ML071210032
| ML071210032 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 05/04/2007 |
| From: | NRC/NRR/ADRO/DLR |
| To: | |
| Medoff J, NRR/DLR/RLRC 415-2715 | |
| References | |
| Download: ML071210032 (89) | |
Text
Audit and Review Plan for Plant Aging Management Reviews, Aging Management Programs, and Time Limited Aging Analyses Susquehanna Steam Electric Plant, Units 1 and 2 Docket Nos.: 50-387 and 50-388
-iii-TABLE OF CONTENTS Page LIST OF TABLES.......................................................... vi LIST OF FIGURES......................................................... vii LIST OF APPENDICES viii 1.
INTRODUCTION...................................................... 1 2.
BACKGROUND....................................................... 2 3.
OBJECTIVES........................................................ 4 4.
SUMMARY
OF INFORMATION PROVIDED IN THE LICENSE RENEWAL APPLICATION........................................................ 6 4.1 Aging Management Review Results.................................. 6 4.1.1 AMR Comparison with GALL................................. 7 4.1.2 Aging Management Reviews Crediting Alternative Aging Management Programs.................................... 10 4.2 Time-Limited Aging Analyses...................................... 10 5.
OVERVIEW OF AUDIT, REVIEW, AND DOCUMENTATION PROCEDURE....... 14 5.1 Aging Management Programs..................................... 14 5.2 Aging Management Reviews...................................... 14 5.3 Time-Limited Aging Analyses...................................... 15 5.4 UFSAR Supplement Review...................................... 16 5.5 Documents Reviewed by the Project Team........................... 16 5.6 Status Meeting................................................. 16 5.7 Documentation Prepared by the Project Team
........................ 16 5.7.1 Audit and Review Plan..................................... 16 5.7.2 Worksheets............................................. 16
-iv-Page 5.7.3 Questions............................................... 17 5.7.4 Work Packages.......................................... 17 5.7.5 Requests for Additional Information........................... 17 5.7.6 Audit Summary Report..................................... 17 5.7.7 Safety Evaluation Report Input............................... 17 6.
PLANNING, AUDIT, REVIEW, AND DOCUMENTATION PROCEDURE.......... 18 6.1 Planning Activities.............................................. 18 6.1.1 Schedule for Key Milestones and Activities
..................... 18 6.1.2 Work Assignments........................................ 18 6.1.3 Training and Preparation................................... 19 6.2 Aging Management Program (AMP) Audits and Reviews................ 19 6.2.1 Types of AMPs........................................... 19 6.2.2 Scope of AMP elements to be audited and reviewed.............. 19 6.2.3 AMPs that Are Consistent with the GALL Report................. 20 6.2.4 Plant-Specific AMPs....................................... 22 6.3 Aging Management Review (AMR) Audits and Reviews................. 24 6.3.1 AMRs that Are Consistent with the GALL Report................. 24 6.3.2 AMRs that Are Not Consistent with the GALL Report or Are Not Addressed in the GALL Report............................... 26 6.4 Time-Limited Aging Analyses (TLAA) Audits and Reviews
............... 27 6.4.1 Identify Generic TLAA Issues................................ 27 6.4.2 Metal Fatigue Analyses.................................... 30 6.4.3 Environmental Qualification of Electrical Equipment............... 32 6.4.4 Other Plant-Specific TLAAs................................. 34
-v-Page 6.5 Audit and Safety Review Documentation............................. 36 6.5.1 Audit Summary Report..................................... 36 6.5.2 Safety Evaluation Report Input............................... 37 6.6 Documents Reviewed and Document Retention....................... 42
-vi-LIST OF TABLES Page Table 1. Aging Management Program Element Descriptions......................... 43 Table 2. Notes for License Renewal Application Tables 3.X.2-Y...................... 44
-vii-LIST OF FIGURES Page Figure 1. Audit of AMPs that are Consistent with the GALL Report.................... 45 Figure 2. Audit of Plant-Specific AMPs......................................... 46 Figure 3. Review of AMRs that are Consistent with the GALL Report.................. 47 Figure 4. Review of TLAAs and Exemptions (from NEI 95-10, Revision 6).............. 48
-viii-LIST OF APPENDICES Page APPENDIX A PROJECT TEAM MEMBERSHIP............................ A-1 APPENDIX B RLRC SCHEDULE FOR THE SAFETY REVIEW OF THE LICENSE RENEWAL APPLICATION FOR THE SUSQUEHANNA STEAM ELECTRIC STATION.................................... B-1 APPENDIX C AGING MANAGEMENT PROGRAM ASSIGNMENTS........... C-1 APPENDIX D AGING MANAGEMENT REVIEW ASSIGNMENTS.............. D-1 APPENDIX E TIME-LIMITED AGING ANALYSIS REVIEW ASSIGNMENTS...... E-1 APPENDIX F CONSISTENT WITH GALL REPORT AMP AUDIT/REVIEW WORKSHEET.......................................... F-1 APPENDIX G PLANT-SPECIFIC AMP AUDIT/REVIEW WORKSHEET.......... G-1 APPENDIX H AMR COMPARISON WORKSHEETS........................ H-1 APPENDIX I ACRONYMS AND ABBREVIATIONS.........................
I-1
Audit and Review Plan of the Aging Management Reviews, Aging Management Programs and Time Limited Aging Analyses License Renewal Application for Susquehanna Steam Electric Station, Unit 1 and 2 NRC Docket Nos.: 50-387 and 50-388 1.
INTRODUCTION By letter dated September 13, 2006, (ADAMS Accession Number ML062620157), PPL Susquehanna, LLC (PPL or the applicant), submitted to the U.S. Nuclear Regulatory Commission (NRC) its application for renewal of Operating License Nos. NPF-14 and NPF-22 for the Susquehanna Steam Electric Station (SSES), Units 1 and 2. The applicant requested renewal of the operating licenses for these reactor units for an additional 20 years beyond the 40-year current license term. Operating License No. NPF-14 for SSES, Unit 1, is scheduled to expire on July 17, 2022. Operating License No. NPF-22 for SSES, Unit 2, is scheduled to expire on March 23, 2024.
In support of the staff's safety review of the license renewal application (LRA) for SSES, the Division of License Renewal (DLR), Branch C (RLRC), will lead a project team that will audit and review selected aging management reviews (AMRs) and associated aging management programs (AMPs), and time-limited aging analyses (TLAAs) developed by the applicant to support its LRA for SSES. The project team will include NRC staff and engineers provided by Advanced Technologies and Laboratories International, Inc., (ATL), RLRCs technical assistance contractor. Appendix A, "Project Team Membership," lists the project team members. This document provides the RLRC plan for auditing and reviewing the AMRs, AMPs, and TLAAs that have been docketed in the SSES LRA.
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),
"Requirements for Renewal of Operating Licenses for Nuclear Power Plants; the guidance provided in NUREG-1800, Revision 1, "Standard Review Plan for Review of License Renewal Application for Nuclear Power Plants" (SRP-LR), dated September 2005; the guidance provided in NUREG-1801, Revision 1, "Generic Aging Lessons Learned (GALL) Report," dated September 2005; and this plan. For the scope of work defined in this audit plan, the project team will verify that the applicant's aging management activities and programs will adequately manage the effects of aging on structures and components, so that their intended functions will be maintained consistently with the SSES current licensing basis (CLB) for the period of extended operation.
The project team will perform its work at NRC Headquarters, Rockville, Maryland; at ATL Headquarters, Germantown, Maryland; and at the SSES site. The project team will perform its work in accordance with the schedule shown in Appendix B, "Schedule." This plan includes the following information:
SSES, Units 1 and 2 Audit and Review Plan for AMRs, AMPs, and TLAAs 2
Introduction and background. Summary of the license renewal requirements, as stated in the Code of Federal Regulations, and a summary of the documents that the project team will use to conduct the audit and review process described in this plan.
Objectives. The objectives of the audits and reviews addressed by this plan.
Summary of Information Provided in License Renewal Application.
Description of the information contained in the license renewal application for SSES that is applicable to this plan.
Overview of the Audit, Review, and Documentation Procedure. Summary of the process the project team will follow to audit and review the LRA information that is within its scope of review.
Planning, Audit, Review, and Documentation Procedure. 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.
Appendices. The appendices provide additional information that is relevant to this audit plan. The project 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 Program Assignments," Appendix D, "Aging Management Review Assignments," Appendix E Time-Limited Aging Analysis Review Assignments. Appendices F, G, and H are the worksheets that the individual team members use to informally document the results of their review and audit work. The application of these worksheets is discussed in Section 6 or this plan. Appendix I is a list of the acronyms and abbreviations used in this plan.
2.
BACKGROUND 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 a qualified life or specified time period (long-lived). Pursuant to 10 CFR 54.21(a)(3), an applicant for a renewed license must demonstrate that the effects of aging will be managed such that the
SSES, Units 1 and 2 Audit and Review Plan for AMRs, AMPs, and TLAAs 3
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 management of a large number of SCs that are subject to an AMR. It also summarizes the aging management evaluations, programs, and activities acceptable to the NRC staff for 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. If an applicant commits to implementing these staff-approved AMPs, the time, effort, and resources needed to review an applicant's LRA will be greatly reduced, thereby improving the efficiency and effectiveness of the license renewal review process. The GALL Report identifies (1) systems, structures, and components, (2) component materials, (3) the environments to which the components are exposed, (4) the aging effects associated with the materials & environments, (5) the AMPs that are credited to manage the aging effects, and (6) recommendations for further applicant evaluations of aging effects and their management for certain component types.
The GALL Report is treated in the same manner as an approved topical report that is generically applicable. An applicant may reference the GALL Report in its LRA to demonstrate that its programs correspond to those that the staff reviewed and approved in the GALL Report.
If the material presented in the LRA is consistent with the GALL Report and is applicable to the applicant's facility, the staff will accept the applicant's reference to the GALL Report. In making this determination, the staff considers whether the applicant has identified specific programs described and evaluated in the GALL Report but does not conduct a re-review of the substance of the matters described in the GALL Report. Rather, the staff confirms that the applicant verified that the approvals set forth in the GALL Report apply to its programs.
If an applicant takes credit for a GALL AMP, it is incumbent on the applicant to ensure that the plant AMP contains all the program elements of the referenced GALL AMP. In addition, the conditions at the plant must be bounded by the conditions for which the GALL AMP was evaluated. The applicant must certify in its LRA that it completed the verifications and that they are documented onsite.
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 in accordance with 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. Pursuant to 10 CFR 54.3, TLAAs are those licensee calculations and analyses that:
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- 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.
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 perform its intended function(s), as delineated in 10 CFR 54.4(b).
6.
Are contained or incorporated by reference in the CLB.
Finally, the applicant must demonstrate that the TLAAs remain valid for the period of 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.
OBJECTIVES 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 consistently with the CLB for the Period of extended operation.
The audit and review procedure for SSES is described in Sections 5 and 6 of this plan. It is intended to accomplish the following objectives:
For SSES 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 SSES 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.
SSES, Units 1 and 2 Audit and Review Plan for AMRs, AMPs, and TLAAs 5
For 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 enhancements as commitments in the Updated Final Safety Analysis Report (UFSAR) or other docketed correspondence.
For AMPs that the applicant identifies are plant-specific, assessing whether the program elements of the AMPs are in conformance with the criteria for program elements in Branch Position RLSB-1, and determining whether the AMPs are acceptable on the basis of a technical review.
For AMR items in Table 1s that the applicant claims do not have applicable GALL Report items, determining whether the AMR line items are acceptable on the basis of a technical review.
For AMR item results in Table 1s in which the GALL Report recommends further evaluation, confirming that the applicant has addressed each further evaluation item, evaluating each further evaluation item in accordance with the SRP-LR, and determining whether the AMR items are acceptable on the basis of a technical review.
For AMR item results in Table 2s that the applicant claims are consistent with the GALL Report, verifying that the AMR line items are consistent with the recommendations of the GALL Report.
For AMR item results in Table 2s that the applicant claims are not consistent with the GALL Report or are not addressed by the GALL Report, determining whether the AMR items are acceptable on the basis of a technical review.
For TLAAs, verifying 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 in 10 CFR 54.3. The area relating to the identification of TLAAs is reviewed. TLAAs may have developed since issuance of a plants operating license. As indicated in 10 CFR 54.30, the adequacy of the plants 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.
Confirming 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.
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4.
SUMMARY
OF INFORMATION PROVIDED IN THE LICENSE RENEWAL APPLICATION 4.1 Aging Management Review Results The SSES LRA closely follows the standard LRA format presented in NEI 95-10, "Industry Guideline for Implementing the Requirements of 10 CFR Part 54 - The License Renewal Rule,"
Revision 6, June 2005. Section 3 of the LRA provides the results of the aging management review for structures and components that the applicant identified as being subject to aging management review.
LRA Table 3.0-1, Table 3.0-2, and Table 3.0-3 provide descriptions of the mechanical, structural, and electrical service environments, respectively, used in the AMRs to determine the aging effects requiring management. Results of the AMRs are presented in two 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, in the reactor coolant system subsection of the LRA Section 3, this is Table 3.1.1, and in the engineered safety features subsection of LRA Section 3, this is Table 3.2.1. For ease of discussion, these table types will hereafter be referred to as "Table 1." These tables are derived from the corresponding tables in NUREG-1801, Volume 1, and present summary information from the AMRs.
Definition 1
Reactor Vessel, Internals, and Reactor Coolant System 2
Engineered Safety Features Systems 3
Auxiliary Systems 4
Steam and Power Conversion 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 in Table 3.1.2-1, and the results for the reactor vessel internals are in Table 3.1.2-2. In the engineered safety features subsection, the residual heat removal system results are presented in Table 3.2.2-1, and the core spray system is in Table 3.2.2-2. For ease of discussion, these table types will hereafter be referred to as "Table 2." These tables present the results of the AMRs.
SSES, Units 1 and 2 Audit and Review Plan for AMRs, AMPs, and TLAAs 7
4.1.1 AMR Comparison with GALL The applicant compared the SSES 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, SSES AMR results have been compared with 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 SSES AMR results compare to the AMR items in the corresponding table of NUREG-1801, Volume 1. These tables are essentially the same as Tables 1 through 6 provided in NUREG-1801, Volume 1, with the following exceptions:
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 of cross-referencing to the applicable AMR item in 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-1801 assumptions.
A discussion of how the line item is consistent with the corresponding line item in NUREG-1801, Volume 1, when it may not be intuitively obvious.
A discussion of how the line item is different from the corresponding line item in NUREG-1801, Volume 1, when it may appear to be consistent.
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4.1.1.2 Purpose of Table 2 Table 2 provides results of the AMR items for those structures and components identified in Section 2 as being subject to an aging management review. There is a Table 2 for each system 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.
Each Table 2 consists of the following nine columns:
Component Type Column 1 identifies the component types from Section 2 of this application that are subject to an 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 subgroups.
For the SSES LRA, mechanical components are grouped, where practical, by component type.
For example valves are evaluated as a component group. Unique mechanical components such as pumps, tanks, and heat exchangers, are individually evaluated.
SSES piping is evaluated as a component group and includes components that form part of the piping boundary such as fittings, couplings, reducers, elbows, thermowells, flanges, and welded attachments. Piping components such as tubing, expansion joints, and orifices are typically broken out into their own component groups based on materials and function.
SSES bolting is treated as a component group and includes components such as bolts, studs, nuts, and washers.
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. Internal/external 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 Requiring Management
SSES, Units 1 and 2 Audit and Review Plan for AMRs, AMPs, and TLAAs 9
Column 5 lists the aging effects requiring management for material and environment combinations for each component type.
Aging Management Programs (AMP)
Column 6 lists the programs used to manage the aging effects requiring management.
NUREG-1801, Vol. 2, Item Column 7 documents identified consistencies by noting the appropriate NUREG-1801, Volume 2, item number. If there is no corresponding item number in NUREG-1801, Volume 2, for a particular combination of factors, column 7 is left blank.
Each combination of the following factors listed in Table 2 is compared to NUREG-1801, Volume 2, to identify consistencies:
Component type.
Material.
Environment.
Aging effect requiring management.
Aging management program.
Table 1 Item Column 8 lists the corresponding line item from Table 1. If there is no corresponding item in NUREG-1801, 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-1801, Volume 2. Notes that use letter designations are standard notes based on a letter from A. Nelson, NEI, to P. T. Kuo, NRC, U.S. Nuclear Industrys Proposed Standard License Renewal Application Format Package, Request NRC Concurrence, dated January 24, 2003 (ML030290201). The staff concurred with the NEI standardized format for license renewal applications by letter dated April 7, 2003, from P. T. Kuo, NRC, to A. Nelson, NEI (ML030990052). Notes that use numeric designators are specific to SSES.
SSES LRA Table 2 contains the aging management review results and indicates whether the
SSES, Units 1 and 2 Audit and Review Plan for AMRs, AMPs, and TLAAs 10 results correspond to line items in Volume 2 of the GALL Report. Correlations between the combination SSES LRA Table 2 and a combination for a line item in Volume 2 of the GALL Report are identified by the GALL Report item number in Column 7. If Column 7 is blank, the applicant did not identify a corresponding combination in the GALL Report. If the applicant identified a GALL Report line item, the next column provides a reference to a Table 1 row number. This reference corresponds to the GALL Report, Volume 2, roll-up to the GALL Report, Volume 1, tables.
4.1.2 Aging Management Reviews Crediting Alternative Aging Management Programs The SSES LRA includes a number of AMRs which the applicant credits a different AMP from that recommended in the GALL Report. In these cases, the applicant considers the SSES evaluation to be consistent with the GALL Report if the other elements are consistent. Any appropriate AMP is considered to be an acceptable alternative to the GALL program if the applicant can demonstrate that the AMP will adequately manage the aging effect listed in the AMR item. Note E is used designate these AMR items.
4.2 Time-Limited Aging Analyses The SSES LRA closely follows the standard LRA format presented in Revision 6 of NEI 95-10, Industry Guidelines for Implementing the Requirements of 10 CFR Part 54 - The License Renewal Rule. Section 4 of the SSES LRA addresses time-limited aging analyses. In Section 4.1.1, the SSES 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.
Quality Assurance Program G.
Operating Licenses H.
Design Calculations and Design Reports I.
Inservice Inspection Program J.
Code Exemption Requests and Relief Requests K.
Industry Documents, including NUREG-1800, Revision 1, NUREG-1801, Revision 1, and NEI 95-10.
In Section 4.1, the SSES LRA states that as required by 10 CFR 54.21(c)(1), an evaluation of SSES-specific time-limited aging analyses must be performed to demonstrate that:
A.
The analyses remain valid for the period of extended operation in accordance with 10 CFR 54.21(c)(1)(i);
B.
The analyses have been projected to the end of the period of extended operation, in accordance with 10 CFR 54.21(c)(1)(ii); or
SSES, Units 1 and 2 Audit and Review Plan for AMRs, AMPs, and TLAAs 11 C.
The effects of aging on the intended functions(s) will be adequately managed for the Period of extended operation, in accordance with 10 CFR 54.21(c)(1)(iii).
In the SSES LRA, the applicant summarized the results of the above evaluations in Table 4.1-1.
These evaluations are discussed in subsequent sections of SSES LRA Section 4.
Following the section identifying the TLAAs, the SSES 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 SSES performed this by reviewing SSES docketed correspondence which identified SSES exemptions. The results of this review determined that no SSES exemptions depend on TLAAs.
The SSES LRA next includes a separate section for each of the identified TLAAs within the outline of the corresponding NUREG-1800 TLAA category. The TLAA categories are outlined in the next table.
TLAA Description Resolution Option Section Reactor Vessel Neutron Embrittlement Analyses 4.2 Neutron Fluence Not a TLAA, but the information in the LRA is needed to support TLAAs in LRA Sections 4.2.2 ! 4.2.7 4.2.1 Upper Shelf Energy (USE)
Analyses projected for the Period of extended operation -
10 CFR 54.21(c)(1)(ii) 4.2.2 Adjusted Reference Temperature (ART)
Analyses projected for the Period of extended operation -
10 CFR 54.21(c)(1)(ii) 4.2.3 Pressure-Temperature (P-T) Limits Analyses projected for the Period of extended operation -
10 CFR 54.21(c)(1)(ii) 4.2.4 Reactor Vessel Circumferential Weld Examination Relief Analyses projected for the Period of extended operation -
10 CFR 54.21(c)(1)(ii) 4.2.5 Reactor Vessel Axial Weld Failure Probability Analyses projected for the Period of extended operation -
10 CFR 54.21(c)(1)(ii) 4.2.6 Reflood Thermal Shock Analysis remains valid for Period of extended operation -
10 CFR 54.21(c)(1)(i) 4.2.7
SSES, Units 1 and 2 Audit and Review Plan for AMRs, AMPs, and TLAAs TLAA Description Resolution Option Section 12 Metal Fatigue Analyses 4.3 Reactor Pressure Vessel Fatigue Analyses Effects of aging will be managed for the Period of extended operation - 10 CFR 54.21(c)(1)(iii) 4.3.1 Reactor Vessel Internals Fatigue Analyses Analyses projected for the Period of extended operation -
10 CFR 54.21(c)(1)(ii), or Effects of aging will be managed for the Period of extended operation - 10 CFR 54.21(c)(1)(iii) 4.3.2 Effects of Reactor Coolant Environment on Fatigue Life of Components and Piping (GSI-190)
Effects of aging will be managed for the Period of extended operation - 10 CFR 54.21(c)(1)(iii) 4.3.3 Reactor Coolant Pressure Boundary Piping and Component Fatigue Analyses Effects of aging will be managed for the Period of extended operation - 10 CFR 54.21(c)(1)(iii) 4.3.4 Non-Class 1 Component Fatigue Analyses Analysis remains valid for Period of extended operation -
10 CFR 54.21(c)(1)(i) 4.3.5 Environmental Qualification Analyses for Electrical Equipment Effects of aging will be managed for the Period of extended operation - 10 CFR 54.21(c)(1)(iii) 4.4 Concrete Containment Tendon Prestress Not Applicable to SSES 4.5 Containment Liner Plate, Metal Containment, and Penetrations Fatigue Analyses 4.6 ASME Class MC Components Analysis remains valid for Period of extended operation -
10 CFR 54.21(c)(1)(i) 4.6.1 Downcomer Vents and SRV Discharge Piping Analysis remains valid for Period of extended operation -
10 CFR 54.21(c)(1)(i) 4.6.2 Safety Relief Valve Quenchers Analysis remains valid for Period of extended operation -
10 CFR 54.21(c)(1)(i) 4.6.3
SSES, Units 1 and 2 Audit and Review Plan for AMRs, AMPs, and TLAAs TLAA Description Resolution Option Section 13 Other TLAA 4.7 Main Steam Line Flow Restrictor Erosion Analysis Analysis projected for the Period of extended operation -
10 CFR 54.21(c)(1)(ii) 4.7.1 High Energy Line Break Cumulative Fatigue Usage Factors Effects of aging will be managed for the Period of extended operation - 10 CFR 54.21(c)(1)(iii) 4.7.2 Core Plate Rim Hold Down Bolts Analysis projected for the Period of extended operation -
10 CFR 54.21(c)(1)(ii) 4.7.3 Additional TLAAs may be added to the scope of the SSES LRA as a result of the NRCs request for additional information process and the applicants LRA amendment process.
SSES, Units 1 and 2 Audit and Review Plan for AMRs, AMPs, and TLAAs 14 5.
OVERVIEW OF AUDIT, REVIEW, AND DOCUMENTATION PROCEDURE 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 SSES AMPs for which the applicant claimed consistency with the AMPs included in the GALL Report, the project team will review the SSES AMP descriptions and compare program elements for the SSES AMPs to the corresponding program elements for the GALL AMPs. The project team will verify that the SSES AMPs contain the program elements of the referenced GALL program and that the conditions at the plant are bounded by the conditions for which the GALL program was evaluated. The Division of Engineering will review and determine the adequacy of the applicants 10 CFR 50, Appendix B Program. Other aspects of these program elements will be reviewed by the project team.
For SSES AMPs that have one or more exceptions or enhancements, the project team will review each exception or enhancement to determine whether the exception or enhancement is acceptable, and whether the AMP, as modified by the exception or the enhancement, would adequately manage the aging effects for which it is credited. In some cases, the project team will identify additional differences from the program attributes of the corresponding GALL AMPs that the applicant did not identify in the LRA. In these cases, the project team will review any additional differences to determine whether the SSES AMP can adequately manage the aging effects for which it is credited or whether additional commitments on the AMP are necessary to ensure adequate aging management.
For those SSES AMPs that are not included in the GALL Report (i.e., plant-specific AMPs), the project team will review the AMP against the ten program elements defined in Appendix A of the SRP-LR. The Division of Engineering will review and determine the adequacy of the applicants 10 CFR 50, Appendix B Program. Other aspect of these program elements will be reviewed by the project team. On the basis of its reviews, the project team will determine whether these AMPs will manage the aging effects for which they are credited.
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 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
SSES, Units 1 and 2 Audit and Review Plan for AMRs, AMPs, and TLAAs 15 addressed the issues for which the GALL Report recommended further evaluation.
5.3 Time-Limited Aging Analyses and Exemptions The TLAAs in the SSES LRA fall into the broad category of those that are consistent with the NUREG-1800 TLAA categories. The applicant did not identify any SSES exemptions that are based on TLAAs.
For its TLAA reviews, the project team will determine if the applicant had provided adequate information to meet the TLAA acceptance requirements of 10 CFR 54.21(c)(1) and the exemption identification requirements of 10 CFR 54.21(c)(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.
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 perform its intended functions, as delineated in 10 CFR 54.4(b).
6.
Contained or incorporated by reference in the CLB.
In addition, the project team will also review the TLAAs to determine if there are 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 project team expertise, past precedent, and complexity of the provided analysis. Candidates for further review by technical specialists could be such as the following:
SSES, Units 1 and 2 Audit and Review Plan for AMRs, AMPs, and TLAAs 16 A.
Reactor Vessel Neutron Embrittlement Analyses (LRA Section 4.2 and its subsections)
B.
Main Steam Line Flow Restrictor Erosion Analysis (LRA Section 4.7.1) 5.4 UFSAR Supplement Review Consistent with the SRP-LR, for the AMPs and TLAAs that are subject to the project teams review, the project team will review the UFSAR supplement that summarizes the applicant's AMPs and TLAAs for the period of extended operation. The project team will also review any commitments associated with these AMPs or TLAAs made by the applicant and verify that the commitments are acceptable for their intended purposes.
5.5 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 activities and programs will adequately manage the effects of aging on structures and components.
5.6 Status Meeting At the conclusion of its audits and reviews, the project team will debrief the applicant's license renewal staff and management regarding the status of the audits and reviews of the LRA AMPs, AMRs and TLAAs assigned to the project team.
5.7 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 summary, 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.
5.7.1 Audit and Review Plan The project team leader will prepare a plant-specific audit and review plan as described herein.
5.7.2 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 F, "Consistent with GALL Report AMP Audit/Review Worksheet," Appendix G, "Plant-Specific AMP Audit/Review Worksheet," and Appendix H, "Aging Management Review Comparison Worksheets." The use of the worksheets is described in Section 6 of this plan.
SSES, Units 1 and 2 Audit and Review Plan for AMRs, AMPs, and TLAAs 17 5.7.3 Questions As specified in Section 6 of this plan, the project team members will ask the applicant questions during the on-site audits, as appropriate, to facilitate its audit and review activities. The team will also track the applicant's answers to the questions.
5.7.4 Work Packages After each site visit, the project team leader, in conjunction with the project manager, will assemble work packages for any work that the team will refer to the NRR Division of Engineering (DE) or the Division of Component Integrity (DCI) 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.
5.7.5 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 LRA and explanations as to where particular information may be found in the LRA or its associated documents. Nevertheless, there may be occasions where an RAI is appropriate to obtain information to support a SER finding. The need for RAIs will be determined by the project team leader during the in-office project staff review or during 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 SER input.
5.7.6 Audit Summary Report At the conclusion of the audits and reviews, the project team will prepare a summary of the audits and reviews highlighting the status of its review and any potential RAIs.
5.7.7 Safety Evaluation Report Input The project team will prepare a SER input based on the results of the project teams audits and reviews. Section 6.5.2 of this audit plan provides a more detailed discussion of the staffs criteria for formatting and writing the contents for SER inputs.
SSES, Units 1 and 2 Audit and Review Plan for AMRs, AMPs, and TLAAs 18 6.
PLANNING, AUDIT, REVIEW, AND DOCUMENTATION PROCEDURE 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 Preparing the audit and review plan Scheduling site visits Scheduling in-office review periods Preparing questions Preparing RAIs Preparing the draft and final audit and review summaries Preparing the draft and final SER inputs 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 and the project team leader will develop assignment tables that designate project team assignments for each AMP, AMR table, and TLAA in the LRA. Appendix A of this audit plan shows the project team membership. Appendix C shows the project team assignments for the AMPs. Appendix D of this audit plan shows the project team assignments for the AMRs. Appendix E of this audit plan shows the project team assignments for the TLAAs.
SSES, Units 1 and 2 Audit and Review Plan for AMRs, AMPs, and TLAAs 19 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.
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.
RAIs, audit reports, and SERs for other plants 10.
Applicant's UFSAR 11.
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 NRC technical reviewers.
6.2 Aging Management Program (AMP) Audits and Reviews 6.2.1 Types of AMPs There are two types (classifications) of AMPs in the LRA: (1) AMPs that the applicant claims are consistent with the GALL Report, and (2) AMPs that the applicant claims are not consistent with the GALL Report or are not addressed in the GALL Report (i.e., plant-specific AMPs). The process for auditing and reviewing these types of AMPs is discussed in Section 6.3 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 the same program elements as those recommended for LRAs in Branch Technical Position (BTP) RLSB-1, "Aging Management Review - Generic." This branch position is provided in Appendix A of the SRP-LR.
The program elements for the AMPs in the LRA are based on these program elements.
SSES, Units 1 and 2 Audit and Review Plan for AMRs, AMPs, and TLAAs 20 The project team will audit the following program elements for the AMPs that are credited in the LRA for aging management: (1) Scope of Program, (2) Preventative Actions, (3) Parameters Monitored or Inspected, (4) Detection of Aging Effects, (5) Monitoring and Trending, (6) Acceptance Criteria, and (10) Operating Experience. License Renewal Branch B will review and determine the adequacy of the program elements by comparing them to the criteria used to establish the applicants 10 CFR 50, Appendix B, Quality Assurance Program: (7) Corrective Actions, (8) Confirmation Process, and (9) Administrative Controls.
6.2.3 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 SSES AMP program elements are consistent with the corresponding elements of the GALL Report AMP by answering the following questions and then following the process shown in Figure 1.
1.
Did the applicant identify any exceptions to the GALL Report AMP?
2.
Did the applicant identity any enhancements to the GALL Report AMP?
3.
Are the elements consistent with the GALL Report AMP?
B.
If either of the above questions results in the identification of an exception/enhancement or a difference to the GALL AMP, determine whether it is acceptable on the basis of an "adequate technical justification."
SSES, Units 1 and 2 Audit and Review Plan for AMRs, AMPs, and TLAAs 21 C.
If an acceptable basis exists for an exception/enhancement or difference, document the basis in the worksheet and in the SER input.
D.
Review the industry and plant-specific operating experience associated with the AMP. The review is to identify aging effects requiring management that are not identified by the industry guidance documents (such as EPRI tools) and to confirm the effectiveness of aging management programs. The project team members should consider the industry guidance when assessing operating experience and formulating questions for the applicant. The industry guidance (from NEI 95-10, Revision 6) is as follows:
1.
Plant-Specific Operating Experience with Aging Effects Requiring Management. 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. Differences with previously documented industry experience such as new aging effects or lack of aging effects allow consideration of plant-specific aging management requirements.
2.
Plant-Specific Operating Experience with existing Aging Management Programs. The operating experience of AMPs, including corrective actions resulting in program enhancements or additional programs, should be considered. The review should provide objective evidence to support the conclusion that the effects of aging will be managed so that the intended function(s) will be maintained during the extended period of operation. Guidance for reviewing industry operating experience is presented in BTP RLSB-1 in Appendix A.1 of the Branch Technical Positions in NUREG-1800.
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-1801 should be evaluated and documented as part of the aging management review. In particular, generic communications such as a bulletin, a generic letter, or an information notice should be evaluated for impact upon the AMP. The evaluation should check for new aging effects or a new component or location experiencing an already identified aging effect.
E.
If it is necessary to ask the applicant a question to clarify the basis for accepting a program element, or an exception or a difference to the GALL Report AMP, follow the logic process shown in Figure 1.
F.
If it is necessary for the applicant to submit additional information to support the basis for accepting the justification, an exception, or a difference to a program
SSES, Units 1 and 2 Audit and Review Plan for AMRs, AMPs, and TLAAs 22 element, the applicant may agree to voluntarily submit the required information as a supplement (docketed letter submitted under oath and affirmation) to the LRA. If not, the NRC may issue an RAI to obtain the information.
AMP audit worksheets Document the audit and review results using the worksheet provided in Appendix F, "Consistent with GALL Report AMP 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 preparation 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 SSES 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)
SSES, Units 1 and 2 Audit and Review Plan for AMRs, AMPs, and TLAAs 23 is as follows:
1.
Plant-Specific Operating Experience with Aging Effects Requiring Management. The review should assess the operating and maintenance history. A review of the prior 5 to 10 years of operating and maintenance history should be sufficient. The results of the review should confirm consistency with documented industry operating experience. Differences with previously documented industry experience such as new aging effects or lack of aging effects allow consideration of plant-specific aging management requirements.
2.
Plant-Specific Operating Experience with Aging Management Programs.
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 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-1801 should be evaluated and documented as part of the aging management review. In particular, generic communications such as a bulletin, a generic letter, or an information notice should be evaluated for impact upon the AMP. The evaluation should check for new aging effects or a new component or location experiencing an already identified aging effect.
C.
If it is necessary to ask the applicant a question, follow the process shown in Figure 2.
E.
If it is necessary for the applicant to submit additional information to resolve a question 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 G, "Plant-Specific AMP Audit/Review Worksheet."
SSES, Units 1 and 2 Audit and Review Plan for AMRs, AMPs, and TLAAs 1
The AMR line item letter notes are based on a letter from A. Nelson, NEI, to P. T. Kuo, NRC, "U.S. Nuclear Industry's Proposed Standard License Renewal Application Format Package, Request NRC Concurrence," dated January 24, 2003 (ML030290201). The staff concurred 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).
24 6.3 Aging Management Review (AMR) Audits and Reviews There are two classifications of AMRs: (1) those AMRs that the applicant claims are consistent with the GALL Report, and (2) those that are not consistent with the GALL Report or are not addressed in the GALL Report. The basis for reviewing these AMR classifications are discussed below.
6.3.1 AMRs that Are Consistent with the GALL Report 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 SSES 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 SSES AMRs.
C.
Identify the documents needed to perform the 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.1 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
SSES, Units 1 and 2 Audit and Review Plan for AMRs, AMPs, and TLAAs 2
Some GALL AMRs reference the use of a plant-specific AMP. In such cases the AMR audit requires the project team member to confirm that the plant-specific AMP is appropriate to manage the aging effects during the period of extended operation.
25 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: For each 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 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 Report for the elements associated with its note.
2.
If Note A applies and the applicant uses a plant-specific AMP2, determine if the component is within the scope of the cited plant AMP. If the component is within the scope of the plant-specific 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. If Note D applies, also review the LRA exceptions and document the basis for acceptance in the worksheet, and later in the audit and review report. If not acceptable, go to Step (7) below.
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)(3). If it does not, go to Step (7) below.
6.
Review the corresponding LRA Table 3.X.1 entry that is referenced in LRA Table 3.X.2.Y. If applicable, determine whether the applicant's "Further Evaluation Recommended" response in LRA Section 3.X.2.2.Z is enveloped by Section 3.X.2.2.Z of the SRP-LR. If not, go to Step (7) below. If the LRA section does not meet the acceptance criteria of
SSES, Units 1 and 2 Audit and Review Plan for AMRs, AMPs, and TLAAs 26 Appendix A of the SRP-LR, go to Step (7) below.
7.
If during the review a difference is identified, prepare a question to the applicant, 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.
b.
If the 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. If it appears acceptable, re-start the audit/review for the AMR line item from Step (1) above.
c.
If it is necessary for the applicant to submit additional information to resolve 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 if docketed information may be needed.
8.
Review 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.
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 reviews the applicant's evaluation to determine if it adequately addressed the issues for which the GALL Report recommended further evaluation, specifically that the applicant has addressed the further evaluation and has evaluated the AMRs in accordance with the SRP-LR Sections 3.X.2.2 and 3.X.3.2 AMR audit/review worksheets Document the audits/reviews of plant AMRs using the worksheet provided in Appendix H, "Aging Management Review Comparison Worksheets."
6.3.2 AMRs that Are Not Consistent with the GALL Report or Are Not Addressed in the GALL Report Review LRA Tables 3.X.2.1 - X (Table 2s) for LRA Sections 3.1 thru 3.6, where the applicant indicated, via Notes F through J, that the combination of component type, material, environment, and AERM does not correspond to a line item in the GALL Report. Specifically, Note F indicates that the material for the AMR line item component is not evaluated in the GALL Report. Note G indicates that the environment for the AMR line item component and material is not evaluated in the GALL Report. Note H indicates that the aging effect for the AMR line item
SSES, Units 1 and 2 Audit and Review Plan for AMRs, AMPs, and TLAAs 27 component, material, and environment combination is not evaluated in the GALL Report. Note I indicates that the aging effect identified in the GALL Report for the line item component, material, and environment combination is not applicable. Note J indicates that neither the component nor the material and environment combination for the line item is evaluated in the GALL Report. For component groups not evaluated in the GALL Report (notes F-J), the project team reviews the applicant's evaluation in accordance with the acceptance criteria described in Branch Technical Position RLSB-1 (Appendix A.1 of the SRP-LR). If during the review a difference is identified, prepare a question to the applicant, in order to obtain clarification.
Review the applicant's response to the question and confirm that acceptance criteria specified in Appendix A.1 of the LRA are met.
The AMR review involves verification that the applicant has satisfied the requirements of 10 CFR 54.21(a)(3). This requirement states: For each 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 intended function(s) will be maintained consistent with the CLB for the period of extended operation.
6.4 Time-Limited Aging Analyses (TLAA) Audits and 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 Division of Component Integrity (DCI) or the Division of Engineering (DE). In general, the project team will review TLAAs that are for which the applicant claims consistency with 10 CFR 54.21(c)(i) the analyses remain valid for the period of extended operation. or 10 CFR 54.21(c)(iii) the effects of aging on the intended function(s) will be adequately managed for the period of extended operation. For TLAAs for which the applicant claims consistency with 10 CFR 54.21(c)(ii) - the analyses have been projected to the end of the period of extended operation, the audit team leader will be consulted to determine which TLAAs the audit team will be capable of reviewing. Consideration should be given to team expertise, past precedent, and complexity of the provided analysis.
6.4.1 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 TLAA that the applicant identifies.
Pre-Review Preparation A.
For the SSES 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-1800 and identify those that will be audited/reviewed in conjunction with each of the SSES TLAAs.
SSES, Units 1 and 2 Audit and Review Plan for AMRs, AMPs, and TLAAs 28 C.
Review the list of the SSES 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.
D.
Identify and locate the documents needed to perform the review. These may include, but are not limited to, the following:
1.
Excel database on TLAAs summarizing how earlier LRAs and SERs were 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
- 11.
Implementation documents
- 12.
Operating experience reports (plant-specific and industry)
- 13.
Lessons learned developed by RLRC
- 14.
Applicants 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 Division of Component Integrity (DCI) or the Division of Engineering (DE).
This is not expected to be an issue for TLAAs for which the applicant claims consistency with 10 CFR 54.21(c)(i) the analyses remain valid for the period of extended operation or 10 CFR 54.21(c)(iii) the effects of aging on the intended function(s) will be adequately managed for the period of extended operation.
For TLAAs for which the applicant claims consistency with 10 CFR 54.21(c)(ii) -
the analyses have been projected to the end of the period of extended operation, the audit team leader will be consulted to determine which TLAAs the audit team will be capable of reviewing. Consideration should be given to team expertise, past precedent, and complexity of the provided analysis. Candidates for further review by technical specialists could be such as the following:
1.
Reactor Vessel Neutron Embrittlement Analysis (SSES LRA Section 4.2) 2.
TLAAs in BWRVIPs 05 and 74 (SSES LRA Section 4.7.3)
Audit/Review A.
Confirm that each SSES TLAA listed in this section is appropriate. Refer to any analyses and evaluations created during the acceptance review process.
SSES, Units 1 and 2 Audit and Review Plan for AMRs, AMPs, and TLAAs 29 B.
If a TLAA is listed in the SRP-LR or NEI 95-10 and not in its LRA, the SSES 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 identification of the results of the time-limited aging analysis review, which may be provided in tabular form, may reference the section in the Integrated Plant Assessment-Aging Management Review chapter where more details of the actual review and disposition (as required by §54.21(c)(1)(i)-(iii)) are located.
2.
The application shall include a demonstration that (1) the analyses remain valid 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 (Appendix A).
D.
If it is necessary to ask the applicant a question to clarify the basis for their analyses, follow the logic process shown in Figure 5 of this audit and review plan.
E.
If it is necessary for the applicant to submit additional information to support the 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 SSES LRA. If not, the NRC may issue an RAI to obtain the information.
SSES, Units 1 and 2 Audit and Review Plan for AMRs, AMPs, and TLAAs 30 6.4.2 Metal Fatigue Analyses Figure 5, Evaluation of TLAAs and Exemptions, 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 TLAA that the applicant identifies.
Pre-Review Preparation A.
The project team will determine if the TLAAs identified in the SSES LRA to be within the NUREG-1800 TLAA category of metal fatigue have provided adequate information to meet the requirements of 10 CFR 54.21(c)(1) and 10 CFR 54.21(c)(2).
B.
Identify and locate the documents needed to perform the review. These may include, but are not limited to, the following:
1.
Excel database on TLAAs summarizing how earlier LRAs and SERs presented 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.
Applicants UFSAR C.
In addition, the project team will also review the SSES TLAAs within 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 Division 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.
SSES, Units 1 and 2 Audit and Review Plan for AMRs, AMPs, and TLAAs 31 Audit/Review A.
Confirm that each SSES TLAA listed in this section is appropriate. Refer to any analyses and evaluations created during the acceptance review process.
B.
If a TLAA is listed in the SRP-LR or NEI 95-10 and not in its LRA, the SSES 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.
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 perform its intended functions, as delineated in 10 CFR 54.4(b).
6.
Contained or incorporated by reference in the CLB.
D.
The project team will ascertain that the SSES 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.
SSES, Units 1 and 2 Audit and Review Plan for AMRs, AMPs, and TLAAs 32 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 SSES LRA. If not, the NRC may issue an RAI to obtain the information.
6.4.3 Environmental Qualification of Electrical Equipment Figure 5, Evaluation of TLAAs and Exemptions, 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 TLAA that the applicant identifies.
Pre-Review Preparation A.
The project team will determine if the TLAAs identified in the SSES LRA to be within the NUREG-1800 TLAA category of environmental qualification of electric equipment have provided adequate information to meet the requirements of 10 CFR 54.21(c)(1) and 10 CFR 54.21(c)(2).
B.
Identify and locate the documents needed to perform the review. These may include, but are not limited to, the following:
1.
Excel database on TLAAs summarizing how earlier LRAs and SERs presented and reviewed TLAAs 2.
GALL Report, especially Section X.E1 3.
SRP-LR 4.
ISG-LR 5.
RAIs, audit and review reports, and SERs for similar plants 6.
LRA 7.
References listed by applicant for each TLAA 8.
NEI 95-10, Section 5.1 and Table 6.2-2 9.
Basis documents 10.
Implementation documents
- 11.
Operating experience reports (plant-specific and industry)
- 12.
Lessons learned developed by RLRC
- 13.
Applicants UFSAR C.
In addition, the project team will also review the SSES TLAAs within the NUREG-1800 TLAA category of environmental qualification of electric equipment to determine if there are emerging issues that should be further evaluated by technical specialists in the NRC Division 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
SSES, Units 1 and 2 Audit and Review Plan for AMRs, AMPs, and TLAAs 33 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 SSES TLAA listed in this section is appropriate. Refer to any analyses and evaluations created during the acceptance review process.
B.
If a TLAA is listed in the SRP-LR or NEI 95-10 and not in its LRA, the SSES 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.
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 perform its intended functions, as delineated in 10 CFR 54.4(b).
6.
Contained or incorporated by reference in the CLB.
D.
The project team will ascertain that the SSES 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 environmental qualification of electric
SSES, Units 1 and 2 Audit and Review Plan for AMRs, AMPs, and TLAAs 34 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 SSES LRA. If not, the NRC may issue an RAI to obtain the information.
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 TLAA that the applicant identifies.
Pre-Review Preparation A.
The project team will determine if the TLAAs identified in the SSES LRA to be within the NUREG-1800 TLAA category of other plant-specific TLAAs have provided adequate information to meet the requirements of 10 CFR 54.21(c)(1) and 10 CFR 54.21(c)(2).
B.
Identify and locate the documents needed to perform the review. These may include, but are not limited to, the following:
1.
Excel database on TLAAs summarizing how earlier LRAs and SERs presented and reviewed TLAAs 2.
GALL Report 3.
SRP-LR 4.
ISG-LR 5.
RAIs, audit and review reports, and SERs for similar plants 6.
LRA 7.
References listed by applicant for each TLAA 8.
NEI 95-10, Section 5.1 and Table 6.2-2 9.
Basis documents 10.
Implementation documents 11.
Operating experience reports (plant-specific and industry)
SSES, Units 1 and 2 Audit and Review Plan for AMRs, AMPs, and TLAAs 35 12.
Lessons learned developed by RLRC
- 13.
Applicants UFSAR C.
In addition, the project team will also review the SSES TLAAs within 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 Division 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 SSES TLAA listed in this section is appropriate. Refer to any analyses and evaluations created during the acceptance review process.
B.
If a TLAA is listed in the SRP-LR or NEI 95-10 and not in its LRA, the SSES 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.
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 perform its intended functions, as delineated in 10 CFR 54.4(b).
6.
Contained or incorporated by reference in the CLB.
SSES, Units 1 and 2 Audit and Review Plan for AMRs, AMPs, and TLAAs 36 D.
The project team will ascertain that the SSES 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 SSES LRA. If not, the NRC may issue an RAI to obtain the information.
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 summary, and a SER input. This section of the plan addresses the preparation of the audit and review summary and the SER input.
6.5.1 Audit and Review Summary The project team should prepare an audit and review summary upon completion of the on-site audits and reviews of the AMPs, AMRs, and TLAAs assigned to the project team. This summary should provide the following information:
- Members who participated in the on-site audits,
- Dates and location of the audits
- Guidance documents used for the review
- Activities performed
- Documents reviewed
- Availability of question and answer database
- Status of the review
SSES, Units 1 and 2 Audit and Review Plan for AMRs, AMPs, and TLAAs 3
AMRs that are not consistent with the GALL Report.
37 6.5.2 Safety Evaluation Report Input A.
General guidance 1.
Each project team member should prepare the SER input for the AMP AMR, and TLAA 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 question and answer database and the team member's worksheets.
3.
SER inputs are to be prepared for:
a.
Each AMP that was determined to be consistent with the GALL Report, 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.
AMR results that are consistent with the GALL Report (including AMRs that are designated in the LRA as Footnote E AMRs).
e.
AMR results that are consistent with the GALL Report for which further evaluation is recommended.
f.
AMR results that are not consistent with the GALL Report or are not addressed in the GALL Report.3 g.
Each TLAA assigned to the project team for review 4.
The SER input will 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 3.0.1 Format of the LRA
SSES, Units 1 and 2 Audit and Review Plan for AMRs, AMPs, and TLAAs 4
The LRA AMR results are broken down into six sections and address the following system/structure groups: (1) Section 3.1, reactor vessel, internals and reactor coolant system, (2) Section 3.2, engineering safety features systems, (3) Section 3.3, auxiliary systems, (4)
Section 3.4, steam power and conversion systems, (5) Section 3.5, structures and component supports, (6) Section 3.6, electrical and instrumentation and controls.
38 3.0.1.1 Overview of Table 1s 3.0.1.2 Overview of Table 2s 3.02 Staff's Review Process 3.0.2.1 Review of AMPs 3.0.2.2 Review of AMR Results 3.0.2.3 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.X4 Aging Management of_____
3.X.1 Summary of Technical Information in the Application 3.X.2 Staff Evaluation 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 4.0 Time-Limited Aging Analyses 4.1 Identification of Time-Limited Aging Analyses
SSES, Units 1 and 2 Audit and Review Plan for AMRs, AMPs, and TLAAs 39 4.3 Metal Fatigue (including its Subsections) 4.4 Environmental Qualification of Electrical Equipment 4.6 Containment Liner Plate, Metal Containment, and Penetrations Fatigue Analyses (including its subsections) 4.7 Other Plant-Specific Time-Limited Aging Analyses 4.7.1, Main Steam Flow Restrictor Erosion Analyses 4.7.2, High Energy Line Break Cumulative Fatigue Usage Factors 4.7.3, Core Plate Rim Hold-down Bolts 4.8 Conclusion for Time-Limited Aging Analyses 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.
If the 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.
If an RAI was issued, identify the RAI number and briefly discuss the RAI.
State if the RAI remains open or if the applicant response has been received and accepted. If the response was acceptable, identify the submittal (including the date and the ADAMS accession number) that provided the response and document the basis for its acceptance.
8.
Issues (e.g., RAIs) that have not been resolved by the applicant at the time the SER input 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 paragraph number, 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.
SSES, Units 1 and 2 Audit and Review Plan for AMRs, AMPs, and TLAAs 5
The audit results documented in this section address the AMRs consistent with the GALL Report for which no further evaluation is recommended.
40 3.
For plant-specific AMPs, the SER input should document the basis for accepting each of the ten elements reviewed by the project team. The SER input should also include a discussion concerning the adequacy of the UFSAR supplement.
4.
For aging management evaluations that are consistent with the GALL Report,5 the SER input should include the following:
a.
Identify the LRA section reviewed.
b.
A summary of the type of information provided in the section of the LRA reviewed, including a listing of the AMPs reviewed.
c.
Identify the LRA Tables 3.X.2-Y reviewed.
d.
A summary review of the AMR Notes A through E used to classify the AMR 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
SSES, Units 1 and 2 Audit and Review Plan for AMRs, AMPs, and TLAAs 6
This section documents reviews of AMRs assigned to the project team that are not consistent with the GALL Report.
41 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.
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.
6.
Staff AMR Review Results.6 This section of the SER input documents the reviews of AMR results assigned to the project team that are not consistent with the GALL Report or are not addressed in the GALL Report. The SER input documents the following aspects of the review, based on a precedent identified by the applicant:
a.
The LRA section reviewed.
b.
A summary of the type of information provided in the section of the LRA, reviewed, including a listing of the AMPs reviewed for this LRA section.
c.
Identify the LRA Tables 3.X.2-Y documented by this audit writeup.
d.
A brief summary of what the staff (project team) reviewed (i.e.,
LRA and applicant basis documents and other implementation documents).
e.
A finding that verifies, if true, that:
The applicant identified the applicable aging effects.
The applicant listed the appropriate combination of materials and environments.
The applicant specified acceptable AMPs.
SSES, Units 1 and 2 Audit and Review Plan for AMRs, AMPs, and TLAAs 42 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.
7.
TLAA Reviews - This section of the SER input documents the reviews of TLAAs assigned to the project team. The SER input should include the following:
- a.
Summary of technical information in the application
- b.
Staff evaluation:
(i) Regulatory basis (ii) Scope of review and technical evaluation c.
UFSAR supplement review - stating, if applicable, that the applicant has provided a UFSAR supplement summary description
- d.
Provide a conclusion stating, if applicable, that the applicant has demonstrated that 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 staff also concludes that the UFSAR supplement contains an appropriate summary description of the activities for managing the effects of aging and the TLAA evaluation, as required by 10 CFR 54.21(d).
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 SER input.
Upon issuance of the SER input, all worksheets that were completed by contractor and NRC personnel shall be given to the NRC project team leader.
After the NRC has made its licensing decision, all copies of documents collected and all documents generated to complete the SER input, such as audit worksheets, question and answer tracking documentation, etc., are to be discarded.
SSES, Units 1 and 2 Audit and Review Plan for AMRs, AMPs, and TLAAs 43 Table 1. Aging Management Program Element Descriptions Element Description 1 Scope of Program The scope of the program should 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 Inspected Parameters monitored or inspected should be linked to the 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 approval process.
10 Operating Experience Operating experience involving 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 period of extended operation.
SSES, Units 1 and 2 Audit and Review Plan for AMRs, AMPs, and TLAAs 7
Each AMR line item is coded 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, to A.
Nelson, NEI (ML030990052).
44 Table 2. Notes for License Renewal Application Tables 3.X.2-Y7 Note Description A
Consistent with NUREG-1801 [GALL Report] item for component, material, environment, and aging effect. AMP is consistent with NUREG-1801 AMP.
B Consistent with NUREG-1801 item for component, material, environment, and aging effect. AMP takes some exceptions to NUREG-1801 AMP.
C Component is different, but consistent with NUREG-1801 item for material, environment, and aging effect. AMP is consistent with NUREG-1801 AMP.
D Component is different, but consistent with NUREG-1801 item for material, environment, and aging effect. AMP takes some exceptions to NUREG-1801 AMP.
E Consistent with NUREG-1801 for material, environment, and aging effect, but a different aging management program is credited.
F Material not in NUREG-1801 for this component.
G Environment not in NUREG-1801 for this component and material.
H Aging effect not in NUREG-1801 for this component, material and environment combination.
I Aging effect in NUREG-1801 for this component, material and environment combination is not applicable.
J Neither the component nor the material and environment combination is evaluated in NUREG-1801.
SSES, Units 1 and 2 Audit and Review Plan for AMRs, AMPs, and TLAAs 45 Figure 1. Audit of AMPs that are Consistent with the GALL Report Yes No Yes Yes No Yes No Start Did applicant identify any exceptions to GALL AMP(s)?
Compare each GA LL AMP auditable element to the LRA AM P Docum ent the basis for acceptance of the attribute element in worksheet Have all attribute elements been audited?
Yes Preparation Steps Identify GALL AM P(s) to which LRA AMP is being compared Identify elem ents of GALL AMP(s) attributes to be audited Identify LRA AM P support documents needed to perform audit Is there a technical basis to accept exception or difference?
Note: If a prior NRC precedent exists, it may be used as an aid to make the technical determination.
Documentation of the acceptance must be made on the technical merits not a citation to the precedent.
Ask applicant a clarifying question to continue audit?
No Notify NRC Team Leader that Audit of AM R may not proceed.
Terminate AMP audit Develop and provide question to Team Leader for PMs submittal to applicant Obtain response from applicant Draft RAI No Note; Preparation steps may be performed as a single combined step for each AMP audited.
Yes No Is the attribute element consistent?
W rite audit report input per guidance in Section D.E.F Conclusion of AM P audit Provide audit report input Write SE input per guidance in Section G.H.J Provide audit SE input Have all 7 AMP attributes been audited?
No
SSES, Units 1 and 2 Audit and Review Plan for AMRs, AMPs, and TLAAs 46 Yes No Yes No Yes Yes No No Start Compare each SRP-LR AMP criteria element to the LRA AMP Document the basis for acceptance of the element in worksheet Have all element criteria been audited?
Preparation Steps Identify criteria of SRP-LR, Appendix A elemets which are auditable Identify LRA AMP support documents needed to perform audit Is there a technical basis to accept exception or difference?
Note: If a prior NRC precedent exist, it may be used as an aid to make the technical determination.
Documentation of the acceptance must be made on the technical merits not a citation to the precedent.
Is it appropriate to ask applicant a clarifying question to continue audit?
Develop question No Notify NRC Team Leader that review of AMP may not proceed.
Terminate AMP audit Provide question to Team leader for PMs submittal to applicant Obtain response from applicant Draft RAI Note; Preparation steps may be performed as a single combined step for each AMP audited.
Yes No Is the AMP element consistent?
Write audit and review report input Conclusion of AMP review Provide NRC team leader and contractor audit report input Write SER input Provide NRC team leader and contractor audit SER input Have all 7 AMP elements been audited?
Figure 2. Audit of Plant-Specific AMPs
SSES, Units 1 and 2 Audit and Review Plan for AMRs, AMPs, and TLAAs 47 Footnote A Confirm that AMP will address AE for this component and environment Compare line item with GALL Vol. 2 System Table line item for:
component type material environment aging effect Confirm AE still managed despite AMP exception Confirm material, environment, AE, and method per AMP are comparable Confirm material, environment and aging effect are comparable and AE still managed despite AMP exception Confirm AMP can manage this AE Footnote B Footnote C Footnote D Footnote E Compare line item with GALL Vol. 2 System Table line item for:
material environment aging effect AMP Compare line item with GALL Vol. 2 System Table line item for:
material environment aging effect Compare line item with GALL Vol. 2 System Table line item for:
material environment aging effect Compare item with GALL Vol. 2 System Table item for:
component type material environment aging effect AMP Item is assigned to DE No Document basis for acceptance in AMR Comparison Checklist Prepare question Review corresponding LRA Table 3.X.1"Further Evaluation Recommended" and "Discussion" columns Review referenced LRA subsection and compare with SRP subsection for any differences Acceptable in all aspects No Mark as Out of Scope Out of RLEP Scope Mark as Acceptable Mark for query Document problem in AMR Comparison Checklist Confirm question is captured AMR line item complete AMR item AMP is Plant-Specific No Yes Yes Yes No No No No No Yes Yes Yes Yes Yes Yes No Further Evaluation Figure 3. Review of AMRs that are Consistent with the GALL Report
SSES, Units 1 and 2 Audit and Review Plan for AMRs, AMPs, and TLAAs 48 Figure 4. Review of TLAAs and Exemptions (from NEI 95-10, Revision 6)
SSES, Units 1 and 2 Audit and Review Plan for AMRs, AMPs, and TLAAs A-1 APPENDIX A PROJECT TEAM MEMBERSHIP Organization Name Function NRC/NRR/DLR/RLRC James Medoff Team Leader (TL) / Lead Team Reviewer
- Materials NRC/NRR/DLR/RLRC Roy Mathew Back-up Team Leader / Lead Team Reviewer - Electrical NRC/NRR/DLR/RLRA Yoira Diaz-Sanabria Project Manager (and Alt. Back-up TL)
NRC/NRR/DLR/RLRA Evelyn Gettys Backup Project Manager NRC/NRR/DLR/RLRC Dan Hoang Lead Team Reviewer - Structures NRC/NRR/DLR/RLRC Surinder Arora Lead Team Reviewer - Mechanical NRC/NRR/DLR/RLRC Zhian Li NRC Team Member - TLAAs NRC/NRR/DLR/RLRC John Rycyna NRC Team Member - Structures ATL (NRC Contractor)
W. Pavinich Contractor lead, Reviewer - Structural ATL (NRC Contractor)
R. Jackson Reviewer - Materials ATL (NRC Contractor)
E. Patel Reviewer - Mechanical and BWRVIP
SSES, Units 1 and 2 Audit and Review Plan for AMRs, AMPs, and TLAAs B-1 APPENDIX B RLRC SCHEDULE FOR THE SAFETY REVIEW OF THE LICENSE RENEWAL APPLICATION FOR THE SUSQUEHANNA STEAM ELECTRIC STATION
SSES, Units 1 and 2 Audit and Review Plan for AMRs, AMPs, and TLAAs B-2 RLRC Schedule for LRA Safety Review Plant:
Susquehanna (SSES) 1 and 2 Team Leader (TL): Jim Medoff Backup Team Leader (BTL): Roy Mathew Project Manager (PM): Y. Diaz-Sanabria, E. Gettys Contractor: ATL ACTIVITY/MILESTONE SCHEDULE Actual Schedule Status 1
Receive LRA 09/13/2006 09/15/2006 Complete 2
Complete Sufficiency Review 10/10/2006 10/05/2006 Complete 3
Planning Conf. Call w/ PPL 04/11/2007 04/11/2007 Complete 4
Make Review Assignments:
04/20/2007 04/18/2007 Complete 5
Issue Audit Plan to PM 05/04/2007 05/04/2007 Complete 6
Kickoff Mtg. w/ ATL 05/31/2007 Kickoff Mtg. w/ Project Team 05/31/2007 7
Preliminary RAIs to PM 06/01/2007 8
Site Visit 1: AMP Audit 07/30-08/03/2007 9
DSER w/ RAIs to TL-AMP TBD 10 Site Visit 2: AMR/TLAA 09/10-14/2007 11 DSER w/ RAIs to TL-AMR/TLAA TBD 12 Optional Site Visit 3 10/2007 13 Cutoff for Addn. RAIs to PM TBD 14 Docketing of Q&A Database 12/07/2007 15 Issue Audit Summary to RLRB 12/31/2007 16 Docket: RAI Resp, LRA Amends TBD 17 DSER w/ OI Input to TL TBD 18 Peer Review - DSER w/ OI TBD 19 DSER w/ OI Input to PM TBD 20 ACRS Subcommittee Meeting TBD 21 ACRS Full Committee Meeting TBD
SSES, Units 1 and 2 Audit and Review Plan for AMRs, AMPs, and TLAAs C-1 APPENDIX C AGING MANAGEMENT PROGRAM ASSIGNMENTS No.
GALL Report AMP Number and Title SSES Aging Management Program New or Existing Program Consistent With GALL?
Assigned Auditor (Yes/PS)
Exception Enhancement 1
B.2.1 XI.M1 ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWC Inservice Inspection (ISI)
Program Existing Yes X (1)
S. Arora 2
B.2.2 XI.M2 Water Chemistry BWR Water Chemistry Program Existing Yes R. Jackson (ATL) 3 B.2.3 XI.M3 Reactor Head Closure Studs Reactor Head Closure Studs Program Existing Yes S. Arora 4
B.2.4 XI.M4 BWR Vessel ID Attachment Welds BWR Vessel ID Attachment Welds Program Existing Yes E. Patel (ATL)
SSES, Units 1 and 2 Audit and Review Plan for AMRs, AMPs, and TLAAs No.
GALL Report AMP Number and Title SSES Aging Management Program New or Existing Program Consistent With GALL?
Assigned Auditor (Yes/PS)
Exception Enhancement C-2 5
B.2.5 XI.M5 BWR Feedwater Nozzle BWR Feedwater Nozzle Program Existing Yes E. Patel (ATL) 6 B.2.6 XI.M6 BWR Control Rod Drive Return Line Nozzle BWR CRD Return Line Nozzle Program Existing Yes X (1)
E. Patel (ATL) 7 B.2.7 XI.M7 BWR Stress Corrosion Cracking BWR Stress Corrosion Cracking Program Existing Yes S. Arora 8
B.2.8 XI.M8 BWR Penetrations BWR Penetrations Program Existing Yes X (1)
E. Patel (ATL) 9 B.2.9 XI.M9 BWR Vessel Internals BWR Vessel Internals Program Existing Yes X (1)
E. Patel (ATL)
SSES, Units 1 and 2 Audit and Review Plan for AMRs, AMPs, and TLAAs No.
GALL Report AMP Number and Title SSES Aging Management Program New or Existing Program Consistent With GALL?
Assigned Auditor (Yes/PS)
Exception Enhancement C-3 10 B.2.10 XI.M13 Thermal Aging and Neutron Embrittlement of Cast Austenitic Stainless Steel (CASS)
Thermal Aging and Neutron Embrittlement of Cast Austenitic Stainless Steel (CASS) Program New Yes S. Arora 11 B.2.11 XI.M17 Flow-Accelerated Corrosion Flow Accelerated Corrosion Program Existing Yes R. Jackson (ATL) 12 B.2.12 XI.M18 Bolting Integrity Bolting Integrity Program Existing Yes X (6)
X (1)
Z. Li 13 B.2.13 XI.M20 Open-Cycle Cooling Water System Piping Corrosion Program Existing Yes X (2) l R. Jackson (ATL)
SSES, Units 1 and 2 Audit and Review Plan for AMRs, AMPs, and TLAAs No.
GALL Report AMP Number and Title SSES Aging Management Program New or Existing Program Consistent With GALL?
Assigned Auditor (Yes/PS)
Exception Enhancement C-4 14 B.2.14 X.M21 Closed-Cooling Water System Closed Cooling Water Chemistry Program Existing Yes X (1)
R. Jackson (ATL) 15 B.2.15 XI.M23 Inspection of Overhead Heavy Load and Light Load (Related to Fuel Handling Systems)
Crane Inspection Program Existing Yes J. Rycyna / B. Lehman 16 B.2.16 XI.M26 Fire Protection Fire Protection Program Existing Yes X (1)
Y Diaz-Sanabria w/
Concurrence of the Fire Protection Branch (DRA/AFPB) 17 B.2.17 XI.M27 Fire Water System Fire Water System Program Existing Yes X (2)
Y Diaz-Sanabria w/
Concurrence of the Fire Protection Branch (DRA/AFPB)
SSES, Units 1 and 2 Audit and Review Plan for AMRs, AMPs, and TLAAs No.
GALL Report AMP Number and Title SSES Aging Management Program New or Existing Program Consistent With GALL?
Assigned Auditor (Yes/PS)
Exception Enhancement C-5 18 B.2.18 XI.M28 Buried Piping and Tanks Surveillance Buried Piping Surveillance Program New Yes X (1)
Z. Li 19 B.2.19 XI.M29 Above-ground Carbon Steel Tanks Condensate and Refueling Water Storage Tanks Inspection New Yes Z. Li 20 B.2.20 XI.M30 Fuel Oil Chem.
Fuel Oil Chemistry Program Existing Yes X (3)
E. Gettys 21 B.2.21 XI.M31 Reactor Vessel Surveillance Reactor Vessel Surveillance Program Existing Yes X (1)
Not Part of the Audit Review S. Sheng (DCI / CVIB) 22 B.2.22 XI.M32 One Time Inspection Chemistry Program Effectiveness Inspection New Yes W. Pavinich (ATL) 23 B.2.23 XI.M32 One Time Inspection Cooling Units Inspection New Yes W. Pavinich (ATL)
SSES, Units 1 and 2 Audit and Review Plan for AMRs, AMPs, and TLAAs No.
GALL Report AMP Number and Title SSES Aging Management Program New or Existing Program Consistent With GALL?
Assigned Auditor (Yes/PS)
Exception Enhancement C-6 24 B.2.24 XI.M32 One Time Inspection Heat Exchanger Inspection New Yes W. Pavinich (ATL) 25 B.2.25 XI.M32 One Time Inspection Lubricating Oil Inspection New Yes E. Gettys 26 B.2.26 XI.M32 One Time Inspection Main Steam Flow Restrictor Inspection New Yes W. Pavinich (ATL) 27 B.2.27 XI.M32 One Time Inspection Monitoring and Collection System Inspection New Yes W. Pavinich (ATL) 28 B.2.28 XI.M32 One Time Inspection Supplemental Piping/Tank Inspection New Yes W. Pavinich (ATL) 29 B.2.29 XI.M33 Selective Leaching of Materials Selective Leaching Inspection New Yes S. Arora
SSES, Units 1 and 2 Audit and Review Plan for AMRs, AMPs, and TLAAs No.
GALL Report AMP Number and Title SSES Aging Management Program New or Existing Program Consistent With GALL?
Assigned Auditor (Yes/PS)
Exception Enhancement C-7 30 B.2.30 XI.M34 Buried Piping and Tanks Inspection Buried Piping and Tanks Inspection Program New Yes X (2)
Z. Li 31 B.2.31 XI.M35 One-time Inspection of ASME Code Class 1 Small Bore-Piping Small Bore Class 1 Piping Inspection New Yes S. Arora 32 B.2.32 XI.M36 External Surfaces Monitoring Systems Walkdown Program Existing Yes X (3)
Y. Diaz-Sanabria 33 B.2.33 XI.M39 Lubricating Oil Analysis Lubricating Oil Analysis Existing Yes X (2)
X (1)
E. Gettys
SSES, Units 1 and 2 Audit and Review Plan for AMRs, AMPs, and TLAAs No.
GALL Report AMP Number and Title SSES Aging Management Program New or Existing Program Consistent With GALL?
Assigned Auditor (Yes/PS)
Exception Enhancement C-8 34 B.2.34 XI.S1 AMSE Section XI, Subsection IWE Inservice Inspection (ISI)
Program - IWE Existing Yes D. Hoang 35 B.2.35 XI.S2 AMSE Section XI, Subsection IWL Inservice Inspection (ISI)
Program - IWL Existing Yes D. Hoang 36 B.2.36 XI.S3 AMSE Section XI, Subsection IWF Inservice Inspection (ISI)
Program - IWF Existing Yes D. Hoang 37 B.2.37 XI.S4 10 CFR Part 50, Appendix J Containment Leak Rate Test Program Existing Yes D. Hoang
SSES, Units 1 and 2 Audit and Review Plan for AMRs, AMPs, and TLAAs No.
GALL Report AMP Number and Title SSES Aging Management Program New or Existing Program Consistent With GALL?
Assigned Auditor (Yes/PS)
Exception Enhancement C-9 38 B.2.38 XI.S5 Masonary Wall Program Masonary Wall Program Existing Yes X
D. Hoang 39 B.2.39 XI.S6 Structures Monitoring Program Structures Monitoring Program Existing Yes X
D. Hoang 40 B.2.40 XI.S7 RG 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants RG 1.127 Water Control Structures Inspection Existing Yes X
D. Hoang
SSES, Units 1 and 2 Audit and Review Plan for AMRs, AMPs, and TLAAs No.
GALL Report AMP Number and Title SSES Aging Management Program New or Existing Program Consistent With GALL?
Assigned Auditor (Yes/PS)
Exception Enhancement C-10 41 B.2.41 XI.E1 Electrical Cables and Connections Not Subject to 10CFR50.49 Environmental Qualification Requirements Non-EQ Electrical Cables and Connections Visual Inspection Program New Yes R. Mathew 42 B.2.42 XI.E2 Electrical Cables Not Subject to 10CFR50.49 Environmental Qualification Requirements Used in Instrument.
Circuits Non-EQ Electrical Cables and Connections Used in Low-Current Instrumentation Circuits Program New Yes E. Gettys
SSES, Units 1 and 2 Audit and Review Plan for AMRs, AMPs, and TLAAs No.
GALL Report AMP Number and Title SSES Aging Management Program New or Existing Program Consistent With GALL?
Assigned Auditor (Yes/PS)
Exception Enhancement C-11 43 B.2.43 XI.E3 Inaccessible Medium Voltage Cables Not Subject to 10CFR50.49 Environment.
Requirements Non-EQ Inaccessible Medium-Voltage Cables Program New Yes R. Mathew 44 B.2.44 XI.E4 Metal-Enclosed Bus Metal Enclosed Bus Program New Yes R. Mathew 45 B.2.45 XI.E5 Electrical Cable Connections Not Subject to 10CFR50.49 Environment.
Qualification Requirements Non-EQ Electrical Cable Connections Program New Yes R. Mathew
SSES, Units 1 and 2 Audit and Review Plan for AMRs, AMPs, and TLAAs No.
GALL Report AMP Number and Title SSES Aging Management Program New or Existing Program Consistent With GALL?
Assigned Auditor (Yes/PS)
Exception Enhancement C-12 46 B.3.1 X.M1 Metal Fatigue of Reactor Coolant Pressure Boundary Fatigue Monitoring Program Existing Yes X
Z. Li Evaluate concurrently with evaluation of TLAAs for LRA Section 4.3 47 B.3.2 X.E1 Environmental Qualification (EQ) of Electrical Components EQ Program Existing Yes X
R. Mathew Evaluate concurrently with evaluation of TLAA for LRA Section 4.4 48 B.2.46 Not Applicable Area-Based NSAS Inspection New PS J. Rycyna / B. Lehman 49 B.2.47 Not Applicable Leak Chase Channel Monitoring Activities Existing PS J. Rycyna / B. Lehman
SSES, Units 1 and 2 Audit and Review Plan for AMRs, AMPs, and TLAAs No.
GALL Report AMP Number and Title SSES Aging Management Program New or Existing Program Consistent With GALL?
Assigned Auditor (Yes/PS)
Exception Enhancement C-13 50 B.2.48 Not Applicable Preventative Maintenance Activities -
RCIC/HPCI Turbine Casings Existing PS R. Jackson (ATL)
SSES, Units 1 and 2 Audit and Review Plan for AMRs, AMPs, and TLAAs D-1 APPENDIX D AGING MANAGEMENT REVIEW ASSIGNMENTS Aging Management Reviews Reviewer 3.1 Aging Management of Reactor Vessel, Internals, and Reactor Coolant System E. Patel w/ Assistance from S. Arora 3.2 Aging Management of Engineered Safety Features R. Jackson or W. Pavinich 3.3 Aging Management of Auxiliary Systems R. Jackson or W. Pavinich 3.4 Aging Management of Steam and Power Conversion Systems R. Jackson or W. Pavinich 3.5 Aging Management of Containment, Structures, and Component Supports D. Hoang 3.6 Aging Management of Electrical and Instrumentation and Controls R. Mathew w/
Assistance from E.
Gettys
SSES, Units 1 and 2 Audit and Review Plan for AMRs, AMPs, and TLAAs E-1 APPENDIX E TIME-LIMITED AGING ANALYSIS REVIEW ASSIGNMENTS LRA TLAA Number TLAA Title 10 CFR 54.21(c)(1)
Assigned Reviewer (i) or (iii)
(ii) 4.1 Identification of TLAAs and Exemptions NRC Project Team Leader 4.2 Reactor Vessel Neutron Embrittlement 4.2.1, Neutron Fluence Not a TLAA but needs to be evaluated DSS (L. Lois) 4.2.2, Upper Shelf Energy (USE)
(ii)
DCI / CVIB (Sheng) 4.2.3, Adjusted Reference Temperature (ART)
(ii)
DCI / CVIB (Sheng) 4.2.4, Pressure-Temperature (P-T) Limits (ii)
DCI / CVIB (Sheng) 4.2.5, Reactor Vessel Circumferential Weld Examination Relief (ii)
DCI / CVIB (Sheng) 4.2.6, Reactor Vessel Axial Weld Failure Probability (ii)
DCI / CVIB (Sheng) 4.2.7, Reflood Thermal Shock Analysis (i)
DCI / CVIB (Sheng) 4.3 Metal Fatigue 4.3.1, Reactor Pressure Vessel Fatigue Analyses (iii)
Z. Li (Fair for Peer Review) 4.3.1, Reactor Vessel Internals Fatigue Analyses (iii) or (ii)
Z. Li (Fair for Peer Review) 4.3.3, Effects of Reactor Coolant Environment on Fatigue Life...
(iii)
Z. Li (Fair for Peer Review) 4.3.4, Reactor Coolant Pressure Boundary Piping and Component Fatigue Analyses (iii)
Z. Li (Fair for Peer Review) 4.3.5, Non-Class 1 Fatigue (i)
Z. Li (Fair for Peer Review)
SSES, Units 1 and 2 Audit and Review Plan for AMRs, AMPs, and TLAAs E-2 4.4 Environmental Qualification or Electrical Components (iii)
R. Mathew 4.5 Concrete Containment Tendon Prestress Not Applicable to SSES N/A N/A 4.6 Containment Liner Plate, Metal Containment, and Penetrations Fatigue Analysis 4.6.1, ASME Class MC Components (i)
D. Hoang 4.6.2, Downcomer Vents and SRV Discharge Piping (i)
D. Hoang 4.6.3, Safety Relief Valve Quenchers (i)
D. Hoang 4.7 Other TLAAs 4.7.1, Main Steam Line Flow Restrictor Erosion Analysis (ii)
DCI / CSGB 4.7.2, High Energy Line Break Cumulative Fatigue Usage Factors (iii)
E. Patel (ATL) 4.7.3, Core Plate Rim Hold-Down Bolts (ii)
S. Arora
SSES, Units 1 and 2 Audit and Review Plan for AMRs, AMPs, and TLAAs F-1 APPENDIX F CONSISTENT WITH GALL REPORT AMP AUDIT/REVIEW WORKSHEET 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 Report AMPs (Chapter XI of NUREG-1801, Volume 2). The worksheet provides a systematic method for recording the basis for assessments or to identify when the applicant needs to provide clarification or additional information. Information recorded in the worksheets will also be used to prepare the audit and review report and the safety evaluation report input.
A complete set of GALL Report AMP worksheets can be found at ADAMS Accession Number ML060950189.
SSES, Units 1 and 2 Audit and Review Plan for AMRs, AMPs, and TLAAs F-2 Consistent With GALL Report AMP Audit/Review Worksheet LRA Appendix Subsection:
Title:
GALL Report Subsection:
Gall Report
Title:
A. Element Review and Audit Program
Description:
G Consistent with GALL Report G Difference Identified Discussion:
- 1. Scope of Program:
G Consistent with GALL Report G Exception G Enhancement G Difference Identified Discussion:
- 2. Preventive Action:
G Consistent with GALL Report G Exception G Enhancement G Difference Identified Discussion:
SSES, Units 1 and 2 Audit and Review Plan for AMRs, AMPs, and TLAAs F-3
- 3. Parameters Monitored/Inspected:
G Consistent with GALL Report G Exception G Enhancement G Difference Identified Discussion:
- 4. Detection of Aging Effects:
G Consistent with GALL Report G Exception G Enhancement G Difference Identified Discussion:
- 5. Monitoring and Trending:
G Consistent with GALL Report G Exception G Enhancement G Difference Identified Discussion:
- 6. Acceptance Criteria:
G Consistent with GALL Report G Exception G Enhancement G Difference Identified Discussion:
- 7. Corrective Action:
SSES, Units 1 and 2 Audit and Review Plan for AMRs, AMPs, and TLAAs F-4
- 8. Confirmation Process:
- 9. Administrative Controls:
- 10. Operating Experience:
B. FSAR supplement review: (Include any commitments.)
C.
Remarks and questions:
D.
References/documents used: (Include number designation, full title, revision number, date, and page numbers, and ADAMS accession number.)
E.
Applicant contact:
Project team member: __________________________________ Date: ______________
SSES, Units 1 and 2 Audit and Review Plan for AMRs, AMPs, and TLAAs G-1 APPENDIX G PLANT-SPECIFIC AMP AUDIT/REVIEW WORKSHEET 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 preparing the audit and review report and the safety evaluation report input.
SSES, Units 1 and 2 Audit and Review Plan for AMRs, AMPs, and TLAAs G-2 Plant-Specific AMP Audit/Review Worksheet AMP
Title:
Appendix Subsection: ____________________________________________________
A.
Element Review and Audit 1.
Scope of Program:
___ Consistent with SRP-LR
____ Exception
____ Difference Identified Discussion:
2.
Preventive Action:
___ Consistent with SRP-LR
____ Exception
____ Difference Identified Discussion:
3.
Parameters Monitored/Inspected:
___ Consistent with SRP-LR
____ Exception
____ Difference Identified Discussion:
4.
Detection of Aging Effects:
___ Consistent with SRP-LR
____ Exception
____ Difference Identified Discussion:
SSES, Units 1 and 2 Audit and Review Plan for AMRs, AMPs, and TLAAs G-3 5.
Monitoring and Trending:
___ Consistent with SRP-LR
____ Exception
____ Difference Identified Discussion:
6.
Acceptance Criteria:
___ Consistent with SRP-LR
____ Exception
____ Difference Identified Discussion:
7.
Corrective Action:
To be performed by DIPM 8.
Confirmation Process:
To be performed by DIPM 9.
Administrative Controls:
To be performend by DIPM 10.
Operating Experience:
___ Consistent with SRP-LR
____ Exception
____ Difference Identified Discussion:
Consistent or technical basis for acceptance exception or difference B.
FSAR supplement review: (Include any committments.)
SSES, Units 1 and 2 Audit and Review Plan for AMRs, AMPs, and TLAAs G-4 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: ______________
SSES, Units 1 and 2 Audit and Review Plan for AMRs, AMPs, and TLAAs H-1 Appendix H AMR COMPARISON WORKSHEET The worksheet provided in this appendix provides, as an aid for the reviewer, a process for documenting the basis for the staffs assessments of an applicants aging management review AMR results. The worksheet provides a systematic method for documenting the degree of consistency of the applicants AMRs against those in the GALL Report, for recording the basis of the staffs assessments and determinations, and for identifying and documenting those AMR issues that will require further action by the applicant for resolution. Information recorded in these worksheets will be used when preparing the audit and review report and the safety evaluation report input
SSES, Units 1 and 2 Audit and Review Plan for AMRs, AMPs, and TLAAs H-2 AMR COMPARISON WORKSHEET SSES AMR Component (Table 1) Worksheet:
Audit Date:
Unit:
Table No.:
Chapter:
Auditor Name(s):
The audit team verified that items in Table 3.X.1 (Table 1) correspond to items in the GALL Volume 1, Table X. All items applicable to BWRs in Table 1 were reviewed and are addressed in the following table.
Item No.
Further Evaluation Recommended Discussion
SSES, Units 1 and 2 Audit and Review Plan for AMRs, AMPs, and TLAAs H-3 Audit Remarks (Document all questions for applicant here):
Number Question for applicant (draft per RAI guidance)
Response (with date)
References/Documents Used:
1.
2.
3.
4.
SSES AMR MEAP Comparison (Table 2) Worksheet Audit Date:
Unit:
Table No.:
Chapter:
Auditor Name(s):
Line items to which Notes A, B, C, D, and E are applied or for which a precedent was cited (except for those assigned to DE) were reviewed for: 1) consistency with NUREG-1801, Volume 2 tables, and 2) adequacy of the aging managing programs. All items in the Table 2 of the system named above are acceptable with the exception of items in boldface type.
(Reviewers need not duplicate information in the 2nd-5th columns that are reflected in the discussion/draft audit report.)
H-4 LRA Page No.
Component Type Material Environment Aging Effect Note:
Discussion (draft as Audit Report Insert)
Audit Remarks (Document all questions for the applicant here):
No.
Question for applicant (draft per RAI guidance)
Response (with date)
References/Documents Used:
- 1.
- 2.
- 3.
SSES, Units 1 and 2 Audit and Review Plan for AMRs, AMPs, and TLAAs I-1 APPENDIX I ACRONYMS, ABBREVIATIONS, AND INITIALISMS ADAMS Agencywide Documents Access and Management System AFPB Fire Protection Branch AMP aging management program AMR aging management review ASME American Society of Mechanical Engineers CLB current licensing basis DCI Division of Component Integrity DE Division of Engineering DIPM Division of Inspection Program Management DLR Division of License Renewal DRA Division of Risk Assessment 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 Regulatory Commission NRR Office of Nuclear Reactor Regulation SSES Susquehanna Steam Electric Station RAI request for additional information RLEP-B License Renewal and Environmental Impacts Program, Section B RLSB License Renewal and Standardization Branch
SSES, Units 1 and 2 Audit and Review Plan for AMRs, AMPs, and TLAAs I-2 SC structures and components SER safety evaluation report SRP-LR Standard Review Plan - License Renewal SSC structure, system, and component TLAA Time Limited Aging Analysis UFSAR updated final safety analysis report