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Chapter 18: Programs and Activities that Manage the Effects of Aging
Table of Contents

Section Title Page

18.1 NEW AGING MANAGEMENT ACTIVITIES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18-1

18.1.1 Buried Piping and Valve Inspection Activities . . . . . . . . . . . . . . . . . . . . . . . . . . . 18-1
18.1.2 Infrequently Accessed Area Inspection Activities . . . . . . . . . . . . . . . . . . . . . . . . . 18-2
18.1.3 Tank Inspection Activities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18-3
18.1.4 Non-EQ Cable Monitoring . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18-4

18.2 EXISTING AGING MANAGEMENT ACTIVITIES . . . . . . . . . . . . . . . . . . . . . . . . 18-5

18.2.1 Augmented Inspection Activities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18-6
18.2.2 Battery Rack Inspections . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18-7
18.2.3 Boric Acid Corrosion Surveillance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18-7
18.2.4 Chemistry Control Program for Primary Systems . . . . . . . . . . . . . . . . . . . . . . . . . 18-8
18.2.5 Chemistry Control Program for Secondary Systems . . . . . . . . . . . . . . . . . . . . . . . 18-8
18.2.6 Civil Engineering Structural Inspection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18-9
18.2.7 Fire Protection Program . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18-10
18.2.8 Fuel Oil Chemistry . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18-11
18.2.9 General Condition Monitoring Activities. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18-11
18.2.10 Inspection Activities - Load Handling Cranes and Devices. . . . . . . . . . . . . . . . . . 18-12
18.2.11 Inservice Inspection (ISI) Program - Component and Component Support
Inspections . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18-13
18.2.12 ISI Program - Containment Inspection. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18-14
18.2.13 ISI Program - Reactor Vessel . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18-15
18.2.14 Reactor Vessel Integrity Management . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18-15
18.2.15 Reactor Vessel Internals Inspection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18-17
18.2.16 Secondary Piping and Component Inspection . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18-17
18.2.17 Service Water System Inspections . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18-18
18.2.18 Steam Generator Inspections . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18-19
18.2.19 Work Control Process. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18-20
18.2.20 Corrective Action System. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18-21

18.3 TIME-LIMITED AGING ANALYSIS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18-22

18.3.1 Reactor Vessel Neutron Embrittlement . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18-22
18.3.1.1 Upper Shelf Energy . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18-22
18.3.1.2 Pressurized Thermal Shock . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18-22
18.3.1.3 Pressure-Temperature Limits. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18-23
18.3.2 Metal Fatigue . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18-23
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Chapter 18: Programs and Activities that Manage the Effects of Aging
Table of Contents (continued)

Section Title Page

18.3.2.1 ASME Boiler and Pressure Vessel Code, Section III, Class 1 . . . . . . . . . . . . . 18-23
18.3.2.2 Reactor Vessel Underclad Cracking . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18-24
18.3.2.3 ANSI B31.1 Piping . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18-24
18.3.2.4 Environmentally Assisted Fatigue. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18-25
18.3.3 Environmental Qualification of Electric Equipment . . . . . . . . . . . . . . . . . . . . . . . 18-27
18.3.4 Containment Liner Plate. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18-27
18.3.5 Plant-Specific Time-Limited Aging Analyses . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18-27
18.3.5.1 Crane Load Cycle Limit . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18-27
18.3.5.2 Reactor Coolant Pump Flywheel . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18-28
18.3.5.3 Leak-Before-Break . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18-28
18.3.5.4 Spent Fuel Pool Liner . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18-29
18.3.5.5 Piping Subsurface Indications . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18-29
18.3.5.6 Reactor Coolant Pump and ASME Code Case N-481. . . . . . . . . . . . . . . . . . . . 18-30
18.3.6 Exemptions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18-30

18.4 TLAA SUPPORTING ACTIVITIES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18-30

18.4.1 Environmental Qualification Program . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18-30
18.4.2 Transient Cycle Counting. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18-32

18.5 REFERENCES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18-33

Revision 45—09/30/09 NAPS UFSAR 18-iii

Chapter 18: Programs and Activities that Manage the Effects of Aging
List of Tables

Table Title Page

Table 18-1 License Renewal Commitments . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18-36

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Intentionally Blank
Revision 45—09/30/09 NAPS UFSAR 18-1

Chapter 18
PROGRAMS AND ACTIVITIES
THAT MANAGE THE EFFECTS OF AGING
The integrated plant assessment for license renewal identified new and existing aging
management programs and activities necessary to provide reasonable assurance that components
within the scope of license renewal will continue to perform their intended functions consistent
with the current licensing basis (CLB) for the period of extended operation. The period of
extended operation is defined as 20 years from the end of each units original operating license
expiration date. This chapter describes these programs and activities and their planned
implementation.

This chapter also discusses the evaluation results for each of the plant-specific time-limited
aging analyses (TLAAs) performed for license renewal. The evaluations have demonstrated that
the analyses remain valid for the period of extended operation; the analyses have been projected to
the end of the period of extended operation; or that the effects of aging on the intended function(s)
will be adequately managed for the period of extended operation.

The NRC Safety Evaluation Report, NUREG-1766, (Reference 24) for the North Anna
renewed operation licenses, identified commitments associated with the future development and
enhancement of various aging management programs and activities. These commitments are
compiled and listed in Appendix D of the NUREG and are provided herein as Table 18-1.

18.1 NEW AGING MANAGEMENT ACTIVITIES

The following sections provide a description of aging management programs and activities
that were not in-place when the renewed operating licenses were issued for North Anna. These
programs and activities were not part of the licensing basis for the original operating license
period but were identified as necessary to manage aging of various station systems, structures, and
components during the period of extended operation.

18.1.1 Buried Piping and Valve Inspection Activities

Prior to the period of extended operation, buried piping and valves will be inspected for the
existence of aging effects (Item 1, Table 18-1). The Buried Piping and Valve Inspection Activities
will include a one-time inspection of representative samples of piping and valves for different
combinations of buried material and burial condition. Visual inspections will be used to detect
cracking of protective coatings and loss of material from protective coatings or the substrate
material.
Revision 45—09/30/09 NAPS UFSAR 18-2

The inspection will be completed in accordance with the schedule provided in Item 1,
Table 18-1, and will include representative valves and sample lengths (i.e., several feet) of piping
for each of the following combinations of material and burial conditions:

• Carbon steel, concrete encased

• Carbon steel, coated

• Carbon steel, coated, wrapped

• Carbon steel, coated, and wrapped with cathodic protection

• Stainless steel, coated, and wrapped

An engineering evaluation of the results of the buried piping and valves inspections will be
performed to determine future actions. Corrective actions for conditions that are adverse to quality
are performed in accordance with the Corrective Action System. Corrective action provides
reasonable assurance that conditions adverse to quality are promptly corrected.

18.1.2 Infrequently Accessed Area Inspection Activities

The purpose of the Infrequently Accessed Area Inspection Activities is to provide
reasonable assurance that equipment and components within the scope of License Renewal, which
are not readily accessible, will continue to fulfill their intended functions during the period of
extended operation (Item 9, Table 18-1). A one-time inspection will be performed in accordance
with the schedule provided in Item 9, Table 18-1, to assess the aging of components and structures
located in areas not routinely accessed due to high-radiation, high-temperature, confined spaces,
location behind security or missile barriers, or normally flooded. The external condition of
structures, supports, piping, and equipment will be determined by visual inspection. These
inspections would detect the aging effect of loss of material. In addition, concrete will be
inspected to detect the aging effects of loss of material, cracking, and change in material
properties (Item 17, Table 18-1).

Infrequently accessed areas determined to be within the scope of license renewal and the
focus of inspections within these area include:

• Reactor containment - Sump areas, cabling and supports*

• Reactor containment keyway - Leakage, structural support provided by the neutron

shield tank

• Subsurface drains - Access shaft and component supports

• Cover for Containment dome plug - Structural condition

• Volume control tank cubicle - Structure, supports, and equipment

Revision 45—09/30/09 NAPS UFSAR 18-3

• Emergency diesel generator (EDG) exhaust bunkers - Structural condition

• Cable spreading rooms, Cable tunnels, Upper areas of emergency switchgear rooms -
Cable raceways and supports*

• New fuel storage area - Supports and structure affecting spent fuel pool cooling*

• Auxiliary Building filter and ion exchanger cubicles - Structure, supports, and
equipment*

• Tunnel from Turbine Building to Auxiliary Building - Structure, supports, and piping*

• Service water (SW) expansion joint vault - Supports and piping

• SW tie-in vault - Supports and piping

• Auxiliary SW valve pit - Supports and piping

• Turbine building SW valve pit - Structures, supports and piping

• SW valve house lower level - Supports, piping, and equipment

• SW pump house lower level - Supports, piping, and equipment

• Spray array structure in SW reservoir - Underwater supports*

• Auxiliary SW expansion joint vault - Supports and piping*

• Charging pump pipe chase - Structure, supports and piping*

• Auxiliary feedwater piping tunnel - Structure, supports and piping*

Note: Representative samples will be inspected in areas denoted with an asterisk.

Inspection results will be documented for evaluation and retention. Engineering evaluation
assesses the severity of the visual inspection results and determines the extent of required actions
or future inspections. Corrective actions for conditions that are adverse to quality are performed in
accordance with the Corrective Action System. Corrective action provides reasonable assurance
that conditions adverse to quality are promptly corrected.

18.1.3 Tank Inspection Activities

The purpose of the Tank Inspection Activities is to perform inspections of above ground and
underground tanks to provide reasonable assurance that the tanks will perform their intended
function through the period of extended operation (Item 10, Table 18-1).

A one-time inspection will be performed in accordance with the schedule provided in

Item 10, Table 18-1, for specified tanks that are within the scope of license renewal and could
Revision 45—09/30/09 NAPS UFSAR 18-4

experience aging effects. The aging effect of concern for tanks is loss of material. A representative
sample of tanks will be designated for the one-time inspections in order to assess the condition of
tanks that require aging management. The choice of representative tanks to be inspected is
dependent on the material of construction for the tank, its contents, the foundation upon which the
tank is based, and the type of coating. Visual inspections of internal and external surfaces will be
performed. Volumetric examinations will be performed to look for indications of wall thinning on
tanks that are founded on soil or buried. Indications of degradation will be referred for evaluation
by engineering.

The following tanks will be inspected or represented by suitable replacement samples:

• EDG tanks (fuel oil, coolant, and starting air)

• AAC diesel generator tanks (fuel oil, coolant and starting air)

• Security diesel generator tank (fuel oil)

• Underground fuel oil storage tanks

• Diesel-driven fire pump fuel oil storage tanks

• Refueling water storage tanks

• Chemical addition tanks

• Emergency condensate storage tanks

• Casing cooling tanks

• SW pump house air receiver

An engineering evaluation may determine that the observed condition is acceptable or

requires repair; or, in the case of degraded coatings, may direct removal of the coating,
non-destructive examination of the substrate material, and replacement of the coating.
Re-inspections will be dependent upon the observed surface condition, and the results of this
engineering evaluation. Corrective actions for conditions that are adverse to quality are performed
in accordance with the Corrective Action System. Corrective action provides reasonable
assurance that conditions adverse to quality are promptly corrected.

18.1.4 Non-EQ Cable Monitoring

The purpose of the Non-EQ Cable Monitoring activities will be to perform inspections on a
limited, but representative, number or accessible cable jackets and connector coverings that are
utilized in non-EQ applications (Item 19, Table 18-1). In order to confirm that ambient conditions
are not changing sufficiently to lead to age-related degradation of the in-scope cable jackets and
connector coverings, initial visual inspections for the non-EQ application insulated power cables,
Revision 45—09/30/09 NAPS UFSAR 18-5

instrumentation cables, and control cables (including low-voltage instrumentation and control
cables that are sensitive to a reduction in insulation resistance) will be performed in accordance
with the schedule provided in Item 19, Table 18-1. Visual inspection of the representative samples
of non-EQ power, instrumentation, and control cable jackets and connector coverings will detect
the presence of cracking, discoloration, or bulging, which could indicate aging effects requiring
management. These effects could be due to high radiation, high temperature, or wetted condition
environments. Subsequent inspections to confirm ambient conditions will be performed at least
once per 10 years following the initial inspection. Additionally, upon issuance of final staff
guidance regarding the aging management of fuse holders, this program will be revised to address
the requirements of the final staff guidance (Item 26, Table 18-1).

The potentially adverse localized environment due to moisture which could lead to
water-treeing in high- or medium-voltage cables that are within the scope of license renewal, is
also detected by visually monitoring for the presence of water around cables. Programs utilizing
periodic inspections and design features such as drains or sump pumps are used to control the
cable localized environment. Cable found to be wetted for any significant period of time will be
tested using an appropriate test method which has been proven to accurately assess the cable
condition with regards to water treeing.

The source, intermediate, and power range neutron detector operate with high-voltage
power supply in conjunction with low-voltage signal cables. The routine calibration of these
detectors will be used to identify the potential existence of aging degradation in the associated
cables.

Any anomalies resulting from the inspections will be dispositioned by Engineering and will
consider the cable environment including the potential for moisture in the areas of the anomalies.
Occurrence of an anomaly that is adverse to quality will be entered into the Corrective Action
System. The corrective action process provides reasonable assurance that deficiencies adverse to
quality are either promptly corrected or are evaluated to be acceptable. Although age-related
degradation is not expected for power, instrumentation, and control cables and connectors in their
normal environments, visual inspections will provide reasonable assurance that the intended
functions will be maintained.

18.2 EXISTING AGING MANAGEMENT ACTIVITIES

The following sections provide a description of aging management programs and activities
that were essentially in-place when the renewed operating licenses were issued for North Anna.
These programs and activities were part of the licensing basis for the original operating license
period. For some programs, however, enhancements were identified during the license renewal
process as necessary to manage aging of various station systems, structures, and components
during the period of extended operation.
Revision 45—09/30/09 NAPS UFSAR 18-6

18.2.1 Augmented Inspection Activities

The purpose of the Augmented Inspection Activities is to perform examinations of selected
components and supports in accordance with requirements identified in the Technical
Specifications, UFSAR, license commitments, industry operating experience, and good practices
for the station. Augmented inspections are outside the required scope of ASME Section XI. The
scope of Augmented Inspection Activities to be performed during each refueling outage is
identified by Engineering in accordance with controlled procedures. Component conditions are
monitored to detect degradation due to loss of material and cracking. Inspections include visual,
surface, and volumetric examinations. The extent of each component inspection is defined within
the Augmented Inspection Activities program description.

Augmented Inspection Activities include:

• High Energy Lines Outside of Containment (Main Steam and Feedwater)

• Reactor vessel incore detector thimble tubes

• Component supports

• Steam generator feedwater nozzles

• Reactor vessel head

• Turbine throttle valves

• Steam generator supports

The scope of augmented inspection has been revised to include the core barrel hold-down
spring (Item 3, Table 18-1). The inspection addresses the aging effect of loss of pre-load.
Additionally, the scope for augmented inspections has been revised to include an inspection of the
pressurizer surge line connection (two welds) to the reactor coolant system hot-leg loop piping
(Item 2, Table 18-1). The inspections address the aging effect of thermal fatigue failure of the
weld due to environmental effects, as described in NRC Generic Safety Issue (GSI)-190. The
scope, frequency, qualifications, and methods of inspection are consistent with those utilized for
the Inservice Inspection Program in accordance with ASME Section XI. The initial baseline
inspection will occur during the fourth inspection interval. Additional inspections will be
performed during each subsequent 40-month inspection period. Industry efforts to study the
environmental effects on weld thermal fatigue failure will continue to be evaluated by Dominion.
If warranted, alternatives to this planned inspection (re-evaluation, replacement, or repair) will be
submitted to the NRC for review.

The acceptance standards for non-destructive examinations for the Augmented Inspection
Activities are consistent with guidance provided in ASME Section XI or are provided within
applicable examination procedures. Evidence of loss of material, loss of pre-load, or cracking
Revision 45—09/30/09 NAPS UFSAR 18-7

requires engineering evaluation for determination of corrective action. Occurrence of significant

degradation that is adverse to quality will be entered into the Corrective Action System.
Corrective action provides reasonable assurance that conditions adverse to quality are promptly
corrected.

18.2.2 Battery Rack Inspections

The purpose of the Battery Rack Inspections is to provide reasonable assurance of the
integrity of the supports for various station batteries. Loss of material due to corrosion is the aging
effect. Periodic checks of the rack integrity are performed, coincident with periodic battery
inspections, to determine the physical condition of the battery support racks. The condition and
mechanical integrity of the battery support racks are visually inspected to provide reasonable
assurance that their function to adequately support the batteries is maintained. Visual inspections
are adequate to identify degradation of the physical condition of the support racks. These
inspections check for corrosion of the support rack structural members.

If any material condition deterioration is sufficiently extensive to interfere with integrity of

the racks, the Corrective Action System will determine the cause and appropriate action to repair
and prevent recurrence of the degradation. Corrective action provides reasonable assurance that
conditions adverse to quality are promptly corrected.

18.2.3 Boric Acid Corrosion Surveillance

Leakage from borated systems inside Containment creates the potential for degradation of
components. Inspections are performed to provide reasonable assurance that borated water
leakage does not lead to undetected loss of material from the reactor coolant pressure boundary
and surrounding components. Carbon steel is particularly susceptible, but copper also can be
damaged.

In Generic Letter 88-05 (Reference 2), the NRC identified concerns with boric acid
corrosion of carbon-steel reactor pressure boundary components inside Containment. In response
to this generic letter, activities were developed to examine primary coolant components for
evidence of borated water leakage that could degrade the external surfaces of nearby structures or
components, and to implement corrective actions to address coolant leakage.

Primary coolant systems inside Containment are examined for evidence of borated water
leakage. An overall visual inspection of coolant system piping is performed, with particular
interest in potential leakage locations. Insulated portions of the coolant systems are examined for
signs of borated water leakage through the insulation by examining accessible joints and exposed
surfaces of piping and equipment. Vertical components are examined at the lowest elevation.
Components and connections that are not accessible are examined by looking for borated water
leakage on the surrounding area of the floor or adjacent equipment and insulation. The inspection
scope includes connections to the reactor coolant system from the normal coolant letdown and
Revision 45—09/30/09 NAPS UFSAR 18-8

makeup piping, and from the emergency core cooling systems. Components that are in the
vicinity of borated water leakage are also examined for damage resulting from the leakage.

When visual inspections indicate evidence of borated water leakage, an evaluation is

performed to determine if degradation of the leaking component or nearby affected components
has occurred; and whether the observed condition is acceptable without repair. Occurrence of
significant degradation that is adverse to quality is entered into the Corrective Action System.
Corrective action provides reasonable assurance that conditions adverse to quality are promptly
corrected.

18.2.4 Chemistry Control Program for Primary Systems

The purpose of the Chemistry Control Program for Primary Systems is to provide
reasonable assurance that water quality is compatible with the materials of construction in the
plant systems and equipment in order to minimize the loss of material and cracking. The
Chemistry Control Program for Primary Systems creates an environment in which material
degradation is minimized, therefore, maintaining material integrity and reducing the amount of
corrosion product that could accumulate and interfere with equipment operation or heat transfer.

Chemistry sampling is performed and the results are monitored and trended by maintaining
logs of measured parameters. Acceptability of the measurements is determined by comparison
with the limits established in the Chemistry Control Program for Primary Systems. Acceptance
criteria for the measured primary chemistry parameters are listed in the Chemistry Control
Program for Primary Systems. The acceptance criteria reflect EPRI guidelines for parameters that
have been shown to contribute to component degradation. Adherence to the guidelines minimizes
the aging effects of loss of material and cracking.

Action levels are established to initiate corrective action when the established limits are
approached or exceeded. Depending on the magnitude of the out-of-limit condition, plant
shutdown may be performed to minimize aging effects while plant actions are being taken.
Corrective actions for conditions that are adverse to quality are performed in accordance with the
Corrective Action System. Corrective action provides reasonable assurance that conditions
adverse to quality are promptly corrected.

18.2.5 Chemistry Control Program for Secondary Systems

The purpose of the Chemistry Control Program for Secondary Systems is to provide
reasonable assurance that water quality is compatible with the materials of construction in the
plant systems and equipment in order to minimize the loss of material and cracking. The
Chemistry Control Program for Secondary Systems creates an environment in which material
degradation is minimized, therefore, maintaining material integrity and reducing the amount of
corrosion product that could accumulate and interfere with equipment operation or heat transfer.
Revision 45—09/30/09 NAPS UFSAR 18-9

Chemistry results are monitored and trended by maintaining logs of measured parameters.
Acceptability of the measurements is determined by comparison with limits established by the
Chemistry Control Program for Secondary Systems. Acceptance criteria for the measured
secondary chemistry parameters are listed in the Chemistry Control Program for Secondary
Systems. The acceptance criteria reflect EPRI guidelines for parameters that have been shown to
contribute to component degradation. Adherence to the guidelines minimizes the aging effects of
loss of material and cracking.

Action levels are established to initiate corrective action when the established limits are
exceeded. Depending on the magnitude of the out-of-limit condition, power is reduced or the
plant is shut down to minimize aging effects while plant actions are being taken. Corrective
actions for conditions that are adverse to quality are performed in accordance with the Corrective
Action System. Corrective action provides reasonable assurance that conditions adverse to quality
are promptly corrected.

18.2.6 Civil Engineering Structural Inspection

The maintenance rule, 10 CFR 50.65, requires licensees to monitor the condition of
structures against established goals. During the period of extended operation, the provisions of the
Maintenance Rule Program will be utilized to provide reasonable assurance of the continuing
capability of civil engineering structures to fulfill their intended functions. The scope of Civil
Engineering Structural Inspections has been expanded to include inspections required for license
renewal (Item 4, Table 18-1). The expanded scope is summarized in a Dominion report.

Annual monitoring of groundwater chemistry, including surveillance scheduling that

accommodates seasonal chemistry variations (Items 16 & 28, Table 18-1), is a commitment that
will be implemented in accordance with the schedule provided in Table 18-1. Fulfilling the
requirements to perform annual monitoring of groundwater chemistry and account for seasonal
variations is accomplished by the implementation of a periodic testing procedure that is
performed quarterly. Having this Chemistry Department periodic test procedure already in place
prior to the period of extended operation complies with the schedule listed in Table 18-1.

Structural monitoring inspections are visual inspections that are performed to assess the
overall physical condition of the structure. For concrete structures, this includes elastomer sealant
materials.

Inspections are performed by trained inspectors and include representative samples of both
the interior and exterior accessible surfaces of structures. Documentation of inspection results
includes a general description of observed conditions, location and size of anomalies, and the
noted effects of environmental conditions. If an inaccessible area becomes accessible by such
means as dewatering, excavation or installation of radiation shielding, an opportunity will exist
for additional inspections. The application for the renewed operating licenses included a
commitment for guidance to be provided in plant procedures in accordance with the schedule
Revision 45—09/30/09 NAPS UFSAR 18-10

provided in Item 5, Table 18-1, to take advantage of such inspection opportunities when they arise
for inaccessible areas. This commitment has been fulfilled through revised Station procedures.

A visual indication of: 1) loss of material for concrete and structural steel, 2) significant
cracking for concrete and masonry walls, 3) cracking or change in material properties for
elastomers, 4) loss of material or loss of form for soil, and 5) gross indications of change in
material properties of concrete, each requires an engineering evaluation (Item 17, Table 18-1).

Inspections of masonry walls are included in this program. The inspections check for cracks
of joints and missing or broken blocks.

The engineering evaluation of inspection results, including groundwater chemistry results,

determines whether analysis, repair, or additional inspections or testing is required to provide
reasonable assurance that structures will continue to fulfill their intended functions. Corrective
actions for conditions that are adverse to quality are performed in accordance with the Corrective
Action System. Corrective action provides reasonable assurance that conditions adverse to quality
are promptly corrected.

18.2.7 Fire Protection Program

Regulatory requirements associated with fire protection systems and implementation plans
are provided in 10 CFR 50.48 and 10 CFR 50, Appendix R. The Fire Protection Plan includes
applicable National Fire Protection Association (NFPA) commitments and maintains compliance
with NRC Branch Technical Position (BTP) 9.5-1 from the Standard Review Plan (Reference 3).
Aging management concerns related to fire protection involve visual inspections of fire protection
equipment and barriers, including doors, walls, floors, ceilings, penetration seals, fire-retardant
coatings, fire dampers, cable-tray covers, and fire stops.

Applicable aging effects that are found by visual examination include loss of material,
separation and cracking/delamination, heat transfer degradation, and change in material
properties. Aging effects on piping systems (including valve bodies and pump casings) that are
dry or that carry water are evaluated in the same manner as for any other mechanical system.
Testing of the fire protection pumps provides indication of heat transfer degradation, and
inspections of the pumps provide indication of loss of material. Verification of piping integrity to
maintain a pressure boundary for the fire protection system, and the availability of water are
addressed by routine plant walkdowns, by pressure/flow tests that are conducted periodically, and
by the Work Control Process (Item 30, Table 18-1). Visual inspections are performed periodically
for hose stations, hydrants, and sprinklers.

Provisions to replace sprinklers or test a representative sample of sprinklers that have been
in service for 50 years will be incorporated into the Fire Protection Program (Item 6, Table 18-1).
This task conforms to the requirements of NFPA-25, Section 2-3.1.1. If testing is performed,
re-testing will be performed at 10-year intervals per NFPA-25.
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Fire protection equipment is examined for indications of visible damage. Acceptable sizes
for breaks, holes, cracks, gaps, or clearances in fire barriers, and acceptable amounts of sealant in
penetrations are established in the inspection procedures. Any questions regarding the ability of
the barrier to fulfill its fire protection function are addressed by engineering evaluation.
Acceptance criteria for fire protection equipment performance tests (i.e., flow and pressure tests)
are provided in the appropriate test procedures. Occurrence of significant degradation that is
adverse to quality is entered into the Corrective Action System. Corrective action provides
reasonable assurance that conditions adverse to quality are promptly corrected.

18.2.8 Fuel Oil Chemistry

The Fuel Oil Chemistry program manages the loss of material by requiring that oil quality is
compatible with the materials of construction in plant systems and equipment. Poor fuel oil
quality could lead either to degradation of storage tanks or accumulations of particulates or
biological growth in the tanks. The purpose of the Fuel Oil Chemistry program is to minimize the
existence of contaminants such as water, sediment, and bacteria which could degrade fuel oil
quality and damage the fuel oil system and interfere with the operation of safety-related
equipment.

The Fuel Oil Chemistry program is an aging effects mitigation activity which does not
directly detect aging effects. The Fuel Oil Chemistry guidelines address the parameters to be
monitored and the acceptance limit for each parameter. The acceptance criteria reflect ASTM
guidelines for parameters that have been shown to contribute to component degradation.
Adherence to the guidelines mitigates the aging effect of loss of material. Parameters analyzed
and found to be outside established limits will be reported to Engineering, an evaluation will be
performed, and appropriate corrective actions will be taken. Occurrence of significant deviations
that are adverse to quality is entered into the Corrective Action System. Corrective action provides
reasonable assurance that conditions adverse to quality are promptly corrected.

18.2.9 General Condition Monitoring Activities

General Condition Monitoring Activities are performed for the assessment and management
of aging for components that are located in normally accessible areas. The results of this
monitoring are the basis for initiating required corrective action in a timely manner. This
monitoring is based on the observations that are made during focused inspections that are
performed on a periodic basis. Guidance is implemented in procedures for engineers and health
physics technicians regarding inspection criteria that focus on detection of aging effects during
General Condition Monitoring Activities (Item 8, Table 18-1). An engineering document provides
direction for performing plant walkdowns to monitor equipment conditions. The walkdowns
include surveillance activities and observations of maintenance tasks. Indications of age-related
degradation are monitored during these walkdowns. Additional inspection information regarding
the integrity of components is provided by inspections that support the implementation of the
Boric Acid Corrosion Control Program. For the health physics technicians, procedural guidance
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exists for performing walkdowns within the Radiological Control Area to monitor potential
pressure-boundary degradation.

The external condition of supports, piping, doors, and equipment will be determined by
visual inspection. General Condition Monitoring Activities are performed in three different ways:

• Inspections of radiologically controlled areas for borated water leakage

• Periodic focused inspections such as system walkdowns

• Area inspections for condition of structural supports and doors

Inspection criteria for non-ASME Section XI component supports and doors, as part of
General Condition Monitoring are procedurally implemented using guidance provided in an
Engineering document. Doors that require inspection for age-related degradation also are
designated as EQ doors. Monitoring of the EQ doors occurs as directed by the Technical
Requirements Manual (Item 7, Table 18-1). Initial inspections will be completed, using the
criteria, in accordance with the schedule provided in Item 7, Table 18-1.

These inspections provide information to manage the aging effects of loss of material,
change in material properties, and cracking.

The acceptance criteria for visual inspections are identified in procedures that direct the
various monitoring activities. Responsibility for the evaluation of identified visual indications of
aging effects is assigned to Engineering personnel. Evaluations of anomalies found during
General Condition Monitoring Activities determine whether analysis, repair, or further inspection
is required. Occurrence of significant degradation that is adverse to quality is entered into the
Corrective Action System. Corrective action provides reasonable assurance that conditions
adverse to quality are promptly corrected.

18.2.10 Inspection Activities - Load Handling Cranes and Devices

The load handling cranes within the scope of license renewal are listed below:

• Containment polar cranes

• Containment jib cranes

• Containment annulus monorails

• Refueling manipulator cranes

• Fuel handling bridge crane

• New fuel transfer elevator

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• Spent fuel crane

• Auxiliary Building monorails

The long-lived passive components of these cranes that are subject to aging management
review include rails, towers, load trolley steel, fasteners, base plates, and anchorage. An internal
inspection of representative sections of the box girders for the polar cranes will be implemented as
a one-time only inspection (Item 13, Table 18-1). This inspection will be performed in accordance
with the schedule provided in Item 13, Table 18-1. An engineering evaluation will determine
whether subsequent inspections are required.

The Inspection Activities - Load Handling Cranes and Devices has been developed in
accordance with ASME B30.2 (Reference 13) and the inspection activities for monorails are
developed in accordance with ASME B30.11 (Reference 14).

The Work Control Process directs structural integrity inspections of applicable cranes which
include specific steps to check (visually inspect) the condition of structural members and fasteners
on the cranes, the runways along which the cranes move, and the baseplates and anchorages for
the runways. The applicable aging effect is identified as loss of material. If the nature of any
identified discrepancies is such that corrective action can be completed within the scope of the
procedure performing the inspection, no additional corrective action may be necessary. Corrective
actions for conditions that are adverse to quality are performed in accordance with the Corrective
Action System. Corrective action provides reasonable assurance that conditions adverse to quality
are promptly corrected.

18.2.11 Inservice Inspection (ISI) Program - Component and Component Support

Inspections
The ISI Program - Component and Component Support Inspections are performed in
accordance with the requirements of Subsections IWB, IWC, and IWF of ASME XI, Rules for
Inservice Inspection of Nuclear Power Plant Components. For this program, the license renewal
concerns with respect to Subsection IWC include only the carbon steel piping that is susceptible
to high energy line breaks in the feedwater and main steam systems. Inservice Inspection
requirements may be modified by applicable Relief Requests and Code Cases, which are
approved by the NRC specifically for each unit. The scope and details of the inspections to be
performed are contained in the individualized Inservice Inspection Plan for each unit. Each
Inservice Inspection Plan is developed for a 120-month inspection interval and submitted to the
NRC. The examinations required by ASME Section XI utilize visual, surface, and volumetric
inspections to detect loss of material, cracking, gross indications of loss of pre-load, and gross
indications of reduction in fracture toughness (which presents itself as cracking of cast-austenitic
stainless steel valve bodies due to thermal embrittlement).
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Dominion actively participates in the EPRI-sponsored Materials Reliability Project Industry

Task Group on thermal fatigue which currently is developing industry guidance for the
management of fatigue caused by cyclic thermal stratification and environmental effects.
Dominion is committed to following industry activities related to failure mechanisms for
small-bore piping and will evaluate changes to inspection activities based on industry
recommendations (Item 11, Table 18-1). This commitment is closed based on an engineering
evaluation indicating that no new industry initiatives have occurred regarding inspections of
small-bore piping. The current ASME requirements remain in effect to perform visual inspections
of small-bore socket welds, and visual and volumetric inspections of small-bore butt welds.

Acceptance standards for inservice inspections are identified in Subsection IWB for Class 1
components, Subsection IWC for included Class 2 components, and in Subsection IWF for
component supports. Table IWB 2500-1 refers to acceptance standards listed in
paragraph IWB 3500. Anomalous indications beyond the criteria set forth in the Code acceptance
standards that are revealed by the inservice inspections of Class 1 components may require
additional inspections of similar components in accordance with Section XI. Evidence of loss of
material, cracking, and gross indications of either loss of pre-load or reduction of fracture
toughness requires engineering evaluation for determination of corrective action. Occurrence of
significant degradation that is adverse to quality will be entered into the Corrective Action
System. Corrective action provides reasonable assurance that conditions adverse to quality are
promptly corrected.

18.2.12 ISI Program - Containment Inspection

The ISI Program - Containment Inspection for concrete containments and containment steel
liners implements the requirements in 10 CFR 50.55a and Subsections IWE and IWL of ASME
Section XI. The program incorporates applicable code cases and approved relief requests. The
provisions of 10 CFR 50.55a are invoked for inaccessible areas within the Containment structure.

Loss of material is the aging effect for the containment steel liner. Surface degradation and
wall thinning are checked by visual and volumetric examinations. The frequency and scope of
examination requirements are specified in 10 CFR 50.55a and Subsection IWE. Loss of material,
cracking and change in material properties are the aging effects for the containment concrete and
are checked by visual examinations. The frequency and scope of examination requirements are
specified in 10 CFR 50.55a and Subsections IWL. These inspections provide reasonable
assurance that aging effects associated with the containment liner and concrete are detected prior
to compromising design basis requirements. The evaluations of accessible areas provide the basis
for extrapolation to the expected condition of inaccessible areas, and an assessment of degradation
in such areas.

During the course of containment inspections, anomalous indications are recorded on

inspection reports that are kept in Station Records. Acceptance standards for the IWE inspections
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are identified in ASME Section XI Table IWE 2500-1 and refer to 10 CFR 50, Appendix J. For
the IWL inspections, acceptance standards are identified in ASME Section XI Table IWL 2500-1.
Engineering evaluations are performed for inspection results that do not meet established
acceptance standards. Occurrence of significant degradation that is adverse to quality will be
entered into the Corrective Action System. Corrective action provides reasonable assurance that
conditions adverse to quality are promptly corrected.

18.2.13 ISI Program - Reactor Vessel

The ISI Program - Reactor Vessel is performed in accordance with the requirements of
Subsection IWB of ASME XI, Rules for Inservice Inspection of Nuclear Power Plant
Components. Inservice Inspection requirements may be modified by applicable Relief Requests
and Code Cases, which are approved by the NRC specifically for each unit. The scope and details
of the inspections to be performed are contained in the individualized Inservice Inspection Plan
for each unit. Each Inservice Inspection Plan is developed and submitted to the NRC for a
120-month inspection interval. Dominion will follow industry efforts (in addition to the existing
reliance on chemistry control and ASME Section XI inspections) regarding inspection of core
support lugs (Item 12, Table 18-1). Industry recommendations will be considered to determine the
need for enhanced inspections.

In accordance with ASME Section XI, reactor vessel components are inspected using a
combination of surface examinations, volumetric examinations, and visual examinations to detect
the aging effects of loss of material, cracking, gross indications of loss of pre-load, and gross
indications of reduction in fracture toughness. Acceptance standards for inservice inspections are
identified in Subsection IWB for Class 1 components. Table IWB 2500-1 refers to acceptance
standards listed in paragraph IWB 3500. Anomalous indications that are revealed by the inservice
inspections may require additional inspections of similar components, in accordance with
Section XI. Evidence of aging effects requires engineering evaluation for determination of
corrective action. Occurrence of significant degradation that is adverse to quality is entered into
the Corrective Action System. Corrective action provides reasonable assurance that conditions
adverse to quality are promptly corrected.

18.2.14 Reactor Vessel Integrity Management

The scope of the Reactor Vessel Integrity Management activities is focused on ensuring
adequate fracture toughness of the reactor vessel beltline plate and weld materials. Neutron
dosimetry and material properties data derived from the reactor vessel materials irradiation
surveillance program are used in calculations and evaluations that demonstrate compliance with
applicable regulations. The Reactor Vessel Integrity Management activities includes the following
aspects:

• Irradiated sample (capsule) surveillance.

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• Vessel fast neutron fluence calculations.

• Measurements and calculations of nil-ductility transition temperature (RTNDT) for vessel

• beltline materials.

• Measurements and calculations of Charpy Upper Shelf Energy (CvUSE).

• Calculation of reactor coolant system pressure/temperature (P-T) operating limits, and

Low Temperature Overpressure Protection System (LTOPS) setpoints.

• Pressurized thermal shock (PTS) screening calculations.

Specimen capsules were placed in each of the reactors prior to initial irradiation and contain
reactor vessel plate and weld material samples. The baseline mechanical properties of reactor
vessel steels are determined from pre-irradiation testing of Charpy V-notch and tensile specimens.
Post-irradiation testing of similar specimens provides a measure of radiation damage. Refer to
Section 5.4.3.6.

Fast neutron irradiation is the cause of radiation damage to the reactor vessel beltline. The
results of surveillance capsule dosimetry analyses are used as benchmarks for calculations of
neutron fluence to the surveillance capsules and to the reactor vessel beltline.

Measured values of Charpy transition temperature and C v USE are obtained from
mechanical testing of irradiation surveillance program specimens. Measured values of transition
temperature are used to determine the reference temperature for nil-ductility transition (RTNDT)
for the limiting reactor vessel beltline material. RT NDT is a key analysis input for the
determination of reactor coolant system P-T operating limits and LTOPS setpoints. Measured
values of transition temperature shift are similarly utilized in PTS screening calculations required
by 10 CFR 50.61. Measured values of CvUSE are used to verify compliance with the upper shelf
energy requirements of 10 CFR 50 Appendix G.

Acceptable values are established for the following parameters:

• Heatup and cooldown limits, as implemented by Technical Specifications, to ensure

reactor vessel integrity.

• A PTS reference temperature that is within the screening criteria of 10 CFR 50.61.

• A fast fluence value for the surveillance capsule that bounds the expected fluence at the
affected vessel beltline material through the period of extended operation.

• CvUSE greater than limits set forth in 10 CFR 50, Appendix G.

Based on established parameters, calculations are performed to ensure that the units will
remain within the acceptable values.
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18.2.15 Reactor Vessel Internals Inspection

Visual inservice inspections are implemented in accordance with Category B-N-3
(Removable Core Support Structures) of ASME Section XI, Subsection IWB, to determine the
possible occurrence of age-related degradation. These inspections are performed at 10-year
intervals in accordance with the inspection plans submitted to the NRC. The scope of components
that comprise the reactor internals includes the upper and lower core internals assemblies. This
includes core support and hold-down spring components, as well as, the baffle/former bolting and
barrel/former bolting. Additionally, a one-time focused inspection of the reactor vessel internals
will be performed in accordance with the schedule provided in Item 14, Table 18-1. The one-time
inspection will look for indications of the presence of aging effects identified in the aging
management review for the reactor vessel internals. The inspection will be performed on one
reactor (at either Surry or North Anna) and an engineering evaluation of results will determine the
need for inspections of the other units. Dominion will remain active in industry groups, including
the EPRI-sponsored Materials Reliability Project Industry Task Group, to stay aware of any new
industry recommendations regarding such aging management issues as neutron embrittlement,
void swelling, and the synergistic effect of thermal and neutron embrittlement of internals
sub-components (Item 14, Table 18-1). If future industry developments suggest the need for an
alternate inspection plan during the period of extended operation, or negate the need for a
one-time inspection, then Dominion will modify the proposed inspection plan.

Visual inspections are utilized to detect loss of material and cracking; as well as, gross
indications of loss of pre-load and/or reduced fracture toughness. The acceptance standards for
the visual examinations are summarized in ASME Subsection IWB-3520.2, Visual Examination,
VT-3. These inspections are directed to be performed with the internals assemblies removed from
the reactor vessel.

Acceptance standards for Reactor Vessel Internals Inspection activities are identified in
ASME Section XI, Subsection IWB. Table IWB 2500-1 identifies references to the acceptance
standards listed in Paragraph IWB 3500. Anomalous indications, that are revealed to be beyond
the criteria in the acceptance standards by the inservice inspections, may require additional
inspections. Evidence of any component degradation requires engineering evaluation for
determination of corrective action. Occurrence of significant degradation that is adverse to quality
is entered into the Corrective Action System. Corrective action provides reasonable assurance that
conditions adverse to quality are promptly corrected.

18.2.16 Secondary Piping and Component Inspection

The purpose of the Secondary Piping and Component Inspection program is to identify,
inspect, and trend components that are susceptible to the aging effect of loss of material as a result
of Flow Accelerated Corrosion (FAC) in either single or two-phase flow conditions. This program
has been implemented in accordance with NRC Generic Letter 89-08, Erosion/Corrosion-Induced
Pipe Wall Thinning (Reference 15), and NUREG-1344, Erosion/Corrosion-Induced Pipe Wall
Revision 45—09/30/09 NAPS UFSAR 18-18

Thinning in U.S. Nuclear Power Plants (Reference 16), and EPRI Guideline NSAC-202L,
Recommendations for an Effective Flow Accelerated Corrosion Program (Reference 17).

The scope of the Secondary Piping and Component Inspection program includes portions of
the feedwater systems, the main and auxiliary steam systems, and the steam generator blowdown
lines.

The Secondary Piping and Component Inspection program also includes susceptible vent
and drain lines.

The identification of components and piping segments to be included in each Secondary

Piping and Component Inspection effort is performed by Engineering using plant chemistry data,
past inspection data, predictions from FAC-monitoring computer codes, and industry experience.
Determination of whether a piping component has experienced FAC degradation is made by
measuring the current wall thickness using the UT method and comparing against previous
baseline thickness measurement, if available. Visual inspections of the internals of non-piping
components, such as pumps and valves, are performed as the equipment is opened for other
repairs and/or maintenance, to determine whether flow-accelerated degradation is occurring.

The decision to repair or replace a component is made by Engineering. For the internal
surface examinations, engineering evaluations are utilized to determine whether the results of
visual inspections indicate conditions that require corrective action. Occurrences of significant
degradation that are adverse to quality are entered into the Corrective Action System. Corrective
action provides reasonable assurance that conditions adverse to quality are promptly corrected.

18.2.17 Service Water System Inspections

Compliance with Generic Letter 89-13 (Reference 18) requires a variety of inspections,
non-destructive examinations, and heat transfer testing for components cooled by service water.
Generic Letter 89-13 directed utilities to assess the following aspects of operational problems
with service water cooling systems:

• Biofouling

• Heat Transfer Testing

• Routine Inspection and Maintenance

• Single-failure Walkdown

• Procedure Review

The SW System Inspections program provides reasonable assurance that corrosion

(including microbiologically-influenced corrosion, MIC), erosion, protective coating failure,
silting, and biofouling of service water piping and components will not cause a loss of intended
Revision 45—09/30/09 NAPS UFSAR 18-19

function. The primary objectives of this program are to (1) remove excessive accumulations of
biofouling agents, corrosion products, and silt; and (2) repair defective protective coatings and
degraded SW system piping and components that could adversely affect performance. Preventive
maintenance, inspection, and repair procedures have been developed to provide reasonable
assurance that any adverse effects of exposure to service water are adequately addressed. The
addition of biocide to the SW system reduces biological growth (including MIC) that could lead
to degradation of components exposed to the service water. Additionally, a one-time measurement
of sludge buildup in the SW reservoir will be performed (Item 23, Table 18-1). This measurement
will be completed in accordance with the schedule provided in Item 23, Table 18-1.

SW System Inspections are performed to check for biofouling, damaged coatings, and
degraded material condition. Heat transfer parameters for components cooled by service water are
monitored. Visual inspections are performed to check for loss of material and changes in material
properties. Heat transfer testing is performed to identify the aging effects of loss of material and
heat transfer degradation.

Volumetric inspections are also performed to check for loss of material due to MIC.

The acceptance criteria for visual inspections are identified in the procedures that perform
the individual inspections. The procedures identify the type and degree of anomalous conditions
that are signs of degradation. In the case of service water, degradation includes biofouling as well
as material degradation. Engineering evaluations determine whether observed deterioration of
material condition is sufficiently extensive to lead to loss of intended function for components
exposed to the service water. An engineering evaluation will also determine if additional sludge
measurements in the SW reservoir are needed. The degraded condition of material or of heat
transfer capability may require prompt remediation. Occurrence of significant degradation that is
adverse to quality is entered into the Corrective Action System. Corrective action provides
reasonable assurance that conditions adverse to quality are promptly corrected.

18.2.18 Steam Generator Inspections

Steam Generator Inspections are performed in accordance with Technical Specifications
and Inservice Inspection requirements of ASME Section XI. Steam Generator Inspections plans
are based upon the guidelines established by Nuclear Energy Institute document, NEI 97-06
(Reference 4) and the Electric Power Research Institute steam generator inspection guidelines
(Reference 5). Steam generator tubing inspections are performed on a sampling basis. The sample
population inspected meets or exceeds the requirements of Technical Specifications. Qualified
techniques, equipment and personnel are used for inspections in accordance with site-specific
eddy current analysis guidelines.

Examination of steam generator sub-components other than tubes are performed as required
by the governing edition and addenda of ASME Section XI, as imposed by 10 CFR 50.55a. In
some cases the specific inspection requirements of ASME Section XI are modified by regulatory
Revision 45—09/30/09 NAPS UFSAR 18-20

commitments and approved Relief Requests. Inspections of the steam generators to check for loss
of material, cracking, and gross indications of loss of pre-load include a combination of visual
inspections, surface examinations, and volumetric examinations. Tubing inspections are
performed in accordance with ASME Section XI, Subsection IWB.

Acceptance standards for steam generator inspections are provided in ASME Section XI,
Subsections IWB-3500 and IWC-3500. Evidence of component degradation requires engineering
evaluation for determination of corrective action. Occurrence of significant degradation that is
adverse to quality will be entered into the Corrective Action System. Corrective action provides
reasonable assurance that conditions adverse to quality are promptly corrected.

18.2.19 Work Control Process

Performance testing and maintenance activities, both preventive and corrective, are planned
and conducted in accordance with the station’s Work Control Process. The Work Control Process
integrates and coordinates the combined efforts of Maintenance, Engineering, Operations, and
other support organizations to manage maintenance and testing activities. Performance testing on
heat exchangers evaluates the heat transfer capability of the components to determine if heat
transfer degradation is occurring. Maintenance activities provide opportunities for inspectors who
are Quality Maintenance Team (QMT) or Visual Test (VT) qualified to visually inspect the
surfaces (internal and external) of plant components and adjacent piping (Item 21, Table 18-1).
Adjacent piping is primarily the internal piping surfaces immediately adjacent to a system
component that is accessible through the component for visual inspection. Visual inspections
performed through the Work Control Process provide data that can be used to determine the
effectiveness of the Chemistry Control Program for Primary Systems and Chemistry Control
Program for Secondary Systems to mitigate the aging effects of cracking, loss of material, and
change of material properties.

The application for the renewed operating licenses included a commitment to have changes
made in procedures to reasonably assure that consistent inspections of components are completed
during the process of performing work control process activities (Item 15, Table 18-1).
Implementation of consistent inspections is accomplished using automated inspection instructions
for work orders involving components and structures that have been identified as requiring aging
management. The instructions consistently require inspections to identify a variety of aging
mechanisms required for the renewed operating licenses.

The Work Control Process also provides opportunities through preventive maintenance
sampling (predictive analysis) to collect lubricating oil and engine coolant samples for subsequent
analysis of contaminants that would provide early indication of an adverse environment that can
lead to material degradation.
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The inspections, testing, and sampling performed under the Work Control Process provide
reasonable assurance that the following aging effects will be detected:

• loss of material

• cracking

• heat transfer degradation

• separation and cracking/delamination

• change in material properties (Item 18, Table 18-1). The change in material properties is
specifically required to be monitored for elastomeric sealants. This monitoring occurs
during the periodic Maintenance Rule visual inspections of structures, and during routine
inspections performed for maintenance activities. These inspection and maintenance
activities are scheduled through the work control process.

The acceptance criteria for visual inspections, testing, or sampling are currently identified in
the procedures that perform the individual maintenance, testing, or sampling activity. The
procedures identify the type and degree of anomalous conditions that are signs of degradation.

Whenever evidence of aging effects exists, an engineering evaluation is performed to

determine whether the observed condition is acceptable without repair. Occurrence of significant
aging effects that is adverse to quality is entered into the Corrective Action System. If the
evaluation of an anomalous condition indicates that the occurrence was unexpected for the
operational conditions involved, the Work Control Process will be used to ensure that locations
with similar material and environmental conditions are inspected as directed by a Station
procedure (Item 29, Table 18-1).

As confirmation that the Work Control Process has inspected representative components
from each component group for which the Work Control Process is credited to manage the effects
of aging, periodic audits of inspections actually performed will be performed and, if Work Control
Process activities are found not to be representative, supplemental inspections will be performed
(Item 22, Table 18-1). Two audits of the Work Control Process are anticipated, and each will
consist of a review of the previous 10 years of historical data. These audits will be performed in
accordance with the schedule provided in Item 22, Table 18-1. Any required supplemental
inspections would be completed within 5 years after the audits are performed.

18.2.20 Corrective Action System

The Corrective Action System is a required element of the Quality Assurance Program
outlined in the Quality Assurance Topical Report (Chapter 17 of the Updated Final Safety
Analysis Report). The Quality Assurance Program implements the requirements of 10 CFR 50,
Appendix B, and is consistent with the summary in Section A.2 of NUREG-1800, Standard
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Review Plan for License Renewal. The Corrective Action System activities include the elements
of corrective action, confirmation process, and administrative controls; and is applicable to the
safety-related and non-safety-related structures, systems, and components that are within the
scope of license renewal.

18.3 TIME-LIMITED AGING ANALYSIS

As part of the application for a renewed license, 10 CFR 54.21(c) requires that an evaluation
of TLAAs for the period of extended operation be provided. The following TLAAs have been
identified and evaluated to meet this requirement.

18.3.1 Reactor Vessel Neutron Embrittlement

The reactor vessel is subjected to neutron irradiation from the core. This irradiation results
in the embrittlement of the reactor vessel materials. Analyses have been performed that address
the following:

• Upper shelf energy

• PTS

• RCS P-T operating limits

18.3.1.1 Upper Shelf Energy

The Charpy V-notch test provides information about the fracture toughness of reactor vessel
materials. 10 CFR 50 requires the CvUSE of reactor vessel beltline materials to meet Appendix G
requirements. If the USE of a reactor vessel beltline material is predicted to not meet Appendix G
requirements, then licensees must submit an analysis that demonstrates an equivalent margin of
safety at least three years prior to the time the material is predicted to not meet those
requirements.

Reactor vessel calculations have been performed which demonstrated that the upper shelf
energy values of limiting reactor vessel beltline materials at the end of the period of extended
operation meet Appendix G requirements. Thus, the TLAA has been projected to the end of the
period of extended operation and is found to be adequate.

18.3.1.2 Pressurized Thermal Shock

A limiting condition on reactor vessel integrity, known as PTS, may occur during postulated
system transients, such as a loss-of-coolant accident (LOCA) or a steam line break. Such
transients may challenge the integrity of the reactor vessel under the following conditions: severe
overcooling of the inside surface of the vessel wall followed by high re-pressurization, significant
degradation of vessel material toughness caused by radiation embrittlement, and the presence of a
critical-size defect in the vessel wall.
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The reference temperature for pressurized thermal shock (RT PTS ) is defined in
10 CFR 50.61. RTPTS values for the limiting reactor vessel materials at the end of the period of
extended operation have been recalculated by Dominion. At the end of the period of extended
operation, the calculated RTPTS values for the beltline materials are less than the applicable
screening criteria established in 10 CFR 50.61. Thus, the TLAA has been projected to the end of
the period of extended operation and is found to be adequate.

18.3.1.3 Pressure-Temperature Limits

Atomic Energy Commission (AEC) General Design Criterion (GDC) 14 of Appendix A of
10 CFR 50, Reactor Coolant Pressure Boundary, requires that the reactor coolant pressure
boundary be designed, fabricated, erected, and tested to have an extremely low probability of
abnormal leakage (or rapid failure) and of gross rupture. AEC GDC 31, Fracture Prevention of
Reactor Coolant Pressure Boundary, requires that the reactor coolant pressure boundary be
designed with sufficient margin to ensure that when stressed under operating, maintenance, and
testing conditions the boundary behaves in a non-brittle manner and the probability of rapidly
propagating fracture is minimized.

Reactor vessel neutron fluence values corresponding to the end of the period of extended
operation and reactor vessel beltline material properties were used to determine the limiting value
of reference nil ductility (RTNDT), and to calculate RCS P-T operating limits valid through the
end of a period of extended operation. Maximum allowable LTOPS power operated relief valve
lift setpoints have been developed on the basis of the P-T limits applicable to the period of
extended operation. Revised RCS P-T limit curves and LTOPS setpoints will be submitted for
review and approval prior to the expiration of the existing technical specification limits in order to
maintain compliance with the governing requirements of 10 CFR 50 Appendix G.

The TLAA has been projected to the end of the period of extended operation and is found to
be adequate.

18.3.2 Metal Fatigue

The thermal fatigue analyses of the station’s mechanical components have been identified
as TLAA.

18.3.2.1 ASME Boiler and Pressure Vessel Code, Section III, Class 1
The steam generators, pressurizers, reactor vessels, loop stop valves, reactor coolant pumps,
control rod drive mechanisms (CRDMs), and all reactor coolant system pressure boundary piping
have been analyzed using the methodology of the ASME Boiler and Pressure Vessel Code,
Section III, Class 1.

The ASME Boiler and Pressure Vessel Code, Section III, Class 1, requires a design analysis
to address fatigue and establish limits such that the initiation of fatigue cracks is precluded.
Revision 45—09/30/09 NAPS UFSAR 18-24

Experience has shown that the transients used to analyze the ASME III requirements are
often very conservative. Design transient magnitude and frequency are more severe than those
occurring during plant operation. The magnitude and number of the actual transients are
monitored. This monitoring assures that the existing frequency and magnitude of transients are
conservative and bounding for the period of extended operation, and that the existing ASME III
equipment will perform its intended functions for the period of extended operation. A cycle
counting program (Section 18.4.2) is in place to provide reasonable assurance that the actual
transients are smaller in magnitude and within number of the transients used in the design.

Fatigue analyses for the steam generators, pressurizers, reactor vessels, reactor coolant
pumps, CRDMs, and all RCS pressure boundary piping have been evaluated and determined to
remain valid for the period of extended operation.

Fatigue analyses for the reactor vessel closure studs and the loop stop valves have been
re-analyzed. The analyses for these components have been projected to be valid for the period of
extended operation.

18.3.2.2 Reactor Vessel Underclad Cracking

In early 1971, an anomaly was identified in the heat-affected zone of the base metal in a
European-manufactured reactor vessel. A generic fracture mechanics evaluation by Westinghouse
demonstrated that the growth of underclad cracks during a 40-year plant life would be
insignificant.

The evaluation was extended to 60 years using fracture mechanics evaluation based on a
representative set of design transients. The occurrences were extrapolated to cover 60 years of
service life. This 60-year evaluation shows insignificant growth of the underclad cracks and is
documented in WCAP-15338 (Reference 21). The plant-specific design transients are bounded by
the representative set used in the evaluation.

The analysis associated with reactor vessel underclad crack growth has been projected to
the end of the period of extended operation and has been found to be acceptable.

18.3.2.3 ANSI B31.1 Piping

The balance-of-plant piping is designed to the requirements of ANSI B31.1, Power Piping.

ANSI B31.1 design requirements assume a stress range reduction factor in order to provide
conservatism in the piping design while accounting for fatigue due to thermal cyclic operation.
This reduction factor is 1.0, provided the number of anticipated cycles is limited to 7000
equivalent full-temperature cycles. A piping system would have to be thermally cycled
approximately once every three days over a plant life of 60 years to reach 7000 cycles.
Considering this limitation, a review of the ANSI B31.1 piping within the scope of license
renewal has been performed to identify those systems that operate at elevated temperature and to
Revision 45—09/30/09 NAPS UFSAR 18-25

establish their cyclic operating practices. Under current plant operating practices, piping systems
within the scope of license renewal are only occasionally subject to cyclic operation. Typically,
these systems are subjected to continuous steady-state operation. Significant variation in
operating temperatures occur only during plant heatup and cooldown, during plant transients, or
during periodic testing.

The analyses associated with ANSI B31.1 piping fatigue have been evaluated and
determined to remain valid for the period of extended operation except for sample lines for the hot
and cold legs. The analyses associated with sample lines for the hot and cold legs have been
projected to be valid to the end of the period of extended operation.

18.3.2.4 Environmentally Assisted Fatigue

GSI-190 (Reference 6) identifies a NRC staff concern about the effects of reactor water
environments on reactor coolant system component fatigue life during the period of extended
operation. The reactor water’s environmental effects as described in GSI-190, are not included in
the CLB. As a result, the criterion specified in 10 CFR 54.3(a)(6) is not satisfied. Hence,
environmental effects are not TLAAs. GSI-190, which was closed in December 1999, has
concluded that environmental effects have a negligible impact on core damage frequency, and as
such, no generic regulatory action is required (Reference 7). However, as part of the closure of
GSI-190, the NRC has concluded that licensees who apply for license renewal should address the
effects of coolant environment on component fatigue life as part of their aging management
programs. As demonstrated in the preceding sections, fatigue evaluation in the original transient
design limits remain valid for the period of extended operation. Confirmation by transient cycle
counting will ensure that these transient design limits are not exceeded. Secondly, the reactor
water’s environmental effects on fatigue life were evaluated using the most recent data from
laboratory simulation of the reactor coolant environment.

As a part of the industry effort to address environmental effects for operating nuclear power
plants during the current 40-year licensing term, Idaho National Engineering Laboratories
evaluated, in NUREG/CR-6260, “Application of NUREG/CR-5999 Interim Fatigue Curves to
Selected Nuclear Power Plant Components” (Reference 8), fatigue-sensitive component locations
at plants designed by all four U. S. Nuclear Steam Supply System vendors. The pressurized water
reactor calculations, especially the early-vintage Westinghouse PWR calculations, are directly
relevant to the Dominion stations. The description of the “Older Vintage Westinghouse Plant”
evaluated in NUREG/CR-6260 applies to the North Anna station. In addition, the transient cycles
considered in the evaluation match or bound the design. The results of NUREG/CR-6260
analyses, and additional data from NUREG/CR-6583 (Reference 9) and NUREG/CR-5704
(Reference 10), were then utilized to scale up the plant-specific cumulative usage factors (CUF)
for the fatigue-sensitive locations to account for environmental effects.
Revision 45—09/30/09 NAPS UFSAR 18-26

Based on these adjusted CUFs (using the environmental fatigue penalty factor), it has been
determined that the surge line connection at the reactor coolant system’s hot leg pipe exceeds the
design threshold of 1.0. As a consequence, management of environmentally assisted fatigue is
required. Additionally, the CUFs that were adjusted for environmental effects for the safety
injection (SI) and charging line nozzles initially were determined to exceed the design threshold
of 1.0. Subsequent fatigue evaluations (Reference 35), using the methodology of ASME
Section III, NB-3200, confirm that the CUFs for the SI and charging line nozzles do not exceed
the ASME Code allowable value of 1.0, including the effects of the reactor water environment.
Therefore, the SI and charging line nozzles will not require enhanced inspections for the
management of environmentally assisted fatigue.

The approach to manage environmentally assisted fatigue for the surge line will be
developed from one or more of the following options and submitted to the NRC for review prior
to the period of extended operation (Items 24 & 25, Table 18-1):

1. Further refinement of the fatigue analysis (e.g., NB-3200 analysis) to lower the CUFs to
below 1.0, or
2. Repair of the affected locations, or
3. Replacement of the affected locations, or
4. Inspection of the affected locations.
The surge line weld at the hot leg pipe connection will be included (Item 2, Table 18-1) in
an Augmented Inspection Activities (Section 18.2.1). Baseline inspections of the surge line welds
are planned prior to entry into the period of extended operation. Inspections will also occur once
per 40-month ISI period, thereafter. The results of these inspections and the results of planned
research by the EPRI-sponsored Materials Reliability Program will be utilized to assess the
appropriate approach for addressing environmentally assisted fatigue of the surge lines during the
period of extended operation.

The use of inspections (Option 4) to manage environmentally assisted fatigue during the
period of extended operation, requires inspection details such as scope, qualification, method, and
frequency be provided to the NRC for review prior to entering the period of extended operation.
The NRC review ensures that the inspection intervals for the periodic inspection of the affected
locations would be determined by a method accepted by the NRC.

Implementation of one or more of the above listed options will ensure that the potential
effects of the reactor water environment have been addressed for the period of extended operation
as required by GSI-190.
Revision 45—09/30/09 NAPS UFSAR 18-27

18.3.3 Environmental Qualification of Electric Equipment

10 CFR 54.49 requires that each holder of a nuclear power plant operating license establish
a program for qualifying safety-related electric equipment. Such a program has been implemented
at the station and is invoked by Administrative Procedure. Analyses and tests that qualify
safety-related equipment for the period of extended operation are considered TLAAs.

The Environmental Qualification (EQ) Program (Section 18.4.1) requires that all electrical
equipment important to safety located in a harsh environment shall be managed through the
period of extended operation.

18.3.4 Containment Liner Plate

The accumulated fatigue effects of applicable liner loading conditions were evaluated in
accordance with Paragraph N-415 of the ASME Boiler and Pressure Vessel Code, Section III,
1968. The evaluation was based on 1000 cycles of operating pressure variations, 4000 cycles of
operating temperature variations, and 20 design earthquake cycles. The operating pressure
variations are anticipated to be less than 100 and temperature variations are anticipated to be less
than 400 for forty years of operation. Extrapolating these anticipated values for sixty years of
operation results in 150 pressure variations and 600 temperature variations (Reference
Table 3.8-7). The number of design cycles was conservatively increased to 1500 cycles of
operating pressure variations, 6000 cycles of operating temperature variation, and 30 design
earthquake cycles by using a multiplication factor of 1.5, to account for the period of extended
operation.

A review of the identified calculations has determined that the increase in the number of
cycles due to the period of extended operation is acceptable. Effects of the Containment Type A
pressure tests on fatigue of the Containment liner plate have been included in the evaluation.
Therefore, the Containment liner is adequate for a 60-year operating period as currently designed.
The analyses associated with the Containment liner plate have been revised and projected to be
valid for the period of extended operation.

18.3.5 Plant-Specific Time-Limited Aging Analyses

18.3.5.1 Crane Load Cycle Limit
The following are cranes included in license renewal scope and in NUREG-0612
(Reference 11):

• Containment polar cranes

• Containment annulus monorails

• Fuel handling bridge crane

• Spent fuel crane

Revision 45—09/30/09 NAPS UFSAR 18-28

• Auxiliary Building monorails

NUREG-0612 requires that the design of heavy load overhead handling systems meet the
intent of Crane Manufacturers Association of America, Inc. (CMAA) Specification #70. The
crane load cycle provided in CMAA-70 has been identified as a TLAA, with the most limiting
number of loading cycles being 100,000.

The most frequently used cranes are spent fuel cranes. Each of these cranes will experience
approximately 25,000 cycles of half-load lifts to support the refueling of both units over a 60-year
period. In addition, the crane is used to load new fuel into the fuel pool, to perform the various
rearrangements required by operations support, to accommodate inspections by fuel vendors, and
to load spent fuel casks. In such service, the crane is conservatively expected to make a total of
50,000 half-load lifts in a 60-year period.

Therefore, the analyses associated with crane design, including fatigue, are valid for the
period of extended operation.

18.3.5.2 Reactor Coolant Pump Flywheel

During normal operation, the reactor coolant pump flywheel possesses sufficient kinetic
energy to produce high-energy missiles in the unlikely event of failure.

The aging effect of concern is fatigue crack initiation in the flywheel bore keyway. An
evaluation of a failure over the period of extended operation has been performed. It demonstrates
that the flywheel design has a high structural reliability with a very high flaw tolerance and
negligible flaw crack growth over a 60-year service life (Reference 12).

The analysis associated with the structural integrity of the reactor coolant pump flywheel
has been evaluated and determined to be valid for the period of extended operation.

18.3.5.3 Leak-Before-Break
Westinghouse (Westinghouse Owners Group) tested and analyzed crack growth with the
goal of eliminating reactor coolant system primary loop pipe breaks from plant design bases. The
objective of the investigation was to examine mechanistically, under realistic yet conservative
assumptions - whether a postulated crack causing a leak, will grow to become unstable and lead to
a full circumferential break when subjected to the worst possible combinations of plant loading.

The detailed evaluation has shown that double-ended breaks of reactor coolant pipes are not
credible, and as a result, large LOCA loads on primary system components will not occur. The
overall conclusion of the evaluation was, that, under the worst combination of loading, including
the effects of safe shutdown earthquake, the crack will not propagate around the circumference
and cause a guillotine break. The plant has leakage detection systems that can identify a leak with
margin, and provide adequate warning before the crack can grow.
Revision 45—09/30/09 NAPS UFSAR 18-29

The concept of eliminating piping breaks in reactor coolant system primary loop piping has
been termed “leak-before-break” (LBB).

In 1986, Westinghouse performed an LBB analysis of the primary loop piping. Two TLAAs
related to LBB have been identified: fatigue crack growth and thermal aging of cast austenitic
stainless steel. The original fatigue crack growth analysis has been performed for the design
transient cycles and with consideration of thermal aging effect for forty years. The steam
generator primary nozzles to safe-end welds in the primary loop piping that have been analyzed
for LBB are the only components fabricated with Alloy 82/182-weld material for NAPS 1 and 2.
Dominion will continue to participate in the ongoing NRC/industry program on Alloy
82/182-weld material and will implement the findings/resolution from this effort, as appropriate
(Item 20, Table 18-1).

To maintain the plant’s LBB design basis, the thermal aging effect for 60 years has been
revalidated. The change in the material property has been found to be insignificant. Since the
number of design transient cycles will not be exceeded during 60 years of operation, the LBB
analysis is projected to be valid for the period of extended operation.

18.3.5.4 Spent Fuel Pool Liner

The spent fuel pool liner located in the Fuel Building is needed to prevent a leak to the
environment. A design calculation has been identified which documents that the spent fuel pool
design meets the general industry criteria. The calculation includes a fatigue analysis to add a
further degree of confidence.

The normal thermal cycles occur at each refueling, resulting in 80 cycles for both units in
60 years. Total number of thermal cycles is expected to be 90, which includes normal, upset,
emergency, and faulted conditions.

The calculations show that the allowable thermal cycles for spent fuel pool liner for the
most severe thermal condition, which includes a loss of cooling, is 100.

Therefore, the existing calculations remain valid for the period of extended operation.

18.3.5.5 Piping Subsurface Indications

Calculations have been identified that addressed piping subsurface indications detected by
inspections, performed in accordance with ASME Section XI. Section XI provides the acceptance
criteria for various flaw orientations, locations and sizes. The calculations determined the number
of thermal cycles required for the flaws to reach unacceptable size.

Required cycles for the flaws to reach an unacceptable size are 20,700 or higher.
Revision 45—09/30/09 NAPS UFSAR 18-30

Since it is expected that the number of the cycles experienced by the piping will not exceed
these values for sixty years of operation, the analyses have been determined to remain valid for
the period of extended operation.

18.3.5.6 Reactor Coolant Pump and ASME Code Case N-481

Periodic volumetric inspections of the welds in the primary loop pump casings in
commercial nuclear power plants are required by Section XI of the ASME Boiler and Pressure
Vessel Code. Since the reactor coolant pump casings are inspected prior to being placed in
service, and no significant mechanisms exist for crack initiation and propagation; it has been
concluded that the inservice volumetric inspection could be replaced with an acceptable alternate
inspection. In recognition of this conclusion, ASME Code Case N-481, Alternative Examination
Requirements for Cast Austenitic Pump Casings, provides an alternative to the volumetric
inspection requirement. The code case allows the replacement of volumetric examinations of
primary loop pump casings with fracture mechanics based integrity evaluations - Item (d) of the
code case - supplemented by specific visual examinations. The analysis has been performed on
the reactor coolant pump casing integrity in accordance with the ASME Code Case N-481
requirements. The analysis has been projected to be valid for 60 years.

18.3.6 Exemptions
The requirements of 10 CFR 54.21(c) stipulate that the application for a renewed license
should include a list of plant-specific exemptions granted pursuant to 10 CFR 50.12 and that are
based on TLAA, as defined in 10 CFR 54.3. Each active 10 CFR 50.12 exemption has been
reviewed to determine whether the exemption is based on a TLAA. No plant-specific exemptions
granted pursuant to 10 CFR 50.12 and based on a TLAA as defined in 10 CFR 54.3 have been
identified.

18.4 TLAA SUPPORTING ACTIVITIES

18.4.1 Environmental Qualification Program

The EQ Program activities are in compliance with the requirements of 10 CFR 50.49. The
EQ Program will be continued throughout the period of extended operation. Electrical equipment
located in a harsh environment is evaluated for environmental qualification if they are required to
function in the conditions that will exist post-accident after being subjected to the normal effects
of aging. A harsh environment results from a LOCA or main steam line break inside Containment,
high radiation levels due to the post-LOCA effects outside Containment, or high energy line
breaks outside Containment.
Revision 45—09/30/09 NAPS UFSAR 18-31

The EQ Program is applicable to the following groups of components:

• Safety-related electrical equipment that is relied upon to remain functional during and
following a design-basis event (DBE)

• Non-safety-related electrical equipment whose failure, under postulated environmental

conditions, could prevent accomplishment of safety functions

• Certain post-accident monitoring equipment as described in Regulatory Guide 1.97

(Reference 19).

Guidance regarding environmental qualification was given in NRC Bulletin 79-01B

(Reference 20) for Unit 1 and in NUREG-0588 (Category II) (Reference 23) for Unit 2.

The Equipment Qualification Master List provides a listing of electrical equipment that is
important to safety and is located in a potentially harsh environment.

Based on the definitions of 10 CFR 54, certain EQ calculations are considered to be TLAA.
As stated in 10 CFR 54.21(c) and in NEI 95-10 (Reference 22), analyses for TLAAs utilize one of
the following three options:

i. The analyses remain valid for the period of extended operation,

ii. The analyses have been projected to the end of extended operation, or
iii. The effects of aging will be adequately managed during the period of extended operation.
For purposes of license renewal, EQ components will be evaluated utilizing Option iii in
accordance with the EQ Program. EQ concerns for license renewal will consider only those
in-scope components that have a qualified lifetime greater than 40 years. Components with a
qualified lifetime of less than 40 years already are included in a program of periodic replacement
and are not considered TLAAs.

10 CFR 50.49(j) requires that a qualification record be maintained for all equipment
covered by the EQ Rule. The qualification process verifies that the equipment is capable of
performing its safety function when subjected to various postulated environmental conditions.
These conditions include expected ranges of temperature, pressure, humidity, radiation, and
accident conditions such as chemical spray and submergence.

The process of qualifying EQ equipment includes analysis, data collection, and data
reduction with appropriate assumptions, acceptance criteria and corrective actions.

Qualification Document Reviews (QDRs) provide the basis for qualifying EQ components.
The QDRs provide the following information for each piece of equipment that is qualified:

• The performance characteristics required under normal, DBE, and post-DBE conditions.
Revision 45—09/30/09 NAPS UFSAR 18-32

• The voltage, frequency, load, and other electrical characteristics for which equipment
performance can be provided with reasonable assurance.

• The environmental conditions, including temperature, pressure, humidity, radiation,

chemical spray, and submergence, at the location where the equipment must function.

18.4.2 Transient Cycle Counting

During normal, upset, and test conditions; reactor coolant system pressure boundary
components are subjected to transient temperatures, pressures, and flows, resulting in cyclic
changes in internal stresses in the equipment. The cyclic changes in internal stresses cause metal
fatigue. Class 1 reactor coolant system components have been designed to withstand a number of
design transients without experiencing fatigue failures during their operating life. The purpose of
the Transient Cycle Counting is to record the number of normal, upset, and test events, and their
sequence that the station experiences during operation. Design transients are counted to provide
reasonable assurance that plant operation does not occur outside the design assumptions.

The Transient Cycle Counting activities are applicable to the reactor coolant system
pressure boundary components for which the design analysis assumes a specific number of design
transients. A summary of reactor coolant system design transients for which transient cycle
counting is performed is listed below:

• Heatups/Cooldowns < 100°F/Hr.

• Step load increase/decrease of 10%

• Large load reduction of 50%

• Loss of load > 15%

• Loss of AC power

• Loss of flow in one loop

• Full power reactor trip

• Inadvertent auxiliary pressurizer spray

• Inadvertent SI

• Normal charging and letdown return to service

• Charging trip with delayed return to service

The aging effect that is managed by counting transient cycles is cracking due to metal
fatigue. The Transient Cycle Counting activities monitor transient cycles that have been
Revision 45—09/30/09 NAPS UFSAR 18-33

experienced by each unit and compare the actual number of cycles to a design assumption. Any
concerns related to fatigue are mitigated, as long as the number and magnitude of transient cycles
are less than the design assumptions. Approaching a design limit may indicate a situation that is
adverse to quality, and would initiate the Corrective Action System. Subsequently, an engineering
analysis will determine the design margin remaining, taking credit for the actual magnitude of
transients and their sequence to confirm that the allowable factor has not been exceeded. If
warranted, component repair or replacement would be initiated.

18.5 REFERENCES

1. Working Draft of the NRC Standard Review Plan for the Review of License Renewal
Applications for Nuclear Power Plants.
2. Generic Letter 88-05, Boric Acid Corrosion of Carbon Steel Reactor Pressure Boundary
Components in PWR Plants, March 17, 1988.
3. NUREG-0800, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear
Power Plants - LWR Edition, US Nuclear Regulatory Commission. (Formerly
NUREG-75/087)
4. NEI 97-06, Steam Generator Program Guidelines, Revision 2, Nuclear Energy Institute.
5. PWR Steam Generator Examination Guidelines, Revision 7, Electric Power Research
Institute.
6. Generic Safety Issue (GSI)-190, Fatigue Evaluation for Metal Components for 60-year Plant
Life, U.S. Nuclear Regulatory Commission, August 1996.
7. Memorandum from Ashok C. Thadani, to William D. Travers, U.S. Nuclear Regulatory
Commission, Closeout of Generic Safety Issue 190, December 26, 1999.
8. NUREG/CR-6260, Application of NUREG/CR-5999 Interim Fatigue Curves to Selected
Nuclear Power Plant Components, U.S. Nuclear Regulatory Commission, March 1995.
9. NUREG/CR-6583, Effects of LWR Coolant Environments on Fatigue Design Curves of
Carbon and Low-Alloy Steels, U.S. Nuclear Regulatory Commission, March 1998.
10. NUREG/CR-5704, Effects of LWR Coolant Environments on Fatigue Design Curves of
Austenitic Stainless Steels, U.S. Nuclear Regulatory Commission, April 1999.
11. NUREG-0612, Control of Heavy Loads at Nuclear Power Plants, U.S. Nuclear Regulatory
Commission, July 1980.
12. WCAP-14535A, Topical Report On Reactor Coolant Pump Flywheel Inspection Elimination,
Westinghouse Electric Corporation, November 1996.
13. American National Standards Institute: ANSI B30.2-1976, Overhead and Gantry Cranes.
Revision 45—09/30/09 NAPS UFSAR 18-34

14. American National Standards Institute: ANSI B30.11-1973, Monorail Systems and
Underhung Cranes.
15. Generic Letter 89-08, Erosion/Corrosion-Induced Pipe Wall Thinning, May 2, 1989.
16. NUREG-1344, Erosion/Corrosion-Induced Pipe Wall Thinning in US Nuclear Power Plants,
April 1, 1989.
17. NSAC-202L, Recommendation for an Effective Flow Accelerated Corrosion Program,
Electric power Research Institute, April 8, 1999.
18. Generic Letter 89-13, Service Water System Problems Affecting Safety-Related Equipment,
July 18, 1989 (Supplement 1 dated 4/4/90).
19. U.S. Nuclear Regulatory Commission, Instrumentation for Light-Water-Cooled Nuclear
Power Plants to Assess Plant and Environs Conditions During and Following an Accident,
Regulatory Guide 1.97, December 1980.
20. IE Bulletin 79-01B, Environmental Qualification of Class 1E Equipment, Office of
Inspection and Enforcement, January 14, 1980 (Supplement 1 dated 2/29/80; Supplement 2
dated 9/30/80; and Supplement 3 dated 10/24/80).
21. WCAP-15338, A Review of Cracking Associated with Weld Deposited Cladding in Operating
PWR Plants, Westinghouse Electric Corporation, March 2000.
22. NEI 95-10, Industry Guidance for Implementing the Requirements of 10 CFR Part 54 - The
License Renewal Rule, Revision 2, August 2000.
23. NUREG-0588 (Category II), Interim Staff Position on Environmental Qualification of
Safety-related Electrical Equipment, August 1, 1979, (Revision 1 dated 11/1/79).
24. NUREG-1766, Safety Evaluation Report Related to the License Renewal of North Anna
Power Station, Units 1 and 2, and Surry Power Station Units 1 and 2, December 2002
25. Letter from Leslie N. Hartz (Dominion) to NRC, Dominion Position Regard Fuse Holders,
Serial No. 02-691, November 4, 2002.
26. Letter from Eugene S. Grecheck (Dominion) to NRC, Supplemental Information to Support
License Renewal, Serial No. 02-706, December 2, 2002.
27. Letter from David A. Christian (Dominion) to NRC, Request for Additional Information
License Renewal Applications, Serial No. 01-686, January 16, 2002.
28. Letter from David A. Christian (Dominion) to NRC, Request for Additional Information
License Renewal Applications, Serial No. 02-163, May 22, 2002.
29. Letter from David A. Christian (Dominion) to NRC, Request for Additional Information
License Renewal Applications, Serial No. 01-685, January 4, 2002.
Revision 45—09/30/09 NAPS UFSAR 18-35

30. Letter from David A. Christian (Dominion) to NRC, Request for Additional Information
License Renewal Applications, Serial No. 01-647, November 30, 2001.
31. Letter from David A. Christian (Dominion) to NRC, Request for Additional Information
License Renewal Applications, Serial No. 01-514, September 27, 2001.
32. Letter from David A. Christian (Dominion) to NRC, Request for Additional Information
License Renewal Applications, Serial No. 01-732, February 5, 2002.
33. Letter from David A. Christian (Dominion) to NRC, License Renewal Applications -
Submittal, Serial No. 01-282, May 29, 2001.
34. Letter from Leslie N. Hartz (Dominion) to NRC, Request for Additional Information License
Renewal Applications, Serial No. 02-332A, October 1, 2002.
35. Letter from Leslie N. Hartz (Dominion) to NRC, Engineering Evaluation Results and Closure
of Commitments for Management of Environmentally-Assisted Fatigue in Accumulator and
Charging Nozzles, Serial No. 03-616, January 6, 2004.
Revision 45—09/30/09 NAPS UFSAR 18-36

Table 18-1
LICENSE RENEWAL COMMITMENTS

Item Commitment Schedule a Source Ref.

1 Develop and implement One-time between years Table B4.0 b, 33
inspection program for buried 30-40. RAI B2.1.1-1 31
piping and valves. Additional inspections
based on results.
2 Add pressurizer surge line to Prior to Period of Extended Table B4.0, 33
Augmented Inspection Operation (Complete) RAI 4.3-7 27
Program.
3 Add core barrel hold-down Prior to Period of Extended Table B4.0 33
spring to Augmented Operation (Complete)
Inspection Program.
4 Expand scope of Civil Prior to Period of Extended Table B4.0 33
Engineering Structural Operation (Complete)
Inspection to cover License
Renewal requirements.
5 Revise plant documents to use Prior to Period of Extended Table B4.0 33
inspection opportunities when Operation (Complete)
inaccessible areas become
accessible during work
activities.
6 Incorporate NFPA-25, Prior to year 50. If testing Table B4.0 33
Section 2-3.1.1 for sprinklers. used, repeat every 10 years.
7 Develop inspection criteria for Prior to Period of Extended Table B4.0 33
non-ASME supports and Operation (Complete)
doors.
8 Develop procedural guidance Prior to Period of Extended Table B4.0 33
for inspection criteria that puts Operation (Complete)
focus on aging effects.
9 Develop and implement One-time between years Table B4.0, 33
inspection program for 30-40. Additional RAI 3.5-1, 30
infrequently accessed areas. inspections based on RAI 3.5.8-1 32
results.

a. The Period of Extended operation is the period of 20 years beyond the expiration date of each unit’s
original operating license. For North Anna Unit 1, the Period of Extended Operation is from
April 2, 2018 to April 1, 2038 and for North Anna Unit 2, from August 22, 2020 to August 21, 2040.
b. Table B4.0 is the table of Licensee Followup Actions located in the License Renewal Application for
North Anna (Reference 33).
Revision 45—09/30/09 NAPS UFSAR 18-37

Table 18-1 (continued)

LICENSE RENEWAL COMMITMENTS

Item Commitment Schedule a Source Ref.

10 Develop and implement One-time between years Table B4.0 33
inspection program for tanks. 30-40. Additional
inspections based on
results.
11 Follow industry activities On-going activity Table B4.0, 33
related to failure mechanisms (Complete) RAI 3.1.1.2-2 30
for small-bore piping. Evaluate
changes to inspection activities
based on industry
recommendations.
12 Follow industry activities On-going activity Table B4.0 33
related to core support lugs.
Evaluate need to enhance
inspection activities based on
industry recommendations.
13 Inspect representative sections One-time between years Table B4.0 33
of polar crane box girders. 30-40. Additional
inspections based on
results.
14 Follow industry activities One-time inspection Table B4.0 33
related to reactor vessel between years 30-40 on
internals issues such as void most susceptible single
swelling, thermal and neutron unit (Surry or North Anna).
embrittlement, etc. Evaluate Additional inspections
industry recommendations. based on results.
15 Implement changes into Prior to Period of Extended Table B4.0 33
procedures to assure consistent Operation (Complete)
inspection of components for
aging effects during work
activities.

a. The Period of Extended operation is the period of 20 years beyond the expiration date of each unit’s
original operating license. For North Anna Unit 1, the Period of Extended Operation is from
April 2, 2018 to April 1, 2038 and for North Anna Unit 2, from August 22, 2020 to August 21, 2040.
Revision 45—09/30/09 NAPS UFSAR 18-38

Table 18-1 (continued)

LICENSE RENEWAL COMMITMENTS

Item Commitment Schedule a Source Ref.

16 Incorporate groundwater Prior to Period of Extended RAI 3.5-2 30
monitoring into the civil Operation (Complete)
engineering structural
monitoring program. Consider
groundwater chemistry in
engineering evaluations of
deficiencies.
17 Incorporate management of Prior to Period of Extended RAI 3.5-7 30
concrete aging into the civil Operation
structural monitoring program
and the infrequently accessed
area inspection programs.
18 Incorporate management of Prior to Period of Extended RAI 3.5.6-4, 32
elastomers into the work Operation (Complete) RAI B2.2.19-3 30
control activities.
19 Develop and implement One-time between years RAI 3.6.2-1 30
inspection program for 30-40. Additional
Non-EQ cables. inspections every 10 years
thereafter.
20 Follow industry activities On-going activity RAI 4.7.3-1 29
related to Alloy 82/182 weld
material. Implement activities
based on industry
recommendations, as
appropriate.
21 Inspectors credited in the Work Prior to Period of Extended RAI B2.2.19-1 30
Control Process will be QMT Operation
or VT qualified.
22 Perform audit of work control Prior to Period of Extended RAI B2.2.19-3 30
inspections to ensure Operation and every
representation by all in-scope 10 years thereafter.
license renewal systems and to Supplemental inspections
determine need for within 5 years of audit.
supplemental inspections.

a. The Period of Extended operation is the period of 20 years beyond the expiration date of each unit’s
original operating license. For North Anna Unit 1, the Period of Extended Operation is from
April 2, 2018 to April 1, 2038 and for North Anna Unit 2, from August 22, 2020 to August 21, 2040.
Revision 45—09/30/09 NAPS UFSAR 18-39

Table 18-1 (continued)

LICENSE RENEWAL COMMITMENTS

Item Commitment Schedule a Source Ref.

23 Measure the sludge buildup in One-time between years 35 RAI 3.5.8-2 28, 32
the SW reservoir at North and 40
Anna.
24 Provide inspection details for Prior to Period of Extended RAI 4.3-7, 27
pressurizer surge line Operation RAI 4.3-6
inspections to the NRC for
review and approval.
25 Provide inspection details for Prior to Period of Extended RAI 4.3-6, 27, 34
SI and charging line Operation (Complete)
inspections to the NRC for
review and approval if analysis
is not successful in reducing
the CUF below 1.0. The
analysis described in
Reference 35 confirms the
CUFs to be below 1.0, and no
inspections are required.
26 Address NRC staff final When issued or prior to See Reference 25
guidance regarding fuse Period of Extended
holders when issued. Operation, whichever is
later.
27 Not applicable to North Anna N/A N/A N/A
28 Revise procedures for Prior to Period of Extended See Reference 26
groundwater testing to account Operation (Complete)
for possible seasonal
variations.

a. The Period of Extended operation is the period of 20 years beyond the expiration date of each unit’s
original operating license. For North Anna Unit 1, the Period of Extended Operation is from
April 2, 2018 to April 1, 2038 and for North Anna Unit 2, from August 22, 2020 to August 21, 2040.
Revision 45—09/30/09 NAPS UFSAR 18-40

Table 18-1 (continued)

LICENSE RENEWAL COMMITMENTS

Item Commitment Schedule a Source Ref.

29 Inspect similar Prior to Period of Extended RAI B2.2.19-3 30
material/environment Operation (Complete)
components, both within the
system and outside the system,
if aging identified in a location
within a system cannot be
explained by
environmental/operational
conditions at that specific
location.
30 Supplement the NFPA pressure Prior to Period of Extended RAI B2.2.7-2 28, 30
and flowrate testing credited in Operation
each LRA as part of the fire
protection program activity
with the work control process
activity in order to manage
aging effects for the fire
protection system piping.

a. The Period of Extended operation is the period of 20 years beyond the expiration date of each unit’s
original operating license. For North Anna Unit 1, the Period of Extended Operation is from
April 2, 2018 to April 1, 2038 and for North Anna Unit 2, from August 22, 2020 to August 21, 2040.