ML062090322

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Email: (PA) AMR Template for Not Consistent with Gall Section
ML062090322
Person / Time
Site: Pilgrim
Issue date: 05/05/2006
From:
- No Known Affiliation
To: Michael Orr, Joseph Zabel
Advanced Technologies & Labs International, Office of Nuclear Reactor Regulation
References
%dam200612, TAC MC9669
Download: ML062090322 (7)


Text

James Davis - AMR template for not consistent with GALL section Page 1 J From: <erachp@comcast.net>

To: Mark Orr <MPOrr@atlintl.com>, Joe Zabel <JZabel@atlintl.com>

Date: Fri, May 5, 2006 1:34 PM

Subject:

AMR template for not consistent with GALL section Joe/Mark, Attached is the NRC concurred template for audit report section 3.X.2.3 - AMRs not consistent with or not addressed in the GALL Report. I used section 3.3 - Auxiliary systems as an example.

Please read the "Note" at the bottom of the template. It applies only to sections 3.2, 3.3, and 3.4 beacause of the way PNPS chose to format the LRA. Also, note that the first two items; none-none" review, and "Not Applicable" review do not have a subsection number.

Also, I am hoping that when we have our team meeting, the audit report template is ready for the AMP sections.We want to start using it.

Audit team, This is for your info so you are aware of how this section will be formatted. Note that even though a table may not have any "not consistent" items, there will be paragraph that will make that statement. This will accomplish two things, 1) that the subsection number and the table number will be consistent, and 2) that all table 2's have been reviewed for non-consistent line items.

If you have any questions, please let me know.

Erach CC: Ram Subbaratnam <rxs2@nrc.gov>, Duc Nguyen <dtnl @nrc.gov>, Wayne Pavinich

<wapavinich@comcast.net>, Dan Hoang <DVH@nrc.gov>, Jim Davis <jad@nrc.gov>, Peter Wen

<pxw@nrc.gov>, Bob Jackson <JacksonWR@msn.com>, Erach Patel <erachp@comcast.net>

c:\teMpýGW)00001.TMP Page 11 Mail Envelope Properties (445B8C9E.F9B : 16: 61339)

Subject:

AMR template for not consistent with GALL section Creation Date Fri, May 5, 2006 1:34 PM From: <erachp @comcast.net>

Created By: erachp@comcast.net Recipients nrc.gov TWGWPO02.HQGWDOO1 RXS2 CC (Ram Subbaratnam)

PXW CC (Peter Wen) nrc.gov TWGWPOO1 .HQGWDOO1 DTN1 CC (Duc Nguyen) nrc.gov OWGWPOO2.HQGWDOO1 DVH CC (Dan Hoang) nrc.gov OWGWPO01 .HQGWDOO1 JAD CC (James Davis) msn.com JacksonWR CC (Bob Jackson) comcast.net wapavinich CC (Wayne Pavinich) atlintl.com JZabel (Joe Zabel)

MPOrr (Mark Orr)

Post Office Route TWGWPO02.HQGWDOO1 nrc.gov TWGWPO01 .HQGWDO01 nrc.gov OWGWPOO2.HQGWDO01 nrc.gov OWGWPO01.HQGWDOO1 nrc.gov msn.com comcast.net atlintl.com

cAtemp\qW)00001.TMP Page 2111 Page 2~I c:\temp\GW}OOOO1 .TMP Files Size Date & Time MESSAGE 1058 Friday, May 5, 2006 1:34 PM TEXT.htm 1192 Template for not consistentwithGALL.wpd 27792 Mime.822 42417 Options Expiration Date: None Priority: Standard ReplyRequested: No Return Notification: None Concealed

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James Davis -Template for-not-consistent with GALL.wpd Page 1 ý1 James- Dai .

  • T m* lte fornotconistnt ithGALL.wpd... i . .. . ... - ". . .iii; Page*ii*[ 1 I 3.3.2.3 AMR Results That Are Not Consistent With The GALL Report Or Not Addressed In The GALL Report Summary of Information in the Application In PNPS LRA Table 3.3.1, Summary of Aging Management Evaluations for the Auxiliary Systems, the applicant provided information regarding components or material/environment combination in the GALL Report that it evaluated and identified as not applicable to its plant.

In PNPS LRA Tables 3.3.2-1 through 3.3.2-14-35, the applicant provided additional details of the results of the AMRs for material, environment, aging effect requiring management, and AMP combinations that are not consistent with the GALL Report. Specifically, the applicant indicated, via Notes F through J, that neither the identified component nor the material/environment combination is evaluated in the GALL Report and provided information concerning how the aging effect requiring management will be managed.

Proiect Team Evaluation The project team reviewed additional details of the results of the AMRs for material, environment, aging effect requiring management, and AMP combinations that are not consistent with the GALL Report or are not addressed in the GALL Report.

Aping Effect/Mechanism in Table 3.3.1 That Are Not Applicable for PNPS

[This section is for write-up of the AMR line-items that the applicant claims are not used or not applicable to its plant in LRA Table 1. The write-up does not include the "further evaluation required" in Table 1 since they are evaluated in Section 3.[Y].2. In addition, the evaluation is not necessary ifthe plant is of a different vintage (PWR vs. BWR)]

The project team reviewed PNPS LRA Table 3.3.1, which provides a summary of aging management evaluations for the auxiliary systems evaluated in the GALL Report.

In PNPS LRA Table 3.1.1, Item [NUMBER] discussion column, the applicant stated that the [list the aging effect] of [list components] due to [list aging mechanism] is not applicable at PNPS.

[The project team evaluation, if applicable]

On the basis that there [is/are] no [list of applicable components] in the auxiliary systems at PNPS, the project team finds that, for this component type, this aging effect is not applicable to PNPS.

[Repeat the above three paragraphs, if applicable, for all items that the applicant claims is not applicable to its plant]

[If there are RAIs or issues that affect all Tables, provide discussion and evaluation here]

[If the LRA lists a series of components which have no aging effect and therefore do not require aging management, the following writeup may be used, as appropriate.]

Auxiliary Systems AMR Line Items That Has No Aqinq Effect (PNPS LRA Tables 3.3.2-1

I James Davis - Template for-noLconsistentwithGALL.wpd Page 2 i Page 211 IJames Davis Template fornotconsistentwithGALL.wpd through 3.3.2-14-35)

In PNPS LRA Tables 3.3.2-1 through 3.3.2-14-35, the applicant identified line-items where no aging effects were identified as a result of its aging review process.

In PNPS LRA Tables 3.3.2-1 through 3.3.2-14-35, the applicant identified AMR line-items where no aging effects were identified as a result of its aging review process. Specifically, instances in which the applicant states that no aging effects were identified occurred when components fabricated from [list materials] material exposed to [list environments] environment. [Provide evaluation why the LRA claim of no aging effect is valid] in environment for these components and materials. No aging effects are considered to be applicable to components fabricated from

[list of material] material exposed to [list of environment] environments.

On the basis of its review of current industry research and operating experience, the project team found that [environments] on [materials] will not result in aging that will be of concern during the period of extended operation. [provide project team evaluation] Therefore, the project team concluded that there are no applicable aging effects requiring management for [materials]

components exposed to [list of environment] environments.

On the basis of its audit and review of the applicant's program, the project team found that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended functions will be maintained during the period of extended operation, as required by 10 CFR 54.21(a)(3). -

3.3.2.3.1 Standby Liquid Control system- Summary of Aging Management Evaluation -

PNPS LRA Table 3.3.2-1 The project team reviewed the PNPS LRA Table 3.3.2-1, which summarizes the results of AMR evaluations for the [table title] component groups.

In LRA Table 3.3.2-1, the applicant proposed to manage [list aging effect] of [list materials]

materials for components types of [list component names] exposed to [list environments]

environment using [PNPS] AMP B[NUMBER], "[Applicant AMP Name]."

The project team reviewed [Applicant AMP Name] program and its evaluation is documented in Section [3.0.3.A.A] of this audit and review report. [Briefly provide summary of the program and the project team evaluation]. On the basis of its review of the applicant's plant-specific and industry operating experience, the project team found the aging effect of [list aging effect] of

[list materials] material exposed to [list environments] environment are effectively managed using [Applicant AMP Name] program. On this basis, the project team found that management of [list aging effect] in [table title] is acceptable.

3.3.2.3.2 [Table Titlel - Summary of Aging Management Evaluation - ([PNPS1 LRA Table 3.[Y1.2-[S])

James Davis -Templatejorý_not consistent with-GALL.wpd Page 3ýj James Davis Template fornotconsistentwithGALL.wpd Paqe 3j 3.3.2.3.3 FTat ble Titlel - Summary of Aqing Management Evaluation - (fPNPSI LRA Table 3.JY].2-fSI) 3.3.2.3.7 Fue I Oil system - Summary of Aaina Manaaement Evaluation - PNPS LRA Table I I I I I 3.3.2-7 The project team reviewed PNPS LRA Table 3.3.2-7, which summarizes the results of AMR evaluations for the fuel oil system component groups. The results of these evaluations are all consistent with the GALL Report.

3.3.2.3.14.1 See section 3.4 3.3.2.3.14.2 Compressed Air system - Summary of Aging Management Evaluation - PNPS LRA Table 3.3.2-14-2 The project team reviewed PNPS LRA Table 3.3.2-7, which summarizes the results of AMR evaluations for the fuel oil system component groups. The results of these evaluations are all consistent with the GALL Report.

NOTE:

[Some tables that are part of section 3.3, that are a sub-set of Table 3.3-14, belong in sections 3.2 and 3.4. Tables 3.3.2-14-1, 14-3, 14-4, 1-5, 14-9, 14-10, 14-11, 14-17, 14-18, and 14-35 belong in section 3.4, under 3.4.2.3.14.X. Tables 14-7, 14-16, 14-25, and 14-28 belong to section 3.2, under 3.2.2.3.14.X]

Conclusion On the basis of its review, the project team found that the applicant appropriately evaluated AMR results involving material, environment, aging effects requiring management, and AMP combinations that are not addressed in the GALL Report. The project team found that the applicant has demonstrated that 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

4James Davis- Template for-notconsistent-with-GALL.wpd Paie 41 Pag operation, as required by 10 CFR 54.21(a)(3).

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