ML062090307

Email: (PA) QA for Aging Management of NSR Components

ML062090307
Person / Time
Site:	Pilgrim
Issue date:	07/03/2006
From:	Patel E - No Known Affiliation
To:	Jennifer Davis Division of Regulatory Improvement Programs
References
TAC MC9669
Download: ML062090307 (5)

Text

James Davis - Re: QA for aging management of NSR components Page 1:1 From: <erachp@comcast.net>

To: "James Davis" <JAD @nrc.gov>

Date: Mon, Jul 3, 2006 4:09 PM

Subject:

Re: QA for aging management of NSR components Jim, I reviewed the Browns Ferry SER. Within the AMR sections 3.1 - 3.6, the SER states, 3.1.2.2.15 Quality Assurance for Aging Management of Non-Safety-Related Components The applicant referenced LRA Section B.1.3. The staff's evaluation of LRA Section B.1.3 is provided in SER Section 3.0.4.

Section 3.0.4 is in the AMP section where a more detailed staff evaluation is provided.

I suggest we do not repeat this in all AMR sections of our audit report. Perhaps we write this just once, maybe in the AMP section as new section 3.0.4. or write it once in the AMR sections and refer to it in the rest of the AMR sections. Our audit report will not be the same as the template or shell, if we add section 3.0.4 to the AMP report. However, it will be in the right spot when and if we have to write the NRC.

Let's discuss this on Wednesday and we can let the audit team know.

Erach

- ------------- Original message --------------

From: "James Davis" <JAD@nrc.gov>

> Erach,

> I looked to see what the QA branch put in the Browns Ferry SER and here is what

> I found.

> "3.0.4 Quality Assurance Program Attributes. Integral to Aging Management

> Programs

> Pursuant to 10 CFR 54.21 (a)(3), a license renewal applicant is required to

> demonstrate that the

> effects of aging on SCs subject to an AMR will be adequately managed so that

> their intended

> functions will be maintained consistent with the CLB for the period of extended

> operation.

> SRP-LR, Branch Technical Position RLSB-1, "Aging Management Review - Generic,"

> describes

> ten attributes of an acceptable AMP. Three of these ten attributes are

> associated with the

> quality assurance activities of corrective action, confirmation processes, and

> administrative

> controls. Table A.1-1, "Elements of an Aging Management Program for License

> Renewal," of

> Branch Technical Position RLSB-1 provides the following description of these

> quality attributes:

>

• Corrective actions, including root cause determination and prevention of

> recurrence,

> should be timely.

>

• The confirmation process should ensure that preventive actions are adequate

> and that

> appropriate corrective actions have been completed and are effective.

>

• Administrative controls should provide a formal review and approval process.

> SRP-LR, Branch Technical Position IQMB-1, "Quality Assurance For Aging

> Management

> Programs," noted that those aspects of the AMP that affect quality of SR SSCs

,J.mes Davis - Re: QA for aging management of NSR components Page 2,1

> are subject to

> the quality assurance (QA) requirements of 10 CFR Part 50, Appendix B.

> Additionally, for NSR

> SCs subject to an AMR, the existing 10 CFR Part 50, Appendix B, QA program may

> be used by

> the applicant to address the elements of corrective action, the confirmation

> process, and

> administrative controls. Branch Technical Position IQMB-1 provides the following

> guidance with

> regard to the QA attributes of AMPs:

>

• SR structures and components are subject to 10 CFR Part 50, Appendix B,

> requirements, which are adequate to address all quality-related aspects of an

> AMP

> consistent with the CLB of the facility for the period of extended operation.

> For NSR SCs that are subject to an AMR for license renewal, an applicant has an

> option

> to expand the scope of its 10 CFR Part 50 Appendix B program to include these

> structures and components to address corrective actions, the confirmation

> process, and

> administrative controls for aging management during the period of extended

> operation.

> In this case, the applicant should document such a commitment in the FSAR

> supplement

> in accordance with 10 CFR 54.21(d)."

> I will send a question to the applicant and ask if they intend to expand the

> scope of their Appendix B program to include NDR SCs and if the commitment to do

> this will go in their FSAR supplement. As far as your write up goes, for

> Element 7 repeat what is said above. For Element 8 and 9 say see Element 7.

> Jim

> >>> 06/29/2006 9:31 AM >>>

> Jim/Peter,

> SRP section 3.3.2.2.15 states:

> 3.3.2.2.15 Quality Assurance for Aging Management of Nonsafety-Related

> Components

> Acceptance criteria are described in Branch Technical Position IQMB-1 (Appendix

> A.2, of this SRP-LR.)

> SRP section 3.3.3.2.15 states:

> "The applicant's aging management programs for license renewal should contain

> the elements of corrective actions, the confirmation process, and administrative

> controls. Safety-related components are covered by 10 CFR Part 50, Appendix B,

> which is adequate to address these program elements. However, Appendix B does

> not apply to nonsafety-related components that are subject to an AMR for license

> renewal. Nevertheless, the applicant has the option to expand the scope of its

> 10 CFR Part 50, Appendix B program to include these components and address the

> associated program elements. If the applicant chooses this option, the reviewer

> verifies that the applicant has documented such a commitment in the FSAR

> Supplement. If the applicant chooses alternative means, the branch responsible

James Davis - Re: OA for aging management of NSR components Page 3 ýj Jae .ais.R:Q .fraigmaa. e.of.RcmonnsPg 3I

> for quality assurance should be requested to review the applicant's proposal on

> a case-by-case basis."

> The same statement appears in each SRP section 3.1, 3.2, 3.3, 3.4, 3.5, 3.6.

> How do we handle this? There should be one set of standard words that is

> applied in each of the AMR sections.

> The following is what is stated in the Oyster Creek Audit Report shell that we

> are following:

> 3.3.2.2.15 Quality Assurance for Aging Management of Nonsafey-Related Components

" OCGS LRA Section 3.3.2.2.15 is reviewed by NRR DE staff and will be addressed

> separately in Section 3 of the SER related to the OCGS LRA.

> The applicant states in LRA Appendix B.O.3:

" PNPS quality assurance (QA) procedures, review and approval processes, and

" administrative controls are implemented in accordance with the requirements of

" 10 CFR Part 50, Appendix B. The Entergy Quality Assurance Program applies to

" PNPS safety-related structures and components. Corrective actions and

" administrative (document) control for both safety-related and nonsafety-related

" structures and components are accomplished per the existing PNPS corrective

" action program and document control program.

" Please advise.

" Erach CC: Wayne Pavinich <wapavinich@comcast.net>, Bob Jackson <JacksonWR@msn.com>,

"Duc Nguyen" <DTN1 @nrc.gov>, "Dan Hoang" <DVH@nrc.gov>, "James Medoff" <JXM@nrc.gov>,

"Peter Wen" <PXW @nrc.gov>

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Re: QA for aging management of NSR components Creation Date Mon, Jul 3, 2006 4:08 PM From: <erachp @comcast.net>

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