ML062480085

E-mail: (PA) Pilgrim Audit Plan

ML062480085
Person / Time
Site:	Pilgrim
Issue date:	04/04/2006
From:	Michael Orr ATL International
To:	Adams S, Jennifer Davis, Dan Hoang, Dang Nguyen, Wen P Office of Nuclear Reactor Regulation
References
%dam200612
Download: ML062480085 (75)

Text

Page 1:1 James Davis - Pilgrim Audit Plan James Davis Pilarim Audit Plan Page 1 I From: "Orr, Mark" <MPOrr@atlintl.com>

To: "Wayne Pavinich" <WAPavinich @Comcast.Net>, "Dan Hoang" <DVH@nrc.gov>,

"Erach Patel" <erachp@comcast.net>, "Jim Davis" <JAD@nrc.gov>, "Peter Wen" <PXW@nrc.gov>,

"Sally Adams" <SAA2@nrc.gov>, "Zabel, Joe" <JZabel@atlintl.com>, "Bob Jackson"

<JacksonWR@msn.com>, "Duc Nguyen" <DTN@NRC.gov>, "Ernie Harr" <ECHarr@atlintl.com>, "Orr, Mark" <MPOrr@atlintl.com>

Date: Tue, Apr 4, 2006 4:29 PM

Subject:

Pilgrim Audit Plan Pilgrim Audit Team:

Attached is the revised draft of the Pilgrim audit plan for your review and comments.

This document incorporates the NRC comments delivered by Peter Wen and Jim Davis on Thursday 3-30-06.

Mark Orr ATL International, Inc 20010 Century Blvd., Suite 500 Germantown, MD 20874 Phone: 301-515-6794 Fax: 301-972-6904 "Confidentiality Notice: The information contained in this message is intended only for the use of the addressee, and may be ATL proprietary, confidential and/or privileged. If the reader of this message is not the intended recipient, or the employee or agent responsible to deliver it to the intended recipient, you are hereby notified that any dissemination, distribution or copying of this communication is strictly prohibited. If you have received this communication in error, please notify the sender immediately."

cAtemM W)00001.TMP Page 1 1 c:\temD\GWIOOOO1 .TMP Page 1 I Mail Envelope Properties (4432D701.CB5: 8 :44213)

Subject:

Pilgrim Audit Plan Creation Date Tue, Apr 4, 2006 4:28 PM From: "Orr, Mark" <MPOrr@atlintl.com>

Created By: MPOrr@atlintl.com Recipients nrc.gov OWGWPOO2.HQGWDOO1 DVH (Dan Hoang) nrc.gov OWGWPOO1.HQGWDOO1 JAD (James Davis)

SAA2 (Sally Adams) nrc.gov TWGWPO02.HQGWDOO1 PXW (Peter Wen) atlintl.com ECHarr (Ernie Harr)

JZabel (Joe Zabel)

NRC.gov NRCWIAO1 .NRCWDOO1 "DTN@NRC.Rov" (Duc Nguyen) msn.com JacksonWR (Bob Jackson) comcast.net erachp (Erach Patel)

WAPavinich (Wayne Pavinich)

Post Office Route OWGWPOO2.HQGWDO01 nrc.gov OWGWPO01 .HQGWDO01 nrc.gov TWGWPO02.HQGWDOO1 nrc.gov atlintl.com NRCWIA01 .NRCWDOOI NRC.gov msn.com

c:\temp\GW)O0OO1.TM P .Page_2-11 comcast.net Files Size Date & Time MESSAGE 866 Tuesday, April 4, 2006 4:28 PM TEXT.htm 1832 Draft Pilgrim Audit Plan 4-4-06.pdf 161235 Mime.822 225688 Options Expiration Date: None Priority: Standard ReplyRequested: No Return Notification: None Concealed

Subject:

No Security: Standard

LJames Davis_-_Praft Pilgrim Audit Plan 4:ýý-Oý.poý James Davis Draft Pilgrim Audit Plan 4-4-06.pdf

- Page ii Audit and Review Plan for Plant Aging Management Reviews and Programs Pilgrim Nuclear Power Station Docket No.: 50-293 April 4, 2006 Prepared by Advanced Technologies and Laboratories International, Inc.

20010 Century Blvd., Suite 500 Germantown, MD 20874 Contract No. DR-03-06-030 Prepared for Division of License Renewal Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001

James Davis-Draft Pilgrim Audit Plan4-4-06Pdf _- Page 21j TABLEOF CONTENTS

1. INTRODUCTION ......................................................... 1

2. BACKGROUND .......................................................... 2

3. OBJECTIVES ............................................................ 4

4.

SUMMARY

OF INFORMATIONPROVIDEDIN THELICENSERENEWALAPPLICATION... 5 4.1 Aging ManagementReview Results ....................................... 5 4.1.1 PNPSAMR Comparisonwith GALL .................................. 6 4.1.2 Plant-Specific Programs .......................................... 9 4.2 Time-Limited Aging Analyses ........................................... 10

5. OVERVIEWOF AUDIT,REVIEW, AND DOCUMENTATIONWROCEDURE ............ 12 5.1 Aging ManagementPrograms ........................................... 12 5.2 Aging ManagementReviews ............................................ 13 5.3 Time-Lin-ited Aging Analyses ........................................... 13 5.4 NRC-Appioved Precedents ............................................. 14 5.5 UFSAR SupplementReview ............................................ 15 5.6 Documents Reviewed by the Project Team ................................. 15 5.7 Public Exit Meeting ................................................... 15 5.8 Documentation Prepared by the Project Team .............................. 15 5.8.1 Audit and Review Plan .......................................... 15 5.8.2 Worksheets ................................................... 15 5.8.3 Questions .................................................... 16 5.8.4 Work Packages ................................................ 16 5.8.5 Requests for Additional Information ................................ 16 5.8.6 Audit and Review Report ......................................... 16 5.8.7 Safety Evaluation Report input .................................... 16

6. PLANNING,AUDIT,REVIEW,AND DOCUMENTATIOWPROCEDURE ................ 17 6.1 Planning Activities .................................................... 17 6.1.1 Schedule for Key Milestones and Activities ........................... 17 6.1.2 W ork Assignments ............................................. 17 6.1.3 Training and Preparation ........................................ 17 6.2 Aging Management Program (AMP) Audits and Reviews ...................... 18 6.2.1 Types of AMPs ................................................ 18 6.2.2 Scope of AMP elements to be audited and reviewed ................... 18 6.2.3 Plant AMPs that Are Consistent with the GALL Report .................. 19 6.2.4 Plant-Specific AM Ps ............................................ 21 6.3 Aging Management Review (AMR) Audits and Reviews ....................... 22 6.3.1 Plant AMRs that Are Consistent with the GALL Report .................. 22 6.3.2 AMRs Based on NRC-ApprovedPrecedents .......................... 25 6.4 Time-Limited Aging Analyses (TLAA)Audits and Reviews ..................... 26 6.4.1 Identify Generic TLAA Issues ...................................... 26 6.4.2 Metal Fatigue Analyses ........................................... 29 6.4.3 Environmental Qualification Analyses for Electrical Components ........... 31 6.4.4 Other Plant-Specific TLAAs ........................................ 34 6.5 Audit and Safety Review Documentation ................................... 36

James Davis - DraftPýillgrim Audit Plan "- -q6.pdf Ja e*_ ai-rf igi ui ln440.d

.. Page 3 i 6.5.1 Audit and Review Report ......................................... 36 6.5.2 Safety Evaluation ReportInput .................................... 37 6.6 Documents Reviewed and Document Retention ............................. 42 APPENDICES Appendix A - Project Team Membership ........................................... A-1 Appendix B - RLRC Schedule for Pilgrim LRA Safety Review ........................... B-1 Appendix C - Aging Management Program Assignments ............................. C-1 Appendix D - Aging ManagementReviewAssignments ................................ D-1 Appendix E - Time-Limited Aging Analysis Review Assignments ......................... E-1 Appendix F - Consistent with Gall ReportAMP Audit/Review Worksheet .................. F-1 Appendix G - Plant-specific AMP Audit/Review Worksheet ............................. G-2 Appendk H - AMR ComparisonWorksheets ........................................ H-1 Appendix I (Later)- Time-LimitedAging Analysis (TLAA)Audit/Review Worksheet ........... I-1 Appendix J - Acronyms, Abbreviations, and Initialisms ................................ J-1 TABLES Table 1. Aging Management Program Element Descriptions ............................ 43 Table 2. Notes for License Renewal Application Tables 3.X.2-Y ......................... 44 FIGURES Figure 1. Audit of AMPs that are Consistent with the GALL Report ....................... 45 Figure 2. Audit of Plant-Specific AMPs ............................................ 46 Figure3. Review of AMRs that are Consistent with the GALL Report ..................... 47 Figure4. Reviewof AMRsUsing NRC-Approved Precedents ........................... 48 Figure 5. Reviewof TLAAsand Exemptions (fromNEI 95-10, Revision 6) ................. 49

James Davis,- Draft Pilgrim Audit Plan 06-pdf .. page.

Audit and Review Plan for Plant Aging Management Reviews and Programs

1. INTRODUCTION By letter dated January 25, 2006 (ADAMS Accession Number ML060300028), Entergy Nuclear Operations, Inc., submitted to the U.S. Nuclear RegulatoryCommission (NRC) its application for renewal of Operating License DPR-35 for Pilgrim Nucdear Power Station (PN PS.) The applicant requested renewalof 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, the Division of License Renewal (DLR), Branch C (RLRC),will lead a project team that will audit and review selected aging management reviews (AM Rs) and associated aging management programs (AMPs), and time-limited aging analyses (TLAAs) developed by the applicant to support its LRAfor 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 managementprograms for PN PS.

The project team will audit and review its assigned AMPs, AMRs, and TLAAs against the requirements of Title 10 of the Code of Federal Regulations, Part 54 (10 CFR Part 54),

"Requirement for Renewal of Operating Licenses for Nuclear Power Plants;" the guidance provided in NUREG-1 800,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-1 801, Revision 1, "Generic Aging Lessons Learned (GALL) Report," dated September 2005; and this plan. For the scope of work defined inthis 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 workat NRC Headquarters, Rockville, Maryland; at ATLs offices in Germantown, Maryland; and at the PNPS site near Plymouth, Massachusetts. The project team will performits work inaccordance with the schedule shown inAppendix 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. Summaryof the license renewal requirements, as stated inthe Code of Federal Regulations, and a summary of the documents that the project team will use to conduct the audit and review process described inthis plan.

" Objectives. The objectives of the audits and reviews addressed by this plan.

JamesI Davis ii I . ..

__Piraý_Pilgrim

. . . .. . .. Audit ..Plan 4-.ý-96.pdfý James Davis Draft Pilgrim Audit Plan 4-4-06.pdf

- Page ~

Pilgrim Nudear Power Staton AMP and AMR Audit and Review Plan 0 Summaryof Information Provided In License Renewal Application Description of the information contained in the license renewal application for PNPS that is applicable to this plan.

• Overview of the Audit, Review, and Documentation Procedure. Summaryof the process the project team will follow to audit and review the LRA information that is within its scope of review.

a Planning, Audit, Review, and DocumentationProcedure. The procedure that the project team will use to plan and schedule its work, to audit and review the LRA information that is within its scope of review, and to document the results of its work.

0 Appendices. Supporting information. Theproject team membership is shown in Appendix A and the schedule is shown in Appendix B. The team's work assignments are shown in Appendix C, "Aging Management ProgramAssignments," Appendix D, "Aging Managerrent Review Assignments," Appendix E "Time-LimitedAging Analysis Review Assignments." Appendices F, G, H, and I 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 J is a list of the acronyms, abbreviations, and initialisms used in this plan.

2. BACKGROUN)

In 10 CFR 54.4, the scope of license renewal is defined as those structures, systems, and components (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 to identify 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 demonstratethat 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 GALL Report is a technical basis document. It summarizes staff-approved AMPs for the aging 2

James Davis-,DraftPilgrim Audit Plan 4-4-06.pdf. .. _Page 611 Pilgrim Nudear Power Station AMP and AMR Audit and Review Plan management of a large numberof SCs that are subject to an AMR. It also summarizes the aging management evaluations, programs, and activities acceptable to the NRC staff for managing aging of most of the SCs used in commercial nuclear power plants, and serves as a reference 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. Ifan 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 is generically applicable. An applicant may reference the GALL Report in its LRAto 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.

Ifan applicant takes credit for a GALL AMP, it is incumbent on the applicant to ensure that the plant AMP contains all the programelements of the referencedGALL 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 LRAthat 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 CFR 54.21 (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 or analysis is a TLAA. Pursuantto 10 CFR 54.3, TLAAsare those licensee calculations and analyses that:

1. Involve systems, structures, and components within the scope of license renewal, as delineated in 10 CFR 54.4(a);

2. Consider the effects of aging:

3

James Davis - raft gim 4-4-06.pdf Page7 Pilgrim Nuclear Power Station AMP and AMR Audit and Revlew Plan

3. Involve time-limited assumptions defined by the current operating term, for example, 40 years;

4. Were determined to be relevant by the licenses in making a safety determination;

5. Involve conclusions or provide the basis for conclusions related to the capability of the system, structure, or component to performits intended function(s), as delineated in 10 CFR 54.4(b); and

6. Are contained or incorporated by reference in the CLB.

Finally, the applicant must demonstrate that the TLAAs remain valid for the period of extended operation; 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. OBJECTIVE The overall objective of the audit and review described in this plan is to verify compliance with 10 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 procedurefor PNPS is described in Sections 5 and 6 of this plan. It is intended to accomplish the following objectives:

" For PNPS AMPs that the applicant claims are consistent with GALL AMPs, verifying that the 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 with exceptions, 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 after specified 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 4

James Davis -_Draft Pilgrim Audit Plan 4-4-0 6.pdf. Page 8 Pilgrim Nuclear Power Station AMP and AMR Audit and Review Plan enhancements as commitments inthe Updated Final Safety Analysis Report (UFSAR)or other docketed correspondence.

For plant-specific PNPS AMPs that the applicant claims are consistent with AMPs that the staff has previously approved for another plant, verifying the AMPs are acceptable on the basis of a technical review.

" 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 is) that the applicant claims are not applicable with the GALL Report, 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 staff has 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 Reportrecommendsfurther evaluation, determine that the applicant has addressed the further evaluation, and evaluating the AMRs inaccordance with the SRP-LR.

" ForTLAAs, determine that the applicant has properly identified the TLAAs. TLAAs are certain 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 in10 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.

" Determhe that the applicant has demonstrated that (1) the TLAAs remain valid for the period 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 INFORMATIONPROVIDEDIN THE LICENSERENEWAL APPLICATON 4.1 Aging Management Review Results 5

James Davis - Draft Pilgrim Audit Plan 4-4-06.pdf Page 9 11 Pilgrim Nudear Power Staton AMP and AMR Audit and Review Plan The PNPS LRAclosely follows the standard LRA formatpresented inNEI 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 inthe AMRs to determine the aging effects requiring management. Results of the AMRs are presented intwo different types of 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, inthe reactor coolant system subsection of the LRA Section 3, this is Table 3.1.1, and inthe engineered safety features subsection of LRA Section 3, this is Table 3.2.1. For ease of discussion, these table types will hereafter be referredto as "Table 1." These tables are derived from the corresponding tables inNUREG-1801, Volume 1, and present summary information from the AMRs.

I Definition 1 Reactor Vessel, Internals, and Reactor Coolant System 2 Engineered Safety Features Systems 3 Auxiliary Systems 4 Steam and PowerConversion Systems 5 Structures and Component Supports 6 Electrical and Instrumentation and Controls The 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 inTable 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 referredto as "Table 2." These tables present the results of the AMRs.

4.1.1 PNPS AMR Comparlsonwith GALL The applicant compared the PNPS AMR results with information set forth in the tables of the GALL 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/

James Davis - Draft Pilgrim Audit Plan_4-4-06.pdf ._ Page 10 Pilgrim Nuclear Power Station AMP and AMR Audit and Review Plan 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.

4.1.1.1 Purpose of Table 1 The purpose of Table 1 is to provide a summary comparison of how the PNPS AMR results align with the corresponding table of NUREG-1 801,Volume 1. These tables are essentially the same as Tables 1 through6 provided in NUREG-1801, Volume 1, with the following exceptions:

" The ID column is labeled "Item Number"and the spacing has been expanded to include the 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 of information that might be contained within this column:

• Any "Further Evaluation Recommended" information or reference to the location of that information.

• The name of a plant-specific program being used.

" Exceptions to the NUREG-1 801 assumptions.

" A discussion of how the line item is consistent with the corresponding line item in NUREG-1 801,Volume 1, when it may not be intuitively obvious.

" A discussion of how the line item is different than the corresponding line item in NUREG-1801,Volume 1, whenit may appearto be consistent.

4.1.1.2 Purpose of Table 2 Table 2 provides results of the aging management reviews for those structures and components identified in Section 2 as being subject to aging management review. Thereis 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:

7

James Davis - Draft Pilgrim Audit Plan 4-4-06.pdf Pagep lii Pilgrim Nudear Power S ataon AMP and AMR Audit and Review Plan 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. Ifsuch components have unique tag numbers or the specific component has a function other than pressure boundary, then flow elements, orifices and thermowelis are identified as a separate component type.

The term "heat exchanger (shell)" may include the bonnet/channel head and tubesheet. In cases 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 accumulators on LRAdrawings.

Intended Function Column 2 identifies the license renewal intended functions (using abbreviations where necessary) 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. InternaVexternal service 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 RequiringManagement Column 5 lists the aging effects requiring managementfor material and environment combinations for each component type.

Aging ManagementPrograms(AMP)

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

NUREG1801, Vol. 2, Item 8

James Davis - Draft Pilgrim Audit Plan 4-4-06.pdf Page 12 ]I

• i

. . Da James - Draft Pi grim Auit.. Plan 4-4-06 *r.pd ......  ;, . .. *. ==** i =** i***= * *... .. . .Page.....12wI Pilgrim Nudear Power Station AMP and AMR Audit and Review Plan Column 7 documents identified consistencies by noting the appropriate NUREG-1801 ,Volume 2, item number. Ifthere 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-1 801, Volume 2, to identify consistencies:

• Component type.

" Material.

" Environment.

" Aging effect requiring management.

" Aging managementprogram.

Table 1 Item Column 8 lists the corresponding line item from Table 1. Ifthere is no corresponding item in NUREG-1 801,Volume 1, column 8 is left blank.

Each combination of the following that has an identified NUREG-1801,Volume 2 item number also 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 items in NUREG-1 801, Volume 2. Notes that use letter designations are standard notes based on a letter fromA. Nelson, NEI,to P. T. Kuo, NRC,"U.S. Nuclear Industry's Proposed Standard License Renewal Application FormatPackage, Request NRC Concurrence",dated January24, 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 (ML030990052ý Notes that use numeric designators are specific to PNPS.

PNPS LRATable 2 contains the aging management review results and indicates whether the results correspond to line items in Volume 2 of the GALL Report. Correlations between the combination PNPS LRATable 2 and a combination fora 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.

James Davisý- PýattPilgrim Audit Plan 4-4-0ý.pdf , ....

Page 1311

.. r ,i 1 3= 1, James Davis Draft Pilgrim Audit Plan 4-4-06.pdf Pilgrim Nudear Power Station AMP and AMR Audit and Review Plan 4.1.2 Plant-Specific Programs Many of the GALL Report evaluations refer to plant-specific programs. In these cases, the applicant 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-LimitedAging Analyses The PNPS LRA closely follows the standard LRA format presented in Revision 6 of NE195-10, "IndustryGuidelines for Implementing the Requirementsof 10 CFR Part 54 -The License Renewal Rule." Section 4 of the PNPS LRA addresses time-limited aging analyses. In Section 4.1.1, 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 Specifications B. UFSAR C. docketed licensing correspondence D. fire protection program documents E. NRC safety evaluation reports F. BWRVIP documents In Section 4.1, the PNPS LRA states that as required by 10 CFR 54.21 (c)(1),an evaluation of PNPS-specific time-limited aging analyses must be performedto demonstratethat:

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 the period 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 identifying any 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 performedthis by reviewing PNPS docketed correspondence which identified PNPS exemptions. The results of this review determined that no PNPS exemptions depend on TLAAs.

10

-Ja-mes Davi -1?ýa Pilgrim _Audit Plan 4-4-06.pdf_ JmsDvs.DatPgr AuiPa...... Pagel4]

YPý_M_

Plinrim MiriA~r Pnw~r 5tatinn AMP end AMR Audit and Review Plan The PNPS LRA next includes a separate section for each of the identified TLAAs within the outline of the corresponding NUREG-1800TLAA category. TheTLAA categories are outlined in the next table.

TLAADescrlption Resolution Option Section ReactorVessel Neutron Embrittlement Analyses 4.2 Pressure-temperaturelimits Analyses remain valid 4.2.2 10 CFR 54.21(c)(1)(i)

Charpy upper-shelf energy Analyses projected 4.2.3 10 CFR 54.21 (c)(1)(ii)

Adjusted reference temperature Analyses projected 4.2.4 10 CFR 54.21 (c)(1)(ii)

Reactor vessel circumferential welds Analysis projected 4.2.5 inspection relief 10 CFR54.21(c)(1)(ii)

Reactor vessel axial welds failure Analysis projected 4.2.6 probability 10 CFR 54.21 (c)(1)(ii)

Metal Fatigue Analyses 4.3 Class 1 fatigue Analyses remain valid 4.3.1 10 CFR 54.21(c)(1)(i)

OR Aging effect managed 10 CFR 54.21 (c)(1)(iii)

Non-Class 1 fatigue Analyses remain valid 4.3.2 10 CFR 54.21 (c)(1)(i)

Effects of reactor water environment on Analyses remain valid 4.3.3 fatigue life 10 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)

Environmental Qualification Analyses for Aging effect managed 4.4 Electrical Equipment 10 CFR 54.21(c)(1)(iii)

Containment Liner Plate, Metal Containment, and Penetrations 4.6 Fatigue Analyses Fatigue of primary containment Analysis projected 4.6.1 10 CFR 54.21 (c)(1)(ii) 11

James Davis - Draft Pilgrim Audit Plan 4-4-06.pdf --Page 15 1;1 Pilnrirn N1*:*r Pnwpr R*finn AMP *n,4l AMfl A~i nnd R~t~ Plan Pil rim Nuclear Pomr Stabon AMP and AMR Audit and Review Plan TLAADescription Resolution Option Section OtherTLAA 4.7 Reflood thermal shock of the reactor Analysis remains valid 4.7.1 vessel internals 10 CFR 54.21 (c)(1)(i)

TLAA in BWRVIPs 4.7.2 BWRVIP-05, RPV circumferentialwelds Addressed in Sections 4.2.5 4.7.2.1 analysis BWRVIP-4E vessel ID attachmentwelds Analysis remainsvalid 4.7.2.2 fatigue analysis 10 CFR 54.21 (c)(1)(ii)

BWRVIP-49, instrument penetrations Analysis projected 4.7.2.3 fatigue analysis 10 CFR 54.21 (c)(1)(ii)

BWRVIP-74, reactor vessel 4.7.2.4 P/T curves analysis Addressed in Section 4.2.2 Fatigue analysis Addressed in Section 4.3.1 CvUSEanalysis Addressed in Section 4.2.3 CirdlAxial welds analysis Addressed in Sections 4.2.5 and 4.2.6 BWRVIP-76, core shroud fatigue analysis Analysis remains valid 4.7.2.5 110 CFR 54.21 (c)(1)(ii) _

5. OVERVIEW OF AUDIT,REVIEW, AND DOCUMENTATIONPROCEDURE The project team will follow the procedure specified in Section 6 of this plan to perform its audits and reviews and to document the results of its work. The process covered by the procedure is summarized below.

5.1 Aging Management Programs Table 1 of this audit and review plan summarizes the program elements that comprise an aging management 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 programelements for the PNPS AMPs to the corresponding program elements for the GALLAMPs. 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 programwas 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 will review 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 12

James Davis_ýý_ýilg(im Audit Plan 4-4-06.pqt_ Page 16 i1 James Davis -~Draft~~~iIgrim Audit Plan 4-4-06.pdf Page 161 Pilgrim Nuclear Power Staton AMP and AMR Audit and Review Plan 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 ReportAMPs. 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), the project team will review the AMP against the ten programelements defined in Appendix A of the SRP-LR. The Division of Engineering will review and determine the adequacyof the applicant's 10 CFR50, 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 whetherthese AMPs will manage the aging effects for which they are credited.

5.2 Aging Management Reviews The AMRs in the GALL Report fall into two broad categories: (1) those that the GALL Report concludes 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.

5.3 Time-LimitedAging Analyses The TLAAs in the PN PS LRA fall into the broad category of those that are consistent with the NUREG-1 80OTLAAcategories. There are no plant-specific exemptions identified inthe VYNPS LRA that depend on time-limited aging analyses.

For its TLAA reviews, the project team will determine if the applicant had provided adequate information to meet the requirements of 10 CFR 54.21©)(1) and 10 CFR 54.21©)(2).

Further, the project team will conduct both regulatory evaluations and technical evaluations to determine, 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 license renewal, as delineated in 10 CFR 54.4(e).

2. consider the effects of aging.

13

James Davis -.Draft Pilgrim Audit Plan 4-4-06.pdf __Page 17 Pi*grim Nudear Power Stadon AMP and AMR Audit and Review Plan

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 the system, structure, and component to performits intended fucntions, as delineated in 10 CFR 54.4(b).

6. are contained or incorporated by reference inthe CLB.

In addition, the project team will also review the TLAAs to determine ifthere are emerging issues that should be further evaluated by technical specialists inthe 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 CFR54.21 (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)(i) - "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 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 Analysis B. Intergranular separation inthe Heat-Affected Zone (HAZ) of Reactor Vessel C. Containment Liner Plate, Metal Containment, and Penetrations Fatigue Analyses D. Low-Aloy Steel under Austenitic SS Cladding 5.4 NRC-Approved Precedents To help facilitate the staff review of its LRA, the applicant referenced NRC-approved precedents 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 whetherthe material presented inthe precedent is applicable to the applicant's facility, (2) determine whetherthe 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 programelements 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 14

James Davis - Draft Pilgrim Audit Plan.4-,!ý-Op.pdf m D sDaPgm utl...age18]l Pilgrim Nuclear Power Staton AMP and AMR Audit and Review Plan AMPs that are based on precedents, the precedent information is typically implicit in the evaluation, ratherthan 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.

5.5 UFSAR Supplement Review Consistent with the SRP-LR, for the AMRs and associated AMPs that it will review, the project team will review the UFSARsupplement that summarizes the applicant's programsand 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.

5.6 Documents Reviewed by the Project Team In 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 actMties and programs will adequately manage the effects of aging on structures and components.

5.7 Public Exit Meeting After it completes its audits and reviews, the project team will hold a public exit meeting to discuss the scope and results of its audits and reviews.

5.8 Documentation Prepared by the Project Team The project team will prepare an audit and review plan, worksheets, work packages, requests for 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.

5.8.1 Audit and Review Plan The project team leader will preparea plant-specific audit and review plan as described herein.

5.8.2 Worksheets Each project team member will informally document the results of his or her work on a variety of worksheets. The worksheets are shown in Appendix E, "Consistent with GALL Report AMP Audit/Review Worksheet"; Appendix F, "Plant-Specific AMP Audit/Review Worksheet"; and 15

James Davis - PTaft_ýilgrim Audit Plan 4-4-06.;:idýJ. e ,... D i D...a Pl i .....A t l. .... ... .. r ..... ... ..... Page 19 11 Pilgrim Nuclear Power Stagon AMP and AMR Audit and Review Plan Appendix G, "Aging Management Review Worksheets", and Appendix H, "TLAA-Audit/Rbview Worksheet." The use of the worksheets is described in Section 6 of this plan.

5.8.3 Questions As specified in Section 6 of this plan, the project team members will ask the applicant questions during while on-site audits, as appropriate, to facilitate its audit and review activities. The team will also track the applicant's answers to the questions.

5.8.4 Work Packages After each site visit, the project team leader, in conjunction with the project manager, will assemble work packages for any workthat 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.

5.8.5 Requests for Additional Information The review process described in this plan is structured to resolve as many questions as possible during the site visits. As examples, the site visits are used to obtain clarifications about the LRAand explanations as to where certain information may be found in the LRAor 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 team members. 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 provide the 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. Ifthe audit reportwas issued before the applicant submitted its response to an RAI, the review of the response will be documented in the SER.

5.8.6 Audit and Review Report The project team will document the results of its work in an audit and review report. The team will 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.

5.8.7 Safety Evaluation Report input The project team will prepare SER input, based on the audit and review report, as described in 16

James Davis_-_Draft PlgrimAuditPlan_ 4-4-06.pdf Page 20 11 Pilgrim Nudear Power Stadon AMP and AMR Audit and Review Plan Section 6.4.2 of this plan.

6. PLANNINGAUDIT, REVIEW, AND DOCUMENTATIONPROCEDUR E This section of the audit and review plan contains the detailed procedures that the project team will follow to plan, perform, and document its work.

6.1 Planning Activities 6.1.1 Schedule for Key Milestones and Activities The 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 and activities 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.

" Holding the project team kickoff meeting.

• Preparng the audit and review plan.

" Scheduling site visits.

" Scheduling in-office review periods.

• Preparing questions.

" Preparing RA/s.

" 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, the NRC license renewal project manager, and the applicant.

Appendix B of this plan contains the target schedule for the key milestones and activities.

6.1.2 Work Assignments The technical assistance contractor will propose team member work assignments to the NRC project 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 memberwill review each AMP and AMR. Appendix A of this plan shows the project team membership. Appendix C shows the team memberassignments 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.

17

James Davis - Draaft Pilgrim Audit Plan 4-4-o6.pdf .. .. Page 21]

Pilgrim Nuclear Power Station AMP and AMR Audit and Review Plan 6.1.3 Training 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 the project team will audit and review.

1. GALL Report

2. SRP-LR

3. Interim Staff Guidance for License Renewal (ISG-LR)

4. LRAAMPs

5. LRAAMRs

6. Basis documents (catalogues of information assembled by the applicant to demonstrate the bases for its programs and activities)

7. Implementing procedures

8. Operating experience reports

9. RAts, audit reports, and SERs for other plants

10. Applicant's UFSAR

11. LRATLAAs C. 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.

6.2 Aging ManagementProgram (AMP) Audits and Reviews 6.2.1 Types of AMPs There are two types of AMPs: those that the applicant claims are consistent with AMPs contained 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.

6.2.2 Scope 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 of each aging management program. These program elements are presented in Branch Technical Positio n (BTP) RLSB-1,"Aging Management Review - Generic," in Appendix A of the SRP-LR, and are summarized in the GALL Report.

18

James Davisý- DraftPilgdm AUdit Plan 4-4-9(ý.pdf _JaesDais- rat

.Page_22jI ilri Adi Pan4--0.pf Pilgrim Nudear Power Staton AMP and AMR Audit and Review Plan The program elements audited or reviewed is the same for both AMPs that are consistent with the 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.

6.2.3 Plant AMPs that Are Consistent with the GALL Report Figure 1, "Audit of AMPs that Are Consistent with the GALL Report," is the process flowchart that 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.

Preparation A. 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 not limited to, the following:

1. GALL Report

2. SRP-LR

3. ISGs

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 Audit/Review A. Confirm that PNPS AMP program elements are consistent with the corresponding elements of the GALL ReportAMP by answering the following questions and then following the process shown in Figure 1.

1. Did the applicant identify any exceptions to the GALL ReportAMP?

2. Did the applicant identity any enhancements to the GALL Report AMP?

3. Are the elements consistent with the GALL Report AMP?

B. Ifeither of the above questions results in the identification of an exception/enhancement or 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 the 19

James Davis -D~raftPigrim Audit Plani 4-4-06.pdf Page231 Pilgrim Nuclear Power Station AMP and AMR Audit and Review Plan basis 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 (fromNEI 95-10, Revision 6) is as follows:

1. Plant-Specific Operating Experience with Aging Effects Requiring Management. A plant-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. Differenceswith 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.

3. Industry Operating Experience. Industry operating experience and its applicability should 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-1 801 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 a programelement, or an exception or a difference to the GALL ReportAMP, follow the logic process shown in Figure 1.

F. If it is necessary for the applicant to submit additional information to support the basis for 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. Ifnot, the NRC may issue an RAI to obtain the information.

20

James Davis - Draft Pilgrim Audit Plan 4-4-06.pdf _Page24j Pilgrim Nudear Power Staton AMP and AMR Audit and Review Plan AMP audit worksheets Document the audits/reviews using the worksheet provided in Appendix E, "Consistent with GALL ReportAMP Audit/Review Worksheet."

6.2.4 Plant-Specific AMPs Figure 2, "Audit of Plant-Specific AMPs," is the process flowchart that shows the activities and decisions used to audit/review each plant-specific AMP.

Pre-review prepargtion A. Review Section A.1.2.3 of the SRP-LR and identify those element criteria that will be reviewed.

B. Identify the documents needed to perform the audit. These may include, but are not limited to, the following:

1. GALL Report

2. 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 Audit/Review A. Audit/review the PNPS AMP program elements and determine that they are in accordance 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 21

James Davis..7_qArft Pilgrim Audit Plan 4-4-06.pdf m i ft gr Ad Pa-...fPage 25J Pilgrim Nudear Power Staton AMP and AMR Audit and Review Plan 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 managemert requirements.

2. Plant-Specific Operating Experience with Aging ManagementPrograms. The operating 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 Al of the Branch Technical Positions in NUREG-1800.

3. Industry Operating Experience. Industry operating experience and its applicability should 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-1 801 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. Ifit 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 or an issue or to support the basis or conclusion, the applicant may voluntarily submit the 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 AMP Audit/Review Worksheet."

6.3 Aging Management Review (AMR) Audits and Reviews There are two types of AMRs: those that the applicant claims are consistent with the GALL Report, and those that are plant-specific. Audit and review of both types of AMRs are discussed below.

6.3.1 Plant AMRs that Are Consistent with the GALL Report 22

James_Davis - DDraft Pilgrim Audit Plan 4-4-06.pdfa Page 26:1 Pilgrim Nudear Power Station AMP and AMR Audit and Review Plan Figure 3, "Review of AMRs that Are Consistent with the GALL Report," is the process flowchart that shows the activities and decisions used to audit/review each AMR that the applicant claims is consistent with the GALL Report.

Preparation A. 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 be audited/reviewed in conjunction with each of the PNPS AMRs.

C. Identify the documents needed to performthe review. These may include, but are not limited to, the following:

1. GALL Report

2. 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 Audit]Review A. Each AMR line item is coded with a letter which represents a standard note designation.'

The letter notes are described in Table 2 of this plan. Notes that use numeric 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 of 10 CFR 54.21 (a)(3). This requirement states: "Foreach structure and component ...

[within the scope of this part ... and ... subject to an aging management review] (the applicant) demonstrate(s) that the effects of aging will be adequately managed so that The AMR line item letter notes are based on a letter from A. Nelson, NEI, to P. T. Kuo, NRC, "U.S. Nuclear Indusrys Proposed Standard License Renewal Application Format Package.

Request NRC Concurrence," dated January 24, 2003 (ML030290201). The staff concurred In the format of the standardized format for LRAs by letter dated April 7,2003, from P.T. Kuo, NRC, to A. Nelson, NEI (ML030990052).

23

James Davis - Draft Pilgrim Audit Plan 4-4-06.pdf Page 27 1 James Davis Draft Pilgrim Audit Plan 4-4-06.pdf Page 271 Pilgrim Nudear Power Station AMP and AMR Audit and Review Plan 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 is summarized below:

1. For each AMR line item, perform the review associated with the letter note (A through E) assigned to the AMR line item. Specifically, determine if the AMR is consistent with the GALL Reportfor the elements associated with its note.

2

2. If Note A applies, and the applicant uses a plant-specific AMP determine ifthe component 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 acceptance in 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 the material, environment, and aging effect. IfNote 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.

5. If Note E applies, review the AMP audit report findings to determine if the scope of the alternate AMP envelopes the AMR line item being reviewed and satisfies 10 CFR 54.21 (a)(J. If itdoes not, go to Step (7) below.

6. Review the corresponding LRA Table 3.X.1 entry that is referenced in LRA Table 3.X.2.Y. Ifapplicable, determine whetherthe applicant's "Further Evaluation Recommended" response in LRASection 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. Ifthe LRA section does not meet the acceptance criteria of Appendix A of the SRP-LR, go to Step (7) below.

7. Ifduring the review a difference is identified, prepare a question to the applicant, in order 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.

2 Some GALL AMRs reference the use ofa plant-spedlic 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 ofextended operation.

24

James Davis - Draft Pilgrim Audit Plan 4-4-06.pdf - - Page 281 Pilgrim Nudear Power Station AMP and AMR Audit and Review Plan

b. Ifthe applicant's response does not resolve the question or issue, prepare an additional question to obtain the information needed to achieve resolution. Review the applicant's response to the second question. Ifit 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 a question 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 ifdocketed information may be needed.

8. view LRA Table 3.X.1. for AMR line items (Table 1s) that the applicant claims are not applicable with the GALL Report, determine that the AMR line items are acceptable on the basis of a technical review.

AMR sudit/review worksheets Document the audits/reviews of plant AM Rs using the worksheet provided inAppendix G, "Aging Management Review Worksheets."

6.3.2 AMRs Based on NRC-ApprovedPrecedents Figure 4, "AMR Review Using NRC-ApprovedPrecedent," is the process flowchart that shows the activities and decisions used to review plant AMRs that the applicant has identified as being consistent with an NRC-approvedprecedent. 3 Preparatin Identify the documents needed to performthe audit/review. These may include, but are not limited to, the following:

1. GALL Report

2. 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 3 Applicent-i dentlfied NRC-approved precedents are only to be used as an aid for performing AMR audits. The audit condusions will be based on the technical basis of the AMR and Its applicability to the plant being reviewed. It is not acceptable to simnply cite the NRC-approved precedent asits basis.

25

James Davis - Draft Pilgrim Audit Plan 4-4-06.pdf Page 29 Pilgrim Nudear Power Staton AMP and AMR Audit and Review Plan

10. Lessons Learned Developed by RLRC Audit/Review A. The AMR audit/review involves verification that the requirements of 10 C FR 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-approvedprecedent, this may be achieved by answering the following 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 technically support the adequacy of the LRA AMR being reviewed?

3. Is the LRA AMR within the bounds of the chosen NRC-approved precedent?

4. Ifany of these questions results in a "No" answer, then additional information is required 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 basis for accepting the AMR, the process shown in Figure 4 should be used.

6. Ifit is necessary for the applicant's response to be docketed as a basis for accepting the exception or difference, the applicant may voluntarily docket the response or the NRC may issue an RAI.

AMR audit/review worksheets Document the audits/reviews using the worksheet provided in Appendix G, "Aging Management Review Worksheets."

6.4 Time-LimitedAgIng Analyses(TLAA) AudItsand Reviews Audit and review of TLAAs are discussed below. The project team will also review the TLAAs to determine if there are emerging issues that should be further evaluated by technical specialists in the NRC Divisions of Componentlntegrity(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 periodof extended operation." ForTLAAsfor 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 26

Ja es Davis wDraft ilarim Audit Plan 44-06.pdf Page 30 ,1 James Davis Draft Pilarim Audit Plan 4-4-06.Ddf Page 301 Pilgrim Nudear Power Staton AMP and AMR Audit and Review Plan be capable of reviewing. Consideration should be given to team expertise, past precedent, and complexity of the provided analysis.

6.4.1 Identify Generic TLAA Issues Figure 5, "Evaluation of TLAAs and Exemptions," taken from NEI 95-10, Revision 6, shows the process 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 TLAAthat the applicant identifies.

Pre-Review Preparation A. For the PNPS TLAAs that the applicant has identified as generic TLAA issues, identify the corresponding TLAAs in NUREG-1800, if appropriate.

B. Review the corresponding TLAAs in NUREG-1800and identify those that will be audited/reviewed in conjunction with each of the PNPS TLAAs.

C. Review the list of the PNPS plant-specific exemptions granted pursuantto §50.12and 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.

D. Identify and locate the documents needed to performthe review. These may include, but are not limited to, the following:

1. Excel database on TLAAs summarizing how earlier LRAs and SERs presented and reviewed

2. TLAAs

3. GALL Report

4. SRP-LR

5. 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 27

James Davis - Draft Pilgrim Audit Plan 4-4-06.pdf -Page Pag...,31_,I Pilgrim Nudear Power Station AMP and AMR Audit and Review Plan

11. implementation documents

12. operating experience reports (plant-specific and industry)

13. lessons learned developed by RLRC

14. applicant's UFSAR E. In addition, the project team will also review the 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 forTLAAs for which the applicant claims consistency with 10 CFR54.21(c)(i)

"the analyses remain valid forthe period of extended operation." or 10 CFR54.21(c)(iii)

"the effects of aging on the intended function(s) will be adequately managed for the period of extended operation." ForTLAAs forwhich 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 EmbrittlementAnalysis (PNPS LRA Section 4.2)

2. Containment Liner Plate, Metal Containment, and Penetrations Fatigue Analyses (PNPS LRA Section 4.6)

3. Reflood Thermal Shock Analyses of the ReactorVessel Internals (PNPS LRA Section 4.7.1)

Audt/Review A. Confirm that each PNPS TLAAlisted in this section is appropriate. Referto any analyses and evaluations created during the acceptance review process.

B. If a TLAA is listed in the SRP-LRor NEI 95-10 and not in its LRA, the PNPS should state 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 28

Jam~esDavris- Draft Pilgrim Audit Plan 4-4-06.pdf Page32 11

] ................... I Pilgrim Nudear Power Staton AMP and AMR Audit and Review Plan identification of the results of the time-limited aging analysis review, which may be provided in tabular form, may reference the section inthe Integrated Plant Assessment-Aging Management Review chapter where more details of the actual review and disposition (as required by §54.21 (c)(1)o)-(iii)) are located.

2. The application shall include a demonstration that (1) the analyses 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.

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 extended operation shall be included in the UFSAR supplement (AppendixA).

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 basis for 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 Worksheets Document the audits/reviews using the worksheet provided in Appendix I, "TLAAAudit/Review Worksheet."

6.4.2 Metal Fatigue Analyses Figure 5, "Evaluation of TLAAs and Exemptions," taken from NEl 95-10, Revision 6, shows the process of evaluating and reviewing TLAAs and also identifying the exemptions in effect. This process flowchart shows the actMties and decisions used to audit/review each TLAAthat the applicant identifies.

Pre-Review Preparation A. The project team will determine if the TLAAs identified in the PNPS LRAto be within the NUREG-1 800TLAA 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).

29

James Davis - Draft Pilgrim Audit Plan 4-4-06.pdf Page 33 i James Davis Draft Pilgrim Audit Plan 4-4-06.pdf Page 33 Pilgrim Nuclear Power Station AMP and AMR Audit and Review Plan B. Identify and locate the documents needed to performthe review. These may include, but are not limited to, the following:

1. Excel database on TLAAs summarizing how earlier LRAs and SERs presented and reviewed 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 UFSAR C. In addition, the projectteam will also reviewthe PNPS TLAAswithin the NUREG-1800 TLAA 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/Reviw A Confirm that each PNPS TLAAlisted in this section is appropriate. Referto any analyses and evaluations created during the acceptance review process.

30

James Davis - Draft P/lgrim Audit Plan 4-4-06.pdf Page 34 Pilgrim Nuclear Power Stadon AMP and AMR Audit and Review Plan B. Ifa TLAAis listed in the SRP-LRor NEI 95-10 and not in its LRA, the PNPS should state in this section that it does not apply.

C. The project team will conduct both regulatory evaluations and technical evaluations to determine, 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 license renewal, 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. are 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 the system, structure, and component to performits intended functions, as delineated in 10 CFR 54.4(b)

6. are contained or incorporated by reference in the CLB D. The project team will ascertain that the PNPS satisfactorily demonstrates that (1) the analyses 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 the summary 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 basis for 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 Worksheets 31

Page 35 1 James Davis

• = i R* m*m* . ... -, Pýaýt

• Pilg(im Audit Plan,ý-4'-06..pd

£=*-mm*[*l James Davis Draft Pilgrim Audit Plan 4-4-06.pdf Page 35 I Pilgrim Nuclear Power Staton AMP and AMR Audit and Review Plan Document the audits/reviews using the worksheet provided in Appendix I, "TLAAAudit/Review Worksheet."

6.4.3 EnvironmentalQualification Analyses for Electrical Components Figure 5, "Evaluation of TLAAs and Exemptions," taken from NEI 95-10, Revision 6, shows the process 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 TLAAthat the applicant identifies.

Pre-Review Preparation A. The project team will determine ifthe TLAAs identified in the PNPS LRA to be within the NUREG-1800TLAA categoryof "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 performthe review. These may include, but are not limited to, the following:

1. Excel database on TLAAs summarizing how earlier LRAs and SERs presented and reviewed TLAAs

2. GALL Report, especially Section X.E1

3. SRP-LR

4. ISG-LR

5. RAls, 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 UFSAR 32

James Davis -_[ý Pilgrim Audit Plan 4-4,-Mpdf Jame Dais -Drat Pigri Audt Rn 4--06pdPage 36]

Pilgrim Nuclear Power Staton AMP and AMR Audit and Review Plan C. In addition, the project team will also review the PNPS TLAAswithin the NUREG-1800 TLAA categoryof "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/Review A. Confirm that each PNPS TLAA listed in this section is appropriate. Referto any analyses and evaluations created during the acceptance review process.

B. If a TLAA is listed in the SRP-LRor NE195-10 and not in its LRA, the PNPS should state in this section that it does not apply.

C. The project team will conduct both regulatory evaluations and technical evaluations to determine, 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 license renewal, 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. are 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 the system, structure, and component to performits intended functions, as delineated in 10 CFR 54.4(b)

6. are contained or incorporated by reference in the CLB D. The project team will ascertain that the PNPS satisfactorily demonstrates that (1) the analyses 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.

33

James Davis - MrýftPilgrim Audit Plan 4-ý-'06'.pqf Jame Dais Drft ilgim

-- udi Pln 44-0.pd Page 37 iI Pilgrim Nudear Power Station AMP and AMR Audit and Review Plan 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 the summary 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 basis for 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 PN PS LRA. If not, the NRC may issue an RAI to obtain the information.

TLAA Audit Worksheets Document the audits/reviews using the worksheet provided in Appendix I, "TLAAAudiVReview Worksheet."

6.4.4 Other Plant-Specific TLAAs Figure 5, "Evaluation of TLAAs and Exemptions," taken from NEI 95-10, Revision 6, shows the process 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 TLAAthat the applicant identifies.

Pre-Review Preparation A. The project team will determine if the TLAAs identified in the PNPS LRAto be within the NUREG-1 800 TLAAcategory of "other plant-specific TLAAs" have provided adequate information to meet the requirementsof 10 CFR 54.21(c)(1) and 10 CFR54.21(c)(2).

B. Identify and locate the documents needed to performthe review. These may include, but are not limited to, the following:

1. Excel database on TLAAs summarizing how earlier LRAs and SERs presented and reviewed TLAAs

2. GALL Report

3. SRP-LR 34

James Davis - DPraftPilgrim Audit Plan 4-4-06.pdf Page 38 i Pilgrim Nudear Power Station AMP and AMR Audit and Review Plan

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 UFSAR C. In addition,the projectteamwill also reviewthe PNPS TLAAswithin the NUREG-1800 TLAA 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 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/Review A. Confirm that each PNPS TLAAlisted in this section is appropriate. Referto any analyses and evaluations created during the acceptance review process.

B. If a TLAA is listed in the SRP-LRor NEI 95-10 and not in its LRA, the PNPS should state in this section that itdoes not apply.

C. The project team will conduct both regulatory evaluations and technical evaluations to determine, 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 license renewal, as delineated in 10 CFR 54.4(a) 35

-Jam.es-D-avis- Dýaftpilgrirn Audit Plan 1-ý-06.pqf .... s ...... ,Draft.Pilgrim.Audit.Plan.. . . ..... .. Page 39]1 Pilgrim Nudear Power Station AMP and AMR Audit and Review Plan

2. consider the effects of aging

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

4. are 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 the system, structure, and component to performits intended functions, as delineated in 10 CFR 54.4(b)

6. are contained or incorporated by reference in the CLB D. The project team will ascertain that the PNPS satisfactorily demonstrates that (1) the analyses 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 basis for 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 Worksheets Document the audits/reviews using the worksheet provided in Appendix I, "TLAAAudit/Review Worksheet."

6.5 Audit and Safety Review Documentation As 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.

36

James Davis- Draft Pilgrim Audit Plan 4-4-06.pdf __Page 40 Pilgrim Nudear Power Staion AMP and AMR Audit and Review Plan 6.5.1 Audit and Review Report The project team should prepare input to the audit report in accordance with the guidance provided in the Writing Guide and Template for Preparing License Renewal Application Audit Report. The audit report should follow the following format:

A. Cover page B. Table of Contents C. Section 1 Introduction and General Information

1. Section 1.1 Introduction

2. Section 1.2 Background

3. Section 1.3 Summaryof Informationin the License RenewalApplication

4. Section 1.4 Audit Scope

5. Section 1.5 Audit Process

6. Section 1.6 Exit Meeting D. Section 2 Aging ManagementPrograms(AMP)

E. Section 3 Aging Management Review (AMR) Results F. Attachment 1 Abbreviations and Acronyms G. Attachment 2 Project Team and Applicant Personnel Il. Attachment 3 Elements of an Aging Management Program for License Renewal L Attachment 4 Disposition of Requests for Additional Information, LRA Supplements, and Open Items J Attachment 5 List of Documents Reviewed K. Attachment 6 List of Commitments 6.5.2 Safety Evaluation Report Input A. General guidance

1. Each project team membershould preparethe SER input for the AMP and AMR audits 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 be available in the project team's audit and review report and the team member's worksheets.

37

James Davis-Draft Pilgrim Audit Plan 4-4-06.pdf Page 411 Pilgrim Nuclear Power Station AMP and AMR Audit and Review Plan

3. SER inputs are to be prepared for:

a. Each AMP that was determined to be consistent with the GALL Report, which has no exceptions or enhancements.

b. Each AMP that was determined to be consistent with the GALL Report, which has 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.'

4. The SER input should contain the following sections. (Note: The following section numbers (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 Results 3.0 Applicant's Use of the Generic Aging Lessons Learned Report 3.01 Format of the LRA 3.02 Staff's Review Process 3.0.2.1 AMRs in the GALL Report 3.0.2.2 NRC-Approved Precedents 3.0.2.3 U FSAR Supplement 3.0.2.4 Documentation and Documents Reviewed 3.0.3 Aging Management Programs 3.0.3.1 AMPs that are Consistent With the GALL Report 3.0.3.2 AMPs that are Consistent With GALL Report With Exceptions or Enhancements 3.0.3.3 AMPs that are Plant-Specific 3.0.4 Quality Assurance Program Attributes Integral to Aging Management Programs 3.X( Aging Management of __

3.X.1 Summaryof Technical Information in the Application 3.X.2 Staff Evaluation

' AMRs that are not consistent with the GALL Report The LRA AMR results are broken down Into six sections and address the following systerrV structure groups: (1) Section 3.1. reactor vessel, Internals and reactor coolant system, (2) Section 32, engineering safety features systems, (3) Section 3.3, auxiliary systems, (4)

Section 3A, steam power and conversion systems, (5) Section 3.5, structures and component supports, (6) Section 3.6, electrical and instrumentation and controls.

38

James Davis -_DTIý Pilgrim Audit Plan 4-4-06:pdf JmPage42, z Pilgrim Nudear Power Station AMP and AMR Audit and Review Plan 3.X.2.1 Aging Management Evaluations that are Consistent with the GALL Report, for Which Further Evaluation is Not Required 3.X.2.2 Aging Management Evaluations that are Consistent with the GALL Report, for Which Further Evaluation is Recommended 3.X.2.3 AMR Results that are Not Consistent with or Not Addressed in the GALL Report 3.X.3 Conclusion

5. For each AMP audited/reviewed by the project team, the SER shall include a discussion of the team's review of the operating experience program element.

6. Ifthe applicant submitted an amendment or a supplement to its LRA that is associated 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. Ifan RAI was issued, identify the RAI number and briefly discuss the RAI. State if the RAI remains open or ifthe 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., RAls) that have not been resolved by the applicant at the time the SER input is prepared should be identified as open items.

B. SER input

1. For AMPs determined to be consistent with the GALL Report,without exceptions, include the AMP title, the plant AMP paragraphnumber, and a discussion of the basis for concluding that the UFSAR update (Appendix A of the LRA) is acceptable. This SER input documents that the AMP is consistent with the GALL Report.

2. For AMPs determined to be consistent with the GALL Report,with exceptions or enhancement, 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 accepting each of the seven elements reviewed by the project team. The SER input should also include a discussion concerning the adequacy of the UFSAR supplement.

39

James Davis - Dýaýt ýflgdm Audit Plan 4-4-06.pqt JPage 431 Pilgrim Nudear Power Station AMP and AMR Audit and Review Plan

4. For aging management evaluations that are consistent with the GALL Report,6 the SER input should include the following:

a. Identify the LRAsection reviewed.

b. A summary of the type of information provided in the section of the LRA reviewed, including a listing of the AMPs reviewed.

c. Identify the LRATables 3.X.2-Y reviewed.

d. A summary review of the AMR Notes A through E used to classify the AMR line items 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 by the 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 and environments

• the applicant specified acceptable AMPs

h. A conclusion stating, if applicable, 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 operation, and that 10 CFR 54.21 (a)(3)has been satisfied.

5. For aging management evaluations that are consistent with the GALL Report, for which further evaluation is recommended, the SER input should include the following:

a. The LRA section containing the applicant's further evaluations of AMRs for which further evaluation is required.

b. A list of the aging effects for which the further evaluation apply.

6 The audit results documented In this sedion address the AMRs consistent with the GALL Report for which no further evaluation is recormended.

40

James Davis, 7,1ýý.IttPýilgrim Audit Plan ý4-06.pdf 44jl s i DPýage Pilgrim Nuclear Power station AMP and AMR Audit and Review Plan

c. For the applicant's further evaluations, provide a summary of the basis for concluding 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 the criteria 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 Results7 This section of the SER input documents the reviews of AMRs 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 LRATables 3.X.2-Y documented by this audit writeup.

d. A brief summaryof what the staff (project team) reviewed (i.e., LRA and applicant basis documents and other implementation documents).

e. A finding that verifies, if true, that:

0 The applicant identified the applicable aging effects.

0 The applicant listed the appropriate combination of materials and environments.

0 The applicant specified acceptable AMPs.

f. Provide a conclusion stating, if applicable, 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 operation, and that 10 CFR 54.21 (a)(3) has been satisfied.

This section documents reviews of AMRs assigned to the project team that are not consistent with the GALL Report 41

James Davis - Draft Pilgrim Audit Plan- 4-4-06.pdf . _P _51

~a ge _4 Pilgrim Nuclear Power Station AMP and AMR Audit and Review Plan 6.6 Documents Reviewed and Document Retention Any documents reviewed that were used to formulate the basis for resolution of an issue, such as 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 contractor and NRC personnel shall be given to the N RC project team leader.

After the NRC has made its licensing decision, all copies of documents collected and all documents generated to complete the audit and review report, such as audit worksheets, question and answer tracking documentation, etc., are to be discarded.

42

James Davis _-__Draýf_ýPilgdm Audit Plan ý-ý-06.pdý_' Jame Dais Drft uditPla 4--06pdfPage 4611I Pilarim Nudear Power Stabon AMP and AMR Audit and Review Plan Table 1. Aginp ManagementProgram Element Descriptions Element 1 Description 1 Scope of the program The scope of the programshould include the specific structures and components subject to an aging management review.

2 Preventive actions Preventive actions should mitigate or prevent the applicable aging effects.

3 Parameters monitored or Parameters monitored or inspected should be linked to the inspected effects of aging on the intended functions of the particular structure and component.

4 Detection of aging effects Detection of aging effects should occur before there is loss of any 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.

5 Monitoring and trending Monitoring and trending should provide prediction of the extent of the effects of aging and timely corrective or mitigative actions.

6 Acceptance criteria Acceptance criteria, against which the need for corrective action 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.

7 Corrective actions Corrective actions, including root cause determination and prevention of recurrence, should be timely.

8 Confirmation process The confirmation process should ensure that preventive actions are adequate and appropriate corrective actions have

_been completed and are effective.

9 Administrative controls Administrative controls should provide a formal review and

_______91____ lapproval process.

10 Operating experience Operating experience invoMng the aging management program, 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 1period of extended operation.

43

James Dayis,- t im Audit P1an4-4-q6.pdf James..a..........i~grimAudi~ , .... . ... Pln 4-4-0.f Page 47 Pilarim Nuclear Power Station AMP and AMR Audit and Review Plan Table 2. Notes for License Renewal Application Tables 3.X.2-V Note i Description A Consistent with NUREG-1 801 [GALL Report] item for component, material, envirorrnent, and aging effect. AMP is consistent with NUREG-1801 AMP.

B Consistent with NUREG-1 801 item for component, material, environment, and aging effect. AMP takes some exceptions to NUREG-1 801 AMP.

C Componentis different, but consistent with NUREG-1 801 item for material,

.environment, and aging effect. AMP is consistent with NUREG-1801 AMP.

D Componentis different, but consistent with NUREG-1801 item for material, environment, and aging effect. AMP takes some exceptions to NUREG-1 801 AMP.

E Consistent with NUREG-1801 for material, environment, and aging effect, buta different aging management program is credited.

F Material not in NUREG-1 801 for this component.

G Environment not in NUREG-1801 for this component and material.

H Aging effect not in NUREG-1 801 for this component, material and environment combination.

I Aging effect in NUREG-1 801 for this component, material and environment combination isnot applicable.

J Neither the component nor the material and environment combination is evaluated in NUREG-1801.

I Each AMR line item Iscoded with a letter which represents a standard note designation 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 In the format of the standardized format for license renewal applications by letter dated April 7,2003, from P.T. Kuo, NRC, toA. Nelson, NEI (ML030990052).

44

James Davis - Draft Pilgrim Audit Plan 4-4-06.pdf Page 48 1 Pilarim Nuclear Power St?~on AMP Rnd AMR Audit and Rp~viw PIan PlIarim Nuclear Pomr Stabon AMP and AMR Audit and RPApw PLqn Figure 1. Audit of AMPs that are Consistent w Ith the GALL Report 45

James Davis 7 Prajýilgýim Audit Plan 4-A-,q6.pqý Page 4p9;I James Davis Draft Pilgrim Audit Plan 4-4-06.pdf Paqe49 I Pilorim Nuclear Power Station AMP and AMR Audit and Review Plan Figure 2. Audit of Plant-Speclfb AMPs 46

James Davis - Draft Pilgrim Audit Plan 4-4-06.pdf Page 50 1 Pienrim Ni dJ'r Pnwv.r *tatIfrn AMP and AMR Audit and Review Plan PH a rim Nudear Power Stadon Figure 3. Review of AMRs that are Consistent with the GALL Report 47

James Davis - Draft Pilgrim Audit Plan 4-4-06.pdf Page 5:1 I Pilgrim Nudear Power Staton AMP and AMR Audit and Review Plan r-ý, -ýý-Y**

No Figure 4. Review of AMRs Using NRC-Approved Precedents 48

James Davis - Draft Pilgjrim Audit Plan 4-4ý-06.pdf J.m..Da....Drft.......AditPlan......... - Page 52]

Pilarim Nudear Power Staton AMP and AMR Audit and Review Plan Figure 5. Review of TLAAsand Exemptions(from NEI 95-10, Revision 6) 49

James Davis - plýaft ýýIgrim Audit P1an4-4-p6.pdf James..Davis...Draft.....r..m.......Plan.......... Page 53j Pilgrimn Mlr .or Pn,~r ttfi~nn AMP and AMR Audit and Review Plan PitN rim Nuclear Power Station AMP and AMR Audit and Review Plan-APPENDIXA PROJECTTEAM MEMBERSHIP 1Organization Name. Functbn NRC/NRR/DLR/RBC James Davis Team leader NRC/NRR/DIPRRLRC Peter Wen Back-up Team Leader NRC/NRR/DIRIRLRC Dan Hoang Reviewer -Structures NRC/IhRR/DLR/RLRC Duc Nguyen Reviewer-Electrical ATL International Erach Patel Contracbr lead, Reviewer- Mechanical ATL International Bob Johnson Reviewer- Systems ATL International Wayne Pavinich Reviewer- Materials A-1

James Davis -,Rrqýt Pilgrim Audit Plan 4-ý7q6.pqt, Page 54 J James Davis- Draft Pilgrim Audit Plan 4-4-06.pdf Page 541 Pilgrim Nuclear Power Station AMP and AMR Audit and Review Plan APPENDIXB RLRCSCHEDULEFOR PILGRIM LRASAFETYREVIEW Team Leader James Davis Contractor ATL International Inc.

Backup Team Leader Peter Wen ATL Audit Team Leader Erach Patel Project Manager Kathy Weaver ATL Project Manager MarkOrr TACNumber MC 9669 ATL Project Number 0229

[ Activity/Milestone - AntcpatedDate 1 Received license renewal application (LRA) 01/27/06" 2 Make review assignments (Project Manager) 03/28/06*

3 Train project team (Team Introduction Meeting) 03/20/06" 4a Hold team planning and kick-off meeting 03/20/06*

4b Finalize split table and issue assignments to audit team 03/24/06 5 Issue audit plan to Project Manager ( 5 days after assignments) 04/05/06 6 First site vt 05/22/06 to 05/26/06 7a Draft AMP audit report information from audit report team to audit 06/09/06 team leader - in sections as completed - completed by 7b Draft AMP audit report from ATLto NRC 06/20/06 8 Draft Safety Evaluation Report(SER) input for AMP reviews Not Applicable 9 Condu-t in-office reviews of Aging Management Reviews 03/20/06 to 06/16/06 10 Conduct second site visit (resolve AMR and AMP questions) 06/19/06 to 06123/06 1 1a Draft AMR audit report notes from team to Audit Team Leader 07/14/06 11b Draft AMR audit report from Audit Team Leader to ATL 07/22/06 11c Draft final AMR audit reportfrom ATL to NRC 08/04/06 11d NRC commentson draftfinal AMR audit reportto ATL 08/18/06 12 Draft SER input for AMR reviews (team members) Not Applicable Conduct third site visit to resolve outstanding issues and questions 07/24/06 to 1 (if needed) 07/27/06 14 Conduct public exit meeting 07/27/06 15 Writing session for audit and review report and SER input Not Applicable 16 Managerrequests for additional information (RAls) to Project 1Provide 08/04/06 B-1

James Davis - Draft Pilgrim Audit Plan 4-4-06.pdf Page 55 1 A- . . AI*D anrl AUI:I A,,rlFeInrl I:I,*A* *an APPENDIXC AGING MANAG EMENTPRO GRAMASSIG NMENTS PNPS GALL LRA ARePrt AglngManagementProgram ConslstentWlthGALL?. Assigned AMP AM*Audtor Number Number B.1.1 XI.M.22 Boraflex Monitoring Yes Peter Wen B.1.2 XI.M.34 Buried Piping and Tanks Inspection Yes Exception Jim Davis B.1.3 XI.M.6 BWR Control Rod Drive Return Line Nozzle Yes Exception Jim Davis B.1.4 XI.M.5 8WR FeedwaterNozzie Yes Exception Jim Davis B.1.5 XI.M.8 BWR Penetrations Yes Exception Bob Jackson B.1.6 XI.M7 BWR Stress Corrosion Cracking Yes Exception. Enhanced Bob Jackson B.1.7 Xl.M4 BWR Vessel ID AttachmentWelds Yes Exception Bob Jackson B.1.8 XI.M9 BWR Vessel Internals Yes Exception - Enhanced Bob Jackson B.1.9 XI.S,4 Containment Leak Rate Yes Dan Hoang 8.1.10 XI.M30 Diesel Fuel Monitoring Yes Exception - Enhanced Wayne Pavinich B.1.11 X.E.1 Environmental Quarification of Electric Components Yes DucNguyen B.1.12 X.M.1 Fatigue Monitoring Yes Exception Erach Patel B.1.13.1 XI.M.26 Fire Protection Yes Exception - Enhanced Erach Patel 8.1.13.2 XIM.27 Fire Water System Yes Exception - Enhanced Erach Patel B.1.14 XI.M.17 Flow-Accelerated Corrosion Yes Peter Wen B.1.15 N/A Heat Exchanger Monitoring Wayne Pavinich C-1

James Davis- Draft!grim Audit Plan 4-4-O6.pdf Page 56qI A)J* anti 6M* A**;t anal *nw Plan L ilQrim Nud e ar Pomr X-on P nd AMRAteR Xnd ReMew Plan PNPS GALL LRA Report AgIng Management Program Conststentilth GALL?

AMP AMP Audtor Number Number B.1.16.1 N'A Containment Inservice Inspection Dan Hoang B.1.16.2 NWA Inservice Inspection IBob Jackson B.1.17 N/A Instrument Air 0uality Wayne Pavinich B.1.18 XLE.4 Metal-Enclosed Bus Inspection Yes Exception DucNguyen B.1.19 XI.E3 Non-EQ Inaccessible Medium-Voltage Cable Program Yes DucNguyen B.1.20 XI.E2 Non-EQ InstrumentationCircufts Test Review Yes Duc Nguyen B.1.21 XI.E1 Non-EQ Insulated Cables and Connections Yes DucNguyen B.1.22 XI.M39 Oil Analysis Yes Exception - Enhanced Wayne Pavinich B.1.23 XLM.32 One-Time Inspection Yes Erach Patel B.1.24 N/A Periodic Surveillance and Preventive Maintenance Wayne Pavinich B.1.25 1Xi.M.3 Reactor Head Closure Studs Yes Exception BobJackson B.1.26 XIM.31 ReactorVessel Surveillance Yes Enhanced DEStaff 6.1.27 XI.M33 Selective Leaching Yes Peter Wen B.1.28 XI.M.20 Service Water Integrity Yes Exception Wayne Pavinich B.1.29.1 XI.S.5 Masonry Wall Yes Dan Hoang B.1.29.2 XIS.6 Structures Monitoring Yes Enhanced Dan Hoang B.1.29.3 :XIS.7 Water Control Structures Monitoring Yes Enhanced Dan Hoang T.1.30 XI.M36 System Walkdown Yes Peter Wen C-2

James Davis - Draft Pilgrim Audit Plan 4-4-06.pdf Page 57 *

...... ABJ*

pilgrim Nudear Pow~er Stagon AMP and AMR Awii J rif0 eew ,,an PN PS GA L L As sig n ed LRA Report Aging Management Program ConsistentWith GALL?, Assigned AMP AMP Ado Number Number B.1.31 XIM.13 Thermal Aging and NeutronIrradiation EFmbrittlement of Yes Peter Wen Cast Austenitic Stainless Steel (CASS)

B.1.32.1 N/A Water Chemistry Control- Awdliary Systems Erach Patel B.1.32.2 XI.M.2 Water Chemistry Control- BWR Yes Erach Patel B.1.32.3 XI.M.21 Water ChemistryControl - Closed Cooling Water Yes Exception Erach Patel C-3

James Davis ---Draft Pilgrim Audit Plan 4-4-06.pdf Page 58 11 James Davis - Draft Pilgrim Audit ~ Page 5811 Pilarim Nudear Power Staflon AMP and AMR Audit and Review Plan APPENDIXD AGING MANAGEMENTREVIEW ASSIGNMENTS Aging Management Reviews Reviewer Si Aging Management of Reactor Vessel, Internals, and Reactor Coolant Bob Jackson System 3.2 Aging Management of Engineered Safety Features Wayne Pavinich 3.3 Aging Management of Auxiliary Systems Erach Patel 3.4 Aging Management of Steam and Power Conversion Systems Peter Wen 3.5 Aging Management of Containment, Structures, and Component Dan Hoang Supports 3.6 Aging Managementof Electrical and Instrumentation and Controls Duc Nguyen D-1

Page 59 11 James Davis - Draft Pilgrim Audit Plan 4-4-06.pdf Page 59 :f James Davis Draft Pilgrim Audit Plan 4-4-06.pdf Pilarim Nuclear Power Station AMP and AMR Audit and Review Plan

. APPENDIXE TIME-LIMITEDAGING ANALYSISREVIEW ASSIGNMENTS LRA GALLpor RepoTLAA . TLAATit le 10 CFR 54.21 (c)(1). Assigned, Revleweri Number Number (I)1r1(1i) b (ii)Q Reiee 4.1 Identification of TLAAs and J. D 4.1 _____ Exemptions _._Davis 4.2 Reactor Vessel Neutron Embrittlement (i) (ii) DCI 4.3 X.M.1 Metal Fatigue (i) or (iii) (ii) E. Patel 4.4 X.E.1 Environmental Qualification or (iii) D. Nguyen Electrical Components Concrete Containment Tendon Not 4.5 X.S.1 Applicable to N/A Prestress PNPS Containment Liner Plate, Metal 4.6 Containment, and Penetrations (ii) DE Fatigue Analysis 4.7.2.2 TLAA in BWRVIPs (i) (ii) J. Davis 4.7.2.3 TLAAin BWRVIPs (i) (ii) J. Davis

[ 4.7.2.5 1 ITLAAin BWRVIPs (i) (ii) J. Davis E-1

James Davis - Draft Pilgrim Audit Plan 4-4-06.pdf Page 60 1 James Davis Draft Pilgrim Audit Plan 4-4-06.pdf Page 60]

Pilgrim Nudear Power Staton AMP and AMR Audit and Review Plan APPENDIXF CONSISTENTWITH GALL REPORTAMP AUDIT/REVIEWWORKSHEET The worksheet provided in this appendix provides, as an aid for the reviewer, a process for documenting the basis for the assessment of the elements and sub-elements contained in the GALL ReportAMPs (ChapterXI of NUREG-1 801 ,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 preparethe audit and review report and the safety evaluation report input.

F-1

James Davis -_Pýattpilg(im Audit Plan 4-4-96.pdt_ Ja e.....D...i i. A Page_61ji Pilarim Nudear Power Staton AMP and AMR Audit and Review Plan LRA Appendix Subsection: LRAAMP

Title:

GALL Report Subsection: Gall Report

Title:

A. Element Review and Audit Program

Description:

G Consistent with GALL Report G Difference Identified Discussion:

1. Scopeof 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:

F-2

jarnesuavis - Rrafýýilgda Audit Plan 4-4-06.pdf --6pfPage airfigimAdtPa Jae Pilgrim Nudear Power Staton AMP and AMR Audit and Review Plan

7. Corrective Action: To be performed by DIPM

8. Confirmation Process: To be performedby DIPM

9. Administrative Controls: To be performedby DIPM

10. Operating Experience:

B. FSAR supplementreview: (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:

F-3

James Davis- Draft Pilgrim Audit Plan 4-4-06.pdf Page 63 :1 AMP nn AMP*f A~l ~nnr R~ Plnn Dif a rim KI-d-r Pomr Station AMP andAMR Audit and vfewPlan Appendix G Plant-Specific AMP Audit/Review Worksheet G-1

James Davis - Draft Pilgrim Audit Plan 4-4-06.pdfa -Page64 Itl Pilgrim Nudear Power Staton AMP and AMR Audit and Review Plan APPENDIXG PLANT-SPECIFICAMP AUDIT/REVIEWWORKSHEET The worksheet provided in this appendix provides, as an aid for the reviewer, a process for documenting 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 preparingthe audit and review report and the safety evaluation report input.

G-2

James Davis - DýqttPilg(im Audit Plan 4-A-0p.pqý James.Dais .. Drft.Pilgim.AuditPlan..... ... .Page 65jI AMP ~n,4 AU~ A,4;t ~nd ~ P~n Dil kirim 14-4-ar P-r station AIýP' and AMR Audit and Review Plan Plant-Specific AMP Audit/Review Worksheet AMP

Title:

Appendix Subsection:

A. Element Review and Audit

1. Scopeof Program:

_ Consistent with SRP-LR Exception I Difference Identified SRP Criteria LRA AMP Comment*

2. Preventive Action:

_ Consistent with SRP-LR - Exception Difference Identified Discussion:

SRP Criteria LRA AMP Comment*

3. Parameters Monitored/inspected:

_ Consistent with SRP-LR - Exception Difference Identified Discussion:

SRP Criteria LRA AMP Comment*

4. Detection of Aging Effects Consistent with SRP-LR __ Exception Difference Identified Discussion:

SRP Criteria LRA AMP Comment*

G-3

James Davis - Draft Pilgrim Audit-Plan 4-4-06.pdf 1., Page Draft Pilgrim Audit Plan 4-4-06.pdf Page 66 66jý1 James Davis -

Pilgrim Nudear Power Station AMP and AMR Audit and Review Plan

5. Monitoring and Trending

_ Consistent with SRP-LR - Exception Difference Identified Discussion:

SRP Criteria LRA AMP Comment*

6. Acceptance Criteria Consistent with SRP-LR - Exception Difference Identified Discussion:

SRP Criteria LRA AMP Comment*

7. Corrective Action: To be performed by DIPM

8. Confirmation Process: To be performed by DIPM

9. Administrative Controls: Tobe performendby DIPM

10. Operat Ing Experience:

__ Consistentwith SRP-LR Exception _ Difference Identified Discussion:

SRP Criteria LRA AMP Comment*

• Consistent or technical basis for acceptance exception or difference B. 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:

G-4

James Davis - Draft Pilgrim Audit Plan 4-4-06.pdf Page 67 ]I James...Davis** - rf

...... .. ...u i . Pla 4-4-.06*.

Plrm .... i 1**  : (. ... T- .] . . ]r Page 67i 0:1or m

KI A 0 0-9 ý AR)ID onrl AIfAI* -'-itrl;f onrl DoiJ;ow I

)l*ln u ear omr AMPandAMOA.,jifand %A-wPlan Appendix H AMR Comparison Worksheets H-1

James Davis.-Draft Pilgrim Audit Plan 4-4-06.pdf Page 6811 I

Pilcrim Nudlear Power Staton AMP and AMR Audit and "es4ew Plan PNPS AMR Component(Table I) Worksheet Audit Date:

Unit: ITableNo.: IChapter:

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 Items applicable to BWRs In Table 1 were review ed and are addressed In the follow Ing table.

I,, I~

I1temnNo. lFurther Evaluation Recommended IO IDIscussIon I--o Audit Remarks (Document all questions for applicant here):

lNumber IQuestIon for applicant (draft per RAI guidance) Response (w"h date)

References/Documents Used:

1.

2.

3.

4.

K-2

James Davis- Draft.Pilgirim Audit Plan 4-4-06.pdf Page 6911I Dih*l -h~~ P* -*

OEM ear ower g on AMP a nd AMR A u dit and -e. P1an PNPS AMR MEAPComparison (Table 2) Worksheet IAudit Date:

Unit: ITable No.: Chapter:

Auditor Name(s):

Line Items to w hich Notes A, B, C, D, and E are applied or for whlch a precedent was cited (except for those assigned to DE) were reviewed for: 1) consistencywlth NUREG-1801, Volume2 tables, and 2) adequacy of theaging 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 dupicate information inthe 2nd-5th columns that are reflected in the discussion/draft audit report.)

LRA Component Material Environment Aging Effect Note: Discussion Page No. Type (draft as Audit Report Insert)

Audit Remarks (Document all questions for the applicant here):

INo. IQueston forapplicant (draft per RAI guidance) Response (with date)

References/Documents Used:

5.

6.

7.

H3

James Davis - Draft Pilgrim Audit Plan 4-4-06.pdf._ Page 70'1 Pilorim Nudear Power Station AMP and AMR Audit and Review Plan APPENDIXI (LATER)

TIME-LMITEDAGINGANALYSIS(TLAA)AUDIT/REVIEWWORKSHEET I-1

James Davis- DraftP lgrim.Audit Plan 4-4-O6.pdf ..... Page 71 ]

Pilgrim Nudear Power Staton AMP and AMR Audit and Review Plan APPENDIXJ ACRONYMS,ABBREVIATIONSANDINITIALISMS ADAMS Agencywide Documents Access and ManagementSystem AMP aging management program AMR aging management review ASME American Society of Mechanical Engineers CLB current licensing basis DE Division of Engineering DPM Division of Inspection Program Management FSAR final safety analysis report GALL Generic Aging Lessons Learned ISG interim staff guidance LRA license renewal application NEI Nuclear Energy Institute NRC U.S. Nuclear RegulatoryCommission NRR Office of Nuclear Reactor Regulation PNPS Pilgrim Nuclear Power Station RAI request for additional information RLEP-B License Renewal and Environmental Impacts Program, Section B RLSB License Renewal and Standardization Branch SC structures and components SER safety evaluation report J-1

James Davis,- DrafttPigrim Audit Plan 4-4-06.pdf. Page 72j Pilgrim Nuclear Power Station AMP and AMR Audit and Review Plan SRP-LR Standard Review Plan - License Renewal SSC structure, system, and component UFSAR updated final safety analysis report J-2