ML042660542
| ML042660542 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  (DPR-024, DPR-027) |
| Issue date: | 09/23/2004 |
| From: | Thatcher D NRC/NRR/DIPM/IPSB |
| To: | Kuo P NRC/NRR/DRIP/RLEP |
| McIntyre R, NRR/DIPM, 415-3215 | |
| References | |
| TAC MC2099, TAC MC3100 | |
| Download: ML042660542 (7) | |
Text
September 23, 2004 MEMORANDUM TO: P.T. Kuo, Program Director License Renewal and Environmental Impacts Division of Regulatory Improvement Programs
/RA/
FROM:
Dale F. Thatcher, Section Chief Plant Support Branch Division of Inspection Program Management Office of Nuclear Reactor Regulation
SUBJECT:
AUDIT TRIP REPORT REGARDING THE NUCLEAR MANAGEMENT COMPANY, LLC, LICENSE RENEWAL APPLICATION FOR THE POINT BEACH NUCLEAR PLANT, UNITS 1 and 2, dated FEBRUARY 25, 2004 Plant Name:
Point Beach Nuclear Plant, Units 1 and 2 Utility Name:
Nuclear Management Company, LLC Docket No.(s):
50-266 (DPR-24) 50-301 (DPR-27)
TAC No.(s):
MC2099 MC2100 Review Branch:
Plant Support Branch (IPSB)
Review Status:
Pending resolution of Open Items From June 21 - 24, 2004, the Plant Support Branch performed an audit of the Nuclear Management Company, LLC, (the applicant) license renewal scoping and screening methodology developed to support the Point Beach Nuclear Plant Units 1 and 2, license renewal application (LRA) dated February 25, 2004. The focus of the staffs audit was evaluation of the applicants administrative controls governing implementation of the LRA scoping and screening methodology and review of the technical basis for selected scoping and screening results for various plant systems, structures, and components.
The team also reviewed quality attributes for aging management programs, training for license renewal project personnel, and quality controls applied to the LRA development process. A trip report containing a summary of the audit results is attached.
Should you require additional information, please contact Richard McIntrye, of my staff, at 415-3215.
Attachment:
As stated CONTACT:
Richard McIntrye, NRR/DIPM/IPSB 301-415-3215
September 23, 2004 MEMORANDUM TO: P.T. Kuo, Program Director License Renewal and Environmental Impacts Division of Regulatory Improvement Programs Office of Nuclear Reactor Regulation
/RA/
FROM:
Dale F. Thatcher, Section Chief Plant Support Branch Division of Inspection Program Management Office of Nuclear Reactor Regulation
SUBJECT:
AUDIT TRIP REPORT REGARDING THE NUCLEAR MANAGEMENT COMPANY, LLC, LICENSE RENEWAL APPLICATION FOR THE POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2, DATED FEBRUARY 25, 2004 Plant Name:
Point Beach Nuclear Plant, Units 1 and 2 Utility Name:
Nuclear Management Company, LLC.
Docket No.(s):50-266 (DPR-24) 50-301 (DPR-27)
TAC No.(s):
MC2099 MC2100 Review Branch:
Plant Support Branch (IPSB)
Review Status:
Pending resolution of Open Items From June 21 - 24, 2004, the Plant Support Branch performed an audit of the Nuclear Management Company, LLC, (the applicant) license renewal scoping and screening methodology developed to support the Point Beach Nuclear Plant Units 1 and 2, license renewal application (LRA) dated February 25, 2004. The focus of the staffs audit was evaluation of the applicants administrative controls governing implementation of the LRA scoping and screening methodology and review of the technical basis for selected scoping and screening results for various plant systems, structures, and components.
The team also reviewed quality attributes for aging management programs, training for license renewal project personnel, and quality controls applied to the LRA development process. A trip report containing a summary of the audit results is attached.
Should you require additional information, please contact Richard McIntrye, of my staff, at 415-3215.
Attachment:
As stated CONTACT:
Richard McIntrye, NRR/DIPM/IPSB 301-415-3215 DISTRIBUTION:
IEPB R/F BBoger MMorgan, LRPM ADAMS: ML042660542 DOCUMENT NAME:C:\\ORPCheckout\\FileNET\\ML042660542.wpd To receive a copy of this document, indicate in the box: "C" = Copy without enclosures "E" = Copy with enclosures "N" = No copy OFFICE IPSB/DIPM IPSB/DIPM IPSB/DIPM NAME FTalbot RMcIntrye DThatcher DATE 9/23/04 9/23/04 9/23/04 OFFICIAL RECORD COPY
Attachment Trip Report Regarding the Nuclear Management Company, LLC, License Renewal Application for the Point Beach Nuclear Plant, Units 1 and 2, dated February 25, 2004 1.
Introduction From June 21-24, 2004, Steven Dennis, Richard McIntyre, and Frank Talbot of the Plant Support Branch, audited the Nuclear Management Company, LLC, (the applicant) license renewal scoping and screening methodology developed to support the Point Beach Nuclear Plant, Units 1 and 2 license renewal application (LRA). The audit was performed at the Point Beach Nuclear Plant (PBNP) located in Two Rivers, Wisconsin. The focus of the teams audit was evaluation of the applicants administrative controls governing implementation of the LRA scoping and screening methodology and review of the technical basis for selected scoping and screening results for various plant structures and components (SCs). The team also reviewed quality attributes for aging management programs, training for license renewal project personnel, and quality controls applied to the LRA development process.
===2.
Background===
Title 10 of the Code of Federal Regulations, Part 54 (10 CFR Part 54), Requirements for Renewal of Operating Licenses for Nuclear Power Plants, Section 54.21, Contents of Application Technical Information, requires that each application for license renewal contain an integrated plant assessment (IPA). Furthermore, the IPA must list and identify those structures and components that are subject to an aging management review (AMR) from the SCs that are within the scope of license renewal. 10 CFR 54.4(a) identifies the plant SCs within the scope of license renewal. Structures and components within the scope of license renewal are screened to determine if they are long-lived, passive equipment that is subject to an AMR in accordance with 10 CFR 54.21(a)(1).
3.
Scoping Methodology The scoping evaluations for the PBNP LRA were performed by the applicants license renewal project personnel. The team conducted detailed discussions with the applicants license renewal project management personnel and reviewed documentation pertinent to the scoping process. The team assessed if the scoping methodology outlined in the LRA and implementation procedures was appropriately implemented and if the scoping results were consistent with current licensing basis requirements. The team also reviewed the system scoping and screening methodology and sampled the methodology results for the Main Steam (MS) and Emergency Power (EP) systems.
In general, the team determined that the applicants overall approach to license renewal SSC scoping appeared to be adequate. However, the team identified three questions associated with the applicants methodology for performing license renewal scoping of nonsafety-related SSCs pursuant to the requirements of 10 CFR 54.4(a)(2) where additional information will be required to complete the LRA review. These questions are documented in a draft request for additional information and are briefly described as follows.
Provide additional information to adequately define short term exposure duration for low and moderate energy piping failures and how it relates to scoping and screening of 10 CFR 54.4(a)(2) piping that could cause these types of failures.
Provide additional information to adequately describe and define what is meant by the term first equivalent anchor and how it relates to the scoping and screening of 10 CFR 54.4(a)(2) non-safety related piping and supports.
Provide additional information to adequately describe how the falling of piping sections is not considered credible, and why a particular piping section itself would not be in-scope for 10 CFR 54.4(a)(2) due to physical impact hazard. Also, describe how the management of flow accelerated corrosion (FAC) relates to the scoping and screening of 10 CFR 54.4(a)(2) Seismic II/I piping systems that could cause these types of failures.
4.
Screening Methodology The team reviewed the methodology used by the applicant to determine if mechanical, civil/structural, and electrical/instrumentation and controls components within the scope of license renewal would be subject to further AMR. The applicant provided the staff with a detailed discussion of the processes used for each discipline and provided administrative documentation that described the screening methodology. The team also reviewed a sample of the screening results reports for the Main Steam and Emergency Power systems since they met the requirements of 10 CFR 54.4(a)(1-3).
The Main Steam system meets 54.4(a)(1) since it senses and provides process conditions and generates signals for reactor trip and engineered safety features actuation, provides emergency heat removal from the Reactor Coolant System (RCS) using secondary heat capability, and provides a primary containment boundary; and 54.4(a)(2) because the system contains non safety-related components credited for mitigating the effects of a high-energy line break, and spatial interaction associated with 54.4(a)(1) components. The Emergency Power system meets 54.4(a)(1) since it senses process conditions and generates signals for reactor trips and engineered safety features, provides electrical power to safety class 1, 2, and 3 components, and during accidents provides signals for post-accident monitoring variables; 54.4(a)(2) because the system contains non safety-related components credited for mitigating the effects of a high-energy line break, and spatial interaction associated with 54.4(a)(1) components; and 54.4(a)(3) because it contains environmentally qualified equipment and supports station blackout. The team noted that the applicants screening process was performed in accordance with their written requirements and was consistent with the guidance provided in the staffs License Renewal-Standard Review Plan and Nuclear Energy Institute (NEI) 95-10, Revision 3.
The team determined that the screening methodology was consistent with the requirements of the Rule, and that the screening methodology would identify SSCs that met the screening criteria of 10 CFR 54.21(a)(1).
5.
Aging Management Program Quality Assurance Attributes The team evaluated the quality attributes of the applicants Aging Management Program (AMP) activities described in Appendix A, UFSAR Supplement, and Appendix B, Aging Management Programs, of the LRA using the guidance contained in NUREG-1800, Section A.2, Quality Assurance for Aging Management Programs (Branch Technical Position IQMB-1). Based on the staffs evaluation, the quality attributes (corrective action, confirmation process, and administrative controls) described in Appendix A, UFSAR Supplement, and Appendix B, Section B1.3, Quality Assurance Program and Administrative Controls, of the LRA for all programs credited for managing aging effects, were consistent with Branch Technical Position IQMB-1.
6.
Quality Assurance Controls on the LRA Scoping and Screening Methodology The team reviewed the QA controls used by the applicant to provide reasonable assurance that the LRA scoping and screening methodologies were adequately implemented. The QA requirements the applicant applied to the development of the LRA were addressed in Section 4.14 of procedure LRPP 1-1, License Renewal Project Procedure. The procedure stated that all work performed for the LR project shall be accomplished in accordance with the requirements of the applicants Nuclear Quality Assurance Program (NQAP) and supporting procedures. The NQAP satisfied the requirements of 10 CFR 50 Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants. The audit team determined that the applicant utilized the following QA processes during the LRA development:
Implementation of the scoping and screening methodology was governed by written procedures and guidelines.
All final scoping and screening information was developed by a technically qualified staff member(s) and independently reviewed by additional technical staff member(s) prior to being reviewed and approved by the program manager or designee.
The applicant developed a database for documenting license renewal information identified during scoping and screening evaluations. This database was considered the formal quality records of the LR implementation process, and was controlled in accordance with written instructions.
The LRA was reviewed and approved by the Plant Operations Review Committee (PORC) and the Offsite Safety Review Committee (OSRC) prior to NRC submittal.
The applicant conducted an informal assessment of the LRA dated December 18, 2003, which looked at areas that included Aging Management Programs and Operating Experience, Environmental review, Time-Limited Aging Analysis, and Project Management. The assessment resulted in recommendations for the areas assessed and follow-up in the corrective action program.
The applicant conducted an evaluation of the quality assurance program elements for license renewal, LR-TR-505-QAPELE, Rev.0, dated January 12, 2004, which concluded that the QA processes implemented were in accordance with the requirements of 10 CFR Appendix B and ANSI N18.7-1976.
The team concluded that these QA activities provided adequate assurance that LRA development activities were performed consistently with the LRA descriptions.
7.
Document Review of LRA Personnel Training Records The team reviewed the following LRAs engineering staff procedures, training sessions and samples of training records for LRA plant engineering personnel during the LRA audit at PBNP.
NMC Phase 2 and Phase 3 Training Sessions NMC Engineering Support Personnel Qualification Guides, License Renewal Engineering Training Guide dated May 30, 2001.
NMC License Renewal Engineering Training Guide, Attachment 1, PBNP License Renewal Study List, License Renewal Group Procedures NMC License Renewal Engineering Training Guide, Attachment 2, PBNP License Renewal Study List, NUREG-1800 Standard Review Plan for License Renewal: Reading Assignments NMC License Renewal Engineering Training Guide, Attachment 3, PBNP License Renewal Study List, NUREG-1801 Generic Aging Lessons Learned:
Reading Assignments Training Records for 4 LR Engineering Personnel who completed NMC Engineering Support Personnel Qualification Guides, License Renewal Engineering Training Guide.
The team found that the LRA training sessions and qualification guides covered all aspects of the rule for scoping and screening methodology, scoping and screening results, and SSCs subject to an aging management review (AMR) and aging management programs (AMP) in accordance with 10 CFR 54. The team found that the applicants engineering staff were qualified through training and experience as LR experts in the mechanical, electrical, and civil/structural areas. These individuals were then used by the applicant to complete the scoping and screening results for system and components that were covered under those three areas that were subject to an AMR or AMP. The team found that the training session documents and the LR Engineering Training Guide for LRA engineering personnel encompassed all aspects of LR and the guidance documents used to implement them. The team also found that the applicants engineering personnel training records were completed by July 2002 in preparation for completion of the PBNP LRA and that the applicant subscribed to the SCIENTECH License Renewal Community database which documented the NRC staff request for additional information (RAI), industry response to RAIs, and any new issues related to LR guidance. Based on a review of all this information, the team concluded that the applicants LR training documents and records were comprehensive and complete.
8.
Exit Meeting A public exit meeting was held with the applicant on June 24, 2004, to discuss the results of the scoping and screening methodology audit. The audit team provided an overview of the areas reviewed during the audit and identified areas where additional information was needed to support the staffs LRA review. The staff concluded that on the basis of this review, and pending acceptable resolution of the requests for additional information, there is reasonable assurance that the applicants methodology for identifying SCs within the scope of license renewal and SCs requiring an AMR is consistent with the requirements of 10 CFR 54.4 and 10 CFR 54.21(a)(1). A draft request for additional information has been forwarded by the IPSB to the NRR License Renewal and Environmental Impacts Program Director.