ML061220630

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License Renewal Audit and Review Plan for Plant Aging Management Review and Programs for the Pilgrim Nuclear Power Plant, Docket Number 50-293
ML061220630
Person / Time
Site: Pilgrim
Issue date: 04/26/2006
From:
Advanced Technologies & Labs International
To:
NRC/NRR/ADRO/DLR
Davis J
References
Download: ML061220630 (67)
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Audit and Review Plan forPlant Aging Management Reviews and Programs Pilgrim Nuclear Power StationDocket No.: 50-293April 26, 2006Prepared byAdvanced Technologies and Laboratories International, Inc.20010 Century Blvd., Suite 500Germantown, MD 20874Contract No. DR-03-06-030Prepared forDivision of License RenewalOffice of Nuclear Reactor RegulationU.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 TABLE OF CONTENTS1.INTRODUCTION.........................................................12.BACKGROUND.........................................................2 3.OBJECTIVES...........................................................4 4.

SUMMARY

OF INFORMATION PROVIDED IN THE LICENSE RENEWAL APPLICATION54.1Aging Management Review Results....................................54.1.1PNPS AMR Comparison with GALL...............................6 4.1.2Plant-Specific Programs.......................................104.2Time-Limited Aging Analyses........................................105.OVERVIEW OF AUDIT, REVIEW, AND DOCUMENTATION PROCEDURE.......125.1Aging Management Programs........................................125.2Aging Management Reviews.........................................135.3Time-Limited Aging Analyses........................................13 5.4NRC-Approved Precedents..........................................145.5UFSAR Supplement Review.........................................155.6Documents Reviewed by the Project Team..............................15 5.7Public Exit Meeting................................................15 5.8Documentation Prepared by the Project Team...........................155.8.1Audit and Review Plan........................................155.8.2Worksheets................................................155.8.3Questions..................................................16 5.8.4Work Packages.............................................16 5.8.5Requests for Additional Information..............................165.8.6Audit and Review Report......................................165.8.7Safety Evaluation Report input..................................166.PLANNING, AUDIT, REVIEW, AND DOCUMENTATION PROCEDURE.............176.1Planning Activities.................................................176.1.1Schedule for Key Milestones and Activities........................176.1.2Work Assignments...........................................17 6.1.3Training and Preparation......................................186.2Aging Management Program (AMP) Audits and Reviews...................186.2.1Types of AMPs..............................................18 6.2.2Scope of AMP elements to be audited and reviewed.................186.2.3Plant AMPs that Are Consistent with the GALL Report...............196.2.4Plant-Specific AMPs..........................................216.3Aging Management Review (AMR) Audits and Reviews....................226.3.1Plant AMRs that Are Consistent with the GALL Report...............226.3.2AMRs Based on NRC-Approved Precedents.......................256.4 Time-Limited Aging Analyses (TLAA) Audits and Reviews..................266.4.1 Identify Generic TLAA Issues...................................276.4.2 Metal Fatigue Analyses........................................29 6.4.3 Environmental Qualification Analyses for Electrical Components.........316.4.4 Other Plant-Specific TLAAs.....................................336.5Audit and Safety Review Documentation................................35 6.5.1Audit and Review Report......................................366.5.2Safety Evaluation Report Input..................................366.6Documents Reviewed and Document Retention..........................41Appendix A - Project Team Membership........................................A-1Appendix B - RLRC Schedule for Pilgrim LRA Safety Review........................B-1Appendix C - Aging Management Program Assignments ..........................C-1Appendix D - Aging Management Review Assignments............................D-1Appendix E - Time-Limited Aging Analysis Review Assignments.....................E-1Appendix F - Consistent with Gall Report AMP Audit/Review Worksheet...............F-1Appendix G - Plant-specific AMP Audit/Review Worksheet..........................G-2Appendix H - AMR Comparison Worksheets....................................H-1Appendix I - Acronyms, Abbreviations, and Initialisms.............................I-1TABLESTable 1. Aging Management Program Element Descriptions.........................42Table 2. Notes for License Renewal Application Tables 3.X.2-Y......................43FIGURESFigure 1. Audit of AMPs that are Consistent with the GALL Report....................44Figure 2. Audit of Plant-Specific AMPs .........................................45 Figure 3. Review of AMRs that are Consistent with the GALL Report ..................46Figure 4. Review of AMRs Using NRC-Approved Precedents ........................47Figure 5. Review of TLAAs and Exemptions (from NEI 95-10, Revision 6) ..............48 1Audit and Review Plan forPlant Aging Management Reviews and Programs1.INTRODUCTIONBy letter dated January 25, 2006 (ADAMS Accession Number ML060300028), Entergy NuclearOperations, Inc., submitted to the U.S. Nuclear Regulatory Commission (NRC) its application for renewal of Operating License DPR-35 for Pilgrim Nuclear Power Station (PNPS.) The applicant requested renewal of the operating license for an additional 20 years beyond the 40-year current license term. In support of the staff's safety review of the license renewal application (LRA) for PNPS, theDivision of License Renewal (DLR), Branch C (RLRC), will lead a project team that will audit and review selected aging management reviews (AMRs) and associated aging management programs (AMPs), and time-limited aging analyses (TLAAs) developed by the applicant to support its LRA for PNPS. The project team will include both NRC staff and engineers provided by Advanced Technologies and Laboratories International, Inc. (ATL), RLRC's technical assistance contractor. Appendix A, "Project Team Membership," lists the project team members. This document is the RLRC plan for auditing and reviewing plant aging management reviews and aging management programs for PNPS. The project team will audit and review its assigned AMPs, AMRs, and TLAAs against therequirements of Title 10 of the Code of Federal Regulations, Part 54 (10 CFR Part 54),

"Requirements for Renewal of Operating Licenses for Nuclear Power Plants;" the guidance provided in NUREG-1800, Revision 1, "Standard Review Plan for Review of License Renewal Application for Nuclear Power Plants" (SRP-LR), dated September 2005; the guidance provided in NUREG-1801, Revision 1, "Generic Aging Lessons Learned (GALL) Report," dated September 2005; and this plan. For the scope of work defined in this audit plan, the project team will verify that the applicant's aging management activities and programs will adequately manage the effects of aging on structures and components, so that their intended functions will be maintained consistent with the PNPS current licensing basis (CLB) for the period of extended operation.The team will perform its work at NRC Headquarters, Rockville, Maryland; at ATL's offices inGermantown, Maryland; and at the PNPS site near Plymouth, Massachusetts. The project team will perform its work in accordance with the schedule shown in Appendix B, "Schedule."

The team will conduct a public exit meeting at or near the applicant's offices in Plymouth, Massachusetts, after it completes its onsite work.This plan includes the following information:*Introduction and background. Summary of the license renewal requirements, asstated in the Code of Federal Regulations, and a summary of the documents that theproject team will use to conduct the audit and review process described in this plan.*Objectives. The objectives of the audits and reviews addressed by this plan.

Pilgrim Nuclear Power StationAMP and AMR Audit and Review Plan 2*Summary of Information Provided in License Renewal Application. Description ofthe information contained in the license renewal application for PNPS that is applicableto this plan.*Overview of the Audit, Review, and Documentation Procedure. Summary of theprocess the project team will follow to audit and review the LRA information that is withinits scope of review.

  • Planning, Audit, Review, and Documentation Procedure. The procedure that theproject team will use to plan and schedule its work, to audit and review the LRAinformation that is within its scope of review, and to document the results of its work.
  • Appendices. Supporting information. The project team membership is shown inAppendix A and the schedule is shown in Appendix B. The team's work assignmentsare shown in Appendix C, "Aging Management Program Assignments," Appendix D, "Aging Management Review Assignments," Appendix E "Time-Limited Aging Analysis Review Assignments." Appendices F, G, and H are the worksheets that the individual team members use to informally document the results of their review and audit work.

The application of these worksheets is discussed in Section 6 or this plan. Appendix I is a list of the acronyms, abbreviations, and initialisms used in this plan.2.BACKGROUNDIn 10 CFR 54.4, the scope of license renewal is defined as those structures, systems, andcomponents (SSCs) (1) that are safety-related, (2) whose failure could affect safety-related functions, and (3) that are relied on to demonstrate compliance with the NRC's regulations for fire protection, environmental qualification, pressurized thermal shock, anticipated transients without scram, and station blackout. An applicant for a renewed license must review all SSCs within the scope of license renewal toidentify those structures and components (SCs) subject to an AMR. SCs subject to an AMR are those that perform an intended function without moving parts or without a change in configuration or properties (passive), and that are not subject to replacement based on qualified life or specified time period (long-lived). Pursuant to 10 CFR 54.21(a)(3), an applicant for a renewed license must demonstrate that the effects of aging will be managed in such a way that the intended function or functions of those SCs will be maintained, consistent with the CLB, for the period of extended operation. 10 CFR 54.21(d) requires that the applicant submit a supplement to the final safety analysis report (FSAR) that contains a summary description of the programs and activities that it credited to manage the effects of aging during the extended period of operation.The SRP-LR provides staff guidance for reviewing applications for license renewal. The GALLReport is a technical basis document. It summarizes staff-approved AMPs for the aging management of a large number of SCs that are subject to an AMR. It also summarizes the aging management evaluations, programs, and activities acceptable to the NRC staff for Pilgrim Nuclear Power StationAMP and AMR Audit and Review Plan 3managing aging of most of the SCs used in commercial nuclear power plants, and serves as areference for both the applicant and staff reviewers to quickly identify those AMPs and activities that the staff has determined will provide adequate aging management during the extended period of operation. If an applicant commits to implementing these staff-approved AMPs, the time, effort, and resources needed to review an applicant's LRA will be greatly reduced, thereby improving the efficiency and effectiveness of the license renewal review process. The GALL Report identifies (1) systems, structures, and components, (2) component materials, (3) the environments to which the components are exposed, (4) the aging effects associated with the materials & environments, (5) the AMPs that are credited to manage the aging effects, and (6) recommendations for further applicant evaluations of aging effects and their management for certain component types.The GALL Report is treated in the same manner as an approved topical report that isgenerically applicable. An applicant may reference the GALL Report in its LRA to demonstrate that its programs correspond to those that the staff reviewed and approved in the GALL Report.

If the material presented in the LRA is consistent with the GALL Report and is applicable to the applicant's facility, the staff will accept the applicant's reference to the GALL Report. In making this determination, the staff considers whether the applicant has identified specific programs described and evaluated in the GALL Report but does not conduct a re-review of the substance of the matters described in the GALL Report. Rather, the staff confirms that the applicant verified that the approvals set forth in the GALL Report apply to its programs. If an applicant takes credit for a GALL AMP, it is incumbent on the applicant to ensure that theplant AMP contains all the program elements of the referenced GALL AMP. In addition, the conditions at the plant must be bounded by the conditions for which the GALL AMP was evaluated. The applicant must certify in its LRA that it completed the verifications and that they are documented onsite in an auditable form. The SRP-LR also provides staff guidance for reviewing TLAAs. Pursuant to 10 CFR54.21(c)(1) a license renewal application is required to provide a list of TLAAs, as defined in 10 CFR 54.3. In addition, the applicant must provide a list of plant-specific exemptions granted under 10 CFR 50.12 that are based on TLAAs. The number and type of TLAAs vary depending on the plant-specific CLB.All six criteria set forth in 10 CFR 54.3 must be satisfied to conclude that a calculation oranalysis is a TLAA. Pursuant to 10 CFR 54.3, TLAAs are those licensee calculations and analyses that:1. Involve systems, structures, and components within the scope of license renewal, asdelineated in 10 CFR 54.4(a).2.Consider the effects of aging.

3.Involve time-limited assumptions defined by the current operating term, for example, 40years. 4.Were determined to be relevant by the licenses in making a safety determination.

Pilgrim Nuclear Power StationAMP and AMR Audit and Review Plan 45.Involve conclusions or provide the basis for conclusions related to the capability of thesystem, structure, or component to perform its intended function(s), as delineated in 10 CFR 54.4(b).6.Are contained or incorporated by reference in the CLB.Finally, the applicant must demonstrate that the TLAAs remain valid for the period of extendedoperation; the TLAAs have been projected to the end of the period of extended operation; or the aging effects of aging on the intended function(s) will be adequately managed for the period of extended operation. The staff performs a technical review as well as reviews the area relating to the identification of TLAAs. The staff also confirms that the applicant did not omit any TLAAs, as defined in 10 CFR 54.3.3.OBJECTIVES The overall objective of the audit and review described in this plan is to verify compliance with10 CFR 54.21(a)(3). Therefore, the audit and review process helps ensure that for each structure and component within the scope of the project team's review, the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB for the period of extended operation.The audit and review procedure for PNPS is described in Sections 5 and 6 of this plan. It isintended to accomplish the following objectives:*For PNPS AMPs that the applicant claims are consistent with GALL AMPs, verifying thatthe plant AMPs contain the program elements of the referenced GALL AMP and that the conditions at the plant are bounded by the conditions for which the GALL AMPs were evaluated.*For PNPS AMPs that the applicant claims are consistent with GALL AMPs withexceptions, verifying that the plant AMPs contain the program elements of the referenced GALL AMPs and that the conditions at the plant are bounded by the conditions for which the GALL AMPs were evaluated. In addition, verifying that the applicant has documented an acceptable technical basis for each exception.*For PNPS AMPs that the applicant claims will be consistent with GALL AMPs afterspecified enhancements are implemented, verifying that the plant AMPs, with the enhancements, will be consistent with the referenced GALL AMPs, or are acceptable on the basis of a technical review. In addition, verifying that the applicant identified the enhancements as commitments in the Updated Final Safety Analysis Report (UFSAR) or other docketed correspondence.*For plant-specific PNPS AMPs that the applicant claims are consistent with AMPs thatthe staff has previously approved for another plant, verifying the AMPs are acceptable on the basis of a technical review.

Pilgrim Nuclear Power StationAMP and AMR Audit and Review Plan 5* For AMR line items that the applicant claims are consistent with the GALL Report,determine that these AMR line items are consistent with the recommendation of the GALL Report.*For AMR line items (Table 1s) that the applicant claims are not applicable with the GALLReport, determine that these AMR line items are acceptable on the basis of a technical review.*For AMR line items that the applicant claims consistent with AMR line items that the staffhas previously approved for another plant, determine that these AMR line items are acceptable on the basis of a technical review.*For AMR line items for which the GALL Report recommends further evaluation,determine that the applicant has addressed the further evaluation, and evaluating the AMRs in accordance with the SRP-LR.*For TLAAs, determine that the applicant has properly identified the TLAAs. TLAAs arecertain plant-specific safety analyses that are based on explicitly assumed 40-year plant life (for example, aspects of the reactor vessel design). Pursuant to 10 CFR 54.219(c)(1), a license renewal applicant is required to provide a list of TLAAs, as defined in 10 CFR 54.3. The area relating to the identification of TLAAs is reviewed.

TLAAs may have developed since issuance of a plant's operating license. As indicated in 10 CFR 54.30, the adequacy of the plant's CLB, which includes TLAAs, is not an area within the scope of the license renewal review. Any question regarding the inadequacy of the CLB must be addressed under the backfit rule (10 CFR 50.109) and is separate from the license renewal process.*Determine that the applicant has demonstrated that (1) the TLAAs remain valid for theperiod of extended operation; (2) the TLAAs have been projected to the end of the period of extended operation; or (3) the aging effects of aging on the intended function(s) will be adequately managed for the period of extended operation.4.

SUMMARY

OF INFORMATION PROVIDED IN THE LICENSE RENEWALAPPLICATION4.1Aging Management Review ResultsThe PNPS LRA closely follows the standard LRA format presented in NEI 95-10, "Industry Guideline for Implementing the Requirements of 10 CFR Part 54 - The License Renewal Rule,"

Revision 6, June 2005. Section 3 of the LRA provides the results of the aging management review for structures and components that the applicant identified as being subject to aging management review. LRA Table 3.0-1, Table 3.0-2, and Table 3.0-3 provide descriptions of the mechanical,structural, and electrical service environments, respectively, used in the AMRs to determine the Pilgrim Nuclear Power StationAMP and AMR Audit and Review Plan 6aging effects requiring management. Results of the AMRs are presented in two different typesof tables. The applicant refers to the two types of tables as Table 1 and Table 2. The first table type is a series of six tables labeled Table 3.X.1, where "X" is the system/component group number (see table below), and "1" indicates it is a Table 1 type. For example, in the reactor coolant system subsection of the LRA Section 3, this is Table 3.1.1, and in the engineered safety features subsection of LRA Section 3, this is Table 3.2.1. For ease of discussion, these table types will hereafter be referred to as "Table 1." These tables are derived from the corresponding tables in NUREG-1801, Volume 1, and present summary information from the AMRs. Definition1Reactor Vessel, Internals, and Reactor Coolant System2Engineered Safety Features Systems 3Auxiliary Systems 4Steam and Power Conversion Systems 5Structures and Component Supports 6Electrical and Instrumentation and ControlsThe second table type is a series of tables labeled Table 3.X.2-Y, where "X" is the system/component group number, "2" indicates it is a Table 2 type, and "Y" indicates the subgroup number within group "X". For example, within the reactor coolant system subsection, the AMR results for the reactor vessel are presented in Table 3.1.2-1, and the results for the reactor vessel internals are in Table 3.1.2-2. In the engineered safety features subsection, the residual heat removal system results are presented in Table 3.2.2-1, and the core spray system is in Table 3.2.2-2. For ease of discussion, these table types will hereafter be referred to as "Table 2." These tables present the results of the AMRs.4.1.1PNPS AMR Comparison with GALLThe applicant compared the PNPS AMR results with information set forth in the tables of theGALL Report and provided the results of its comparisons in two table types that correlate with the two table types described above.To take full advantage of the GALL Report, PNPS AMR results have been compared w/information set forth in the tables of NUREG-1801. Results of that comparison are provided in the following two table types, Table 1 and Table 2.4.1.1.1Purpose of Table 1 The purpose of Table 1 is to provide a summary comparison of how the PNPS AMR resultsalign with the corresponding table of NUREG-1801, Volume 1. These tables are essentially the same as Tables 1 through 6 provided in NUREG-1801, Volume 1, with the following exceptions:

Pilgrim Nuclear Power StationAMP and AMR Audit and Review Plan 7*The ID column is labeled "Item Number" and the spacing has been expanded to includethe table number.*The "Type" column has been deleted. Items applicable to PWRs only are noted as such.*The "Related Item" column has been replaced by a "Discussion" column.The "Item Number" column provides a means to cross-reference to Table 1 from the Table 2s.

Further information is provided in the "Discussion" column. The following are examples ofinformation that might be contained within this column:*Any "Further Evaluation Recommended" information or reference to the location of thatinformation.*The name of a plant-specific program being used.

  • A discussion of how the line item is consistent with the corresponding line item inNUREG-1801, Volume 1, when it may not be intuitively obvious.*A discussion of how the line item is different than the corresponding line item inNUREG-1801, Volume 1, when it may appear to be consistent.4.1.1.2Purpose of Table 2 Table 2 provides results of the aging management reviews for those structures andcomponents identified in Section 2 as being subject to aging management review. There is a Table 2 for each aging management review within a NUREG-1801 system group. For example, the engineered safety features system group contains tables specific to residual heat removal, core spray, automatic depressurization, high pressure coolant injection, reactor core isolation cooling, standby gas treatment, and primary containment penetrations.Table 2 consists of the following nine columns:

Component Type Column 1 identifies the component types from Section 2 of this application that are subject to aging management review. Similar to Section 2, component types are listed in alphabetical order. In the Class 1 tables in Section 3.1 and the structural tables in Section 3.5, component types are alphabetical by sub-groups.The term "piping" in component lists may include pipe, pipe fittings (such as elbows &reducers), flow elements, orifices, and thermowells. If such components have unique tag Pilgrim Nuclear Power StationAMP and AMR Audit and Review Plan 8numbers or the specific component has a function other than pressure boundary, then flowelements, orifices and thermowells are identified as a separate component type.The term "heat exchanger (shell)" may include the bonnet/channel head and tubesheet. Incases where the bonnet/channel head and tubesheet provide a unique material and environment combination, they will be uniquely identified as a separate component type.The general component type of "tank" includes components identified as tanks or accumulatorson LRA drawings.Intended Function Column 2 identifies the license renewal intended functions (using abbreviations wherenecessary) for the listed component types. Definitions and abbreviations of intended functions are listed in Table 2.0-1 in Section 2.Material Column 3 lists the particular materials of construction for the component type being evaluated.

Environment Column 4 lists the environment to which the component types are exposed. Internal/externalservice environments are indicated. A description of these environments is provided in Tables 3.0-1, 3.0-2, and 3.0-3 for mechanical, structural, and electrical components, respectively.Aging Effect Requiring Management Column 5 lists the aging effects requiring management for material and environmentcombinations for each component type.Aging Management Programs (AMP)

Column 6 lists the programs used to manage the aging effects requiring management.

NUREG-1801, Vol. 2, Item Column 7 documents identified consistencies by noting the appropriate NUREG-1801, Volume2, item number. If there is no corresponding item number in NUREG-1801, Volume 2, for a particular combination of factors, column 7 is left blank.Each combination of the following factors listed in Table 2 is compared to NUREG-1801,Volume 2, to identify consistencies:*Component type.*Material.

  • Environment.

Pilgrim Nuclear Power StationAMP and AMR Audit and Review Plan 9*Aging effect requiring management.*Aging management program.Table 1 Item Column 8 lists the corresponding line item from Table 1. If there is no corresponding item inNUREG-1801, Volume 1, column 8 is left blank.Each combination of the following that has an identified NUREG-1801, Volume 2 item numberalso has a Table 1 line item reference number:*Component type.*Material.

  • Environment.
  • Aging effect requiring management.
  • Aging management program.Notes Column 9 contains notes that are used to describe the degree of consistency with the line itemsin NUREG-1801, Volume 2. Notes that use letter designations are standard notes based on a letter from A. Nelson, NEI, to P. T. Kuo, NRC, "U.S. Nuclear Industry's Proposed Standard License Renewal Application Format Package, Request NRC Concurrence", dated January 24, 2003 (ML030290201). The staff concurred with the NEI standardized format for license renewal applications by letter dated April 7, 2003, from P. T. Kuo, NRC, to A. Nelson, NEI (ML030990052). Notes that use numeric designators are specific to PNPS.PNPS LRA Table 2 contains the aging management review results and indicates whether theresults correspond to line items in Volume 2 of the GALL Report. Correlations between the combination PNPS LRA Table 2 and a combination for a line item in Volume 2 of the GALL Report are identified by the GALL Report item number in Column 7. If Column 7 is blank, the applicant did not identify a corresponding combination in the GALL Report. If the applicant identified a GALL Report line item, the next column provides a reference to a Table 1 row number. This reference corresponds to the GALL Report, Volume 2, "roll-up" to the GALL Report, Volume 1, tables.4.1.2Plant-Specific ProgramsMany of the GALL Report evaluations refer to plant-specific programs. In these cases, theapplicant considers the PNPS evaluation to be consistent with the GALL Report if the other elements are consistent. Any appropriate AMP is considered to be a match to the GALL program for line items referring to a plant-specific program. 4.2 Time-Limited Aging AnalysesThe PNPS LRA closely follows the standard LRA format presented in Revision 6 of NEI 95-10,"Industry Guidelines for Implementing the Requirements of 10 CFR Part 54 - The License Pilgrim Nuclear Power StationAMP and AMR Audit and Review Plan 10Renewal Rule." Section 4 of the PNPS LRA addresses time-limited aging analyses. In Section4.1.1, the PNPS LRA states that the calculations and evaluations that could potentially meet the six criteria of 10 CFR 54.3 were identified by searching CLB documents including the following:A.Technical SpecificationsB.UFSAR C.docketed licensing correspondence D.fire protection program documents E.NRC safety evaluation reports F.BWRVIP documentsIn Section 4.1, the PNPS LRA states that as required by 10 CFR 54.21(c)(1), an evaluation ofPNPS-specific time-limited aging analyses must be performed to demonstrate that:A.The analyses remain valid for the period of extended operation; B.The analyses have been projected to the end of the period of extended operation; or C.The effects of aging on the intended functions(s) will be adequately managed for theperiod of extended operation.In the PNPS LRA, the applicant summarized the results of the above evaluations in Table 4.1-1. These evaluations are discussed in subsequent sections of PNPS LRA Section 4.Following the section identifying the TLAAs, the PNPS LRA next includes a section identifyingany exemptions. Section 10 CFR 54.21(c) also requires that the application for a renewed license includes a list of plant-specific exemptions granted pursuant to 10 CFR 50.12 and in effect that are based on time-limited aging analyses as defined in 10 CFR 54.3. The PNPS performed this by reviewing PNPS docketed correspondence which identified PNPS exemptions. The results of this review determined that no PNPS exemptions depend on TLAAs.The PNPS LRA next includes a separate section for each of the identified TLAAs within theoutline of the corresponding NUREG-1800 TLAA category. The TLAA categories are outlined in the next table.TLAA DescriptionResolution OptionSectionReactor Vessel Neutron Embrittlement Analyses4.2Pressure-temperature limitsAnalyses remain valid10 CFR 54.21(c)(1)(i)4.2.2Charpy upper-shelf energy Analyses projected10 CFR 54.21(c)(1)(ii)4.2.3Adjusted reference temperatureAnalyses projected10 CFR 54.21(c)(1)(ii)4.2.4 Pilgrim Nuclear Power StationAMP and AMR Audit and Review PlanTLAA DescriptionResolution OptionSection 11Reactor vessel circumferential weldsinspection reliefAnalysis projected10 CFR 54.21(c)(1)(ii)4.2.5Reactor vessel axial welds failureprobabilityAnalysis projected10 CFR 54.21(c)(1)(ii)4.2.6Metal Fatigue Analyses4.3Class 1 fatigueAnalyses remain valid10 CFR 54.21(c)(1)(i)

OR Aging effect managed 10 CFR 54.21(c)(1)(iii)4.3.1Non-Class 1 fatigueAnalyses remain valid10 CFR 54.21(c)(1)(i)4.3.2Effects of reactor water environment onfatigue lifeAnalyses remain valid10 CFR 54.21(c)(1)(i)

OR Analyses projected 10 CFR 54.21(c)(1)(ii)

OR Aging effect managed 10 CFR 54.21(c)(1)(iii)4.3.3Environmental Qualification Analyses forElectrical EquipmentAging effect managed10 CFR 54.21(c)(1)(iii)4.4Containment Liner Plate, Metal Containment, and PenetrationsFatigue Analyses4.6Fatigue of primary containmentAnalysis projected10 CFR 54.21(c)(1)(ii)4.6.1Other TLAA4.7Reflood thermal shock of the reactorvessel internalsAnalysis remains valid10 CFR 54.21(c)(1)(i)4.7.1TLAA in BWRVIPs4.7.2BWRVIP-05, RPV circumferential weldsanalysisAddressed in Sections 4.2.5 4.7.2.1BWRVIP-48, vessel ID attachment weldsfatigue analysisAnalysis remains valid10 CFR 54.21(c)(1)(ii)4.7.2.2BWRVIP-49, instrument penetrationsfatigue analysisAnalysis projected10 CFR 54.21(c)(1)(ii)4.7.2.3 Pilgrim Nuclear Power StationAMP and AMR Audit and Review PlanTLAA DescriptionResolution OptionSection 12BWRVIP-74, reactor vesselP/T curves analysis Fatigue analysis

C VUSE analysisCirc/Axial welds analysisAddressed in Section 4.2.2Addressed in Section 4.3.1 Addressed in Section 4.2.3 Addressed in Sections 4.2.5 and 4.2.64.7.2.4BWRVIP-76, core shroud fatigue analysisAnalysis remains valid10 CFR 54.21(c)(1)(ii)4.7.2.55.OVERVIEW OF AUDIT, REVIEW, AND DOCUMENTATION PROCEDUREThe project team will follow the procedure specified in Section 6 of this plan to perform itsaudits and reviews and to document the results of its work. The process covered by the procedure is summarized below.5.1Aging Management ProgramsTable 1 of this audit and review plan summarizes the program elements that comprise an agingmanagement program. For the PNPS AMPs for which the applicant claimed consistency with the AMPs included in the GALL Report, the project team will review the PNPS AMP descriptions and compare program elements for the PNPS AMPs to the corresponding program elements for the GALL AMPs. The project team will verify that the PNPS AMPs contain the program elements of the referenced GALL program and that the conditions at the plant are bounded by the conditions for which the GALL program was evaluated. The Division of Engineering will review and determine the adequacy of the applicant's 10 CFR 50, Appendix B Program. Other aspects of these program elements will be reviewed by the project team. For PNPS AMPs that have one or more exception and/or enhancement, the project team willreview each exception and/or enhancement to determine whether the exception and/or enhancement is acceptable, and whether the AMP, as modified by the exception and/or the enhancement, would adequately manage the aging effects for which it is credited. In some cases, the project team will identify differences that the applicant did not identiry between the PNPS AMPs credited by the applicant and the GALL Report AMPs. In these cases, the project team will review the difference to determine whether the PNPS AMP, as modified by the difference, would adequately manage the aging effects for which it is credited.For those PNPS AMPs that are not included in the GALL Report (i.e., plant- specific AMPs), theproject team will review the AMP against the ten program elements defined in Appendix A of the SRP-LR. The Division of Engineering will review and determine the adequacy of the applicant's 10 CFR 50, Appendix B Program. Other aspect of these program elements will be reviewed by the project team. On the basis of its reviews, the project team will determine whether these AMPs will manage the aging effects for which they are credited.

Pilgrim Nuclear Power StationAMP and AMR Audit and Review Plan 135.2Aging Management ReviewsThe AMRs in the GALL Report fall into two broad categories: (1) those that the GALL Reportconcludes are adequate to manage aging of the components referenced in the GALL Report, and (2) those for which the GALL Report concludes that aging management is adequate, but further evaluation is recommended for certain aspects of the aging management process. For its AMR reviews, the project team will determine (1) whether the AMRs reported by the applicant to be consistent with the GALL Report are indeed consistent with the GALL Report, and (2) whether the plant-specific AMRs reported by the applicant to be based on a previously-approved precedent are technically acceptable and applicable. For component groups evaluated in the GALL Report for which the applicant claimed consistency with the GALL Report, and for which the GALL Report recommends further evaluation, the project team will review the applicant's evaluation to determine if it adequately addressed the issues for which the GALL Report recommended further evaluation.5.3Time-Limited Aging AnalysesThe TLAAs in the PNPS LRA fall into the broad category of those that are consistent with theNUREG-1800 TLAA categories. There are no plant-specific exemptions identified in the PNPS LRA that depend on time-limited aging analyses.For its TLAA reviews, the project team will determine if the applicant had provided adequateinformation to meet the requirements of 10 CFR 54.21(c)(1) and 10 CFR 54.21(c)(2).Further, the project team will conduct both regulatory evaluations and technical evaluations todetermine, as defined in 10 CFR 54.3, that each TLAA meets the following six criteria:1.Involve systems, structures, and components that are within the scope of licenserenewal, as delineated in 10 CFR 54.4(e).2.Consider the effects of aging.

3.Involve time-limited assumptions defined by the current operating term (40 years).

4.Determined to be relevant by the applicant in making a safety determination.

5.Involve conclusions, or provide the basis for conclusions, related to the capability of thesystem, structure, and component to perform its intended fucntions, as delineated in 10 CFR 54.4(b). 6.Contained or incorporated by reference in the CLB.In addition, the project team will also review the TLAAs to determine if there are emergingissues that should be further evaluated by technical specialists in the NRC Divisions ofComponent Integrity (DCI) or the Division of Engineering (DE). This is not expected to be an issue for TLAAs for which the applicant claims consistency with 10 CFR 54.21(c)(i) "the Pilgrim Nuclear Power StationAMP and AMR Audit and Review Plan 14analyses remain valid for the period of extended operation" or 10 CFR 54.21(c)(iii) "the effectsof aging on the intended function(s) will be adequately managed for the period of extended operation."For TLAAs for which the applicant claims consistency with 10 CFR 54.21(c)(ii) - "the analyseshave been projected to the end of the period of extended operation," the audit team leader will be consulted to determine which TLAAs the audit team will be capable of reviewing.

Consideration should be given to project team expertise, past precedent, and complexity of the provided analysis. Candidates for further review by technical specialists could be such as the following:A.Reactor Vessel Neutron Embrittlement AnalysisB.Reflood Thermal Shock Analyses of the Reactor Vessel Internals 5.4NRC-Approved PrecedentsTo help facilitate the staff review of its LRA, the applicant referenced NRC-approvedprecedents to demonstrate that certain non-GALL AMPs correspond to programs that the staff had approved for other plants during its review of previous applications for license renewal.

Using the precedent information, the project team will (1) determine whether the material presented in the precedent is applicable to the applicant's facility, (2) determine whether the applicant's AMP is bounded by the conditions for which the precedent was evaluated and approved, and (3) verify that the applicant's AMP contains the program elements of the referenced precedent. In general, if the project team determines that these conditions are satisfied, it will use the precedent to frame and focus its review of the applicant's AMP.It is important to note that precedent information is not a part of the license renewal application;it is supplementary information voluntarily provided by the applicant as a reviewers' aid. The existence of a precedent, in and of itself, is not a sufficient basis to accept the applicant's AMP.

Rather, the precedent facilitates the review of the substance of the matters described in the applicant's AMP. As such, in the project team's documentation of its reviews of AMPs that are based on precedents, the precedent information is typically implicit in the evaluation, rather than explicit. If the project team determines that a precedent identified by the applicant is not applicable to the particular plant AMP for which it is credited, then the project team reviews the AMP as a plant-specific AMP without consideration of the precedent information.5.5UFSAR Supplement ReviewConsistent with the SRP-LR, for the AMRs and associated AMPs that it will review, the projectteam will review the UFSAR supplement that summarizes the applicant's programs and activities for managing the effects of aging for the extended period of operation. The project team will also review any commitments associated with its programs and activities made by the applicant and verify that they are acceptable for the stated purpose.5.6Documents Reviewed by the Project Team Pilgrim Nuclear Power StationAMP and AMR Audit and Review Plan 15In performing its work, the project team will rely heavily on the LRA, the audit and review plan,the SRP-LR, and the GALL Report. The project team will also examine the applicant's precedent review documents, its AMP, AMR, and TLAA basis documents (catalogs of the documentation used by the applicant to develop or justify its AMPs, AMRs, and TLAAs), and other applicant documents, including selected implementing procedures, to verify that the applicant's activities and programs will adequately manage the effects of aging on structures and components. 5.7Public Exit MeetingAfter it completes its audits and reviews, the project team will hold a public exit meeting todiscuss the scope and results of its audits and reviews.5.8Documentation Prepared by the Project TeamThe project team will prepare an audit and review plan, worksheets, work packages, requestsfor additional information (RAIs), an audit and review report, and a safety evaluation report (SER) input. The project team will also prepare questions during site visits and will track the applicant's responses to the questions. 5.8.1Audit and Review Plan The project team leader will prepare a plant-specific audit and review plan as described herein.

5.8.2Worksheets Each project team member will informally document the results of his or her work on a variety ofworksheets. The worksheets are shown in Appendix E, "Consistent with GALL Report AMP Audit/Review Worksheet"; Appendix F, "Plant-Specific AMP Audit/Review Worksheet"; and Appendix G, "Aging Management Review Worksheets", and Appendix H, "TLAA-Audit/Review Worksheet." The use of the worksheets is described in Section 6 of this plan. 5.8.3Questions As specified in Section 6 of this plan, the project team members will ask the applicant questionsduring the on-site audits, as appropriate, to facilitate its audit and review activities. The team will also track the applicant's answers to the questions.5.8.4Work Packages After each site visit, the project team leader, in conjunction with the project manager, willassemble work packages for any work that the team will refer to the NRR Division of Engineering (DE) for review. Each work package will include a work request and any applicable background information on the review item that was gathered by the project team.5.8.5Requests for Additional Information Pilgrim Nuclear Power StationAMP and AMR Audit and Review Plan 16The review process described in this plan is structured to resolve as many questions aspossible during the site visits. As examples, the site visits are used to obtain clarificationsabout the LRA and explanations as to where certain information may be found in the LRA or its associated documents. Nevertheless, there may be occasions where an RAI is appropriate to obtain information to support an SER finding. The need for RAIs will be determined by the project team leader during the site visits through discussions with the individual project teammembers. When the project team leader determines that an RAI is needed, the project team member who is responsible for the area of review will prepare the RAI. RAIs will include the technical and regulatory basis for requesting the information. After the NRC receives a response to an RAI from the applicant, the team leader will providethe response to the team member who prepared the RAI. The team member will review the response and determine if it resolves the issue that was the reason for the RAI. The team member will document the disposition of the RAI in the audit and review report (unless the report was issued before the RAI response was received) and in the SER input. If the audit report was issued before the applicant submitted its response to an RAI, the review of the response will be documented in the SER.5.8.6Audit and Review Report The project team will document the results of its work in an audit and review report. The teamwill prepare its report as described in Section 6.4.1 of this plan and the latest version of the RLRC Guidelines For Preparing Audit and Review Reports.5.8.7Safety Evaluation Report input The project team will prepare SER input, based on the audit and review report, as described inSection 6.4.2 of this plan.6.PLANNING, AUDIT, REVIEW, AND DOCUMENTATION PROCEDUREThis section of the audit and review plan contains the detailed procedures that the project teamwill follow to plan, perform, and document its work.6.1Planning Activities6.1.1Schedule for Key Milestones and ActivitiesThe project team leader will establish the schedule for the key milestones and activities,consistent with the overall schedule for making the licensing decision. Key milestones andactivities include, as a minimum:*Receiving the LRA from the applicant.*Receiving work split tables from the project manager.

  • Making individual work assignments.
  • Training project team members.

Pilgrim Nuclear Power StationAMP and AMR Audit and Review Plan 17*Holding the project team kickoff meeting.*Preparing the audit and review plan.

  • Scheduling site visits.
  • Scheduling in-office review periods.
  • Preparing questions.
  • Preparing draft and final audit and review report.
  • Preparing draft and final SER input.Site visits will be scheduled on the basis of discussions between the project team leader, theNRC license renewal project manager, and the applicant.Appendix B of this plan contains the target schedule for the key milestones and activities.

6.1.2Work Assignments The technical assistance contractor will propose team member work assignments to the NRCproject team leader. The NRC project team leader will approve all work assignments. After the audit plan is issued, the team leader may reassign work as necessary.The contractor will develop assignment tables that show which project team member will revieweach AMP and AMR. Appendix A of this plan shows the project team membership. Appendix C shows the team member assignments for the AMPs. Appendix D of this plan shows the team member assignments for the AMRs. Appendix E shows the project team member assignments for TLAAs.6.1.3Training and Preparation The training and preparation will include the following:A.A description of the audit and review process.

B.An overview of audit/review-related documentation and the documentation that theproject team will audit and review.1.GALL Report2.SRP-LR 3.Interim Staff Guidance for License Renewal (ISG-LR) 4.LRA AMPs 5.LRA AMRs 6.Basis documents (catalogues of information assembled by the applicant todemonstrate the bases for its programs and activities)7.Implementing procedures 8.Operating experience reports 9.RAIs, audit reports, and SERs for other plants

10. Applicant's UFSAR
11. LRA TLAAs Pilgrim Nuclear Power StationAMP and AMR Audit and Review Plan 18C.The protocol for interfacing with the applicant.D.Administrative issues such as travel, control of documentation, work hours, etc.

E.Process for preparing questions, RAIs, the audit and review report, and SER input.

F.Process for interfacing with DE technical reviewers.6.2Aging Management Program (AMP) Audits and Reviews6.2.1Types of AMPsThere are two types of AMPs: those that the applicant claims are consistent with AMPscontained in the GALL Report, and those that are plant-specific. The process for auditing and reviewing both types of AMPs is presented in the following sections of this plan.6.2.2Scope of AMP elements to be audited and reviewed Table 1 of this plan shows the 10 program elements that are used to evaluate the adequacy ofeach aging management program. These program elements are presented in Branch Technical Position (BTP) RLSB-1, "Aging Management Review - Generic," in Appendix A of the SRP-LR, and are summarized in the GALL Report. The program elements audited or reviewed is the same for both AMPs that are consistent withthe GALL Report and for plant-specific AMPs. The Division of Engineering will reveiw and determine the adequacy of the applicant's 10 CFR 50, Appendix B Program. Other aspects of these program elements will be reviewed by the project team.6.2.3Plant AMPs that Are Consistent with the GALL Report Figure 1, "Audit of AMPs that Are Consistent with the GALL Report," is the process flowchartthat shows the activities and decisions used by the project team to review and audit each plant AMP that the applicant claims is consistent with the GALL Report.PreparationA.For the plant AMP being reviewed, identify the corresponding GALL AMP.

B.Review the associated GALL AMP and identify those elements that will be audited.

C.Identify the documents needed to perform the audit. These may include, but are notlimited to, the following:1.GALL Report2.SRP-LR 3.ISGs Pilgrim Nuclear Power StationAMP and AMR Audit and Review Plan 194.RAIs and SERs for similar plants5.LRA 6.Basis documents 7.Implementation procedures 8.Operating experience reports (plant-specific and industry) 9.UFSARAudit/ReviewA.Confirm that PNPS AMP program elements are consistent with the correspondingelements of the GALL Report AMP by answering the following questions and then following the process shown in Figure 1.1.Did the applicant identify any exceptions to the GALL Report AMP?2.Did the applicant identity any enhancements to the GALL Report AMP?

3.Are the elements consistent with the GALL Report AMP?B.If either of the above questions results in the identification of an exception/enhancementor a difference to the GALL AMP, determine whether it is acceptable on the basis of an "adequate technical justification."C.If an acceptable basis exists for an exception/enhancement or difference, document thebasis in the worksheet and later in the audit and review report and the SER input.D.Review the industry and plant-specific operating experience associated with the AMP. The review is to identify aging effects requiring management that are not identified by the industry guidance documents (such as EPRI tools) and to confirm the effectiveness of aging management programs. The project team members should consider the industry guidance when assessing operating experience and formulating questions for the applicant. The industry guidance (from NEI 95-10, Revision 6) is as follows:1.Plant-Specific Operating Experience with Aging Effects Requiring Management. Aplant-specific operating experience review should assess the operating and maintenance history. A review of the prior 5 to 10 years of operating and maintenance history should be sufficient. The results of the review should confirm consistency with documented industry operating experience. Differences with previously documented industry experience such as new aging effects or lack of aging effects allow consideration of plant-specific aging management requirements.2.Plant-Specific Operating Experience with existing Aging Management Programs. The operating experience of AMPs, including corrective actions resulting in program enhancements or additional programs, should be considered. The review should provide objective evidence to support the conclusion that the effects of aging will be managed so that the intended function(s) will be maintained during the extended period of operation. Guidance for reviewing industry operating experience is presented in BTP RLSB-1 in Appendix A.1 of the Branch Technical Positions in NUREG-1800.

Pilgrim Nuclear Power StationAMP and AMR Audit and Review Plan 203.Industry Operating Experience. Industry operating experience and its applicabilityshould be assessed to determine whether it changes plant-specific determinations.

NUREG-1801 is based upon industry operating experience prior to its date of issue.

Operating experience after the issue date of NUREG-1801 should be evaluated and documented as part of the aging management review. In particular, generic communications such as a bulletin, a generic letter, or an information notice should be evaluated for impact upon the AMP. The evaluation should check for new aging effects or a new component or location experiencing an already identified aging effect.E.If it is necessary to ask the applicant a question to clarify the basis for accepting aprogram element, or an exception or a difference to the GALL Report AMP, follow the logic process shown in Figure 1.F.If it is necessary for the applicant to submit additional information to support the basisfor accepting the justification, an exception, or a difference to a program element, the applicant may agree to voluntarily submit the required information as a supplement (docketed letter submitted under oath and affirmation) to the LRA. If not, the NRC may issue an RAI to obtain the information. AMP audit worksheets Document the audits/reviews using the worksheet provided in Appendix E, "Consistent withGALL Report AMP Audit/Review Worksheet."6.2.4Plant-Specific AMPs Figure 2, "Audit of Plant-Specific AMPs," is the process flowchart that shows the activities anddecisions used to audit/review each plant-specific AMP.Pre-review preparationA.Review Section A.1.2.3 of the SRP-LR and identify those element criteria that will bereviewed.B.Identify the documents needed to perform the audit. These may include, but are notlimited to, the following:1.GALL Report2.SRP-LR 3.ISG-LR 4.RAIs and SERs for similar plants 5.LRA 6.Basis documents 7.Implementation procedures 8.Operating experience reports (plant-specific and industry)

Pilgrim Nuclear Power StationAMP and AMR Audit and Review Plan 219.UFSAR 10.Lessons Learned Developed by RLRCAudit/ReviewA.Audit/review the PNPS AMP program elements and determine that they are inaccordance with the acceptance criteria for the corresponding program elements of Section A.1.2.3 of the SRP-LR. B.Review the industry and plant-specific operating experience associated with the AMP. This is an area of review emphasis. They require review to identify aging effects requiring management that are not identified by the industry guidance documents (such as EPRI tools) and to confirm the effectiveness of aging management programs. The project team members should consider the industry guidance when assessing operating experience and formulating questions for the applicant. The industry guidance (from NEI 95-10, Revision 6) is as follows:1.Plant-Specific Operating Experience with Aging Effects Requiring Management. The review should assess the operating and maintenance history. A review of the prior 5 to 10 years of operating and maintenance history should be sufficient. The results of the review should confirm consistency with documented industry operating experience. Differences with previously documented industry experience such as new aging effects or lack of aging effects allow consideration of plant-specific aging management requirements.2.Plant-Specific Operating Experience with Aging Management Programs. Theoperating experience of aging management programs, including past corrective actions resulting in program enhancements or additional programs, should be considered. The review should provide objective evidence to support the conclusion that the effects of aging will be managed so that the intended function(s) will be maintained during the extended period of operation. Guidance for reviewing industry operating experience is presented in BTP RLSB-1 in Appendix A.1 of the Branch Technical Positions in NUREG-1800.3.Industry Operating Experience. Industry operating experience and its applicabilityshould be assessed to determine whether it changes plant-specific determinations.

NUREG-1801 is based upon industry operating experience prior to its date of issue.

Operating experience after the issue date of NUREG-1801 should be evaluated and documented as part of the aging management review. In particular, generic communications such as a bulletin, a generic letter, or an information notice should be evaluated for impact upon the AMP. The evaluation should check for new aging effects or a new component or location experiencing an already identified aging effect.C.If it is necessary to ask the applicant a question, follow the process shown in Figure 2.

E.If it is necessary for the applicant to submit additional information to resolve a question Pilgrim Nuclear Power StationAMP and AMR Audit and Review Plan 22or an issue or to support the basis or conclusion, the applicant may voluntarily submitthe information as a supplement (docketed letter submitted under oath and affirmation) to the LRA. If not, the NRC may issue an RAI to obtain the information. AMP review worksheets Document the audit/review using the worksheet provided in Appendix F, "Plant-Specific AMPAudit/Review Worksheet." 6.3Aging Management Review (AMR) Audits and ReviewsThere are two types of AMRs: those that the applicant claims are consistent with the GALLReport, and those that are plant-specific. Audit and review of both types of AMRs are discussed below. 6.3.1Plant AMRs that Are Consistent with the GALL Report Figure 3, "Review of AMRs that Are Consistent with the GALL Report," is the process flowchartthat shows the activities and decisions used to audit/review each AMR that the applicant claims is consistent with the GALL Report.PreparationA.For the PNPS AMRs that the applicant claims are consistent with the GALL Report,identify the corresponding AMRs in Volume 2 of the GALL Report.B.Review the associated GALL AMRs and identify those line items that will beaudited/reviewed in conjunction with each of the PNPS AMRs.C.Identify the documents needed to perform the review. These may include, but are notlimited to, the following:1.GALL Report2.SRP-LR 3.ISG-LR 4.RAIs and SERs for similar plants 5.LRA 6.Basis documents 7.Implementation procedures 8.Operating experience reports (plant-specific and industry) 9.UFSAR

10. Lessons Learned Developed by RLRC Pilgrim Nuclear Power StationAMP and AMR Audit and Review Plan 1The AMR line item letter notes are based on a letter from A. Nelson, NEI, to P. T. Kuo, NRC,"U.S. Nuclear Industry's Proposed Standard License Renewal Application Format Package, Request NRC Concurrence," dated January 24, 2003 (ML030290201). The staff concurred inthe format of the standardized format for LRAs by letter dated April 7, 2003, from P.T. Kuo, NRC, to A. Nelson, NEI (ML030990052).

2Some GALL AMRs reference the use of a plant-specific AMP. In such cases the AMR audit requires the project team member to confirm that the plant-specific AMP is appropriate to manage the aging effects during the period of extended operation.

23Audit/ReviewA.Each AMR line item is coded with a letter which represents a standard notedesignation.

1 The letter notes are described in Table 2 of this plan. Notes that usenumeric designators are plant-specific. The note codes A though E are classified as "consistent with the GALL Report," and will be reviewed in accordance with the guidance contained in this plan.B.The AMR review involves verification that the applicant has satisfied the requirements of10 CFR 54.21(a)(3). This requirement st ates: "For each stru cture and component ... [within the scope of this part ... and ... subject to an aging management review] (theapplicant) demonstrate(s) that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB for the period of extended operation." C.Determine compliance by following the process shown in Figure 3. The process issummarized below:1.For each AMR line item, perform the review associated with the letter note (Athrough E) assigned to the AMR line item. Specifically, determine if the AMR is consistent with the GALL Report for the elements associated with its note.2.If Note A applies, and the applicant uses a plant-specific AMP 2 determine if thecomponent is within the scope of the cited plant AMP. If the component is within the scope of the plant AMP, the AMR line item is acceptable. If not acceptable, go to Step (7) below.3.If Note B applies, review the LRA exceptions and document the basis for acceptancein the worksheet, and later in the audit and review report. If not acceptable, go to Step (7) below.4.If Note C or D applies, determine if the component type is acceptable for thematerial, environment, and aging effect. If Note D applies, also review the LRA exceptions and document the basis for acceptance in the worksheet, and later in the audit and review report. If not acceptable, go to Step (7) below.

Pilgrim Nuclear Power StationAMP and AMR Audit and Review Plan 3Applicant-identified NRC-approved precedents are only to be used as an aid for performingAMR audits. The audit conclusions will be based on the technical basis of the AMR and its applicability to the plant being reviewed. It is not acceptable to simply cite the NRC-approved precedent as its basis.

245.If Note E applies, review the AMP audit report findings to determine if the scope ofthe alternate AMP envelopes the AMR line item being reviewed and satisfies 10 CFR 54.21(a)(3). If it does not, go to Step (7) below. 6.Review the corresponding LRA Table 3.X.1 entry that is referenced in LRA Table3.X.2.Y. If applicable, determine whether the applicant's "Further Evaluation Recommended" response in LRA Section 3.X.2.2.Z is enveloped by Section 3.X.2.2.Z of the SRP-LR. If not, go to Step (7) below. If the LRA section does not meet the acceptance criteria of Appendix A of the SRP-LR, go to Step (7) below.7.If during the review a difference is identified, prepare a question to the applicant, inorder to obtain clarification. a.Review the applicant's response to the question. If it appears acceptable,re-start the audit/review for the AMR line item from Step (1) above. b.If the applicant's response does not resolve the question or issue, prepare anadditional question to obtain the information needed to achieve resolution.

Review the applicant's response to the second question. If it appears acceptable, re-start the audit/review for the AMR line item from Step (1) above. c.If it is necessary for the applicant to submit additional information to resolve aquestion or an issue or to support a basis or conclusion, the applicant may submit the information as a supplement to the LRA or the NRC may issue an RAI to obtain the information. The team leader should be consulted if docketed information may be needed. 8.Review LRA Table 3.X.1. for AMR line items (Table 1s) that the applicant claims arenot applicable with the GALL Report, determine that the AMR line items are acceptable on the basis of a technical review. AMR audit/review worksheets

Document the audits/reviews of plant AMRs using the worksheet provided in Appendix G, "Aging Management Review Worksheets."6.3.2AMRs Based on NRC-Approved Precedents Figure 4, "AMR Review Using NRC-Approved Precedent," is the process flowchart that showsthe activities and decisions used to review plant AMRs that the applicant has identified as beingconsistent with an NRC-approved precedent.

3 Pilgrim Nuclear Power StationAMP and AMR Audit and Review Plan 25PreparationIdentify the documents needed to perform the audit/review. These may include, but are notlimited to, the following:1.GALL Report2.SRP-LR 3.ISG-LR 4.RAIs and SERs for similar plants 5.LRA 6.Basis documents 7.Implementation procedures 8.Operating experience reports (plant-specific and industry) 9.UFSAR

10. Lessons Learned Developed by RLRCAudit/ReviewA.The AMR audit/review involves verification that the requirements of 10 CFR 54.21(a)(3)are satisfied. This criterion states that, "For each structure and component [within the scope of license renewal], demonstrate that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB for the period of extended operation."B.For AMRs with an NRC-approved precedent, this may be achieved by answering thefollowing questions while following the assessment process shown in Figure 4.1.Is the precedent appropriate for the LRA AMR being reviewed?

2.Is the NRC-approved precedent sufficiently documented or understood to technicallysupport the adequacy of the LRA AMR being reviewed?3.Is the LRA AMR within the bounds of the chosen NRC-approved precedent?

4.If any of these questions results in a "No" answer, then additional information isrequired to make a determination that the AMR is acceptable.5.If it is necessary to ask the applicant a question to obtain clarification on the basisfor accepting the AMR, the process shown in Figure 4 should be used.6.If it is necessary for the applicant's response to be docketed as a basis for acceptingthe exception or difference, the applicant may voluntarily docket the response or the NRC may issue an RAI.

Pilgrim Nuclear Power StationAMP and AMR Audit and Review Plan 26AMR audit/review worksheetsDocument the audits/reviews using the worksheet provided in Appendix G, "Aging ManagementReview Worksheets."6.4Time-Limited Aging Analyses (TLAA) Audits and ReviewsAudit and review of TLAAs are discussed below. The project team will also review the TLAAsto determine if there are emerging issues that should be further evaluated by technical specialists in the NRC Divisions of Component Integrity (DCI) or the Division of Engineering(DE). In general, the project team will review TLAAs that are for which the applicant claims consistency with 10 CFR 54.21(c)(i) "the analyses remain valid for the period of extended operation." or 10 CFR 54.21(c)(iii) "the effects of aging on the intended function(s) will be adequately managed for the period of extended operation." For TLAAs for which the applicant claims consistency with 10 CFR 54.21(c)(ii) - "the analyses have been projected to the end of the period of extended operation," the audit team leader will be consulted to determine which TLAAs the audit team will be capable of reviewing. Consideration should be given to team expertise, past precedent, and complexity of the provided analysis.6.4.1Identify Generic TLAA Issues Figure 5, "Evaluation of TLAAs and Exemptions," taken from NEI 95-10, Revision 6, shows theprocess of evaluating and reviewing TLAAs and also identifying the exemptions in effect. This process flowchart shows the activities and decisions used to audit/review each TLAA that the applicant identifies.Pre-Review PreparationA.For the PNPS TLAAs that the applicant has identified as generic TLAA issues, identifythe corresponding TLAAs in NUREG-1800, if appropriate.B.Review the corresponding TLAAs in NUREG-1800 and identify those that will beaudited/reviewed in conjunction with each of the PNPS TLAAs.C.Review the list of the PNPS plant-specific exemptions granted pursuant to §50.12 and ineffect that are based on TLAAs as defined in §54.3. The application shall include an evaluation that justifies the continuation of these exemptions for the period of extended operation.D.Identify and locate the documents needed to perform the review. These may include,but are not limited to, the following:1.Excel database on TLAAs summarizing how earlier LRAs and SERs were presentedand reviewed 2.TLAAs 3.GALL Report 4.SRP-LR Pilgrim Nuclear Power StationAMP and AMR Audit and Review Plan 275.ISG-LR 6.RAIs, audit and review reports, and SERs for similar plants 7.LRA 8.References listed by applicant for each TLAA 9.NEI 95-10, Section 5.1 and Table 6.2-2

10. Basis documents
11. Implementation documents
12. Operating experience reports (plant-specific and industry)
13. Lessons learned developed by RLRC
14. Applicant's UFSARE.In addition, the project team will also review the TLAAs to determine if there areemerging issues that should be further evaluated by technical specialists in the NRC Divisions of Component Integrity (DCI) or the Division of Engineering (DE). This is not expected to be an issue for TLAAs for which the applicant claims consistency with 10 CFR 54.21(c)(i) "the analyses remain valid for the period of extended operation." or 10 CFR 54.21(c)(iii) "the effects of aging on the intended function(s) will be adequately managed for the period of extended operation." For TLAAs for which the applicant claims consistency with 10 CFR 54.21(c)(ii) - "the analyses have been projected to the end of the period of extended operation," the audit team leader will be consulted to determine which TLAAs the audit team will be capable of reviewing. Consideration should be given to team expertise, past precedent, and complexity of the provided analysis. Candidates for further review by technical specialists could be such as the following:1.Reactor Vessel Neutron Embrittlement Analysis (PNPS LRA Section 4.2) 2.Reflood Thermal Shock Analyses of the Reactor Vessel Internals (PNPS LRASection 4.7.1)Audit/ReviewA.Confirm that each PNPS TLAA listed in this section is appropriate. Refer to anyanalyses and evaluations created during the acceptance review process.B.If a TLAA is listed in the SRP-LR or NEI 95-10 and not in its LRA, the PNPS shouldstate in this section that it does not apply.C.Review any industry and plant-specific operating experience associated with the TLAA. This is an area of review emphasis. The project team members should consider the following industry guidance (from NEI 95-10, Table 6.2-2) as follows:1.The application shall include a list of time-limited aging analyses, as defined by§54.3. The application should include the identification of the affected systems, structures, and components, an explanation of the time dependent aspects of the calculation or analysis, and a discussion of the TLAA's impact on the associated aging effect. The identification of the results of the time-limited aging analysis Pilgrim Nuclear Power StationAMP and AMR Audit and Review Plan 28review, which may be provided in tabular form, may reference the section in theIntegrated Plant Assessment-Aging Management Review chapter where more details of the actual review and disposition (as required by §54.21(c)(1)(i)-(iii)) are located. 2.The application shall include a demonstration that (1) the analyses remain valid forthe period of extended operation, (2) the analyses have been (or have been identified and will be [§54.29(a)]) projected to the end of the period of extended operation or (3) the effects of aging on the intended function(s) will be adequately managed for the period of extended operation. 3.The application shall include a list of plant-specific exemptions granted pursuant to§50.12 and in effect that are based on TLAAs as defined in §54.3. The application shall include an evaluation that justifies the continuation of these exemptions for the period of extended operation. 4.Summary descriptions of the evaluations of TLAAs for the period of extendedoperation shall be included in the UFSAR supplement (Appendix A).D.If it is necessary to ask the applicant a question to clarify the basis for their analyses,follow the logic process shown in Figure 5 of this audit and review plan.E.If it is necessary for the applicant to submit additional information to support the basisfor the conclusions in their TLAA, the applicant may agree to voluntarily submit the required information as a supplement (docketed letter submitted under oath and affirmation) to the PNPS LRA. If not, the NRC may issue an RAI to obtain the information.TLAA Audit WorksheetsDocument the audits/reviews using a worksheet which contains, as a minimum, the projectteam's question(s) related to the particular TLAA, the applicant's response(s) and notation of documents reviewed.6.4.2 Metal Fatigue Analyses Figure 5, "Evaluation of TLAAs and Exemptions," taken from NEI 95-10, Revision 6, shows theprocess of evaluating and reviewing TLAAs and also identifying the exemptions in effect. This process flowchart shows the activities and decisions used to audit/review each TLAA that the applicant identifies.Pre-Review PreparationA.The project team will determine if the TLAAs identified in the PNPS LRA to be within theNUREG-1800 TLAA category of "metal fatigue" have provided adequate information to meet the requirements of 10 CFR 54.21(c)(1) and 10 CFR 54.21(c)(2).

Pilgrim Nuclear Power StationAMP and AMR Audit and Review Plan 29B.Identify and locate the documents needed to perform the review. These may include,but are not limited to, the following: 1.Excel database on TLAAs summarizing how earlier LRAs and SERs presented andreviewed TLAAs 2.GALL Report, especially Section X.M1 3.SRP-LR 4.ISG-LR 5.RAIs, audit and review reports, and SERs for similar plants 6.LRA 7.References listed by applicant for each TLAA 8.NEI 95-10, Section 5.1 and Table 6.2-2 9.Basis documents

10. Implementation documents
11. Operating experience reports (plant-specific and industry)
12. Lessons learned developed by RLRC
13. Applicant's UFSARC.In addition, the project team will also review the PNPS TLAAs within the NUREG-1800TLAA category of "metal fatigue" to determine if there are emerging issues that should be further evaluated by technical specialists in the NRC Divisions of Component Integrity (DCI) or the Division of Engineering (DE). This is not expected to be an issue for TLAAs for which the applicant claims consistency with 10 CFR 54.21(c)(i) "the analyses remain valid for the period of extended operation." or 10 CFR 54.21(c)(iii) "the effects of aging on the intended function(s) will be adequately managed for the period of extended operation." For TLAAs for which the applicant claims consistency with 10 CFR 54.21(c)(ii) - "the analyses have been projected to the end of the period of extended operation," the audit team leader will be consulted to determine which TLAAs the audit team will be capable of reviewing. Consideration should be given to team expertise, past precedent, and complexity of the provided analysis.Audit/ReviewA.Confirm that each PNPS TLAA listed in this section is appropriate. Refer to anyanalyses and evaluations created during the acceptance review process.B.If a TLAA is listed in the SRP-LR or NEI 95-10 and not in its LRA, the PNPS shouldstate in this section that it does not apply.C.The project team will conduct both regulatory evaluations and technical evaluations todetermine, as defined in 10 CFR 54.3, that each TLAA meets the following six criteria: 1.Involve systems, structures, and components that are within the scope of licenserenewal, as delineated in 10 CFR 54.4(a). 2.Consider the effects of aging.

Pilgrim Nuclear Power StationAMP and AMR Audit and Review Plan 303.Involve time-limited assumptions defined by the current operating term (40 years). 4.Determined to be relevant by the applicant in making a safety determination.

5.Involve conclusions, or provide the basis for conclusions, related to the capability ofthe system, structure, and component to perform its intended functions, as delineated in 10 CFR 54.4(b). 6.Contained or incorporated by reference in the CLB.D.The project team will ascertain that the PNPS satisfactorily demonstrates that (1) theanalyses remain valid for the period of extended operation, (2) the analyses have been (or have been identified and will be [§54.29(a)]) projected to the end of the period of extended operation or (3) the effects of aging on the intended function(s) will be adequately managed for the period of extended operation.E.Review any industry and plant-specific operating experience associated with the TLAA. This is an area of review emphasis. The project team members should consider the following industry guidance on metal fatigue (from NEI 95-10, Table 6.2-2) as follows: 1.Disposition chosen for each of the identified TLAAs. Also, provide a reference to thesummary description of TLAA evaluations in the FSAR supplement (Appendix A).

Use hypertext to link to the appropriate location in the appendix for electronic submittals [§54.21(c)(1) and §54.21(d)1.F.If it is necessary to ask the applicant a question to clarify the basis for their analyses,follow the logic process shown in Figure 5 of this audit and review plan.G.If it is necessary for the applicant to submit additional information to support the basisfor the conclusions in their TLAA, the applicant may agree to voluntarily submit the required information as a supplement (docketed letter submitted under oath and affirmation) to the PNPS LRA. If not, the NRC may issue an RAI to obtain the information.TLAA Audit WorksheetsDocument the audits/reviews using a worksheet which contains, as a minimum, the projectteam's question(s) related to the particular TLAA, the applicant's response(s) and notation of documents reviewed.6.4.3 Environmental Qualification Analyses for Electrical Components Figure 5, "Evaluation of TLAAs and Exemptions," taken from NEI 95-10, Revision 6, shows theprocess of evaluating and reviewing TLAAs and also identifying the exemptions in effect. This process flowchart shows the activities and decisions used to audit/review each TLAA that the applicant identifies.

Pilgrim Nuclear Power StationAMP and AMR Audit and Review Plan 31Pre-Review PreparationA.The project team will determine if the TLAAs identified in the PNPS LRA to be within theNUREG-1800 TLAA category of "environmental qualification of electric equipment" have provided adequate information to meet the requirements of 10 CFR 54.21(c)(1) and 10 CFR 54.21(c)(2).B.Identify and locate the documents needed to perform the review. These may include,but are not limited to, the following: 1.Excel database on TLAAs summarizing how earlier LRAs and SERs presented andreviewed TLAAs 2.GALL Report, especially Section X.E1 3.SRP-LR 4.ISG-LR 5.RAIs, audit and review reports, and SERs for similar plants 6.LRA 7.References listed by applicant for each TLAA 8.NEI 95-10, Section 5.1 and Table 6.2-2 9.Basis documents

10. Implementation documents
11. Operating experience reports (plant-specific and industry)
12. Lessons learned developed by RLRC
13. Applicant's UFSARC.In addition, the project team will also review the PNPS TLAAs within the NUREG-1800TLAA category of "environmental qualification of electric equipment" to determine if there are emerging issues that should be further evaluated by technical specialists in the NRC Divisions of Component Integrity (DCI) or the Division of Engineering (DE). This is not expected to be an issue for TLAAs for which the applicant claims consistency with 10 CFR 54.21(c)(i) "the analyses remain valid for the period of extended operation." or 10 CFR 54.21(c)(iii) "the effects of aging on the intended function(s) will be adequately managed for the period of extended operation." For TLAAs for which the applicant claims consistency with 10 CFR 54.21(c)(ii) - "the analyses have been projected to the end of the period of extended operation," the audit team leader will be consulted to determine which TLAAs the audit team will be capable of reviewing. Consideration should be given to team expertise, past precedent, and complexity of the provided analysis.Audit/ReviewA.Confirm that each PNPS TLAA listed in this section is appropriate. Refer to anyanalyses and evaluations created during the acceptance review process.B.If a TLAA is listed in the SRP-LR or NEI 95-10 and not in its LRA, the PNPS shouldstate in this section that it does not apply.

Pilgrim Nuclear Power StationAMP and AMR Audit and Review Plan 32C.The project team will conduct both regulatory evaluations and technical evaluations todetermine, as defined in 10 CFR 54.3, that each TLAA meets the following six criteria: 1.Involve systems, structures, and components that are within the scope of licenserenewal, as delineated in 10 CFR 54.4(a). 2.Consider the effects of aging.

3.Involve time-limited assumptions defined by the current operating term (40 years).

4.Determined to be relevant by the applicant in making a safety determination.

5.Involve conclusions, or provide the basis for conclusions, related to the capability ofthe system, structure, and component to perform its intended functions, as delineated in 10 CFR 54.4(b). 6.Contained or incorporated by reference in the CLB.D.The project team will ascertain that the PNPS satisfactorily demonstrates that (1) theanalyses remain valid for the period of extended operation, (2) the analyses have been (or have been identified and will be [§54.29(a)]) projected to the end of the period of extended operation or (3) the effects of aging on the intended function(s) will be adequately managed for the period of extended operation.E.Review any industry and plant-specific operating experience associated with the TLAA.This is an area of review emphasis. The project team members should consider the following industry guidance on environmental qualification of electric equipment (from NEI 95-10, Table 6.2-2) as follows: 1.Disposition chosen for each of the identified TLAAs. Also, provide a reference to thesummary description of TLAA evaluations in the FSAR supplement (Appendix A).

Use hypertext to link to the appropriate location in the appendix for electronic submi ttals [§54.21(c)(1) and §54.21(d)1.F.If it is necessary to ask the applicant a question to clarify the basis for their analyses,follow the logic process shown in Figure 5 of this audit and review plan.G.If it is necessary for the applicant to submit additional information to support the basisfor the conclusions in their TLAA, the applicant may agree to voluntarily submit the required information as a supplement (docketed letter submitted under oath and affirmation) to the PNPS LRA. If not, the NRC may issue an RAI to obtain the information.

Pilgrim Nuclear Power StationAMP and AMR Audit and Review Plan 33TLAA Audit WorksheetsDocument the audits/reviews using a worksheet which contains, as a minimum, the projectteam's question(s) related to the particular TLAA, the applicant's response(s) and notation of documents reviewed.6.4.4 Other Plant-Specific TLAAs Figure 5, "Evaluation of TLAAs and Exemptions," taken from NEI 95-10, Revision 6, shows theprocess of evaluating and reviewing TLAAs and also identifying the exemptions in effect. This process flowchart shows the activities and decisions used to audit/review each TLAA that the applicant identifies.Pre-Review PreparationA.The project team will determine if the TLAAs identified in the PNPS LRA to be within theNUREG-1800 TLAA category of "other plant-specific TLAAs" have provided adequate information to meet the requirements of 10 CFR 54.21(c)(1) and 10 CFR 54.21(c)(2).B.Identify and locate the documents needed to perform the review. These may include,but are not limited to, the following: 1.Excel database on TLAAs summarizing how earlier LRAs and SERs presented andreviewed TLAAs 2.GALL Report 3.SRP-LR 4.ISG-LR 5.RAIs, audit and review reports, and SERs for similar plants 6.LRA 7.References listed by applicant for each TLAA 8.NEI 95-10, Section 5.1 and Table 6.2-2 9.Basis documents

10. Implementation documents
11. Operating experience reports (plant-specific and industry)
12. Lessons learned developed by RLRC
13. Applicant's UFSARC.In addition, the project team will also review the PNPS TLAAs within the NUREG-1800TLAA category of "other plant-specific TLAAs" to determine if there are emerging issues that should be further evaluated by technical specialists in the NRC Divisions of Component Integrity (DCI) or the Division of Engineering (DE). This is not expected to be an issue for TLAAs for which the applicant claims consistency with 10 CFR 54.21(c)(i) "the analyses remain valid for the period of extended operation." or 10 CFR 54.21(c)(iii) "the effects of aging on the intended function(s) will be adequately managed for the period of extended operation." For TLAAs for which the applicant claims consistency with 10 CFR 54.21(c)(ii) - "the analyses have been projected to the end of the period of extended operation," the audit team leader will be consulted to determine Pilgrim Nuclear Power StationAMP and AMR Audit and Review Plan 34which TLAAs the audit team will be capable of reviewing. Consideration should be givento team expertise, past precedent, and complexity of the provided analysis.Audit/ReviewA.Confirm that each PNPS TLAA listed in this section is appropriate. Refer to anyanalyses and evaluations created during the acceptance review process.B.If a TLAA is listed in the SRP-LR or NEI 95-10 and not in its LRA, the PNPS shouldstate in this section that it does not apply.C.The project team will conduct both regulatory evaluations and technical evaluations todetermine, as defined in 10 CFR 54.3, that each TLAA meets the following six criteria:1.Involve systems, structures, and components that are within the scope of licenserenewal, as delineated in 10 CFR 54.4(a). 2.Consider the effects of aging.

3.Involve time-limited assumptions defined by the current operating term (40 years).

4.Determined to be relevant by the applicant in making a safety determination.

5.Involve conclusions, or provide the basis for conclusions, related to the capability ofthe system, structure, and component to perform its intended functions, as delineated in 10 CFR 54.4(b). 6.Contained or incorporated by reference in the CLB.D.The project team will ascertain that the PNPS satisfactorily demonstrates that (1) theanalyses remain valid for the period of extended operation, (2) the analyses have been (or have been identified and will be [§54.29(a)]) projected to the end of the period of extended operation or (3) the effects of aging on the intended function(s) will be adequately managed for the period of extended operation.E.Review any industry and plant-specific operating experience associated with the TLAA.This is an area of review emphasis. The project team members should consider the following industry guidance on "other plant-specific TLAAs" (from NEI 95-10, Table 6.2-2) as follows: 1.Identify and evaluate any plant-specific TLAAs.F.If it is necessary to ask the applicant a question to clarify the basis for their analyses,follow the logic process shown in Figure 5 of this audit and review plan.G.If it is necessary for the applicant to submit additional information to support the basisfor the conclusions in their TLAA, the applicant may agree to voluntarily submit the Pilgrim Nuclear Power StationAMP and AMR Audit and Review Plan 35required information as a supplement (docketed letter submitted under oath andaffirmation) to the PNPS LRA. If not, the NRC may issue an RAI to obtain the information.TLAA Audit WorksheetsDocument the audits/reviews using a worksheet which contains, as a minimum, the projectteam's question(s) related to the particular TLAA, the applicant's response(s) and notation of documents reviewed.6.5Audit and Safety Review DocumentationAs noted in Section 5.7 of this plan, the project team will prepare an audit and review plan,worksheets, work packages, requests for additional information, an audit and review report, and a SER input. This section of the plan addresses the preparation of the audit and review report and the SER input.6.5.1Audit and Review Report The project team should prepare input to the audit report in accordance with the guidanceprovided in the Writing Guide and Template for Preparing License Renewal Application Audit Report. The audit report should follow the following format:A.Cover pageB.Table of Contents C.Section 1 Introduction and General Information1.Section 1.1 Introduction2.Section 1.2 Background 3.Section 1.3 Summary of Information in the License Renewal Application 4.Section 1.4 Audit Scope 5.Section 1.5 Audit Process 6.Section 1.6 Exit MeetingD.Section 2 Aging Management Programs (AMP)

E.Section 3 Aging Management Review (AMR) Results F.Attachment 1Abbreviations and Acronyms G.Attachment 2Project Team and Applicant Personnel H.Attachment 3Elements of an Aging Management Program for License Renewal I.Attachment 4Disposition of Requests for Additional Information, LRA Supplements,and Open Items Pilgrim Nuclear Power StationAMP and AMR Audit and Review Plan 4AMRs that are not consistent with the GALL Report.

36J.Attachment 5List of Documents ReviewedK.Attachment 6List of Commitments6.5.2Safety Evaluation Report InputA.General guidance1.Each project team member should prepare the SER input for the AMP and AMRaudits and reviews that he or she performed. The technical assistance contractor shall collect, assemble, and prepare the complete SER input.2.In general, the data and information needed to prepare the SER input should beavailable in the project team's audit and review report and the team member's worksheets. 3.SER inputs are to be prepared for:a.Each AMP that was determined to be consistent with the GALL Report, whichhas no exceptions or enhancements.b.Each AMP that was determined to be consistent with the GALL Report, whichhas exceptions (identified by either the applicant or the project team) or enhancements.c.Each plant-specific AMP.

d.AMRs that are consistent with the GALL Report.

e.Project team AMR review results.

44.The SER input should contain the following sections. (Note: The following sectionnumbers (3. through 3.X.3) are based on the numbering system for the SER input.

They are not a continuation of the numbering convention used throughout this plan.)3.Aging Management Review Results3.0Applicant's Use of the Generic Aging Lessons Learned Report3.01Format of the LRA 3.02Staff's Review Process3.0.2.1AMRs in the GALL Report 3.0.2.2NRC-Approved Precedents 3.0.2.3UFSAR Supplement 3.0.2.4Documentation and Documents Reviewed3.0.3Aging Management Programs Pilgrim Nuclear Power StationAMP and AMR Audit and Review Plan 5The LRA AMR results are broken down into six sections and address the followingsystem/structure groups: (1) Section 3.1, reactor vessel, internals and reactor coolant system, (2) Section 3.2, engineering safety features systems, (3) Section 3.3, auxiliary systems, (4)

Section 3.4, steam power and conversion systems, (5) Section 3.5, structures and component supports, (6) Section 3.6, electrical and instrumentation and controls.

373.0.3.1AMPs that are Consistent With the GALL Report3.0.3.2AMPs that are Consistent With GALL Report WithExceptions or Enhancements3.0.3.3AMPs that are Plant-Specific3.0.4Quality Assurance Program Attributes Integral to Aging ManagementPrograms3.X 5Aging Management of ______ 3.X.1Summary of Technical Information in the Application 3.X.2Staff Evaluation3.X.2.1Aging Management Evaluations that are Consistent withthe GALL Report, for Which Further Evaluation is Not Required3.X.2.2Aging Management Evaluations that are Consistent withthe GALL Report, for Which Further Evaluation is Recommended3.X.2.3AMR Results that are Not Consistent with or NotAddressed in the GALL Report3.X.3Conclusion5.For each AMP audited/reviewed by the project team, the SER shall include adiscussion of the team's review of the operating experience program element.6.If the applicant submitted an amendment or a supplement to its LRA that isassociated with the project team's audit or review activities, document the submittal (include the date and ADAMS accession number) and explain the issue that the submittal resolved and discuss the basis for the resolution.7.If an RAI was issued, identify the RAI number and briefly discuss the RAI. State ifthe RAI remains open or if the applicant response has been received and accepted.

If the response was acceptable, identify the submittal (including the date and the ADAMS accession number) that provided the response and document the basis for its acceptance.8.Issues (e.g., RAIs) that have not been resolved by the applicant at the time the SERinput is prepared should be identified as open items.B.SER input1.For AMPs determined to be consistent with the GALL Report, without exceptions,include the AMP title, the plant AMP paragraph number, and a discussion of thebasis for concluding that the UFSAR update (Appendix A of the LRA) is Pilgrim Nuclear Power StationAMP and AMR Audit and Review Plan 6The audit results documented in this section address the AMRs consistent with the GALLReport for which no further evaluation is recommended.

38acceptable. This SER input documents that the AMP is consistent with the GALLReport. 2.For AMPs determined to be consistent with the GALL Report, with exceptions orenhancement, the SER input should include a statement that the audit found the AMP consistent with the GALL Report and that any applicant-identified exceptions to the GALL Report were found technically acceptable to manage the aging effect during the period of extended operation. The SER input should identify the exceptions and provide the basis for acceptance. The SER input will also address the UFSAR supplement, and document the basis for concluding that it is acceptable.3.For plant-specific AMPs, the SER input should document the basis for acceptingeach of the seven elements reviewed by the project team. The SER input should also include a discussion concerning the adequacy of the UFSAR supplement.4.For aging management evaluations that are consistent with the GALL Report, 6 theSER input should include the following: a.Identify the LRA section reviewed.

b.A summary of the type of information provided in the section of the LRAreviewed, including a listing of the AMPs reviewed. c.Identify the LRA Tables 3.X.2-Y reviewed.

d.A summary review of the AMR Notes A through E used to classify the AMR lineitems used in these tables.e.A brief summary of what the staff (project team) reviewed to perform the audit(i.e., LRA and applicant basis documents and other implementation documents).

Reference the appendix that lists the details of the documents reviewed.f.The bases for accepting any exceptions to GALL AMRs that were identified bythe applicant or the project team member.g.A finding that verifies that: *The applicant identified the applicable aging effects.

  • The applicant defined the appropriate combination of materials andenvironments. *The applicant specified acceptable AMPs.

Pilgrim Nuclear Power StationAMP and AMR Audit and Review Plan 7This section documents reviews of AMRs assigned to the project team that are not consistentwith the GALL Report.

39h.A conclusion stating, if applicable, that the applicant has demonstrated that theeffects of aging will be adequately managed so that the intended functions will be maintained consistent with the CLB for the period of extended operation, and that 10 CFR 54.21(a)(3) has been satisfied.5.For aging management evaluations that are consistent with the GALL Report, forwhich further evaluation is recommended, the SER input should include the following:a.The LRA section containing the applicant's further evaluations of AMRs for whichfurther evaluation is required.b.A list of the aging effects for which the further evaluation apply.

c.For the applicant's further evaluations, provide a summary of the basis forconcluding that it satisfied the criteria of Section 3.1.3.2 of the SRP-LR. d.A statement that the staff audited the applicant's further evaluations against thecriteria contained in Section 3.1.3.2 of the SRP-LR.e.A statement that the audit and review report contains additional information. Also identify the issue date and the ADAMS accession number for the audit and review report.6.Staff AMR Review Results.

7 This section of the SER input documents the reviews ofAMRs assigned to the project team that are not consistent with the GALL Report.

The audit report should document the following, based on a precedent identified by the applicant:a.The LRA section reviewed.

b.A summary of the type of information provided in the section of the LRA,reviewed, including a listing of the AMPs reviewed for this LRA section. c.Identify the LRA Tables 3.X.2-Y documented by this audit writeup.

d.A brief summary of what the staff (project team) reviewed (i.e., LRA andapplicant basis documents and other implementation documents). e.A finding that verifies, if true, that: *The applicant identified the applicable aging effects.

Pilgrim Nuclear Power StationAMP and AMR Audit and Review Plan 40*The applicant listed the appropriate combination of materials andenvironments. *The applicant specified acceptable AMPs.f.Provide a conclusion stating, if applicable, that the applicant has demonstratedthat the effects of aging will be adequately managed so that the intended functions will be maintained consistent with the CLB for the period of extended operation, and that 10 CFR 54.21(a)(3) has been satisfied.6.6Documents Reviewed and Document RetentionAny documents reviewed that were used to formulate the basis for resolution of an issue, suchas the basis for a technical resolution, the basis for the acceptance of an exception or an enhancement, etc., should be documented as a reference in the audit and review report.Upon issuance of the audit and review report, all worksheets that were completed by contractorand NRC personnel shall be given to the NRC project team leader.After the NRC has made its licensing decision, all copies of documents collected and alldocuments generated to complete the audit and review report, such as audit worksheets, question and answer tracking documentation, etc., are to be discarded.

Pilgrim Nuclear Power StationAMP and AMR Audit and Review Plan 41Table 1. Aging Management Program Element DescriptionsElementDescription1Scope of the programThe scope of the program should include the specificstructures and components subject to an aging management review. 2Preventive actionsPreventive actions should mitigate or prevent the applicableaging effects. 3Parameters monitored orinspectedParameters monitored or inspected should be linked to theeffects of aging on the intended functions of the particular structure and component. 4Detection of aging effectsDetection of aging effects should occur before there is loss ofany structure and component intended function. This includes aspects such as method or technique (i.e., visual, volumetric, surface inspection), frequency, sample size, data collection and timing of new/one-time inspections to ensure timely detection of aging effects. 5Monitoring and trendingMonitoring and trending should provide prediction of the extentof the effects of aging and timely corrective or mitigative actions. 6Acceptance criteriaAcceptance criteria, against which the need for correctiveaction will be evaluated, should ensure that the particular structure and component intended functions are maintained under all current licensing basis design conditions during the period of extended operation. 7Corrective actionsCorrective actions, including root cause determination andprevention of recurrence, should be timely.8Confirmation processThe confirmation process should ensure that preventiveactions are adequate and appropriate corrective actions have been completed and are effective. 9Administrative controlsAdministrative controls should provide a formal review andapproval process. 10Operating experienceOperating experience involving the aging managementprogram, including past corrective actions resulting in program enhancements or additional programs, should provide objective evidence to support a determination that the effects of aging will be adequately managed so that the structure and component intended functions will be maintained during the period of extended operation.

Pilgrim Nuclear Power StationAMP and AMR Audit and Review Plan 8Each AMR line item is coded with a letter which represents a standard note designation basedon a letter from A. Nelson, NEI, to P.T. Kuo, NRC, "U.S. Nuclear Industry's ProposedStandard License Renewal Application Format Package, Request NRC Concurrence," datedJanuary 24, 2003 (ML030290201). The staff concurred in the format of the standardized format for license renewal applications by letter dated April 7, 2003, from P.T. Kuo, NRC, to A.

Nelson, NEI (ML030990052).

42Table 2. Notes for License Renewal Application Tables 3.X.2-Y 8NoteDescriptionAConsistent with NUREG-1801 [GALL Report] item for component, material,environment, and aging effect. AMP is consistent with NUREG-1801 AMP.BConsistent with NUREG-1801 item for component, material, environment, and agingeffect. AMP takes some exceptions to NUREG-1801 AMP.CComponent is different, but consistent with NUREG-1801 item for material,environment, and aging effect. AMP is consistent with NUREG-1801 AMP.DComponent is different, but consistent with NUREG-1801 item for material,environment, and aging effect. AMP takes some exceptions to NUREG-1801 AMP.EConsistent with NUREG-1801 for material, environment, and aging effect, but adifferent aging management program is credited.FMaterial not in NUREG-1801 for this component.GEnvironment not in NUREG-1801 for this component and material.HAging effect not in NUREG-1801 for this component, material and environmentcombination.IAging effect in NUREG-1801 for this component, material and environmentcombination is not applicable.JNeither the component nor the material and environment combination is evaluated inNUREG-1801.

Pilgrim Nuclear Power StationAMP and AMR Audit and Review Plan 43Figure 1. Audit of AMPs that are Consistent with the GALL Report Yes NoYesYes No Yes NoStartDid applicant identifyany exceptions to GALLAMP(s)?Compare each GALL AMPauditable element to the LRAAMPDocument the basis foracceptance of the attributeelement in worksheetHave all attribute elementsbeen audited?

YesPreparation StepsIdentify GALL AMP(s) towhich LRA AMP is beingcomparedIdentify elements of GALLAMP(s) attributes to beauditedIdentify LRA AMP supportdocuments needed toperform auditIs there a technicalbasis to accept exception ordifference?Note: If a prior NRCprecedent exists, it maybe used as an aid to make the technicaldetermination.Documentation of the acceptance must be made on the technicalmerits not a citation tothe precedent.Ask applicant a clarifyingquestion to continue audit?

NoNotify NRCTeam Leaderthat Audit ofAMR may notproceed.Terminate AMPauditDevelop andprovide questionto Team Leaderfor PM's submittalto applicantObtainresponse fromapplicantDraft RAI NoNote; Preparation stepsmay be performed as asingle combined step foreach AMP audited.

Yes NoIs the attributeelement consistent?Write audit report input perguidance in Section D.E.FConclusion ofAMP auditProvide audit report inputWrite SE input per guidance inSection G.H.JProvide audit SE inputHave all 7 AMPattributes been audited?

No Pilgrim Nuclear Power StationAMP and AMR Audit and Review Plan 44Yes NoYes NoYesYes No NoStartCompare each SRP-LR AMPcriteria element to the LRAAMPDocument the basis foracceptance of the element inworksheetHave all element criteriabeen audited?Preparation StepsIdentify criteria of SRP-LR,Appendix A elemets whichare auditableIdentify LRA AMP supportdocuments needed toperform auditIs there a technical basisto accept exception ordifference?Note: If a prior NRCprecedent exist, it may be used as an aid to make the technicaldetermination.Documentation of the acceptance must be made on the technicalmerits not a citation tothe precedent.Is it appropriateto ask applicant a clarifyingquestion to continue audit?Developquestion NoNotify NRCTeam Leader that review ofAMP may notproceed.Terminate AMP auditProvidequestion toTeam leaderfor PM'ssubmittal toapplicantObtainresponse fromapplicantDraft RAINote; Preparation stepsmay be performed as asingle combined step foreach AMP audited.Yes NoIs the AMP elementconsistent?Write audit and review reportinputConclusion ofAMP reviewProvide NRC team leader andcontractor audit report inputWrite SER inputProvide NRC team leader andcontractor audit SER inputHave all 7 AMPelements been audited?Figure 2. Audit of Plant-Specific AMPs Pilgrim Nuclear Power StationAMP and AMR Audit and Review Plan 45Footnote AConfirm that AMP willaddress AE for thiscomponent andenvironmentCompare line item withGALL Vol. 2 SystemTable line item for:component type materialenvironmentaging effect

-Confirm AE stillmanaged despiteAMP exceptionConfirm material,environment, AE, andmethod per AMP arecomparableConfirm material,environment and agingeffect are comparable andAE still managed despiteAMP exceptionConfirm AMP can managethis AEFootnote BFootnote CFootnote DFootnote ECompare line item withGALL Vol. 2 SystemTable line item for:

- materialenvironmentaging effectAMPCompare line item withGALL Vol. 2 SystemTable line item for:

- materialenvironmentaging effect

-Compare line item withGALL Vol. 2 SystemTable line item for:

- materialenvironmentaging effect

-Compare item withGALL Vol. 2 SystemTable item for:component type materialenvironmentaging effect AMPItem isassigned to DE NoDocument basis for acceptancein AMR Comparison ChecklistPrepare questionReview corresponding LRA Table3.X.1"Further Evaluation Recommended"and "Discussion" columnsReview referenced LRA subsection andcompare with SRP subsection for anydifferencesAcceptable inall aspects NoMark as Out of ScopeOut of RLEPScopeMark as AcceptableMark for queryDocument problem inAMR Comparison ChecklistConfirm questionis capturedAMR line itemcompleteAMR item AMPis Plant-Specific NoYesYesYes NoNoNoNoNoYesYesYesYesYesYes NoFurtherEvaluation Figure 3. Review of AMRs that are Consistent with the GALL Report Pilgrim Nuclear Power StationAMP and AMR Audit and Review Plan 46Review cited SERValid precedentApplicantproposesprecedentReview cited LRA(may not berequired in allcases)RAIs existReview all relevantRAIsDocument basis for acceptancein AMR Comparison ChecklistMark as AcceptableAMR completeAlternativeprecedentidentifiedPreparequestionMark for queryDocument problem inAMR ComparisonChecklistConfirm questionis capturedOut of RLEPScopeMark as Open ItemProposeassignmentto DEAdditionalinformationneededIdentify or requestalternativeprecedentDocument absence ofprecedent in AMRComparison ChecklistYesYesYes Yes Yes No No No No No Figure 4. Review of AMRs Using NRC-Approved Precedents Pilgrim Nuclear Power StationAMP and AMR Audit and Review Plan 47Figure 5. Review of TLAAs and Exemptions (from NEI 95-10, Revision 6)

Pilgrim Nuclear Power StationAMP and AMR Audit and Review PlanA-1APPENDIX APROJECT TEAM MEMBERSHIPOrganizationNameFunctionNRC/NRR/DLR/RLRCJames DavisTeam leaderNRC/NRR/DLR/RLRCPeter WenBack-up Team Leader NRC/NRR/DLR/RLRCDan HoangReviewer - Structures NRC/NRR/DLR/RLRCDuc NguyenReviewer - Electrical ATL InternationalErach PatelContractor lead, Reviewer - Mechanical ATL InternationalBob JacksonReviewer - Systems ATL InternationalWayne PavinichReviewer - Materials Pilgrim Nuclear Power StationAMP and AMR Audit and Review PlanB-1APPENDIX BRLRC SCHEDULE FOR PILGRIM LRA SAFETY REVIEW Plant:Pilgrim Nuclear Power StationTAC No. MC9669Team Leader:James DavisScope of Work:Backup Team Leader:Peter WenAMPs - 37 of 38Project Manager:Kathy WeaverTLAAs - 6 of 9Contractor:ATL International, IncAMRs - 3,375 Total line itemsAssignments:Erach Patel (ATL)RAI Target Date:08/04/06Peter Wen (NRC), Dan Haung (NRC), SE Input to PM:10/16/06Duc Nguyen (NRC), Robert Jackson (ATL), Wayne Pavinich (ATL)Activity/MilestoneScheduled Date1Received license renewal application (LRA)01/27/062Make review assignments (Project Manager)03/28/06 3Train project team (Team Introduction Meeting)03/20/06 4Hold team planning and kick-off meeting 03/20/06 5Issue audit plan to Project Manager 05/01/06 6Conduct first site visit (AMP audit and review)05/22 - 05/26/06 7Draft AMP audit report input06/09/06 8Conduct in-office AMR reviews06/12 - 06/16/06 9Conduct second site visit (AMR audit and review)06/19 - 06/23/0610Draft AMR audit report input07/14/06 11Third site visit to resolve issues and questions (if needed)07/24 - 07/27/06 12Conduct public exit meeting07/27/06 13Cutoff for providing RAIs to Project Manager08/04/06 14Peer review of final draft audit and review report08/07 - 08/18/06 15Issue final audit and review report 09/08/06 16Issue final draft SER input to Project Manager10/16/06 17ACRS subcommittee meetingApril 2007 18ACRS full committee meetingSept. 2007

Pilgrim Nuclear Power StationAMP and AMR Audit and Review Plan C-1APPENDIX CAGING MANAGEMENT PROGRAM ASSIGNMENTS PNPS LRAAMPNumberGALL ReportAMPNumberAging Management Program Consistent With GALL?AssignedAuditorB.1.1XI.M.22Boraflex Monitoring YesPeter WenB.1.2XI.M.34Buried Piping and Tanks InspectionYesExceptionJim Davis B.1.3XI.M.6BWR Control Rod Drive Return Line Nozzle YesExceptionJim Davis B.1.4XI.M.5BWR Feedwater NozzleYesExceptionJim Davis B.1.5XI.M.8BWR PenetrationsYesExceptionBob Jackson B.1.6XI.M.7BWR Stress Corrosion CrackingYesException - EnhancedBob Jackson B.1.7XI.M.4BWR Vessel ID Attachment WeldsYesExceptionBob JacksonB.1.8XI.M.9BWR Vessel InternalsYesException - EnhancedBob JacksonB.1.9XI.S.4Containment Leak RateYesDan Hoang B.1.10XI.M.30Diesel Fuel Monitoring YesException - EnhancedWayne Pavinich B.1.11X.E.1Environmental Qualification of Electric ComponentsYesDuc Nguyen B.1.12X.M.1Fatigue Monitoring YesException Erach Patel B.1.13.1XI.M.26Fire ProtectionYesException - EnhancedErach Patel B.1.13.2XI.M.27Fire Water SystemYesException - EnhancedErach Patel B.1.14XI.M.17Flow-Accelerated CorrosionYesPeter Wen B.1.15N/AHeat Exchanger MonitoringWayne Pavinich B.1.16.1N/AContainment Inservice InspectionDan Hoang Pilgrim Nuclear Power StationAMP and AMR Audit and Review Plan PNPS LRAAMPNumberGALL ReportAMPNumberAging Management Program Consistent With GALL?AssignedAuditor C-2B.1.16.2N/AInservice InspectionBob JacksonB.1.17N/AInstrument Air QualityWayne Pavinich B.1.18XI.E.4Metal-Enclosed Bus Inspection YesExceptionDuc Nguyen B.1.19XI.E.3Non-EQ Inaccessible Medium-Voltage Cable ProgramYesDuc Nguyen B.1.20XI.E.2Non-EQ Instrumentation Circuits Test Review YesDuc Nguyen B.1.21XI.E.1Non-EQ Insulated Cables and Connections YesDuc Nguyen B.1.22XI.M.39Oil Analysis YesException - EnhancedWayne Pavinich B.1.23XI.M.32One-Time Inspection YesErach Patel B.1.24N/APeriodic Surveillance and Preventive MaintenanceWayne Pavinich B.1.25XI.M.3Reactor Head Closure Studs YesExceptionBob Jackson B.1.26XI.M.31Reactor Vessel Surveillance YesEnhancedDE Staff B.1.27XI.M.33Selective Leaching YesPeter Wen B.1.28XI.M.20Service Water Integrity YesExceptionWayne Pavinich B.1.29.1XI.S.5Masonry WallYesDan Hoang B.1.29.2XI.S.6Structures MonitoringYesEnhancedDan Hoang B.1.29.3XI.S.7Water Control Structures MonitoringYesEnhancedDan Hoang B.1.30XI.M.36System Walkdown YesPeter Wen B.1.31XI.M.13Thermal Aging and Neutron Irradiation Embrittlementof Cast Austenitic Stainless Steel (CASS) YesPeter WenB.1.32.1N/AWater Chemistry Control - Auxiliary SystemsErach Patel Pilgrim Nuclear Power StationAMP and AMR Audit and Review Plan PNPS LRAAMPNumberGALL ReportAMPNumberAging Management Program Consistent With GALL?AssignedAuditor C-3B.1.32.2XI.M.2Water Chemistry Control - BWR YesErach PatelB.1.32.3XI.M.21Water Chemistry Control - Closed Cooling Water YesExceptionErach Patel Pilgrim Nuclear Power StationAMP and AMR Audit and Review Plan D-1APPENDIX DAGING MANAGEMENT REVIEW ASSIGNMENTSAging Management ReviewsReviewer3.1Aging Management of Reactor Vessel, Internals, and ReactorCoolant SystemBob Jackson3.2Aging Management of Engineered Safety FeaturesWayne Pavinich3.3Aging Management of Auxiliary SystemsErach Patel 3.4Aging Management of Steam and Power Conversion SystemsPeter Wen 3.5Aging Management of Containment, Structures, and ComponentSupports Dan Hoang3.6Aging Management of Electrical and Instrumentation and ControlsDuc Nguyen Pilgrim Nuclear Power StationAMP and AMR Audit and Review PlanE-1APPENDIX ETIME-LIMITED AGING ANALYSIS REVIEW ASSIGNMENTS LRATLAANumberGALL ReportTLAANumberTLAA Title10 CFR 54.21(c)(1)AssignedReviewer(i) or (iii)(ii)4.1Identification of TLAAs andExemptionsJ. Davis4.2Reactor Vessel NeutronEmbrittlement(i)(ii)DCI4.3X.M.1Metal Fatigue (i) or (iii)(ii)E. Patel 4.4X.E.1Environmental Qualification orElectrical Components(iii)D. Nguyen4.5X.S.1Concrete Containment TendonPrestress Not Applicableto PNPSN/A4.6Containment Liner Plate, MetalContainment, and Penetrations Fatigue Analysis (ii)D. Hoang4.7.1Reflood Thermal Shock Analysisof the Reactor Vessel Internals(i)DCI4.7.2.1TLAA in BWRVIP-05DCI4.7.2.2TLAA in BWRVIP-48(ii)B. Jackson 4.7.2.3TLAA in BWRVIP-49 (ii)B. Jackson 4.7.2.4TLAA in BWRVIP-74 DCI 4.7.2.5TLAA in BWRVIP-76 (ii)B. Jackson Pilgrim Nuclear Power StationAMP and AMR Audit and Review Plan F-1 APPENDIX FCONSISTENT WITH GALL REPORT AMP AUDIT/REVIEW WORKSHEETThe worksheet provided in this appendix provides, as an aid for the reviewer, a process fordocumenting the basis for the assessment of the elements and sub-elements contained in the GALL Report AMPs (Chapter XI of NUREG-1801, Volume 2). The worksheet provides a systematic method for recording the basis for assessments or to identify when the applicant needs to provide clarification or additional information. Information recorded in the worksheets will also be used to prepare the audit and review report and the safety evaluation report input. A complete set of GALL Report AMP worksheets can be found at ADAMS Accession NumberML060950189.

Pilgrim Nuclear Power StationAMP and AMR Audit and Review Plan F-2LRA Appendix Subsection: LRA AMP Title: GALL Report Subsection:Gall Report Title:A. Element Review and AuditProgram

Description:

G Consistent with GALL Report G Difference Identified Discussion: 1. Scope of Program:

G Consistent with GALL Report G Exception G Enhancement G Difference Identified Discussion:2. Preventive Action:

G Consistent with GALL Report G Exception G Enhancement G Difference Identified Discussion:3. Parameters Monitored/Inspected:

G Consistent with GALL Report G Exception G Enhancement G Difference Identified Discussion:4. Detection of Aging Effects:

G Consistent with GALL Report G Exception G Enhancement G Difference Identified Discussion:5. Monitoring and Trending:

G Consistent with GALL Report G Exception G Enhancement G Difference Identified Discussion:6. Acceptance Criteria:

G Consistent with GALL Report G Exception G Enhancement G Difference Identified Discussion:7. Corrective Action:

Pilgrim Nuclear Power StationAMP and AMR Audit and Review Plan F-38. Confirmation Process: 9. Administrative Controls: 10. Operating Experience:B. FSAR supplement review: (Include any commitments.)C.Remarks and questions:

D.References/documents used: (Include number designation, full title, revision number,date, and page numbers, and ADAMS accession number.)E.Applicant contact:Project team member: __________________________________ Date: ______________

Pilgrim Nuclear Power StationAMP and AMR Audit and Review Plan G-1APPENDIX GPLANT-SPECIFIC AMP AUDIT/REVIEW WORKSHEETThe worksheet provided in this appendix provides, as an aid for the reviewer, a process fordocumenting the basis for the assessments concerning individual program elements and sub-elements contained in Branch Technical Position RLSB-1 "Aging Management Review -

Generic," in Appendix A to the SRP-LR. The worksheet provides a systematic method to record the basis for assessments or identifying when the applicant needs to provide additional information. Information recorded in these worksheets will be used when preparing the audit and review report and the safety evaluation report input.

Pilgrim Nuclear Power StationAMP and AMR Audit and Review Plan G-2Plant-Specific AMP Audit/Review Worksheet AMP Title: ______________________________________________________________

Appendix Subsection: ____________________________________________________A.Element Review and Audit1.Scope of Program:

___ Consistent with SRP-LR____ Exception____ Difference Identified Discussion:SRP CriteriaLRA AMPComment*2.Preventive Action:

___ Consistent with SRP-LR____ Exception____ Difference Identified Discussion:SRP CriteriaLRA AMPComment*3.Parameters Monitored/Inspected:

___ Consistent with SRP-LR____ Exception____ Difference Identified Discussion:SRP CriteriaLRA AMPComment*4.Detection of Aging Effects

___ Consistent with SRP-LR____ Exception____ Difference Identified Discussion: SRP CriteriaLRA AMPComment*

Pilgrim Nuclear Power StationAMP and AMR Audit and Review Plan G-35.Monitoring and Trending___ Consistent with SRP-LR____ Exception____ Difference Identified Discussion:SRP CriteriaLRA AMPComment*6.Acceptance Criteria___ Consistent with SRP-LR____ Exception____ Difference Identified Discussion:SRP CriteriaLRA AMPComment*7.Corrective Action:To be performed by DIPM 8.Confirmation Process:To be performed by DIPM 9.Administrative Controls:To be performend by DIPM 10.Operating Experience:

___ Consistent with SRP-LR____ Exception____ Difference Identified Discussion:SRP CriteriaLRA AMPComment**Consistent or technical basis for acceptance exception or differenceB.FSAR supplement review: (Include any committments.)C.Remarks and questions:

D.References/Documents used: (Include number designation, full title, revision number,date, page numbers, and ADAMS accession number.)E.Applicant Contact:

Project team member:

_________________________________Date: ______________

Pilgrim Nuclear Power StationAMP and AMR Audit and Review Plan H-1Appendix HAMR Comparison Worksheets Pilgrim Nuclear Power StationAMP and AMR Audit and Review Plan H-2PNPS AMR Component (Table 1) Worksheet: Audit Date:Unit:Table No.: Chapter:

Auditor Name(s): The audit team verified that items in Table 3.X.1 (Table 1) correspond to items in the GALL Volume 1, Table X. All itemsapplicable to BWRs in Table 1 were reviewed and are addressed in the following table.

Item No.Further Evaluation RecommendedDiscussionAudit Remarks (Document all questions for applicant here):

NumberQuestion for applicant (draft per RAI guidance)Response (with date) References/Documents Used:

1.

2.

3.

4.

Pilgrim Nuclear Power StationAMP and AMR Audit and Review Plan H-3PNPS AMR MEAP Comparison (Table 2) Worksheet Audit Date:Unit:Table No.:Chapter:

Auditor Name(s): Line items to which Notes A, B, C, D, and E are applied or for which a precedent was cited (except for those assigned toDE) were reviewed for: 1) consistency with NUREG-1801, Volume 2 tables, and 2) adequacy of the aging managing programs. All items in the Table 2 of the system named above are acceptable with the exception of items in boldface type.(Reviewers need not duplicate information in the 2nd-5th columns that are reflected in the discussion/draft audit report.)

LRAPage No.ComponentTypeMaterialEnvironmentAging EffectNote:Discussion (draft as Audit Report Insert)Audit Remarks (Document all questions for the applicant here):

No.Question for applicant (draft per RAI guidance)Response (with date)References/Documents Used:

1.
2.
3.

Pilgrim Nuclear Power StationAMP and AMR Audit and Review Plan J-1APPENDIX IACRONYMS, ABBREVIATIONS, AND INITIALISMSADAMSAgencywide Documents Access and Management SystemAMPaging management program AMRaging management review ASMEAmerican Society of Mechanical Engineers CLBcurrent licensing basis DEDivision of EngineeringDIPMDivision of Inspection Program Management FSARfinal safety analysis report GALLGeneric Aging Lessons Learned ISGinterim staff guidance LRAlicense renewal application NEINuclear Energy InstituteNRCU.S. Nuclear Regulatory Commission NRROffice of Nuclear Reactor RegulationPNPSPilgrim Nuclear Power Station RAIrequest for additional information RLEP-BLicense Renewal and Environmental Impacts Program, Section B RLSBLicense Renewal and Standardization BranchSCstructures and components Pilgrim Nuclear Power StationAMP and AMR Audit and Review Plan J-2SERsafety evaluation reportSRP-LRStandard Review Plan - License Renewal SSCstructure, system, and componentTLAATime Limited Aging Analysis UFSARupdated final safety analysis report

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