rate (alloy)P111.25% Cr, 0.50% Mo 34P222.25% Cr, 1.00% Mo 6530418% Cr>2504. In-Line Components - Addition or replacement of such components as thermowells, flowelements and pressure-reducing orifices should be evaluated. The local effects caused by thesecomponents can generate FAC damage in areas where overall conditions don't indicate the needfor inspections.5. Component Supports - Additions or deletions of components supports which could result in theneed for a review of the existing code minimum wall value or a new code minimum wallcalculation.6. Operational Changes - System operational changes such as the normal operation of emergencyheater drains, switching of spare components, extended use of normal start-up or by-pass lines,etc.

QUALITYRELATEDEN-DC-315REV. 0NUCLEARMANAGEMENTMANUALINFORMATIONALUSEPAGE 32 OF 34Flow Accelerated Corrosion ProgramATTACHMENT9.1GUIDANCE ONPARAMETERSAFFECTINGFACSheet 3 of 37. Component Replacements - Records should be updated for like for like replacement of fittingsalready in the program including new baseline data, changing next scheduled inspection duedate, etc. Note and track whether the replacement components have had surface preparationand a UT grid applied for future outage planning.8. External Sources - Information concerning FAC Inspection results from other stations andNuclear Plants operated by others. General information distributed by EPRI Reports, INPO &NRC Bulletins, etc. should also be considered.9. Maintenance History - A review of the maintenance performed on valves, orifices, steam traps,etc. should be considered. Valves that have had seat leakage can cause very localized wear insystems normally exempted. Plugged traps create water pockets in steam systems thataccelerate metal loss. Eroded orifices can cause increased metal loss due to decrease in backpressure and increase in flow rates.

QUALITYRELATEDEN-DC-315REV. 0NUCLEARMANAGEMENTMANUALINFORMATIONALUSEPAGE 33 OF 34Flow Accelerated Corrosion ProgramATTACHMENT9.2FLOWACCELERATEDCORROSIONPROGRAMATTRIBUTESSheet 1 of 1PROGRAM ATTRIBUTESAttributes: Program Infrastructure(a) Program Structure: Roles & Responsibilities, Program Ownership,Organizational Interfaces, etc.(b) Configuration management(c) Program Bases(d) Engineering Documentation(e) Flow Accelerated Corrosion System Susceptibility Evaluation, Latest Revision.(f) CHECWORKS models(g) Change processesProgram Staffing and Experience(a) Background and Expertise.(b) Qualification and training.(c) Bench Strength(d) Time Allotment(e) Industry ParticipationProgram Implementation(a) Work control(b) Inspections(c) Maintenance and Repairs(d) Control of Changes and Deferrals(e) Review of INPO Operating Experience documents, CHUG operatingexperience, NRC notices.Health Monitoring:(a) System Engineering Health reports.(b) FAC Quarterly Health Reports.Effective Assessment:(a) Perform FAC Self-Assessment on a periodic basis or as defined by applicableprocedures.Oversight:(b) Effective assessment, Benchmarking or Audits.

QUALITYRELATEDEN-DC-315REV. 0NUCLEARMANAGEMENTMANUALINFORMATIONALUSEPAGE 34 OF 34Flow Accelerated Corrosion ProgramATTACHMENT9.3 WALL THINNING EVALUATION PROCESS MAPSheet 1 of 1