IR 05000325/2014012
Download: ML14279A488
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION REGION II 245 PEACHTREE CENTER AVENUE N.E., SUITE 1200 ATLANTA, GEORGIA 30303 October 6, 2014 Mr. William Site Vice President Brunswick Steam Electric Plant 8470 River Road SE Southport, NC 28461-0429
SUBJECT: BRUNSWICK STEAM ELECTRIC PLANT - NRC POST-APPROVAL SITE INSPECTION FOR LICENSE RENEWAL, INSPECTION REPORT 05000325/2014012 AND 05000324/2014012
Dear Mr. Gideon:
On August 21, 2014, the U.S. Nuclear Regulatory Commission (NRC) completed a Post-
Approval Site Inspection for License Renewal at your Brunswick Steam Electric Plant, Units 1 and 2 in accordance with NRC Inspection Procedure 71003. The enclosed report documents the inspection results, which were discussed on August 21, 2014, with Mr. George Hamrick, Site Vice President, and other members of the Brunswick management staff.
The inspection examined activities conducted under your license as they relate to safety and compliance with the Commission's rules and regulations and with the conditions of your license.
The inspectors reviewed selected procedures and records, and interviewed plant personnel. Based on the inspection sample selected for review, no findings were identified. The inspectors identified a number of observations associated with the implementation of certain aging management activities. The inspectors determined that the overall implementation of Aging Management Programs and Time-Limited Aging Analyses was consistent with the license renewal commitments, the Updated Final Safety Analysis Report (UFSAR) supplement for license renewal, and the conditions in the renewed operating license. The inspectors also determined that structures, systems, and components within the scope of 10 CFR 54.37(b) were adequately identified and evaluated. The inspectors determined that commitment changes not affecting the UFSAR were evaluated in accordance with the applicable requirements.
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure(s), and your response (if any), will be made available electronically for public inspection in the NRC Public Document Room or from the NRC's Agencywide Documents Access and Management System (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html. To the extent possible, your response should not include any personal privacy or proprietary, information so that it can be made available to the Public without redaction.
Sincerely,/RA/ Mark G. Kowal, Chief (Acting) Engineering Branch 3 Division of Reactor Safety Docket No.: 50-325, 50-324 License No.: DPR-71, DPR-62
Enclosures:
Inspection Report 05000325/2014012, 05000324/2014012
w/Attachment:
Supplementary Information cc: Distribution via ListServ http://www.nrc.gov/reading-rm/adams.html. To the extent possible, your response should not include any personal privacy or proprietary, information so that it can be made available to the Public without redaction.
Sincerely,/RA/ Mark G. Kowal, Chief (Acting) Engineering Branch 3 Division of Reactor Safety Docket No.: 50-325, 50-324 License No.: DPR-71, DPR-62
Enclosures:
Inspection Report 05000325/2014012, 05000324/2014012
w/Attachment:
Supplementary Information cc: Distribution via ListServ
(SEE PREVIOUS PAGE) X PUBLICLY AVAILABLE NON-PUBLICLY AVAILABLE SENSITIVE X NON-SENSITIVE ADAMS: X Yes ACCESSION NUMBER:_ML14279A488_______________ X SUNSI REVIEW COMPLETE FORM 665 ATTACHED OFFICE RII:DRS RII:DRS RII:DRS RII:DRS NRR:DLR RII:DRS RII:DRS SIGNATURE BCC2 REW1 TLO1 MSC2 BCC2 FOR AXS2 PEC MXK7 NAME BCOLLINS RWILLIAMS TOHARA MCOURSEY ASENGUPTA PCOOPER MKOWAL DATE 10/ 2 /2014 10/3 /2014 10/ 5 /2014 10/ 6 /2014 10/ 2 /2014 10/ 6 /201410/ 6 /2014 E-MAIL COPY? YES NO YES NO YES NO YES NO YES NO YESN YES NO OFFICE RII:DRP RII:DRS SIGNATURE GTH1 MXK7 NAME GHOPPER KOWAL DATE 10/ 6 /2014 10/ 6 /2014 E-MAIL COPY? YES NO YES NO YES NO YES NO YES NO YESN YES NO OFFICIAL RECORD COPY DOCUMENT NAME: S:\DRS\ENG BRANCH 3\INSPECTIONS\WORKING DOCUMENTS\INPUTS\INPUTS 2014\BRUNSWICK 71003 PHASE 2 - IR 2014-012.DOCX Letter to Mr. William from Mark G. Kowal dated October 6, 2014
SUBJECT: BRUNSWICK STEAM ELECTRIC PLANT - NRC POST-APPROVAL SITE INSPECTION FOR LICENSE RENEWAL, INSPECTION REPORT 05000325/2014012 AND 05000324/2014012
Distribution w/encl: Sarah Price, RII EICS OE Mail RIDSNRRDIRS PUBLIC RidsNrrPMBrunswick Resource
Enclosure U.S. NUCLEAR REGULATORY COMMISSION REGION II Docket Nos.: 05000325, 05000324
License Nos.: DPR-71, DPR-62 Report Nos.: 05000325/2014012, 05000324/2014012
Licensee: Duke Energy Progress, Inc.
Facility: Brunswick Steam Electric Plant, Units 1 and 2 Location: Southport, NC 28461 Dates: August 4 - August 21, 2014 Inspectors: B. Collins, Senior Reactor Inspector, Team Lead R. Williams, Senior Reactor Inspector T. OHara, Reactor Inspector M. Coursey, Reactor Inspector A. Sengupta, Reactor Inspector P. Cooper, Reactor Inspector
Approved by: Mark G. Kowal, Chief (Acting)
Engineering Branch 3 Division of Reactor Safety
SUMMARY
IR 05000325, -324/2014012; 8/4/2014 - 8/21/2014; Brunswick Steam Electric Plant, Units 1, and 2; Post Approval Site Inspection for License Renewal.
The report covers a team inspection conducted by six regional inspectors in accordance with NRC Manual Chapter 2515 and NRC Inspection Procedure 71003. There were no violations of regulatory requirements identified. The inspectors identified a number of observations associated with the implementation of certain aging management activities.
On the basis of the sample selected for review, the inspectors determined that the licensee had completed, or was on track to complete, the necessary tasks to meet the license renewal commitments, license conditions, and regulatory requirements associated with the issuance of the renewed operating license at Brunswick Steam Electric Plant, Units 1 and 2. Based on the review of program documents and activities completed at the time of this inspection, the inspectors determined that the licensee had established the majority of required programs to manage aging effects of in-scope structures, systems, and components in order to maintain their function(s) through the period of extended operation (PEO) of the two units. For the established Aging Management Programs (AMPs) and Time-Limited Aging Analyses (TLAAs),
the inspectors determined that the licensee completed all planned aging management activities due prior to entering the PEOs of Units 1 and 2, with two exceptions, which are addressed in the sections below. For all programs, the inspectors determined that all the required aging management activities such as inspections, procedure revisions, and evaluations were performed as described in the commitments.
The inspectors determined that the licensee took appropriate actions to assure that "newly identified" structures, systems, and components within the scope of 10 CFR 54.37(b) were identified and evaluated for management of aging effects. The inspectors did not identify significant inconsistencies between the aging management program description in the Updated Final Safety Analysis Report (UFSAR) supplement for license renewal, as revised, and the aging management activities being implemented. The inspectors also determined that commitment changes not affecting the UFSAR were evaluated in accordance with the applicable requirements.
The significance of inspection findings are indicated by their color (i.e. greater than Green, or Green, White, Yellow, Red) and determined using Inspection Manual Chapter (IMC) 0609,
"Significance Determination Process" (SDP) dated June 2, 2011. Cross-cutting aspects are determined using IMC 0310, "Components Within The Cross-Cutting Areas" dated October 28, 2011. All violations of NRC requirements are dispositioned in accordance with the NRC's Enforcement Policy dated July 9, 2013. The NRC's program for overseeing the safe operations of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 4.
NRC-Identified and Self-Revealed Findings None Licensee-Identified Violations None
REPORT DETAILS
OTHER ACTIVITIES
4OA5 Other Activities: Post-Approval Site Inspection for License Renewal (Phase 2)
.1 License Conditions and Commitments for License Renewal, Implementation of Aging Management Programs and Time-Limited Aging Analyses
a. Inspection Scope
The inspectors reviewed a sample of regulatory commitments, Aging Management Programs (AMPs), and Time-Limited Aging Analyses (TLAAs) associated with the renewed operating licenses for Brunswick Steam Electric Plant (BSEP), Units 1 and 2 issued in June, 2006. This inspection took place prior to the period of extended operation (PEO) for Units 1 and 2, which will begin on September 9, 2016 and December 28, 2014, respectively. The inspectors reviewed license renewal commitment books, developed by the licensee, which contained implementing documents, plant drawings, completed work orders, self-assessments and other program-related documentation. Additionally, the inspectors conducted interviews with licensee staff. The above actions were completed to verify that the licensee completed the necessary actions to: (a) comply with the conditions stipulated in the renewed facility operating licenses; (b) meet the license renewal commitments described in the letter from James Scarola to the U.S. Nuclear Regulatory Commission (BSEP 05-0148) which is available in ADAMS via Accession Number ML053500114), and (c) implement the AMPs and TLAAs as described in the NRC SER and the license renewal supplement to the UFSAR.
For those license renewal action items that were not completed at the time of this inspection, the team verified that there was reasonable assurance that such action items were scheduled for completion prior to the PEO or in accordance with an established implementation schedule consistent with the LRA, the NRC SER, the UFSAR supplement or NRC-approved alternative. The licensee was tracking the completion of regulatory commitments for license renewal through their corrective action program, via individual entries into said program.
The AMPs/TLAAs and commitment items selected for the inspection sample are summarized below based on their description in the NRC SER supplement issued in June 2006 (ADAMS Accession Numbers ML061730123 and ML061730129), and the UFSAR supplement for license renewal, as revised, submitted with the LRA. The specific inspection activities conducted for each commitment, AMP, and TLAA are also described below. Specific documents reviewed for each commitment are listed in the report attachment.
Quality Assurance Program (UFSAR Section 18.1 and Commitment No. 1): The BSEP Quality Assurance Program was not specifically identified as a license renewal program in either the UFSAR supplement or program description. Commitment No. 1 stated that "The elements of the corrective action, confirmation process, and administrative controls in the BSEP Quality Assurance Program will be applied to required aging management activities for both safety related and non-safety related structures and components subject to aging management review." This language was repeated in the front matter of the UFSAR supplement, and the licensee's approach was to credit the existing Quality Assurance Program and Corrective Action Program with meeting the commitment.
The inspectors reviewed the licensing basis, program basis documents, administrative and implementing procedures, and self-assessments to verify that the Quality Assurance Program and Corrective Action Program were implemented in a manner which would ensure that Commitment No. 1 would be met throughout the PEO. To that same end, the inspectors interviewed licensee personnel to discuss the program methodology.
American Society of Mechanical Engineers (ASME)Section XI, Inservice Inspection, Subsections IWB, IWC, and IWD Program (UFSAR Section 18.1.1) The UFSAR supplement stated that the ASME Section XI, Inservice Inspection, Subsection IWB, IWC, and IWD Program consists of periodic volumetric, surface, and/or visual examination of components for assessment, signs of degradation, and corrective actions. Additionally, it stated that the program was implemented in accordance with Section XI of the ASME Boiler & Pressure Vessel Code, 1989 Edition (no addenda).
Furthermore, it stated that the program included NRC-approved risk-informed provisions in accordance with the BSEP Risk-Informed (RI) ISI Program and is consistent with the corresponding program described in NUREG-1801.
The inspectors reviewed the licensing basis and administrative and implementing procedures to verify that the program was developed as described in the LRA and the corresponding NRC SER. The inspectors also reviewed a sample of work orders and inspections to verify that the examination and evaluation of results were performed in accordance with the program implementing procedures.
Water Chemistry Program (UFSAR Section 18.1.2): The Water Chemistry Program was designed to minimize loss of material, cracking and flow blockage. The UFSAR supplement stated that the program was developed to mitigate the aging effects on component surfaces exposed to water as a process fluid, and that the program relied on monitoring and control of water chemistry to keep peak levels of various contaminants below system-specific levels. Additionally, the UFSAR supplement stated that chemical agents - such as corrosion inhibitors, oxygen scavengers and biocides - may be introduced to prevent certain aging mechanisms. Control of water chemistry was based on the latest version of Electric Power Research Institute (EPRI) guidelines in EPRI Report TR-103515-R2, February 2000, BWRVIP-79 for water chemistry in Boiling Water Reactors (BWRs), and the UFSAR supplement stated that the Water Chemistry Program would be updated as revisions to the guidelines are released. The inspectors reviewed the licensing basis, program basis documents, administrative and implementing procedures, and self-assessments to verify that the program was developed as described in the LRA and the corresponding NRC SER. The inspectors interviewed licensee personnel to discuss the program methodology to verify that the program effectively implemented the guidelines of EPRI TR-103515-R2.
Reactor Head Closure Studs Program (UFSAR Section 18.1.3):
The Reactor Head Closure Studs Program was credited with managing the aging effects of cracking due to stress corrosion cracking (SCC) and loss of material due to corrosion for the reactor head closure studs and stud components. The UFSAR supplement stated that the program consisted of inspections performed on the closure studs, nuts, bushings, and washers that were included within the scope of the ASME Section XI Inservice Inspection, Subsections IWB, IWC and IWD Program.
The inspectors reviewed the licensing basis, program basis documents, administrative and implementing procedures to verify that the program was developed as described in the LRA and the corresponding NRC SER. The inspectors interviewed licensee personnel to discuss the program methodology to verify that the program effectively implemented the guidelines of Section XI.M3 of NUREG-1801.
BWR Stress Corrosion Cracking Program (UFSAR Section 18.1.4): The BWR Stress Corrosion Cracking Program was developed to manage intergranular stress corrosion cracking in stainless steel reactor coolant pressure boundary components. The UFSAR supplement stated that the program was consistent with NUREG-0313, "Technical Report on Material Selection and Processing Guidelines for BWR Coolant Pressure Boundary Piping;" BWRVIP-75, "Technical Basis for Revisions to Generic Letter 88-01 Inspection Schedules;" and Nuclear Regulatory Commission Generic Letter 88-01, "NRC Position on Intergranular Stress Corrosion Cracking in BWR Austenitic Stainless Steel Piping." The program included: 1) component replacement and preventive measures to mitigate SCC and 2) inspections to monitor SCC and its effects. Preventive measures included heat sink welding, induction heating, mechanical stress improvement, and water chemistry control - each conducted in accordance with industry guidelines. Replacement methodologies included piping replacement with SCC-resistant stainless steel.
The inspectors reviewed the licensing basis, program basis documents, administrative and implementing procedures, and self-assessments to verify that the program was developed as described in the LRA and the corresponding NRC SER. The inspectors interviewed licensee personnel to discuss the program methodology to verify that the program effectively implemented the guidelines of NUREG-0313, BWRVIP-75 and NRC Generic Letter 88-01.
Flow-Accelerated Corrosion Program (UFSAR Section 18.1.5 and Commitment No. 2): The Flow-Accelerated Corrosion Program was developed to predict, inspect and monitor piping and fittings for a loss-of-material aging effect so that timely and appropriate action may be taken to minimize the probability of a leak or rupture. The UFSAR supplement stated that the Flow-Accelerated Corrosion Program elements are based on the recommendations identified in NSAC-202L-R2, "Recommendations for an Effective Flow-Accelerated Corrosion Program," which requires controls to assure the structural integrity of carbon steel lines containing high energy fluids (two-phase as well as single-phase). The UFSAR supplement contained one enhancement, which stated that prior to the PEO, the Flow-Accelerated Corrosion Program susceptibility analyses would be updated to include additional components within the scope of license renewal that were not part of the existing program.
The inspectors reviewed the licensing basis, program basis documents, administrative and implementing procedures, and license renewal drawings to verify that the program was developed as described in the LRA and the corresponding NRC SER. The inspectors interviewed licensee personnel to discuss the program methodology to verify that the program effectively implemented the guidelines of NSAC-202L-R2. The inspectors confirmed that the enhancement had been completed as stated in the UFSAR supplement. The inspectors also reviewed a sample of inspection results that were performed in accordance with the program implementing procedures.
Bolting Integrity Program (UFSAR Section 18.1.6 and Commitment No. 3): The Bolting Integrity Program was developed to address aging management requirements for bolting on mechanical components within the scope of license renewal, except for structural bolting, which is addressed by other programs. The UFSAR supplement stated that the program utilizes industry recommendations and EPRI guidance which consider material properties, joint/gasket design, chemical control, service requirements and industry/site operating experience in specifying torque and closure requirements. The UFSAR supplement also stated that the program relies on recommendations for a Bolting Integrity Program, as delineated in NUREG-1339,
"Resolution of Generic Safety Issue 29: Bolting Degradation or Failure in Nuclear Power Plants," and industry recommendations, as delineated in the EPRI NP-5769, "Degradation and Failure of Bolting in Nuclear Power Plants," and EPRI TR-104213,
"Bolted Joint Maintenance & Application Guide," for pressure retaining bolting within the scope of license renewal. The UFSAR supplement contained one enhancement, which stated that prior to the PEO, a precautionary note would be added to plant bolting guidelines to limit the sulfur content of compounds used on bolted connections. The inspectors reviewed the licensing basis, program basis documents, administrative and implementing procedures, and self-assessments to verify that the program was developed as described in the LRA and the corresponding NRC SER. The inspectors interviewed licensee personnel to discuss the program methodology to verify that the program effectively implemented the guidelines of NUREG-1339, EPRI NP-5769 and EPRI TR-104213. The inspectors confirmed that the enhancement had been completed as stated in the UFSAR supplement.
The inspectors identified one observation associated with the Bolting Integrity Program.
This observation is discussed in further details in section 4OA5.1.b.(1)a of this report. Open-Cycle Cooling Water System Program (UFSAR Section 18.1.7 and Commitment No. 4): The Open-Cycle Cooling Water System Program was developed to address the aging effects of material loss and fouling due to micro- or macro-organisms and various corrosion mechanisms in the plant open-cycle cooling water systems. The program description stated that the program utilizes monitoring, inspecting and testing to verify heat transfer and provides assurance that aging effects for the open-cycle cooling water systems can be managed during the PEO. The UFSAR supplement stated that the program was originally developed in response to NRC Generic Letter 89-13, "Service Water System Problems Affecting Safety-Related Equipment". The UFSAR supplement contained six enhancements, which stated that prior to the PEO: 1) Program scope include portions of the Service Water (SW) System credited in the Aging Management Review, including non-safety related piping, 2) the Residual Heat Removal (RHR) Heat Exchangers are subject to periodic eddy current testing with results compared to previous testing to evaluate degradation and aging, 3) periodic inspections of SW Pump casings are performed, 4) Program procedures include verification of cooling flow and heat transfer effectiveness of SW Pump Oil Cooling Coils, inspections associated with SW flow to the DGs (including inspection of expansion joints), and inspection and replacement criteria for RHR Seal Coolers, 5) piping inspections, include locations where throttling or changes in flow direction might result in erosion of copper-nickel piping, and 6) performance testing of the Emergency Diesel Generator Jacket Water heat exchangers has been implemented to verify heat transfer capability, and will be performed during the PEO consistent with docketed responses to NRC Generic Letter 89-13.
The inspectors reviewed the licensing basis, program basis documents, administrative and implementing procedures to verify that the program was developed as described in the LRA and the corresponding NRC SER. The inspectors interviewed licensee personnel to discuss the scope of the program and verified that program procedures incorporated requirements as described in the program basis documents. The inspectors also reviewed a sample of inspection results and work orders that were performed in accordance with the program implementing procedures. The inspectors confirmed that the enhancements had been completed as stated in the UFSAR supplement.
The inspectors identified one observation associated with the Open-Cycle Cooling Water Program. This observation is discussed in further details in section 4OA5.1.b.(1)b of this report.
Closed-Cycle Cooling Water System Program (UFSAR Section 18.1.8 and Commitment 5): The Closed-Cycle Cooling Water System Program was developed to address aging management of components in the Reactor Building Closed Cooling Water (RBCCW)and Diesel Generator (DG) Jacket Water Cooling Systems. The program description stated that these systems are closed cooling loops with controlled chemistry, consistent with the NUREG-1801 description of a closed-cycle cooling water system. The UFSAR supplement stated that both the Reactor Building Closed Cooling Water and Diesel Generator Jacket Water Cooling Water Systems employ a chemistry program augmented by component testing and inspection based on EPRI TR-107396, "Closed Cooling Water Chemistry Guideline," to assure the license renewal intended function(s) are maintained. The UFSAR supplement contained two enhancements, which stated that prior to the PEO: 1) Inspections of components wetted by closed cooling water are used to verify the efficacy of chemistry controls, 2) Program activities will be added to assure that preventive maintenance activities include inspections of DG combustion air intercoolers and heat exchangers. The UFSAR supplement stated that following enhancement, the Closed-Cycle Cooling Water System Program will be consistent with the corresponding program described in NUREG-1801.
The inspectors reviewed the licensing basis, program basis documents, administrative and implementing procedures to verify that the program was developed as described in the LRA and the corresponding NRC SER. The inspectors interviewed licensee personnel to discuss the scope of the program and verified that program procedures incorporated requirements as described in the program basis documents. The inspectors also reviewed a sample of inspection results and work orders that were performed in accordance with the program implementing procedures. The inspectors confirmed that the enhancements had been completed as stated in the UFSAR supplement.
Inspection of Overhead Heavy Load and Light Load Handling Systems Program (USFAR Section 18.1.9 and Commitment No. 6) The UFSAR supplement stated that the Overhead Heavy Load and Light Load Handling Systems Program manages the aging effects of corrosion of structural components and wear of crane rails for the Reactor Building Bridge Cranes, the Refueling Platforms, and the Intake Structure Gantry Crane. The program description stated that the program provides for periodic inspection of rails and structural members for degradation. The UFSAR supplement contained two enhancements, which stated that prior to the PEO: 1)include in the Program all cranes/platforms within the scope of License Renewal, 2)specify an annual inspection frequency for the Reactor Building Bridge Cranes and the Intake Structure Gantry Crane, and every fuel cycle for the Refuel Platforms, 3) allow use of maintenance crane inspections as input for the condition monitoring of License Renewal cranes, 4) require maintenance inspection reports to be forwarded to the responsible engineer, and 5) include inspection of structural component corrosion and monitoring crane rails for abnormal wear. The UFSAR supplement stated that the enhanced program will be consistent with the corresponding program described in NUREG-1801.
The inspectors reviewed the licensing basis and administrative and implementing procedures to verify that the program was as described in the LRA and the corresponding NRC SER. The inspectors also reviewed a sample of work orders and inspections to verify that the examination and evaluation of results were performed in accordance with the program implementing procedures. The inspectors confirmed that the enhancements had been completed as stated in the UFSAR supplement.
Fire Protection Program (UFSAR Section 18.1.10): The program description stated that the Fire Protection Program was credited for aging management of the fire protection components, fire suppression systems, the diesel-driven fire pump fuel oil supply line, and the fire pump diesel engine heat exchanger at BSEP. The UFSAR supplement stated that: 1) the Fire Protection Program includes fire barrier inspections and a diesel-driven fire pump inspection, 2) the fire barrier inspections require periodic visual inspection of fire barrier penetration seals; fire barrier walls, ceilings, and floors; and periodic visual inspection and functional tests of fire rated doors to ensure that their operability is maintained, 3) the diesel driven fire pump inspection requires that the pump be periodically tested to ensure that the fuel supply line can perform its intended function, and 4) the program also includes periodic inspection and testing of Halon and carbon dioxide fire suppression systems.
The inspectors reviewed the licensing basis, program basis documents, administrative and implementing procedures to verify that the program was developed as described in the LRA and the corresponding NRC SER. The inspectors interviewed licensee personnel to discuss the scope of the program and verified that program procedures incorporated requirements as described in the program basis documents. The inspectors also reviewed a sample of inspection results and work orders to verify that they were performed in accordance with the program implementing procedures.
Fire Water Systems Program (UFSAR Section 18.1.11 and Commitment No. 7): The Fire Water System Program was developed to manage corrosion and biofouling of fire water system components to ensure the capability of the water-based Fire Suppression System to perform its intended function. The UFSAR supplement stated that: 1) the Fire Water System Program includes system pressure monitoring, inspections, and periodic testing in accordance with applicable National Fire Protection Association commitments, 2) these inspections include the sprinkler heads and assure that corrosion products that could block flow of the sprinkler heads are not accumulating, and 3) the program also incorporates periodic selective leaching inspections of gray cast iron components wetted by fire water, based on operating experience gained in the License Renewal Selective Leaching of Materials Program. The UFSAR supplement contained one enhancement, which stated that prior to the PEO, program administrative controls will be enhanced to require assessing results from the initial 40-year service life tests and inspections to determine whether a representative sample of such results has been collected and whether expansion of scope and use of alternate test/inspection methods are warranted. The UFSAR supplement stated that; following enhancement, the Fire Water System Program will be consistent with the corresponding program described in NUREG-1801 and subsequent NRC interim staff guidance.
The inspectors reviewed the licensing basis, program basis documents, and implementing procedures to verify that the program was developed as described in the LRA and the corresponding NRC SER. The inspectors interviewed licensee personnel to discuss the administrative and implementing procedures to verify that these documents effectively implemented the commitment. The inspectors also reviewed a sample of work requests and corrective actions associated with various Fire Water System components to verify that the examination and evaluation of results were performed in accordance with the program implementing procedures. The inspectors confirmed that the enhancement had been completed as stated in the UFSAR supplement.
Aboveground Carbon Steel Tanks Program (UFSAR Section 18.1.12 and Commitment No. 8): The Aboveground Carbon Steel Tanks Program was developed to manage aging effects of loss of material by performing inspections of carbon steel Main Fuel Oil Storage, Condensate Storage, and Fire Protection Water Storage tanks. The UFSAR supplement stated that the program includes measures to monitor corrosion or degradation by: 1) inspection of the external surface of tanks that have protective paint or coating and sealant or caulking at the foundation interface, 2) performing one-time volumetric examinations of tank bottoms, and 3) performing one time inspections of all interior surfaces of the Condensate Storage Tanks and Fire Protection Water Storage Tank.
The program description stated that the program credits the Systems Monitoring Program and One-Time Inspection Program with accomplishing these measures. The UFSAR supplement stated that once implemented, the Aboveground Carbon Steel Tanks Program will be consistent with the corresponding program described in NUREG-1801.
The inspectors reviewed the licensing basis, program basis documents, implementing procedures to verify that the program was developed as described in the LRA and the corresponding NRC SER. The inspectors interviewed licensee personnel to discuss the administrative and implementing procedures to verify that these documents effectively implemented the commitment. The inspectors also reviewed a sample of work requests and corrective actions associated with various Aboveground Steel Tank components to verify that the examination and evaluation of results were performed in accordance with the program implementing procedures. Fuel Oil Chemistry Program (UFSAR Section 18.1.13 and Commitment No. 9): The UFSAR supplement stated that: 1) the Fuel Oil Chemistry Program monitors fuel oil quality to control fuel oil contamination in accordance with the guidelines of the American Society for Testing Materials (ASTM) Standards specified in the BSEP Technical Specification Bases applicable to the Surveillance Requirements for fuel oil testing, 2) that exposure to fuel oil contaminants, such as water and microbiological organisms is minimized by verifying the quality of new oil before its introduction into the storage tanks and by periodic sampling to assure that the tanks are free of water and particulates, and 3) the effectiveness of the program is verified using thickness measurement of tank bottom surfaces to ensure that significant degradation is not occurring.
The UFSAR supplement contained four enhancements, which stated that prior to the PEO: 1) the program was modified to include program administrative controls to add a requirement to trend data for water and particulates, 2) through the program, the condition of the in-scope fuel oil tanks will be verified by means of thickness measurements under the One-Time Inspection Program, 3) periodic internal inspections of the Main Fuel Oil Storage Tank and Four Day Tanks would occur through the PEO, and 4) the program would be modified such that a biocide treatment would be utilized in the diesel generator fuel oil systems.
The inspectors reviewed the licensing basis, program basis documents, administrative and implementing procedures, and engineering changes to verify that the program was developed as described in the LRA and the corresponding NRC SER. The inspectors interviewed licensee personnel to discuss the program methodology to verify that the program effectively implemented the appropriate acceptance criteria as described in plant ASTM Standards and BSEP Technical Specifications. The inspectors confirmed that the enhancements had been completed as stated in the UFSAR supplement.
Reactor Vessel Surveillance Program (UFSAR Section 18.1.14 and Commitment No. 10): The Reactor Vessel Surveillance Program was credited with managing the reduction in fracture toughness due to neutron irradiation embrittlement of the reactor vessel intermediate beltline shell and associated welds. The UFSAR supplement stated that the program was an Integrated Surveillance Program, in accordance with 10 CFR Part 50, Appendix H, Paragraph III.C, that was based on requirements established by the Boiling Water Reactor Vessel and Internals Project (BWRVIP) reports. Additionally, the UFSAR supplement contained one enhancement, which stated that prior to the PEO, any additional requirements resulting from the NRC SER documented in BWRVIP-86, "BWR Vessel and Internals Project Updated BWR Integrated Surveillance Program (ISP)
Implementation Plan," Revision 1-A would be addressed. The activities in this AMP were also credited by the licensee for covering License Conditions O and L in the renewed operating licenses (for Units 1 and 2, respectively).
The inspectors reviewed the licensing basis, program basis documents, administrative and implementing procedures to verify that the program was developed as described in the LRA and the corresponding NRC SER. The inspectors interviewed licensee personnel to discuss the scope of the program and verified that program procedures incorporated requirements as described in the program basis documents. The inspectors confirmed that the enhancement had been completed as stated in the UFSAR supplement. The inspectors identified one observation associated with the license renewal controls for the storage of reactor vessel surveillance capsules. This observation is discussed in further details in section 4OA5.1.b.(2) of this report.
One-Time Inspection Program (UFSAR Section 18.1.15 and Commitment Nos. 11 and 30): The One-Time Inspection Program was developed as a repository program for one-time inspection activities intended to verify the effectiveness of various AMPs or to confirm the absence of an aging effect. For the Water Chemistry Program and Fuel Oil Chemistry Program, the inspections were intended to confirm that unacceptable degradation was not occurring and that the intended function of a component would be maintained during the PEO. The remaining inspections were performed to address aging effect concerns for structures and components where either an aging effect was not expected to occur but there was insufficient data to completely rule it out, or an aging effect was expected to progress very slowly. The UFSAR supplement stated that The One-Time Inspection Program included: 1) procedural controls to track, implement, complete, and report activities associated with one-time inspections, 2) inspection of the non-safety related core shroud head and separators and the surveillance capsule holder, 3) inspection of at least one of the four Emergency Diesel Engine Sumps, and at least one of the ten Service Water Pump Lubricating Oil Cooling Coils for corrosion products and evidence of moisture, and 4) application of inspection criteria consistent with Section XI.M32 of NUREG-1801.
The inspectors reviewed the licensing basis, program basis documents, administrative and implementing procedures, and license renewal drawings to verify that the program was developed as described in the LRA and the corresponding NRC SER. The inspectors interviewed licensee personnel to discuss the scope of the program and verified that program procedures included requirements as described in the LRA. The inspectors also reviewed a sample of inspection results to verify that they were performed in accordance with the program implementing procedures.
Selective Leaching of Materials Program (UFSAR Section 18.1.16 and Commitment No. 12): The Selective Leaching of Materials Program was designed to ensure the integrity of components made of cast iron, brasses and aluminum-bronze which are exposed to a raw water, treated water, moisture-laden air or buried environment. Originally, the program was intended to rely on a one-time inspection approach under the One-Time Inspection Program, as was reflected in the UFSAR supplement at the time. This approach included one-time inspections and qualitative determinations for a sample population of susceptible components. However, after completion of those one-time inspections, the licensee concluded that a periodic inspection approach would be more appropriate for gray cast iron components in the Fire Water System Program and selected valves in the Service Water system. The Open-Cycle Cooling Water System Program (18.1.7), the Fire Water System Program (18.1.11) and the Selective Leaching of Materials Program descriptions in the UFSAR supplement were updated to reflect the new approach.
The inspectors reviewed the licensing basis, program basis documents, administrative and implementing procedures, and inspection results to verify that the program was developed as described in the LRA and the corresponding NRC SER. The inspectors interviewed licensee personnel to discuss the program methodology to verify that the program was implemented as described in the UFSAR. The inspectors confirmed that the changes to the AMP and UFSAR supplement had appropriately incorporated the requirements of 10 CFR 50.59 and that these changes will be included with the next UFSAR update submitted to the NRC.
Buried Piping and Tanks Inspection Program (UFSAR Section 18.1.17 and Commitment No. 13): The Buried Piping and Tanks Inspection Program was developed to manage the aging effect of loss of material for the external surfaces of carbon steel, stainless steel and cast iron piping components that are buried in soil or sand. The UFSAR supplement stated that: 1) no buried tanks fall within the scope of this program, 2) the program includes preventive measures to mitigate corrosion by protecting the external surface of buried piping components through the use of coating or wrapping, 3) the program includes visual examinations of buried piping components on a frequency not to exceed ten years, and 4) the program includes procedural requirements to: a) ensure an appropriate as-found pipe coating and material condition inspection is performed whenever buried piping within the scope of this Program is exposed, b) add precautions concerning excavation and use of backfill to the excavation procedure to include precautions for License Renewal piping, c) add a requirement that coating inspection shall be performed by qualified personnel to assess its condition, and d) add a requirement that a coating engineer or other qualified individual should assist in evaluation of any coating degradation noted during the inspection.
The inspectors reviewed the licensing basis, program basis documents and implementing procedures to verify that the program was developed as described in the LRA and the corresponding NRC SER. The inspectors interviewed licensee personnel to discuss the administrative and implementing procedures to verify that these documents effectively implemented the commitment. The inspectors also reviewed a sample of work requests and corrective actions associated with various buried piping components to verify that the examination and evaluation of results were performed in accordance with the program implementing procedures.
ASME Section XI, Subsection IWE Program (UFSAR Section 18.1.18): The UFSAR supplement stated that the ASME Section XI, Subsection IWE Program consists of periodic inspection of steel containment components for signs of degradation, assessment of damage, and corrective actions. Additionally, it stated that this program is in accordance with ASME Section XI, Subsection IWE, 1992 Edition, including 1992 Addenda, and in accordance with 10 CFR 50.55a. Furthermore, it stated that the ASME Section XI, Subsection IWE Program is consistent with the corresponding program described in NUREG-1801.
The inspectors reviewed the licensing basis and administrative and implementing procedures to verify that the program was as described in the LRA and the corresponding NRC SER. The inspectors also reviewed a sample of work orders and inspections to verify that the examination and evaluation of results were performed in accordance with the program implementing procedures.
ASME Section XI, Subsection IWL Program (UFSAR Section 18.1.19): The UFSAR supplement stated that: 1) the ASME Section XI, Subsection IWL Program is credited for the aging management of accessible and inaccessible pressure-retaining Primary Containment concrete for both BSEP Units, 2) the BSEP containment structures do not use prestressed tendons, and therefore, ASME Section XI, Subsection IWL rules regarding post-tensioning systems are not applicable, 3) this program is in accordance with ASME Section XI, Subsection IWL, 1992 Edition, including 1992 Addenda, and in accordance with 10 CFR 50.55a, and 4) ASME Section XI, Subsection IWL Program is consistent with the corresponding program described in NUREG-1801 with the exception of requirements associated with a post-tensioning system, which are not applicable.
The inspectors reviewed the licensing basis and administrative and implementing procedures to verify that the program was as described in the LRA and the corresponding NRC SER. The inspectors also reviewed a sample of work orders and inspections to verify that the examination and evaluation of results were performed in accordance with the program implementing procedures.
ASME Section XI, Subsection IWF Program (UFSAR Section A.1.1.20 and Commitment No. 14): The UFSAR supplement stated that the ASME Section XI, Subsection IWF Program consists of periodic visual examination of component supports for loss of material and loss of mechanical function. It also stated that this program is in accordance with ASME Section XI, Subsection IWF, 1989 Edition, and in accordance with ASME Code Case N-491. Additionally, the UFSAR supplement contained one enhancement, which stated that prior to the PEO, the program will be enhanced to include the torus vent system supports within the scope of the program. The UFSAR supplement stated that following enhancement, the ASME Section XI, Subsection IWF Program will be consistent with the corresponding program described in NUREG-1801.
The inspectors reviewed the licensing basis and administrative and implementing procedures to verify that the program was as described in the LRA and the corresponding NRC SER. The inspectors also reviewed a sample of work orders and inspections to verify that the examination and evaluation of results were performed in accordance with the program implementing procedures. The inspectors confirmed that the enhancement had been completed as stated in the UFSAR supplement.
10 CFR 50, Appendix J Program (UFSAR Section 18.1.21): The UFSAR supplement stated that the 10 CFR Part 50, Appendix J Program consists of monitoring of leakage rates through containment liner/welds, penetrations, fittings, and access openings to detect degradation of the pressure boundary and that corrective actions are taken if leakage rates exceed acceptance criteria. It also stated that this program is implemented in accordance with Option B (performance-based leak testing) of 10 CFR Part 50, Appendix J; Regulatory Guide 1.163; and NEI 94-01, "Industry Guideline for Implementing Performance Based Option of 10 CFR Part 50, Appendix J."
Furthermore, the UFSAR supplement stated the program is consistent with the corresponding program described in NUREG-1801.
The inspectors reviewed the licensing basis and administrative and implementing procedures to verify that the program was as described in the LRA and the corresponding NRC SER. The inspectors also reviewed a sample of work orders and inspections to verify that the examination and evaluation of results were performed in accordance with the program implementing procedures.
Masonry Wall Program (UFSAR Section 18.1.22 and Commitment No. 15) The Masonry Wall Program was developed as a condition monitoring program consisting of inspections to identify cracking of masonry walls within the Service Water Building, Reactor Building, Augmented Off-Gas Building, Diesel Generator Building, Control Building, and Turbine Building, all on frequencies established such that no loss of intended function would occur between inspections. The UFSAR supplement stated that the program was based on NRC Bulletin 80-11, "Masonry Wall Design," for managing the cracking of Masonry Walls. The UFSAR supplement contained one enhancement, which stated that prior to the PEO, the administrative controls for the program would be enhanced to require inspecting all accessible surfaces of the walls for evidence of cracking. The inspectors reviewed the administrative and implementing procedures to verify that the program was as described in the LRA and the corresponding NRC SER. The inspectors interviewed licensee personnel to discuss the scope of the program and verified that program procedures incorporated requirements as described in the program basis documents. The inspectors also conducted a walkdown of the Diesel Generator Building and the Service Water Building and observed the condition of a sample of masonry walls which are monitored by the Masonry Wall Program. The inspectors confirmed that the enhancement had been completed as stated in the UFSAR supplement.
Structures Monitoring Program (UFSAR Section 18.1.23 and Commitment No. 16) The Structures Monitoring Program was developed as a condition monitoring program consisting of inspections to identify degradation in structural components that could lead to loss of intended function. The UFSAR supplement stated that the program is implemented in accordance with the Maintenance Rule, 10 CFR 50.65; NEI (NUMARC) 93-01, "Industry Guidelines for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," Rev. 2, and Regulatory Guide 1.160, "Monitoring the Effectiveness of Maintenance of Nuclear Power Plants," Rev. 2, and that the inspection criteria are based on ACI 349.3R 96, "Evaluation of Existing Nuclear Safety-Related Concrete Structures,"
and ASCE 11-90, "Guideline for Structural Condition Assessment of Existing Buildings,"
as well as, INPO Good Practice document 85-033, "Use of System Engineers," and NEI 96-03, "Guidelines for Monitoring the Condition of Structures at Nuclear Plants." The UFSAR supplement contained nine enhancements, which stated that prior to the PEO, the Structures Monitoring Program would be enhanced to: 1) identify License Renewal systems managed by the Program and inspection boundaries between structures and systems, 2) require notification of the responsible engineer regarding availability of exposed below-grade concrete for inspection and require that an inspection be performed, 3) identify specific license renewal commodities and inspection attributes, 4)require responsible engineer review of groundwater monitoring results, 5) specify that an increase in sample size for component supports shall be implemented (rather than should be) commensurate with the degradation mechanisms found, 6) improve training of system engineers in condition monitoring of structures, 7) include inspections of the submerged portions of the Service Water Intake Structure on a frequency not to exceed five years, 8) specify an annual groundwater monitoring inspection frequency for concrete structures, and 9) specify the inspection frequency for the Service Water Intake Structure and Intake Canal not to exceed five years. The Structures Monitoring Program was also credited by the Phase Bus Monitoring Program with inspection of external surfaces of phase bus housing. The UFSAR supplement stated that following enhancement, the Structures Monitoring Program will be consistent with the corresponding program described in NUREG-1801.
The inspectors reviewed the administrative and implementing procedures to verify that the program was as described in the LRA and the corresponding NRC SER. The inspectors interviewed licensee personnel to discuss the scope of the program and verified that program procedures incorporated requirements as described in the program basis documents. The inspectors also reviewed a sample of work orders which documented inspections in the Unit 1 Diesel Generator Building. The inspectors confirmed that the enhancements had been completed as stated in the UFSAR supplement.
Protective Coating Monitoring and Maintenance Program (UFSAR Section 18.1.24 and Commitment No. 17): The Protective Coating Monitoring and Maintenance Program was developed as a condition monitoring program for Service Level I coatings applied inside the primary containment (drywell and torus) of Units 1 and 2. The program description stated that the goal was to prevent clogging of ECCS suction strainers and containment spray nozzles by assuring that the quantity of damaged or degraded coatings inside primary containment that could detach during a loss of coolant accident remains within analyzed limits. These limits were established in design basis calculations for ECCS suction strainers installed in the mid-1990s. The UFSAR supplement contained one enhancement, which stated that prior to the PEO, the Program administrative controls would incorporate the following changes: 1) add a requirement for a walk-through, general inspection of containment areas during each refueling outage, including all accessible pressure boundary coatings not inspected under the ASME Section XI, Subsection IWE Program, 2) add a requirement for a detailed, focused inspection of areas noted as deficient during the general inspection, 3) assure that the qualification requirements for persons evaluating coatings are consistent among the Service Level I coating specifications, inspection procedures, and application procedures, and meet the requirements of ANSI N 101.4, "Quality Assurance for Protective Coatings Applied to Nuclear Facilities," and 4) document the results of inspections and compare the results to previous inspection results and to acceptance criteria. Following enhancement, the Program will be consistent with the corresponding program described in NUREG-1801 with the exception that the Program is not credited in the License Renewal review for preventing corrosion of primary containment components.
The inspectors reviewed the licensing basis, program basis documents, administrative and implementing procedures, and inspection results to verify that the program was developed as described in the LRA and the corresponding NRC SER. The inspectors interviewed licensee personnel to discuss the program methodology to verify that the program was implemented as described in the UFSAR. The inspectors confirmed that the enhancements had been completed as stated in the UFSAR supplement. The inspectors also confirmed that the changes to the AMP and UFSAR supplement had appropriately incorporated the requirements of 10 CFR 50.59 and that these changes would be included with the next UFSAR update submitted to the NRC.
Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Program (UFSAR Section 18.1.25 and Commitment No. 18): The Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Program was a new program which was developed to manage aging for cables and connections not included in the BSEP Environmental Qualification (EQ) Program. The program description stated that the licensee has implemented this program by: 1) revising Cable & Connections Inspection Procedure EGR-NGGC-0507 as applicable to BSEP, 2) establishing PMs and model WOs to perform cable inspections, 3) developing and implementing training under Training Guide ESG007N for individuals performing cable/connection inspections under this program, and 4) completing all initial inspections required prior to the PEO for Unit 1.
The UFSAR supplement stated that: 1) under this program, accessible electrical cables and connections installed in adverse environments are visually inspected at least once every 10 years for cable and connection jacket surface anomalies, such as embrittlement, discoloration, cracking, swelling, or surface contamination, which are precursor indications of conductor aging degradation from heat, radiation, or moisture, 2)an adverse localized environment is a condition in a limited plant area that is significantly more severe than the specified service condition for the electrical cable or connection, and 3) the program is consistent with the corresponding program described in NUREG-1801.
The inspectors reviewed the administrative and implementing procedures to verify that the program was as described in the LRA and the corresponding NRC SER. The inspectors also reviewed a sample of work orders and corrective action documents to verify that activities were performed in accordance with the program implementing procedures.
Electrical Cables Not Subject to 10 CFR 50.49 Environmental Qualification Program Requirements Used in Instrumentation Circuits Program (UFSAR Section 18.1.26 and Commitment No. 19): The Electrical Cables Not Subject to 10 CFR 50.49 Environmental Qualification Program Requirements Used in Instrumentation Circuits Program was a new program which was developed to manage aging for radiation monitoring and neutron flux monitoring instrumentation cables not included in the BSEP EQ Program. The UFSAR supplement stated that: 1) for radiation monitoring instrumentation circuits, the results of routine calibration tests will be used to identify the potential existence of cable aging degradation, 2) for neutron flux instrumentation circuits, field cables will be tested at least once every 10 years, 3) testing may include IR tests, time domain reflectometry (TDR) tests, current versus voltage (I/V) testing, or other testing judged to be effective in determining cable insulation condition, and 4) this Program is consistent with the corresponding program described in NUREG-1801, with the exception that it allows direct cable testing for neutron flux monitoring circuits.
The inspectors reviewed the administrative and implementing procedures to verify that the program was as described in the LRA and the corresponding NRC SER. The inspectors also reviewed system health reports, corrective action documents and personnel certifications to verify that activities were performed in accordance with the program implementing procedures.
Inaccessible Medium Voltage Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Program (UFSAR Section 18.1.27 and Commitment No. 20): The Inaccessible Medium Voltage Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Program was a new program which was developed to manage aging for inaccessible medium-voltage cables not included in the BSEP EQ Program. The UFSAR supplement stated that: 1) in-scope, medium-voltage cables exposed to significant moisture and significant voltage are tested at least once every 10 years to provide an indication of the condition of the conductor insulation, 2) the specific type of test performed is a proven test for detecting deterioration of the insulation system due to wetting, such as power factor, partial discharge, or polarization index, or other testing that is state-of-the-art at the time the test is performed, 3) manholes associated with inaccessible non-EQ medium-voltage cables are inspected for water accumulation and drained, as needed, 4) the manhole inspection frequency is based on actual field data and shall not exceed two years, and 5) this program is consistent with the corresponding program description in NUREG-1801.
The inspectors reviewed the administrative and implementing procedures to verify that the program was as described in the LRA and the corresponding NRC SER. The inspectors also reviewed a sample of work orders and corrective action documents to verify that activities were performed in accordance with the program implementing procedures.
Reactor Coolant Pressure Boundary Fatigue Monitoring Program (UFSAR Section 18.1.28 and Commitment No. 21): The Reactor Coolant Pressure Boundary Fatigue Monitoring Program was developed to address fatigue cracking caused by anticipated cyclic strains in metal components of the reactor coolant pressure boundary. The program description stated that activities would include monitoring and tracking of significant thermal and pressure transients which could challenge the fatigue design limit of pressure boundary components. The UFSAR supplement stated that the program included environmental fatigue evaluations of the sample locations specified in NUREG/CR-6260, "Application of NUREG/CR-5999, Interim Fatigue Curves to Selected Nuclear Power Plant Components," for older-vintage BWRs. The UFSAR supplement contained one enhancement, which stated that prior to the start of the PEO, the program would be updated in the following ways: 1) expand the Program scope to include an evaluation of each reactor coolant pressure boundary component beyond the Reactor Pressure Vessel, including each NUREG/CR-6260 location, 2) provide preventive action requirements including requirement for trending and consideration of operational changes to reduce the number or severity of transients affecting a component, 3) include a requirement to reassess the locations that are monitored considering the RCPB locations that were added to the Program scope, 4)specify the selection criterion to be locations with a 60-year CUF value (including environmental effects where applicable) of 0.5 or greater, 5) address corrective actions for components approaching limits, with options to include a revised fatigue analysis, repair or replacement of the component, or in-service inspection of the component (with prior NRC approval), and 6) address criteria for increasing sample size for monitoring if a limiting location is determined to be approaching the design limit.
The inspectors reviewed the licensing basis, program basis documents, administrative and implementing procedures to verify that the program was developed as described in the LRA and the corresponding NRC SER. The inspectors interviewed licensee personnel to discuss the program methodology to verify that the program was implemented as described in the UFSAR. The inspectors confirmed that the changes to the AMP had appropriately incorporated the requirements of 10 CFR 50.59.
Environmental Qualification Program (UFSAR 18.1.29): The UFSAR supplement stated that: 1) the existing BSEP Environmental Qualification Program was credited for aging management of electric equipment important to safety in accordance with the requirements of 10 CFR 50.49, which requires EQ components that are not qualified for the current license term to be refurbished, replaced, or have their qualifications extended prior to reaching the aging limits established in the aging evaluation, 2) reanalysis of aging evaluations to extend the qualifications of components is performed on a routine basis as part of the EQ Program. Important attributes for the reanalysis of aging evaluations include analytical methods, data collection and reduction methods, underlying assumptions, acceptance criteria and corrective actions (if acceptance criteria are not met), 3) TLAA demonstration option 10 CFR 54.21(c)(1)(iii), which states that the effects of aging will be adequately managed for the PEO, was chosen, 4) the EQ Program manages the aging effects of the components associated with the EQ TLAA, and 5) the program is consistent with the corresponding program described in NUREG-1801.
The inspectors reviewed the licensing basis, program basis documents, and administrative procedures to verify that the program was developed as described in the LRA and the corresponding NRC SER. The inspectors interviewed licensee personnel to discuss the scope of the program and verified that program procedures incorporated requirements as described in the program basis documents. The inspectors also reviewed the periodicity of replacements or refurbishments of EQ program components within the scope of license renewal to verify the licensee had measures in place to replace or refurbish these long-lived components during the PEO.
Reactor Vessel and Internals Structural Integrity Program (UFSAR Section 18.1.30 and Commitment Nos. 22 and 28): The UFSAR supplement stated that: 1) the Reactor Vessel and Internals Structural Integrity Program was credited with ensuring the long-term integrity and safe operation of the reactor vessel and internals components through inspection in accordance with the ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD Program and inspection and flaw evaluation in conformance with the guidelines of the BWRVIP documents, 2) the program included monitoring and control of reactor coolant water chemistry, through the use of the Water Chemistry Program, in accordance with the latest guidelines of the BWRVIP documents, 3) the program had been prepared using BWRVIP-74-A, "BWR Reactor Pressure Vessel Inspection and Flaw Evaluation Guidelines for License Renewal," and was based on the guidance set forth in BWRVIP-94, "BWR Vessel and Internals Project Program Implementation Guide," 4) the scope of the program included aging management of steam dryers and the feedwater spargers, managing the loss of preload due to stress relaxation of the Unit 2 spring-loaded core plate plugs, managing flow blockage due to fouling of the core spray lines and spargers and established inspection criteria for the VT-3 examination of the core shroud repair brackets. The UFSAR supplement contained two enhancements, which stated that prior to the start of the PEO, the program would be enhanced to: 1) incorporate augmented inspections of the top guide using enhanced visual examination or other acceptable inspection methods that will focus on the high fluence region; sample size will be 10% of the affected susceptible area within 12 years of the beginning of the PEO, with 5% being completed within 6 years of the beginning of the PEO including reinspection per BWRVIP-183, and (2) establish inspection criteria for the VT-3 examination of the Core Shroud Repair Brackets.
The inspectors reviewed the licensing basis, program basis documents, administrative and implementing procedures, and license renewal drawings to verify that the program was developed as described in the LRA and the corresponding NRC SER. The inspectors interviewed licensee personnel to discuss the scope of the program and verified that program procedures included requirements as described in the LRA. The inspectors confirmed that the enhancements had been completed as stated in the UFSAR supplement. The inspectors noted that, in accordance with a letter dated February 14, 2013 from the NRC to M. Annacone of Brunswick Steam Electric Plant, the licensee will replace the Unit 2 core plate plugs during the 2015 refueling outage, which is beyond the commencement of the PEO.
The inspectors identified one observation associated with the license renewal controls for the storage of reactor vessel surveillance capsules. This observation is discussed in further details in section 4OA5.3.b.(1) of this report.
Systems Monitoring Program (UFSAR Section 18.1.31 and Commitment No. 23): The Systems Monitoring Program was developed to manage aging effects such as loss of material and cracking for external surfaces of piping, heat exchangers, ductwork, tanks, and other mechanical components within the scope of License Renewal. The UFSAR supplement stated that: 1) specific guidelines for assessing the material condition of components during system walkdowns have been incorporated into administrative controls used to implement the Program, and 2) the aging effects are managed through visual inspection and monitoring of external surfaces. The UFSAR supplement contained one enhancement, which stated that prior to the start of the PEO, a procedure would be developed to implement: 1) inspection of in-scope License Renewal components for identified aging effects, 2) guidelines for establishing inspection frequency requirements, 3) listing of inspection criteria in checklist form, 4) recording of extent of condition during system walkdowns and 5) addressing of appropriate corrective action(s) for degradations discovered.
The inspectors reviewed the licensing basis, program basis documents, and implementing procedures to verify that the program was developed as described in the LRA and the corresponding NRC SER. The inspectors interviewed licensee personnel to discuss the administrative and implementing procedures to verify that these documents effectively implemented the commitment. The inspectors also reviewed a sample of work requests and corrective actions of various structural components to verify that the examination and evaluation of results were performed in accordance with the program implementing procedures. The inspectors confirmed that the enhancement had been completed as stated in the UFSAR supplement.
The inspectors identified one observation associated with the Systems Monitoring Program. This observation is discussed in further details in section 4OA5.1.b.(1)a of this report.
Preventive Maintenance Program (UFSAR Section 18.1.32 and Commitment No.24): The Preventive Maintenance (PM) Program was credited as an existing program which assures that various aging effects are managed for a wide range of components through the use of periodic component replacement, inspections and testing, each of which utilize predetermined criteria to ensure activities are accomplished in an acceptable manner. The UFSAR supplement stated that program activities include: 1) routine internal visual inspections for corrosion of the Demineralized Water Tank, 2) regular monitoring and removal of debris to manage accumulation of sludge, dirt/dust, rust, and other miscellaneous debris in the torus, 3) periodic inspection of high-voltage insulators for water beading on silicone coating and for age related degradation, 4) routine sampling and analysis to address corrosion concerns related to potential water intrusion into lubricating oil in the Service Water Pump Motor Cooler Coils and the Emergency Diesel Engines Lube Oil System, and 5) inspections of floor drains periodically exposed to service water and roof drains exposed to coastal atmospheric conditions to address aging concerns related to potential locally aggressive environments. The UFSAR supplement contained one enhancement, which stated that prior to the start of the PEO, activities would be incorporated into the Program, as needed, to satisfy aging management reviews of components that rely on the PM Program for management of aging effects.
The inspectors reviewed the licensing basis, program basis documents, and implementing procedures to verify that the program was developed as described in the LRA and the corresponding NRC SER. The inspectors interviewed licensee personnel to discuss the administrative and implementing procedures to verify that these documents effectively implemented the commitment. The inspectors also reviewed a sample of work requests, corrective actions of various structural components to verify that the examination and evaluation of results were performed in accordance with the program implementing procedures. The inspectors confirmed that the enhancement had been completed as stated in the UFSAR supplement.
The inspectors identified one observation associated with the Preventive Maintenance Program. This observation is discussed in further details in section 4OA5.1.b.(1)c of this report.
Phase Bus Aging Management Program (UFSAR Section 18.1.33 and Commitment No. 25): The Phase Bus Aging Management Program was developed to manage the aging of in-scope iso-phase and non-segregated phase bus at BSEP. The program description stated that the technical basis for the BSEP License Renewal Phase Bus Aging Management Program is described in report 0BNP-TR-052. The UFSAR supplement stated that: 1) the program involves various activities conducted at least once every 10 years to identify the potential existence of aging degradation, 2) in addition to general cleanliness inspection activities, a sampling of accessible bolted connections will be checked for proper contact resistance while inaccessible bolted connections will be visually inspected for signs of embrittlement, cracking, melting, swelling, or discoloration, which may indicate overheating, 3) the program applies to the iso-phase bus as well as all non-segregated 4.16 KV and 480 V phase bus within the scope of license renewal, 4)industry operating experience has shown that phase bus exposed to appreciable ohmic or ambient heating during operation may experience loosening of bolted connections related to the repeated cycling of connected loads or of the ambient temperature environment, 5) specific program activities include: a) inspecting the interior condition of the bus enclosure for foreign debris, excessive dust build up, and evidence of water intrusion, b) use of the Structures Monitoring Program to inspect the external surfaces of the phase bus housing, and c) checking accessible and inaccessible Phase Bus bolted connections for loose connections by thermography or by measuring connection resistance using a low range ohmmeter on a 10-year frequency, and 6) thermography is performed while the bus is energized and loaded.
The inspectors reviewed the administrative and implementing procedures to verify that the program was as described in the LRA and the corresponding NRC SER. The inspectors interviewed licensee personnel to discuss the administrative and implementing procedures to verify that these documents effectively implemented the commitment. The inspectors also reviewed a sample of work orders and preventive maintenance documents to verify that activities were performed in accordance with the program implementing procedures.
Fuel Pool Girder Tendon Inspection Program (UFSAR Section 18.1.34 and Commitment Nos. 26 and 29): The Fuel Pool Girder Tendon Inspection Program was an existing program developed to manage loss of prestress in the fuel pool girder tendons of each Reactor Building. The program description noted that although these tendons are not associated with the containment pressure boundary and are not within the scope of the ASME Section XI, Subsection IWL Program (UFSAR 18.1.19), the program is conservatively based on guidance within ASME Section XI, Subsection IWL. The UFSAR supplement stated that program activities include visual inspections and physical inspections of tendon prestress, and that inspection results are used to project an estimated loss of prestress through the next inspection period to ensure the tendons' prestress values do not fall below minimum design requirements. The UFSAR supplement contained five enhancements, which stated that prior to the PEO, the program would be enhanced to:
1) specify inspection frequencies, numbers of tendons to be inspected, and requirements for expansion of sample size, 2) identify test requirements and acceptance criteria for tendon lift-off forces, measurement of tendon elongation, and determination of ultimate strength, 3) specify inspections for tendons, tendon anchor assemblies, surrounding concrete, and grease, 4) require prestress values to be trended and compared to projected values, and 5) identify acceptable corrective actions for tendons that fail to meet testing criteria.
The inspectors reviewed the administrative and implementing procedures to verify that the program was as described in the LRA and the corresponding NRC SER. The inspectors interviewed licensee personnel to discuss the administrative and implementing procedures to verify that these documents effectively implemented the commitments. The inspectors also reviewed inspection documentation from the most recent tendon prestress inspection to verify that activities were performed in accordance with the program implementing procedures. The inspectors confirmed that the enhancement had been completed as stated in the UFSAR supplement.
Compressed Air Monitoring Program (UFSAR Section 18.1.35): The Compressed Air Monitoring Program was not an activity described in the LRA. It was developed as a result of ongoing efforts to apply lessons learned from operating experience to license renewal activities. The program was designed to credit existing activities to ensure that instrument air supplied to components is maintained free of water and significant contaminants. These activities included periodic checks on dew point and contaminants, NDE examinations of system air receivers, and periodic and opportunistic inspections of internal surfaces of compressed air systems. The UFSAR supplement was updated to include the Compressed Air Monitoring Program description.
The inspectors reviewed the licensing basis, program basis documents, administrative and implementing procedures to verify that the program was developed consistently with other license renewal programs and the NRC SER. The inspectors interviewed licensee personnel to discuss the program methodology to verify that the program was implemented as described in the UFSAR. The inspectors confirmed that the changes to the UFSAR supplement would be included with the next UFSAR update submitted to the NRC.
RPV Operating Pressure-Temperature (P-T) Limits (UFSAR Section 18.2.1.3 and Commitment No. 27): The TLAA for the RPV Operating Pressure-Temperature Limits required that programmatic controls would be in place such that P-T limit curves for use during the PEO were submitted in a timely fashion. The UFSAR supplement stated that P-T limit curves for use during the PEO of Units 1 and 2 would be submitted for NRC review and approval in accordance with 10 CFR 50.90 at least one year prior to expiration of the 32 effective full power years (EFPY) P-T limit curves that were currently approved in the Brunswick Technical Specifications. Additionally, it stated that if an exemption request to permit the use of ASME Code Case N-640 was required as part of the submittal, an exemption request would be included as part of the license amendment request.
The inspectors reviewed the licensing basis, program basis documents, administrative and implementing procedures, and license renewal drawings to verify that the program was developed as described in the LRA and the corresponding NRC SER. The inspectors interviewed licensee personnel to discuss the scope of the program and verified that program procedures included requirements as described in the LRA. The inspectors noted that the licensee had issued a corrective action document to track the commitment due date such that the new P-T curves would be submitted prior to reaching the 32 EFPY limit. The inspectors also noted that the estimate date the EFPY limit would be reached was January 2019.
Fuel Pool Girder Tendon Loss of Pre-Stress Program, TLAA (UFSAR Section 18.2.6 and Commitment No. 29): The Fuel Pool Girder Tendon Inspection Program (UFSAR 18.1.34) was credited with addressing the TLAA relating to loss of prestress in the Fuel Pool Girders. This program was developed to detect and manage the following aging effects: 1) loss of prestress in tendons, 2) loss of material in tendons (due to corrosion/pitting), 3) other "deleterious conditions" such as corrosion, cracks, and broken or missing wires (applies to tendons and associated concrete/hardware). Calculation 0BNP-TR-045, License Renewal Fuel Pool Girder Tendon Inspection Aging Management Program, Rev. 1 contained the details of the TLAA. This plant-specific program was developed using the regulatory guidance regarding the ten elements of an effective program found in NUREG-1801, Rev. 0.
The inspectors reviewed the administrative and implementing procedures and interviewed licensee personnel to verify the program appropriately addressed the concerns for the TLAA.
Operating Experience Review for Extended Power Uprate Aging Management (Commitment No. 31): Commitment No. 31 stated that an evaluation of plant and industry operating experience will be submitted for NRC review at least one year prior to the PEO and that the purpose of the evaluation will be to assure that relevant aging effects caused by operation at power uprate conditions are adequately addressed by AMPs. This commitment was precipitated by ACRS Report ACRSR-2091 that stated, in part:
"-the staff should require that the applicant conduct an evaluation of operating experience at all four units and at other plants operating at EPU levels, to ensure that this experience has been properly addressed by the aging management programs. The staff should review and approve this evaluation.
Such an evaluation should be required of all license renewal applicants that plan to operate during the license renewal period at EPU levels that are substantially higher than experienced in the bases supporting their license renewal applications. Such an evaluation is consistent with the intent of 10 CFR 54.17(c)that substantial operating experience be reflected in the bases supporting the license renewal application."
This commitment was originally made after the submittal of the LRA, by letter from the licensee, in BSEP 05-0055, Response to Request for Additional Information - License Renewal (NRC TAC Nos. MC4639 and MC4640) see ADAMS Accession No.
ML051370298. On December 17, 2013, BSEP submitted, BSEP 13-0137, License Renewal Commitment Completion Evaluation of Operating Experience at Extended Power Uprate Conditions (ADAMS Accession No. ML14023A594). A Request for Additional Information was made via email on April 25, 2014 (ADAMS Accession No.
ML14115A443) and the response was given on May 25, 2014 (ADAMS Accession No. ML14163A007).
The inspectors reviewed the licensing basis, commitment requirements, and correspondence between the licensee and the NRC for this commitment to verify the commitment was developed as described in the commitment documentation. The inspectors interviewed licensee personnel to discuss the scope of the commitment and verify that actions taken to evaluate the OE for the commitment were comprehensive and specific for the licensee as described in the commitment documentation. The inspectors also reviewed the evaluation of OE specific to the licensee and engineering evaluations of components within OE specific to EPU components.
b. Findings and Observations
(1) Observation for the Bolting Integrity Program (UFSAR Section 18.1.6 and Commitment No. 3), Open-Cycle Cooling Water Program (UFSAR Section 18.1.7 and Commitment No. 4), Systems Monitoring Program (UFSAR Section 18.1.31 and Commitment No. 23), and Preventive Maintenance Program (UFSAR Section 18.1.32 and Commitment No.24): Commitment No. 1 stated that "The elements of the corrective action, confirmation process, and administrative controls in the BSEP Quality Assurance Program will be applied to required aging management activities for both safety related and non-safety related structures and components subject to aging management review." The Definitions section of NGGM-PM-0007, "Quality Assurance Program Manual," defined Acceptance Criteria as "A limit or limits placed on the variation permitted in the characteristics of an item expressed in definitive engineering terms such as dimensional tolerances, chemical composition limits, density and size of defects, temperature ranges, time limits, operating parameters, and other similar characteristics." Three examples were identified where the implementing procedures did not contain clear inspection criteria to ensure that important activities have been satisfactorily accomplished:
a) Example 1, Bolting Integrity Program, Systems Monitoring Program: The Bolting Integrity Program utilized walkdown-type inspections performed under the Systems Monitoring Program to ensure aging mechanisms for non-ASME Code bolting are appropriately managed. Attachment 1 of 0ENP-648, "System Walkdown Procedure" for the Systems Monitoring Program identified several conditions to be observed during these walkdown inspections, but nothing identified what rendered these conditions acceptable or unacceptable. As such, these condition statements did not meet the requirement of a clear inspection criterion, and the potential exists that the inspection could be performed without appropriate inspection criteria being applied to ensure that license renewal requirements are met. b) Example 2, Open-Cycle Cooling Water Program: The Open-Cycle Cooling Water Program utilized the existing NRC GL 89-13 Program to address the aging effects for open-cycle cooling systems in the scope of license renewal. One of the implementing activities was a generic header inspection of Nuclear and Non-Nuclear Service Water, using existing procedures 1PM-MEC502/2PM-MEC501, "Conventional Service Water Header Inspection," and 1PM-MEC506/2PM-MEC505, "Nuclear Service Water Header Inspection." No acceptance criteria were identified in any of these procedures. Discussion in 0BNP-TR-051, "License Renewal Open-Cycle Cooling Water System Aging Management Program," stated that the Open-Cycle Cooling Water Program relied on the GL 89-13 Program Owner to perform these inspections because he/she would have the necessary qualifications to discern the appropriate inspection criteria to ensure license renewal requirements would be met. However, there are no administrative measures in the implementing procedures for either program that ensures that the GL 89-13 Program Owner will be the one performing the inspections. As such, the potential exists that the inspection could be performed without appropriate inspection criteria being applied to ensure that license renewal requirements are met. c) Example 3, Preventive Maintenance Program: The Preventive Maintenance Program addressed certain license renewal inspections for the Demineralized Water Tank ("MUD Tank"). The licensee's process established a Preventive Maintenance ID document (PMID), which in turn established Model Work Order (MWO) 378261, which generates periodic Work Orders (WOs) to accomplish these inspections. The work instructions used to develop the PMID contained detailed inspection criteria to be implemented during the inspections, but these criteria were not translated through the process to the documents which would be used by the craft to actually perform the inspections. As such, the potential exists that the inspection could be performed without appropriate inspection criteria being applied to ensure that license renewal requirements are met. The licensee entered these issues into its corrective action program as CR 703867.
(2) Observation for the Reactor Vessel Surveillance Program (UFSAR Section 18.1.14): The third license condition, listed in NUREG-1856, "Safety Evaluation Report Related to the License Renewal of the Brunswick Steam Electric Plant, Units 1 and 2," required, in part, that, "All capsules placed in storage must be maintained for future insertion. Any changes to storage requirements must be approved by the staff, as required by 10 CFR Part 50, Appendix H." For removal and storage of reactor vessel surveillance capsules at Brunswick, controls were in place to notify reactor engineering as described in Section 6.12 of procedure 0AI-112, "Control of Materials in Spent Fuel Pool," and in notes contained in Section 3.0, 3.6 and Attachment 1 of procedure 0PT-90.8, "Removal of Reactor Material Irradiation Surveillance Specimens." However, these notifications were to reactor engineering only and contained no specific ties to the applicable License Conditions nor was there any notification to or authorization required from the Reactor Vessel Surveillance Program owner to changes in the surveillance capsule storage program. This could potentially allow changes in the storage condition of removed specimens that could be violation of License Conditions O and L (for Units 1 and 2, respectively) and Commitment No. 10. The licensee entered this issue into its corrective action program as CR 703864.
.2 Newly Identified Structures, Systems, and Components
c. Inspection Scope
The inspectors discussed the evaluation of newly identified structures, systems, or components (SSCs) with the licensee's staff to verify compliance with the provisions of 10 CFR 54.37(b). The inspectors reviewed licensee evaluations performed for two newly identified components within the scope of license renewal to verify that aging management review was performed in accordance with 10 CFR 54.37. The inspectors also reviewed a list of plant modifications performed from the time the LRA was submitted to the time the renewed operating license was issued to identify any potentially new SSCs that would have been subject to aging management review at the time the NRC was reviewing the LRA. Additionally, the inspectors reviewed a sample of licensee procedures to verify that adequate guidance was provided to ensure that SSCs with the scope of 10 CFR 54.37(b) were identified, evaluated, and reported.
d. Findings and Observations
No findings were identified.
On the basis of the sample selected for review, the inspectors determined that the licensee took appropriate actions to assure "newly identified" SSCs were identified and evaluated for management of aging affects. Based on the review of licensee self-assessments, the inspectors determined that "newly identified" components had been identified that would have been subject to aging management during the preparation of the original LRA and subsequent revisions. These components were the compressed air systems, and were addressed by the Compressed Air Monitoring Program (UFSAR 18.1.35). The inspectors determined that the licensee performed an aging management review of these structures consistent with the requirement in 10 CFR 54 and included them within the scope of existing AMPs. The licensee also planned to update the UFSAR to include these newly identified SSCs. The inspection team did not identify any other new SSCs that were subject to the provisions of 10 CFR 54.37(b) during the independent review of commitments and AMPs described in section 4OA5.1.a of this report.
.3 Description of Aging Management Programs in the UFSAR Supplement
a. Inspection Scope
As part of the review of implementation activities for the selected AMPs and TLAAs described in section 4OA5.1.a of this report, the inspectors reviewed the corresponding UFSAR sections to verify that the program descriptions were consistent with the LRA and the corresponding section of the NRC SER. The inspectors reviewed three versions of the UFSAR supplement for license renewal as follows:
- The inspectors reviewed the UFSAR supplement submitted with the LRA, as revised, to identify the program attributes and future inspection activities that were originally relied upon for the approval of the renewed operating license.
- The inspectors reviewed the revision of the UFSAR submitted to the NRC pursuant to the requirements in 10 CFR 50.71(e)(4) following the issuance of the renewed operating license to verify that the UFSAR supplement for license renewal was included with the updated FSAR as required by the condition of the renewed operating license.
- The inspectors reviewed the latest revision of the UFSAR supplement for license renewal (Revision 24) to verify that the program attributes and inspection activities were consistent with the AMPs as originally approved by the NRC and subsequent revisions performed under the provisions of 10 CFR 50.59. The inspectors also verified that any changes caused by the inclusion of "newly identified" SSCs were included in the UFSAR supplement.
b. Findings and Observations
With the exception of the observation detailed below, the inspectors determined the UFSAR supplement submitted for license renewal, as revised, was incorporated into the UFSAR. Additionally, the inspectors determined that the UFSAR supplement description matched the AMPs and TLAAs being implemented. The inspectors also determined that changes, caused by the inclusion of "newly identified" SSCs, were scheduled to be included in the next revision of the UFSAR under 10 CFR 50.71(e).
(1) Observation for the Reactor Vessel and Internals Structural Integrity Program (UFSAR Section 18.1.30): Commitment No. 22 stated, in part, "-the scope of the program described in the UFSAR Supplement will be revised to state that-loaded core plate plugs will be managed by replacing the plugs. Any evaluation to extend the service life of the spring-loaded core plate plugs will be submitted to the NRC for review and approval." Section 18.1.30 of the most recent update to the Final Safety Analysis Report stated, in part, "Loss of preload due to stress relaxation of the Unit 2 spring-loaded core plate plugs is managed by replacing the plugs. Per Reference 18-21, NRC approved a commitment revision permitting deferral of the Unit 2 spring-loaded core plate plugs until the Spring 2015 refueling outage if installation problems precluded completion of the replacements during the 2013 refueling outage. Replacement of the Unit 2 spring-loaded core plate plugs was attempted during the 2013 refueling outage, but problems were encountered that precluded completion." The text contained in the UFSAR supplement did not dictate, as the commitment stated, that all future evaluations performed must be submitted to the NRC for review and approval, rather it only listed the prior evaluation that had been submitted. The licensee entered this issue into its corrective action program as CR 703582.
.4 Changes to License Renewal Commitments and the UFSAR Supplement for License Renewal
a. Inspection Scope
As part of the review of license renewal commitments, AMPs, and TLAAs described in section 4OA5.1.a of this report, the inspectors reviewed license renewal commitment change documents to verify the licensee followed the guidance in NEI 99-04, "Guidelines for Managing NRC Commitment Changes," for any change to the commitments, including their elimination. The inspectors verified that the licensee properly evaluated, reported, and approved where necessary, changes to license renewal commitments listed in the UFSAR in accordance with 10 CFR 50.59. The inspectors also reviewed the licensee's procedures for commitment revision to obtain reasonable assurance that future changes to regulatory commitments would follow the guidance in NEI 99-04, and would properly evaluate, report, and approve changes to license renewal commitments listed in the UFSAR in accordance with 10 CFR 50.59.
b. Findings and Observations
The renewed operating licenses for Brunswick Steam Electric Plant Unit 1, Condition M and Unit 2, Condition J, stated in part that the revised UFSAR supplement submitted with the LRA shall be included in the next scheduled update to the UFSAR required by 10 CFR 50.71(e)(4) following the issuance of the renewed operating license. Until that update is complete, the license conditions for each Unit allowed the licensee to make changes to the programs and activities described in the supplement without prior Commission approval, provided that Brunswick evaluates such changes pursuant to the criteria set forth in 10 CFR 50.59 and otherwise complies with the requirements in that section. On the basis of the sample selected for review, the inspectors determined that the licensee followed the established plant procedures to modify license renewal commitments, which referenced the guidance in NEI 99-04. Commitment changes were implemented against the guidance in NEI 99-04 and formal notification was submitted to the NRC where applicable. The inspectors also identified that the licensee made changes to the UFSAR supplement after the renewed license was issued, but prior to the next update required by 10 CFR 50.71(e)(4). The inspectors determined that the UFSAR changes were evaluated pursuant to the criteria set forth in 10 CFR 50.59.
4OA6 Management Meetings
Exit Meeting Summary On August 21, 2014, the inspectors presented the inspection results to Mr. George Hamrick, Site Vice President, and other members of the licensee staff. The licensee acknowledged the issues presented. The inspectors confirmed that none of the potential report input discussed was considered proprietary. Proprietary material received during the inspection was returned to the licensee. ATTACHMENT:
SUPPLEMENTARY INFORMATION
KEY POINTS OF CONTACT
Licensee personnel
- C. Cruz, Engineering Programs
- L. Grzeck, Site Licensing Supervisor
- J. Lane, License Renewal Engineer
- C. Mallner, License Renewal Engineer
- R. F. Rich, Site License Renewal Program Owner
- R. Zambo, Site Licensing Engineer
NRC personnel
- M. Catts, Senior Resident Inspector, Brunswick Steam Electric Plant
LIST OF ITEMS OPENED, CLOSED, DISCUSSED AND UPDATED
Opened
None
Closed
- None
Discussed
None Updated
None
LIST OF DOCUMENTS REVIEWED
- - document generated during the inspection
- Quality Assurance Program (UFSAR Section 18.1 and Commitment No. 1) *CR
- 704042, NRC Concern: Quality Assurance Program Connection to License Renewal Programs
- 179954-03, Self-Assessment Report: BSEP License Renewal (LR) Implementation, Rev. 3
- AD-DC-ALL-0201, Development and Maintenance of Controlled Procedure Manual Procedures, Rev. 9
- AD-EG-ALL-1650, License Renewal Aging Management, Rev. 1
- CAP-NGGC-0200, Condition Identification and Screening Process, Rev. 39
- CAP-NGGC-0205, Condition Evaluation and Corrective Action Process, Rev. 18
- NGGM-PM-0007, Quality Assurance Program Manual, Rev. 21
- ASME Section XI, Inservice Inspection, Subsections IWB, IWC, and IWD Program (UFSAR Section 18.1.1) 0BNP-PM003, BNP Fourth Ten-Year ISI Inspection Program, Rev. 1 0BNP-TR-030, License Renewal ASME Section XI, Subsection IWB, IWC and IWD Program, Rev. 1 0ENP-016, Procedure for Administrative Control of Inservice Inspection Activities, Rev. 46
- BNP-LR-606, License Renewal Aging Management Program Description of the ASME Section XI, Subsection IWB, IWC and IWD Program, Rev. 2
- WO 1040369-01, Flange 2-B21-F013H Bolting, dated 4/8/2013
- WO 2216800, Valve 2-B21-F032A Internals, dated 3/22/13
- Water Chemistry Program (UFSAR Section 18.1.2) 0AI-81, Water Chemistry Guidelines, Rev. 70 0BNP-TR-062, License Renewal Water Chemistry Aging Management Program, Rev. 0 0E&RC-1000, Sampling and Analysis for Technical, ODCM and TRM Specifications Chemistry, Rev. 56 0E&RC-1001, Sampling and Analysis for Non-Regulatory Specification Chemistry, Rev. 45
- 0E&RC-1005, Collection of Routine and Non-Routine Aqueous Samples, Rev. 39
- 0E&RC-1700, Verification of Analytical Performance, Rev. 29
- BNP-LR-600, License Renewal Aging Management Program Description of the Water Chemistry Program, Rev. 4
- Reactor Head Closure Studs Program (UFSAR Section 18.1.3): 0BNP-TR-056, License Renewal Reactor Head Closure Studs Program, Rev. 0
- BNP-LR-0619, License Renewal Aging Management Program Description of the Reactor Head Closure Studs Program, Rev. 0
- BWR Stress Corrosion Cracking Program (UFSAR Section 18.1.4) 0BNP-TR-035, License Renewal BWR Stress Corrosion Cracking Aging Management Program, Rev. 0 0ENP-16.2, Administrative Control of ASME Section XI Non-Destructive Examination Program, Rev. 21
- BNP-LR-654, License Renewal Aging Management Program Description of the BWR Stress Corrosion Cracking Program, Rev. 1
- Flow-Accelerated Corrosion Program (UFSAR Section 18.1.5 and Commitment No. 2) 0132-00142-01, Calculation: "Brunswick Units 1 and 2 Systems Elimination Calculation for Flow Accelerated Corrosion Monitoring Program," ABB IMPELL Corporation, dated April 28, 1993 0BNP-TR-043, License Renewal Flow Accelerated Corrosion Aging Management Program, Rev. 1
- AD-EG-ALL-1610, Flow Accelerated Corrosion Implementation, Rev. 0
- BNP-LR-603, License Renewal Aging Management Program Description of the Flow-Accelerated Corrosion (FAC) Program, Rev. 1
- EGR-NGGC-0202, Flow Accelerated Corrosion Monitoring Program, Rev. 8
- Bolting Integrity Program (UFSAR Section 18.1.6 and Commitment No. 3) 0BNP-PM-003, Brunswick Steam Electric Plant, Unit No. 1 & 2 Fourth Ten-Year Interval Inservice Inspection Program, Rev. 1 0BNP-TR-030, License Renewal ASME Section XI, Subsection IWB, IWC and IWD Aging Management Program, Rev. 1 0BNP-TR-033, License Renewal Bolting Integrity Aging Management Program, Rev. 1
- 0BNP-TR-061, License Renewal Systems Monitoring Aging Management Program, Rev. 1 0ENP-16, Procedure for Administrative Control of Inservice Inspection Activities, Rev. 46
- 0MMM-017, Maintenance Methods and Guidelines for Torquing, Rev. 40
- AR 00704138, Review of License Renewal Bolting Aging Management
- BNP-LR-625, License Renewal Aging Management Program Description of the Bolting Integrity Program, Rev. 1
- CHE-NGGC-0045, NGG Chemical Control Program, Rev. 18
- EGR-NGGC-0005, Engineering Change,
- EGR-NGGC-0204, Evaluation and Selection of Materials for Plant Components,
- Open-Cycle Cooling Water System Program (UFSAR Section 18.1.7 and Commitment No. 4) 0AI-86, Service/Circulating Water Treatment Strategic Plan, Rev. 8
- 0BNP-TR-051, License Renewal Open Cycle Cooling Water System Aging Management Program, Rev. 02 0ENP-2704, Administrative Control of NRC Generic Letter 89-13 Requirements, Rev. 23 0ENP-2705, Emergency Diesel Generator Jacket Water Cooler Heat Exchanger Thermal Performance Testing, Rev. 7 0MST-DG500R, Emergency Diesel Generators 24 Month Inspection, Rev. 39
- 1PM-MEC502, Conventional Service Water Header Inspection, Rev. 15
- 1PM-MEC506, Nuclear Service Water Header Inspection, Rev. 11 2PM-MEC501, Nuclear Service Water Header Inspection, Rev. 16 2PM-MEC505, Conventional Service Water Header Inspection, Rev. 8
- BNP-LR-602, License Renewal Aging Management Program Description of the Open Cycle Cooling Water System Program, Rev. 3
- WO 0859297-06, U/1 Outage Conventional Service Water Header Piping Inspection, dated 3/30/10
- Closed-Cycle Cooling Water System Program (UFSAR Section 18.1.8 and Commitment 5) 0AI-82, Closed Cooling Water Chemistry Guidelines, Rev. 10
- 0AI-88, Closed Cooling Water Strategic Plan, Rev. 10
- 0BNP-TR-036, License Renewal Closed Cycle Cooling Water System Aging Management Program, Rev. 01 0E&RC-1001, Sampling and Analysis for Non-Regulatory Specification Chemistry, Rev. 46
- 0MST-DG501R3, Emergency Diesel Generators 72 Month Inspection, Rev. 34BNP-LR-627, License Renewal Aging Management Program Description of the Closed Cycle Cooling Water System Program, Rev. 02
- WO 01856747-01, 2-DG1-ENG, Perform 72 Month MST IAW 0MST-DG501R3, dated 10/15/12
- Inspection of Overhead Heavy Load and Light Load Handling Systems Program (USFAR Section 18.1.9 and Commitment No. 6) 0BNP-TR-047, License Renewal Inspection of Overhead Heavy Load And Light Load Handling Systems Program, Rev. 0 0PM-CRN501, PM for the Fixed Gantry and Track Cranes, Rev. 37 0PM-CRN502, Maintenance Instructions for the Stearns-Roger Refueling Platform, Rev. 19
- BNP-LR-628, License Renewal Aging Management Program Description of the Inspection of Overhead Heavy Load and Light Load Handling Systems Program, Rev. 0
- EGR-NGGC-0351, Condition Monitoring of Structures, Rev. 21
- WO 01906916-01, 2-F15-E003-BRIDGE, dated 11/7/12
- WO 02169767, 1-BC-RB-BRIDGE-CRANE, dated 1/16/14
- Fire Protection Program (UFSAR Section 18.1.10) 0AP-033, Fire Protection Program Manual, Rev. 15 0BNP-TR-041, License Renewal Fire Protection Program, Rev. 0 0MST-DP500R, Diesel Fire Pump P1 Engine Drive Annual Inspection, Rev. 10
- 0PLP-01.2, Fire Protection System Operability, Action, and Surveillance Requirements, Rev. 42
- 0PT-34.1.1.0, Fire Pump Test (Electric and Diesel), Rev. 25
- 0PT-34.15.9.7, Cable and Conduit Fire Barriers, Rev. 24
- 0PT-34.2.2.1, Fire Door, Pressure Boundary Door, ASSD Access/Egress Door, and Severe Weather/Flood Control Door Inspections, Rev. 49 0PT-34.4.2.0, Carbon Dioxide Cylinder Weight Verification, Rev. 18
- 0PT-34.4.2.1, Diesel Generator Building Halon Fire Extinguishing Systems Liquid Level and Cylinder Pressure Verification, Rev. 7 0PT-34.5.5.0, Diesel and Electric Fire Pump Functional Test, Rev. 32 0PT-34.5.6.0, Diesel Generator Building Halon System Functional Test, Rev. 11 0PT-34.6.7.1, Rollup Fire Door Test, Rev. 14
- 0PT-34.6.7.10, Fire Barrier Penetration Seals Diesel Generator Building, Rev. 17
- 0PT-34.6.7.12, Fire Barrier Penetration Seals Augmented Off-Gas Building, Rev. 19
- 0PT-34.6.7.2, Miscellaneous Fire Barriers, Fire Doors, Hatches, and Panels, Rev. 21
- 0PT-34.6.7.7, Fire Barrier Penetration Seals Service Water Intake Structure, Rev. 17 0PT-34.6.7.8, Fire Barrier Penetration Seals Control Building, Rev. 20 1PT-34.5.3.1, HPCI High Pressure CO2 Operability Test, Rev. 27
- 1PT-34.6.7.5, Fire Barrier Penetration Seals Reactor/Turbine Buildings, Rev. 17
- 2PT-34.6.7.6, Fire Barrier Penetration Seals Reactor/Turbine Buildings, Rev. 17
- BNP-LR-612, License Renewal Aging Management Program Description of the Fire Protection Program, Rev. 2
- EGR-NGGC-0351, Condition Monitoring Of Structures, Rev. 21
- PT-34.6.7.1, Roll Up Fire Door Inspection, dated 12/21/12
- WO 2208441-02, 2-FP-P1-ENG: DG Run and General Inspection, dated 1/21/14
- Fire Water Systems Program (UFSAR Section 18.1.11 and Commitment No. 7) *CR
- 703867, Incorporation of Procedural Guidance in LR Work Orders
- BNP-LR-611, License Renewal Aging Management Program Description of the Fire Water System Program, Rev. 6
- BNP-TR-042 - License Renewal Fire Water System Program, Rev. 1 BSEP 05-0097, Clarification of Responses to Requests for Additional Information -License Renewal (NRC TAC Nos. MC4639 & MC4640), dated July 18, 2005
- CR 533690, NRC Information Notice 2012-06: Ineffective Use of Vendor Technical Recommendations
- CR 586280, NRC Information Notice 2012-22, Counterfeit, Fraudulent, Suspect Items (CFSI) Training Offerings
- CR 596852, IN2013-02 Issues Potentially Affecting Nuclear Facility Fire Safety
- CR 617110, T Measured Fell Below T Acceptable Limit
- CR 619625, Through Wall Leak on the Fire Header to Foam Supply System
- CR 692215, Jockey Fire Pump Degraded and Unable to Meet Normal System Pressure
- EPRI Performance Demonstration Initiative Program Certification:
- PDI-UT-1 (Lininger)
- EPRI Performance Demonstration Initiative Program Certification:
- PDI-UT-2 (Lininger)
- NDEP-0408, Ultrasonic Thickness Measurement (A-scan), Rev. 14 NFPA 25, Standard for the Inspection, Testing, and Maintenance of Water-Based Fire Protection Systems, 1998 Edition
- OPT-34.1.1.0, Fire Pump Test (Electric and Diesel), Rev. 26
- PLP-01.1, Fire Protection Commitment Document, Rev. 38
- PLP-01.2, Fire Protection System Operability, Action, and Surveillance Requirements, Rev. 43
- PMR 500962-11, Sprinkler Head Replacement
- PMR 630550, Generate PMRQ to Test Remaining Fire Water Sprinkler Head
- PMR 670458, Revise Inspection to Correct NDE Request Form to Reflect Correct Thickness Progress Energy Brunswick Plant NDE Personnel Qualification/Certification Review Form (Bjerke)
- PT-34.11.1.0, Hydrant and Sprinkler Gauge Pressure Inspection, Rev. 20
- PT-34.13.1.0, Dry Barrel Hydrant Test, Rev. 23
- PT-34.5.2.1, Fire Hose Station Inspection, Rev. 17
- PT-34.8.1.0, Fire Hose Service/Hydrostatic Testing, Rev. 24
- WO 13387087-02, Ultrasonic Thickness Measurements
- WO 2061894, Fire Hose Service/Hydrostatic Testing (OPT-34.8.10, Rev. 23)
- WO 2062606-02, Ultrasonic Thickness NDE Report
- WO 2092800-01, License Renewal/Replace Sprinkler Heads
- WO 2197173-01, Hydrant and Sprinkler Gauge Pressure Inspection (OPT-34.11.1.0, Rev. 20)
- WO 2230207-01, Fire Hose Station Inspection (OPT-34.5.2.1, Rev. 17)
- WO 2255046-01, Dry Barrel Hydrant Test (OPT-34.13.10, Rev. 23)
- WO 2263778, LR System Engineer Review NDE Results Fire Prot. Water Piping
- WO 2263926-01, System Engineer Review NDE Results
- WO 278547-02, 1-FP-DV12-A Deluge Valve Tripped
- WO 68709-02, Ultrasonic Thickness Measurements
- Aboveground Carbon Steel Tanks Program (UFSAR Section 18.1.12 and Commitment No. 8) *CR
- 703861, UFSAR Chapter 18 Program Description Inconsistencies
- BNP-LR-630, License Renewal Aging Management Program Description of the Above Ground Carbon Steel Tanks Program, Rev. 1
- BNP-TR-029, License Renewal Above Ground Carbon Steel Tanks Program, Rev. 1
- BNP-TR-061, License Renewal Systems Monitoring Program, Rev. 1
- CR 236595, Degraded Unit 2 CST Coating
- CR 496748, Degraded FWST Coating
- EC 6268, MFOST Corrosion Evaluation
- EPRI Performance Demonstration Initiative Program Certification:
- PDI-UT-1 (Lininger)
- EPRI Performance Demonstration Initiative Program Certification:
- PDI-UT-2 (Lininger)
- ER 68260R0, 7-day Fuel Oil Storage Tank (FOST) Corrosion Evaluation
- LTAM
- BNP-10-0090, License Renewal - Fire Protection Storage Tank Examination
- NDEP-0408, Ultrasonic Thickness Measurement (A-scan), Rev. 14 PMID 37230, 2-DW-DEM-WTR-Storage-Tank:Internal Tank Inspection PMID 6861, Fire Water Tank: Perform 1 year Internal Tank Inspection
- PMR 250751, Corrosion Identified on bottom of 7 day FO Tank Progress Energy Brunswick Plant NDE Personnel Qualification/Certification Review Form (Bjerke)
- WO 1016690, MFOST Inspection
- WO 13363505-01, Perform 1 year Internal Tank Inspection, FPT
- WO 13363505-05, Perform 1 year Internal Tank Inspection, FPT
- WO 2072506, FWST Internal Inspection
- WR 793856, 2-DW-DEM-WTR-Storage-Tank: 10 year Internal Inspection Fuel Oil Chemistry Program (UFSAR Section 18.1.13 and Commitment 9):
- 0BNP-TR-044, License Renewal Fuel Oil Chemistry Aging Management Program, Rev. 1 0E&RC-1010, Diesel Fuel Oil Testing Program, Rev. 45
- BNP-LR-631, License Renewal Aging Management Program Description of the Fuel Oil Chemistry Program, Rev. 4
- CR 164345, LCO Arising from High Particulates
- EC 88819, One-Time Inspections for Fuel Oil, Rev. 1
- Reactor Vessel Surveillance Program (UFSAR Section 18.1.14 and Commitment No. 10) *CR
- 703582, UFSAR Chapter 18 Level of Detail
- CR
- 703859, UFSAR Supplement: Core Plate Plugs *CR
- 703864, Reactor Vessel Surveillance Capsule Management 001N6537, Calculation: Brunswick Unit 2 Extended Life Core Support Plug Interference Study, Rev. 0 0BNP-TR-058, License Renewal Reactor Vessel Surveillance Program, Rev. 0
- 0ENP-15, Reactor Vessel & Internals Structural Integrity Program, Rev. 11
- 0ENP-15, Reactor Vessel & Internals Structural Integrity Program, Rev. 11 223D5497, Drawing: Plug Core Support Plate, Rev. 3
- BNP-LR-613, License Renewal Aging Management Program Description of the Reactor Vessel Surveillance Program, Rev. 2 BWRVIP Letter 2014-073, from Bob Carter, EPRI, BWRVIP Assessment Task Manager to John Becker, Manager Engineering Programs, Transmittal of New BWRVIP Integrated Surveillance Program (ISP) Data Applicable to Brunswick Units 1 and 2, dated May 15, 2014 Letter from Sher Bahadur (Division of Policy and Rulemaking, Office of Nuclear Reactor Regulation) to Dennis Madison (Chairman, BWR Vessel and Internals Project), Subject:
- U.S. Nuclear Regulatory Commission Approval Letter for "BWRVIP [Boiling Water Reactor
(BWR) Vessel Integrity Program]-86, Revision 1 A: Updated BWR Integrated Surveillance Program [(ISP)] Implementation Plan" (TAC NO. MF2154), dated March 26, 2014 (ADAMS Accession No. ML13168A073)
- One-Time Inspection Program (UFSAR Section 18.1.15 and Commitment Nos. 11 and 30) 0BNP-TR-018, Reactor Pressure Vessel & Internals Inspection Plan, Rev. 6
- 0ENP-649, One Time Inspection Program, Rev.5
- BNP-611234-49-M02, Calculation: Torus Internal Structural Component Evaluations for 60 Year Plant Life, Rev. 1
- BNP-LR-312, License Renewal Aging Management Review Reactor Coolant Recirculation System (2020), Rev. 1
- BNP-LR-632, License Renewal Aging Management Program Description of the One Time Inspection Program, Rev. 4
- CR 326294, Significant Flow Erosion Found During One Time Inspection
- CR 387576, Unit 1 HPCI Torus Suction Strainer Found Damaged
- CR 481805, One Time Inspection Finding -
- WO 1387886 FOR 2-SCW-2B-STR
- CR 695927, Corrosion of Torus Internal Components
- EC 88819, Evaluation of License Renewal One Time Inspection Program Results, Rev. 1
- Selective Leaching of Materials Program (UFSAR Section 18.1.16 and Commitment No. 12) 0ENP-650, Selective Leaching Inspection Program, Rev. 8
- BNP-LR-633, License Renewal Aging Management Program Description of the Selective Leaching of Materials Program, Rev. 2
- CR 674835, Potential Vulnerabilities in Selective Leaching Program Identified during NRC Phase I Inspection ESG0091N, Selective Leaching Inspection Training Guide, Rev. 2
- Buried Piping and Tanks Inspection Program (UFSAR Section 18.1.17 and Commitment No. 13) 0BNP-TR-034, License Renewal Buried Piping and Tanks Inspection Program, Rev. 1
- AD-EG-ALL-1613, Buried Piping Integrity Program Implementation, Rev. 0
- BNP-LR-634, License Renewal Aging Management Program Description of the BP and Tanks Inspection Program
- Buried Piping and Tanks Inspection Program Datasheet, CST Gravity Feed Supply Line to HPCI & RCIC, 1-C0-38-16-C-7, dated 3/13/2012 Buried Piping and Tanks Inspection Program Datasheet, pipe 2-FP-1-10-J-1, 5/22/2012 Buried Piping and Tanks Inspection Program Datasheet, pipe 2-FP-1-12-8-J-1, 5/22/2012
- Buried Piping and Tanks Inspection Program Datasheet, pipe 2-FP-1-27-6-J-1, 5/22/2012
- Buried Piping and Tanks Inspection Program Datasheet, Standby Gas Treatment Main Line to Stack, 1-SGT -7 -24-159A, dated 3/11/2012 Buried Piping and Tanks Inspection Program Datasheet, Unit 1 Service Water Nuclear Header, 1-SW-103-30-157, dated 11/13/2012 Buried Piping and Tanks Inspection Program Datasheet, valve 2-PIV-1, 5/22/2012
- CR 523279, Guided Wave Screening of SW Piping
- CR 674832, Buried Piping Program Observations from IP71003, Phase 1
- CR 676402, Fire Protection Ring Header Corrective Actions
- CR 683260-28, Complete Confirmatory Visual Exams on 1-SW-103-30-157
- EC 78689, Impressed Current Cathodic Protection System for Underground Piping
- MNT-NGGC-0024, Excavation and Backfill Procedure, Rev. 5
- 102346, LR, Buried Pipe Program Engineer Create 10 Year Inspection Program
- WO 1715994, Line as Shown per Sketch
- SK-75312-M-2100
- WO 2119085, Buried Piping Program Inspection of Pipe 1-SW-199-30-157
- WO 2288442, Buried Pipe Program Engineer Create 10 Year Inspection Program
- ASME Section XI, Subsection IWE Program (UFSAR Section 18.1.18) 0BNP-TR-031, License Renewal ASME Section XI, Subsection IWE Program, Rev. 0
- 0ENP-16, Procedure for Administrative Control of Inservice Inspection Activities, Rev. 24 0PT-20.5.1, Primary Containment Inspection, Rev. 17 B221R1, BNP Unit 2 Containment Inspection Report, dated 3/20/13
- BNP-LR-616, License Renewal Aging Management Program Description of the ASME Section XI, Subsection IWE Program, Rev. 1
- EGR-NGGC-0015, Containment Inspection Program, Rev. 5
- ASME Section XI, Subsection IWL Program (UFSAR Section 18.1.19) 0BNP-TR-064, License Renewal ASME Section XI, Subsection IWL Program, Rev. 0
- 0ENP-16, Procedure for Administrative Control of Inservice Inspection Activities, Rev. 24
- 0PT-20.5.1, Primary Containment Inspection, Rev. 17
- B221R1, BNP Unit 2 Containment Inspection Report, dated 3/20/13
- BNP-LR-617, License Renewal Aging Management Program Description of the ASME Section XI, Subsection IWL Program, Rev. 1
- EGR-NGGC-0015, Containment Inspection Program, Rev. 5
- ASME Section XI, Subsection IWF Program (UFSAR Section 18.1.20 and Commitment No. 14) 0BNP-PM-003, Fourth Ten-Year Interval Inservice Inspection Program, Rev. 1
- 0BNP-TR-032, License Renewal ASME Section XI, Subsection IWF Program, Rev. 0
- 0ENP-16, Procedure for Administrative Control of Inservice Inspection Activities, Rev. 24
- 1BNP-PM-001, Unit 1 Fourth Ten-Year Interval Inservice Inspection Plan, Rev. 3
- 2BNP-PM-002, Unit 2 Fourth Ten-Year Interval Inservice Inspection Plan, Rev. 2
- BNP-LR-618, License Renewal Aging Management Program Description of the ASME Section XI, Subsection IWF Program, Rev. 0
- WO 1313034, Strut A1(b), dated 4/27/08
- WO 1325415, Strut F2 Half and Full Support, dated 3/18/09
- CFR 50, Appendix J Program (UFSAR Section 18.1.21) 0BNP-TR-028, License Renewal 10
- CFR 50 Appendix J Program, Rev. 0 0ENP-16.8, Containment Leakage Tracking, Rev. 28
- B119R1, Local Leak Rate Outage Summary Report, dated 7/12/12
- B219R1, Local Leak Rate Outage Summary Report, dated 5/11/09
- BNP-LR-615, License Renewal Aging Management Program Description of the 10
- CFR 50 Appendix J Program, Rev 0.
- EGR-NGGC-0015, Containment Inspection Program, Rev. 5
- Masonry Wall Program (UFSAR Section 18.1.22 and Commitment No. 15) 0BNP-TR-009, Duke Energy, Brunswick Nuclear Plant: Maintenance Rule Structural Walkdown Technical Report, Rev. 5 AR16469, Cracked Concrete at the SWB BNP Common System Health Report - Plant Buildings; Period: Q3-2013
- Structures Monitoring Program (UFSAR Section 18.1.23 and Commitment No. 16) 0BNP-TR-009, Duke Energy, Brunswick Nuclear Plant: Maintenance Rule Structural Walkdown Technical Report, Rev. 5 0E&RC-3250, Brunswick Nuclear Plant, Plant Operating Manual, Volume III, Environmental and Radiation Control; Groundwater Monitoring Program, Rev. 34 0E&RC-3295, Brunswick Nuclear Plant, Plant Operating Manual, Volume III, Environmental and Radiation Control; Intake Canal Monitoring, Rev.29
- AR11638131, Corrosion on Halon Tank Support, dated 8/7/14 AR16469, Cracked Concrete at the SWB
- BNP-LR-608, Nuclear Generation Group, Section 7.2,
- NUREG-1801 Consistency Review Brunswick Nuclear Plant Unit 1 & 2, 0BNP-TR-060, License Renewal Structures Monitoring Program, Rev. 0 Unit 1 Intake Canal Health Report, week of 1/2/12
- WO 00838819-01 (LR), Unit 1, Zone
- DW1-1,
- EGR-NGGC-0153 Inspection, dated 3/5/12
- WO 00838819-01 (LR), Unit 1, Zone
- DW1-1,
- EGR-NGGC-0351 Inspection, dated 3/5/12
- WO 01788328-01, (LR) Zone: Diesel Generator Building, Miscellaneous Structures and structural supports, dated 1/17/12
- Protective Coating Monitoring and Maintenance Program (UFSAR Section 18.1.24 and Commitment No. 17): 0BNP-TR-054, License Renewal Protective Coating Monitoring and Maintenance Aging Management Program, Rev. 0 0MISCEL-1027, Calculation: RHR/CS Strainer Debris Head Loss Analysis Post-LOCA, Rev. 6
- 0PT-20.5.1, Primary Containment Inspection, Rev. 24
- B117R1, Work Order Close Out for
- WO 859339-01, "Eng Monitor Drywell Service Level I Coatings," dated 4/21/08 B120R1, Work Order Close Out for
- WO 02076221, "Eng Monitor Drywell Service Level I Coatings," dated 2014.03.24
- BNP-LR-639, License Renewal Aging Management Program Description of the Protective Coating Monitoring and Maintenance Program, Rev. 0
- EGR-NGGC-0023, Primary Containment Coatings Condition Assessment, Rev. 5 ESG0032N, Common ESP Training Guide: Coatings Program Manager, Rev. 4
- Electrical Cables and Connections Not Subject to 10
- CFR 50.49 Environmental Qualification Requirements Program (UFSAR Section 18.1.25 and Commitment No. 18)
- AD-EG-ALL-1202, Preventive Maintenance and Surveillance Testing Administration, Rev. 0
- AR 00700866, E5-E6 Crosstie Bus Finding, dated 7/31/14
- OPM-NSB001, Duke Energy, Brunswick Unit 0, Preventive Maintenance Procedure, Inspection and Cleaning non-Segregated Buses, Rev. 8
- WO 01915667 03 (LR) PM the 2-E7-E8 Crosstie Connection NSB, PM the 1-2-E7-E8 Crosstie Connection Unit 1 IAW
- OPM-NSB001 due by 12/28/12
- WO 01915668 01 (LR) PM the 2-E3-E4 Crosstie Connection NSB, PM the 2-E3-E4 Crosstie Connection Unit 1 IAW
- OPM-NSB001 due by 12/28/12
- WO 02159583 01 (LR) PM the 1-E1-E2 Crosstie Connection NSB, PM the 1-E1-E2 Crosstie Connection Unit 1 IAW
- OPM-NSB001 due by 9/10/14
- WO 0219584 01 (LR) PM the E5-E6 Crosstie Connection, PM the 1-E5-E6 Crosstie Connection ON NSB IAW
- OPM-NSB001 due by 6/5/14
- Electrical Cables Not Subject to 10
- CFR 50.49 Environmental Qualification Program Requirements Used in Instrumentation Circuits Program (UFSAR Section 18.1.26 and Commitment No. 19)
- AR 00680363, 4/6/14, 1 APRM, 2 LPRMS that Require Repair (Cable Failure)
- BSEP Unit 1, Neutron Monitoring System Health Report, Period: Q2-2014
- BSEP Unit 2, Neutron Monitoring System Health Report, Period: Q2-2014 PDQ Qualification Verification for Instrumentation Technicians, dated 10/7/13
- Inaccessible Medium Voltage Cables Not Subject to 10
- CFR 50.49 Environmental Qualification Requirements Program (UFSAR Section 18.1.27 and Commitment No. 20) *CR703866, NRC Concern: Non-EQ Instrument Cables (E2) Program
- WO 01882192 03, 1-SW-1A-CONV-PMP-M
- WETED CABLE TAN EL: NOTIFY ENG - ONE
- Reactor Coolant Pressure Boundary Fatigue Monitoring Program (UFSAR Section 18.1.28 and Commitment No. 21): 0B11-0050, Calculation: Update of the Reactor Pressure Vessel (RPV) Component Fatigue CUF for Brunswick Units 1 & 2, Rev. 2 0BNP-TR-055, License Renewal Reactor Coolant Pressure Boundary (CRPB) Fatigue Monitoring Aging Management Program, Rev. 0 0ENP-44, Reactor Pressure Vessel Component Fatigue Monitoring Program, Rev. 10
- BNP-LR-605, License Renewal Aging Management Program Description of the Reactor Coolant Pressure Boundary Fatigue Monitoring Program, Rev. 1
- Environmental Qualification Program (UFSAR 18.1.29) 0BNP-TR-040, License Renewal Environmental Qualification Aging Management Program, Rev. 1
- BNP-LR-650, License Renewal Aging Management Program Description of the EQ Program, Rev. 0
- CR 603682, EQ Program Self-Assessment of Brunswick Nuclear Plant (BNP)
- EGR-NGGC-0156, Environmental Qualification of Electrical Equipment Important to Safety, Rev. 18 EQ PMIDs by Equipment - BNP, dated 8/19/2014
- Reactor Vessel and Internals Structural Integrity Program (UFSAR Section 18.1.30 and Commitment Nos. 22 and 28) *CR
- 703582, UFSAR Chapter 18 Level of Detail
- 0BNP-TR-013, Basis Document for Reactor Pressure Vessel & Internals, Rev. 8
- 0BNP-TR-018, Reactor Pressure Vessel & Internals Inspection Plan, Rev. 6 0ENP-15, Reactor Vessel & Internals Structural Integrity Program, Rev. 11 0PT-90.1, Vessel Internal Component Remote Examinations, Rev. 38
- Systems Monitoring Program (UFSAR Section 18.1.31 and Commitment No. 23): *CR
- 703867, Incorporation of Procedural Guidance in LR Work Orders
- AD-EG-ALL-1202, Preventive Maintenance and Surveillance Testing Administration, Rev. 0
- BNP-LR-640, License Renewal Aging Management Program Description of the Systems Monitoring Program, dated 7/7/2005
- BNP-TR-061, License Renewal Systems Monitoring Aging Management Program, Rev. 1
- CR 647701, System Walkdowns May Not Include 100% of the System Components
- CR 687605, Poor Housekeeping in the MWT Building
- CR 687628, Material Condition Issues in the MWT Building
- ENP-648, System Walkdown Procedure, Rev. 7
- 104347, Engineering Quarterly Systems Walkdown
- PMR 694659, Quarterly Review of System Walkdown Reports Systems Health Report for Fire Protection System, dated 4/1-6/30/2014
- Systems Health Report for Residual Heat Removal System, dated 4/1-6/30/2014 Systems Monitoring Walkdowns for Fire Protection System, dated 5/15/2014 Systems Monitoring Walkdowns for Residual Heat Removal System, dated 7/23/2014
- WO 13402350, MWT/Diesel Fire Pump Room Paint Touch-Up Components
- WR 11626649, 2-FO-V122 is Leaking by and Allowing Fuel to Leak onto Floor Preventive Maintenance Program (UFSAR Section 18.1.32 and Commitment No.24) *CR
- 703867, Incorporation of Procedural Guidance in LR Work Orders
- BNP-LR-642, License Renewal Aging Management Program Description of the Preventive Maintenance Program, Rev. 4
- BNP-TR-053, License Renewal Preventive Maintenance Program, Rev. 1
- EC 88819, Evaluation of License Renewal One-Time Inspection Program Results
- PMID 45999, Inspection of Roof Drains for License Renewal
- PMID 72558, U-1 License Renewal Silicone Test H-V Sat
- PMID 88258-01, LR, 1-C11-FO-D007A, Replace F/O, Sleeve & Original Pipe PMID 90750, Unit 1 Inspect the Torus for the Sludge Generation Rate PMID104347, LR Engr Supervisor AX3 Create Quarterly Report for each Systems
- WO 1639611-04, 1-C11-FO-D007A, Replace F/O, Sleeve & Original Pipe
- WO 1773538-01, U-1 License Renewal Silicone Test H-V Sat
- WO 180236-09, Torus Sludge Calculations B119R1
- WO 1802536-09, Unit 1, Inspect the Torus for Sludge Generation
- WO 2231885-01, 2-DG-1-ENG, Obtain Quarterly Oil Sample
- WO 36536, Inspect the Unit 1 Inspect the Torus for the Sludge Generation Rate
- WO 378286, 2-DW-Dem-WTR-Storage Tank
- WO 6386, 2-DG-1-ENG: Obtain Quarterly Oil Sample
- Phase Bus Aging Management Program (UFSAR Section 18.1.33 and Commitment No. 25) 0BNP-TR-052, License Renewal Phase Bus Aging Management Program, Rev. 1
- 0PM-IPB001A, Brunswick Nuclear Plant Operating Manual Volume XII, Preventive Maintenance: Clean, Inspect, and Meggar Isophase Bus from Main Transformer to No Load Disconnect, Rev. 4 0PM-IPB001C, Brunswick Nuclear Plant Operating Manual Volume XII, Preventive Maintenance: Inspection of Main Transformer Bushing Box Dampers, Rev. 4
- AR 00458961, Hole Found in the Top of 2-2S6-4KV Bus Duct , dated 4/11/11
- AR 00703866, Minimum Personnel Qualification Requirements for License Renewal, dated 8/19/14
- WO 01773269 02 (LR), Perform
- OPM-1PB001A, Clean and Inspect Isophase Bus, dated 1/24/11
- Fuel Pool Girder Tendon Inspection Program (UFSAR Section 18.1.34 and Commitment Nos. 26 and 29) 02503, Drawing: Progress Energy, Reactor Building Plan - EL. 50'-0" General Arrangement 02508, Drawing: Progress Energy, Reactor Building Arrangement & Details Fuel Pool 9527-1-RB-PG-01-F, United Engineers & Constructors, Inc., Carolina Power & Light Company, Brunswick Steam Electric Plant, Calculation Record Sheet
- 9527-F-1187, Drawing: Carolina Power & Light Company, Reactor Building- Unit 2 Pool Girder Construction Supports - Plan 9527-F-1187, Drawing: Progress Energy, Reactor Building Plan - EL. 80'- 0"General Arrangement
- 9527-F-1188, Drawing: Carolina Power & Light Company, Reactor Building- Unit 2 Pool Girder Construction Supports - Details
- AR 00704137, Clarification of Fuel Pool Girder Tendon Test Requirements, dated 8/20/14
- Brunswick Design Basis Document 58, Spent Fuel Pool, Rev. 17 Brunswick Regression Analysis of Unit 1 & 2 Post-Tensioned Concrete Fuel Pool Girders,
- REP-1101-510, 1/17/14 Brunswick Unit 1, Technical Specification, 4.3 Fuel Storage; Amendment No. 243
- Brunswick Unit 2, Technical Specification, 4.3 Fuel Storage; Amendment No. 271
- CP&L Brunswick Plant, Reactor Building Fuel Pool Girders; Design Data for Post Tensioned Girders, dated 1/1971 F-02505, Drawing: Progress Energy, Reactor Building Plan - EL. 117'-4", (original) F-02506, Drawing: Carolina Power & Light Company, Brunswick Steam Electric Plant, Reactor Building General Arrangement Section "A-A", Unit No. 2, Rev. 11 F-02507, Drawing: Progress Energy, Reactor Building General Arrangement Section "B-B" Unit No. 2, (original) F-02508, Drawing: Progress Energy, Reactor Building Plan Arrangement & Details Fuel Pool
- F-02509, Drawing: Carolina Power & Light Company, Reactor Building Refueling Equipment Layout Plan - EL. 117'-4"
- ISFSI-0019, Calculation: Structural Analysis of Unit 1 & 2 Reactor Building for ISFSI Induced Loads, Rev. 1
- ORXB-0016, Carolina Power and Light Company, P.O. Box 1551, Raleigh, North Carolina 27602, Calculation for Brunswick Fuel Pool Girder ISI, dated 8/11/94 Prestressed Concrete Fuel Pool Girder - Structural Calculations, dated 5/70
- WO 02206185, Engineering Review of the Ground Water Monitoring Results License Renewal, dated 1/20/14
- Compressed Air Monitoring Program (UFSAR Section 18.1.35) 0BNP-TR-048, License Renewal Compressed Air Monitoring Program, Rev. 1 0E&RC-0900, Operation of GE Model PM880 Portable Hygrometer and Sampling of the Instrument Air System, Rev. 14 0E&RC-0902, Operation of the MET One Model 237A Laser Particle Counter, Rev. 9
- 0ENP-53, Instrument Air System Analysis and Tracking Program, Rev. 9
- 70110, Engineering Change: Reliability Upgrades for the Emergency Diesel Generators (EDGs), Rev. 5
- BNP-LR-669, License Renewal Aging Management Program Description of the Compressed Air Monitoring Program, Rev. 0
- RPV Operating Pressure-Temperature (P-T) Limits (UFSAR Section 18.2.1.3 and Commitment No. 27) 0B11-0027, Development of RPV Pressure-Temperature Curves for License Renewal, Rev. 0
- 0ENP-15, Reactor Vessel & Internals Structural Integrity Program, Rev. 11
- BNP-LR-501, Neutron Embrittlement Time-Limited Aging Analysis Evaluation, Rev. 4
- Fuel Pool Girder Tendon Loss of Pre-Stress Program, TLAA (UFSAR Section 18.2.6 and Commitment No. 29) 0BNP-TR-045, Duke Energy, Brunswick Nuclear Plant, Units 1 and 2, License Renewal Fuel Pool Girder Tendon Inspection Aging Management Program, Rev. 1
- BNP-LR-506, Nuclear Generation Group, Prestressed Steel Tendons Time-Limited Aging Analysis, dated 9/16/14
- BNP-LR-645, Nuclear Generation Group, Fuel Pool Girder Tendon Inspection Program, Rev. 9
- OPT-15.10, Brunswick Unit 0 Surveillance Test Procedure Safety Related, Fuel Pool Girder Tendon Inspection Program, Rev. 0
- Operating Experience Review for Extended Power Uprate Aging Management (Commitment No. 31)
- AR 100627-51, Evaluation of Operating Experience (OE) at Extended Power Uprate Levels Prior to Period of Extended Operation for Brunswick Steam Electric Plant (BSEP) Units 1 &
- 0B11-0026, BNP Units 1 and 2 Leakage Evaluation, Rev. 5