NUREG-1891, April 2008 Evidentiary Hearing - Staff Exhibit 23, NUREG-1891 (Sept. 2007, Published Nov. 2007) Excerpt - 3.0.2 Staffs Review Process
| ML081120261 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 04/15/2008 |
| From: | NRC/SECY |
| To: | |
| SECY RAS | |
| References | |
| 50-293-LR, ASLBP 06-848-02-LR, Pilgrim-Staff-61, RAS J-91 | |
| Download: ML081120261 (7) | |
Text
combination of component type, material, environment, AERM, and AMP in LRA Table 2 with the GALL Report items. If there are no corresponding items in the GALL Report, the applicant leaves the column blank. In this way the applicant identified the AMR results in the LRA tables corresponding to the items in the GALL Report tables.
(8)
Table 1 Item - The eighth column lists the corresponding summary item.number from LRA Table 1. If the applicant identifies in each LRA Table 2 AMR results consistent with the GALL Report the Table 1 line item summary number should be listed, in LRA Table.2.
If there is no corresponding item in the GALL Report, column eight is left blank. In this manner, the information from the two tables can be correlated.
(9)
Notes - The ninth column lists the corresponding notes used to identify how the information in each Table 2 aligns with the information in the GALL Report. The notes, identified by letters, were developed by an NEI work group and will be used in future LRAs. Any plant-specific notes identified by numbers provide additional information about the consistency of the line item with the GALL Report.
3.0.2 Staff's Review Process The staff conducted three types of evaluations of the AMRs and AMPs:
(1)
For items that the applicant stated were consistent with the GALL Report, the staff conducted either an audit or a technical review to determine such consistency.
(2)'
For items that the. applicant stated were consistent with the GALL Report with exceptions, enhancements, or both, the staff conducted either an audit or a technical review of the item to determin-.
technical review adequacy of the The SRP-LR sta AMP elements; I described and ju GALL AMP that In some cases, the program eler commitment to a of extended opei be enhancemeni ensure consister expand, but not I (3)
For other items, I 10 CFR 54.21(a)
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combination of component type, material, environment, AERM, and AMP in LRA Table 2 with the GALL Report items. If there are no corresponding items in the GALL Report, the applicant leaves the column blank. In this way the applicant identified the AMR results in the LRA tables corresponding to the items in the GALL Report tables.
(8)
Table 1 Item - The eighth column lists the corresponding summary item.number from LRA Table 1. If the applicant identifies in each LRA Table 2 AMR results consistent with the GALL Report the Table 1 line item summary number should be listed in LRA Table 2.
if there is no corresponding Item in the GALL Report, column eight is left blank. In this manner, the information from the two tables can be correlated.
(9)
Notes - The ninth column lists the corresponding notes used to identify how the information in each Table 2 aligns with the information in the GALL Report. The notes, identified by letters, were developed by an NEI work group and will be used in future LRAs. Any plant-specific notes identified by numbers provide additional information about the consistency of the line item with the GALL Report.
3.0.2 Staffs Review Process The staff conducted three types of evaluations of the AMRs and AMPs:
(1)
For Items that the applicant stated were consistent with the GALL Report, the staff conducted either an audit or a technical review to determine such consistency.
(2)
For Items 'that the applicant stateci were consistent with the GALL Rep6rt with exceptions, enhancements, or both, the staff conducted either an audit or a technical review of the item to determine such consistency. In addition, the staff conducted either an audit or a technical review of the applicant's technical justifications for the exceptions or the, adequacy of the enhancements.
The SRP-LR states that an applicant may take one or more exceptions to specific GALL AMP elements; however, any deviation from or exception to the GALL AMP should be described and justified. Therefore, the staff considers exceptions as being portions of the GALL AMP that the applicant, does not intend to implement.
In some cases, an applicant may choose an existing plant program that does not meet all the program elements defined in the GALL AMP. However, the applicant may make a commitment to augment the existing program to satisfy the GALL AMP pror to the period of extended operation. Therefore, the staff considers these augmentations or additions to be enhancements. Enhancements Include, but are not limited to, activities needed to ensure consistency with the GALL Report recommendations. Enhancements may expand, but not reduce, the scope of an AMP.
(3)
For other items, the staff conducted a technical review to verify conformance with 10 CFR 54.21(a)(3) requirements.
Staff audits and technical reviews of the applicant's AMPs and AMRs determine whether the aging effects on SCs can be adequately managed to maintain their inlended function(s) consistent with the plant's current licensing basis (CLB) for the period of extended operation, as required by 10 CFR Part 54.
3-4
3.0.2.1 Review of AMPs For AMPs for which the applicant claimed consistency with the GALL AMPs, the staff conducted either an audit or a technical review to verify the claim. For each AMP with one or more deviations, the staff evaluated each deviation to determine whether the deviation was acceptable and whether the modified AMP would adequately manage the aging effect(s) for which it was credited. For AMPs not evaluated in the GALL Report, the staff performed a full review to determine their adequacy. The staff evaluated the AMPs against the following 10 program elements defined in SRP-LR Appendix A.
(1)
Scope of the Program - Scope of the program should include the specific SCs subject to an AMR for license renewal.
(2)
Preventive Actions - Preventive actions should prevent or mitigate aging degradation.
(3)
Parameters Monitored or Inspected - Parameters monitored or inspected should be linked to the degradation of the particular structure or component, intended. function(s),
(4)
Detection of Aging Effects - Detection of aging effects should occur before there is a loss of structure or component intended function(s), 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 predictability of the extent of degradation, as well as timely corrective or mitigative actions..
(6)
Acceptance Criteria - Acceptance criteria, against which the need for corrective action will be evaluated, should ensure that the structure or component intended function(s) are maintained under all CLB 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 - Confirmation process should ensure that preventive actions are adequate and that appropriate corrective actions have been completed and are effective.
(9)
Administrative Controls - Administrative controls should provide for a formal review and approval process.
(10) Operating Experience - Operating experience of the AMP, including past corrective actions resulting in program enhancements or additional programs, should provide objective evidence to support the conclusion that the effects of aging will be adequately managed so that the SC intended function(s) will be maintained during the period of extended operation.
Details of the staffs audit evaluation of program elements (1) through.(6) are documented in SER Section 3.0.3.
The staff reviewed the applicant's quality assurance (QA) program and documented its evaluations in SER Section 3.0.4, The staff's evaluation of. the QA program included assessment of the "corrective actions," 'confirmation process," and "administrative controls" program elements.
3-5
The staff reviewed the information on the "operating experience" program element and documented its evaluation in SER Section 3.0.3.
3.0.2.2. Review of AMR Results Each LRA Table 2 contains information concerning whether or not the AMRs identified by the applicant align with the GALL AMRs. For a given AMR in a Table 2, the staff reviewed the
-intended function, material, environment, AERM, and AMP combination for a particular system component type. Item numbers in column seven of the LRA, "GALL Report Volume 2 Item,"
correlates to an AMR combination as identified in the GALL Report. The staff also conducted onsite audits to verify these correlations. A blank in.column seven indicates that the applicant was unable to identify an appropriate correlation In the GALL Report. The staff also conducted a technical review of combinations not consistent with the GALL Report. The next column, "Table 1 Item," refers to a number indicating the correlating row in Table*1.
3.0.2.3 UFSAR Supplement Consistent with the SRP-LR, for the AMRs-and AMPs that it reviewed, the staff also reviewed the UFSAR supplement, which summarizes the applicant's programs and activities for managing aging effects for the period of extended operation, as required by 10 CFR 54.21 (d).
3.0.2.4 Documentation and Documents Reviewed In its review, the staff'used the LRA, LRA amendments, the SRP-LR, and thb GALL Report.
During the onsite audit, the staff also examined the applicant's justifications to verify that the applicant's activities and programs willadequately manage the effects of aging on SCs. The staff also conducted detailed discussions and interviews with the applicant's license renewal project personnel and others with technical expertise relevant to aging management.
3.0.3 Aging Management Programs SER Table 3.0.3-1 presents the AMPS credited by the applicant and described in LRA Appendix B. The table also indicates the SSCs that credit the AMPs and the GALL AMP with which the applicant claimed consistency and shows the section of this SER in which the staff's.
evaluation of the program is documented.
Table 3.0.3-1 PNPS Aging Management Programs
_-' :PNPS AMP..
'0""i
L GAL YRep*
ri iRA stems or"br, Structures',.
staf,',
.(LRA Section Comparison 7'AMs That Credit the AMP:
SER Section Existing AMPs Boraflex Monitoring Consistent XIM22 auxiliary systems 3.0.3.1.1 Program (Bil,)
3-6
SAMP GALL.Repo.
.GALL:Report, LRA Systems or'Structuros.
ta Fll (LRA Section) comparson AMPs :..
- 'That Credit the AMP SER Section BWR CRD Return Line Consistent with XI.M6 reactor vessel, internals, and 3.0.3.2.2 Nozzle Program exceptions reactor coolant system (B,1.3)
BWR Feedwater Consistent with XI.M5 reactor vessel, internals, and 3.0.3.2.3 Nozzle Program exceptions reactor coolant system (B.1,4)
BWR Penetrations Consistent with XIM8 reactor vessel, internals, and 3.0.3.2.4 Program exceptions reactor coolant system (B.1.5)
BWR Stress Corrosion Consistent with XI.M7 reactor vessel, internals, and 3.0.3.2.5 Cracking Program exception and reactor coolant system (B.1.6) enhancement BWR Vessel ID Consistent with Xi.M4 reactor vessel, internals, and 3.0.3.2.6 Attachment Welds exception reactor coolant system Program (B.1.7)
BWR Vessels Internals Consistent with XI.M9 reactor vessel, internals, and 3.0,3.2.7 Program exceptions and reactor coolant system (B.1.8) enhancement Containment Leak Rate Consistent XI.S4 engineered safety features 3.0.3.1.2 Program systerps / structures and (B. 1.9) component supports Diesel Fuel Monitoring Consistent with XL.M30 auxiliary systems 3.0.3.2.8 Program exceptions and (B.1.10) enhancements Environmental Consistent X.Et electrical and instrumentation 3.0.3.1.3 Qualification (EQ) of and controls Electric Components Program (B.1.11)
Fatigue Monitoring Consistent '
X.M1 reactor vessel,'internals, and 3.0.3.2,9 Program reactor coolant system I (B.1.12) engineered safety features systems / auxiliary systems /
steam and power conversion systems / structures and component supports Fire Protection Consistent with XI.M26 auxiliary systems / structures 3.0.3.2110 Program exceptions and and component supports (B.1.13.1) enhancements Fire Water System Consistent with XI.M27 auxiliary systems 3,0.3.2.11 Program exception and (B.113.2) enhancements 3-7
zf*-.,
PNP3 AMP'
-ALLRiAport Astems :or Structures staf.s.
.(iLA Section)
',comparlson""
AMPs.
That Credit the, AMP.:,':.
SER Section.
Flow-Accelerated Consistent XI.M17 reactor vessel, Internals, and 3.0.3.1.4 Corrosion Program reactor coolant system /
(B.14) auxiliary systems / steam and power conversion systems Containment Inservice Plant-specific structures and component 3,0.3.3.2 Inspection Program supports (B.1.16.1)
Inservice inspection Plant-specific reactor vessel, internals, and 3.0.3.3.3
-Program reactor coolant system /
(B.1.16.2) structures and component supports instrument Air Quality Plant-specific engineered safety features 3.0.3.3.4 Program systems / auxiliary systems (B.1 17)
Oil Analysis Program Consistent with XI.M39 engineered safety features 3.0.3.2.13 (6.1.22) exception and systems / auxiliary systems enhancements Periodic Surveillance Plant-specific engineered safety features 3.0.3.3.5 and Preventive systems / auxiliary systems /
Maintenance Program steam and power conversion (B.1.24) systems / structures and corfhponent supports Reactor Head Closure Consistent with XIM3 reactor vessel, internals, and 3.0.3.2.14 Studs Program exception reactor coolant system (B.1.25)
Reactor Vessel Consistent with XLM31 reactor vessel, internals, and 3.0.3.2.15 Surveillance Program enhancement reactor coolant system (B.1.26)
Service Water Integrity Consistent with XIM20 auxiliary systems 3.0.3.2.16 Program exceptions (B.1.28)
Masonry Wall Program Consistent XI.S5 structures and component 3.0.3.1,10 (B.L29.1) supports Structures Monitoring Consistent with XI.S6 structures and component
.30.3.2.17 Program enhancements supports (B.1.29.2)
Water Control Consistent with XIS7 structures and component 3.0.3.2.18 Structures Monitoring enhancement supports Program (B.1.29.3)
System Walkdown Consistent XI.M36 reactor vessel, internals, and 3.0.3.1.11 Program reactor coolant system /
(B.1.30) engineered safety features systems / auxiliary systems /
steam and power conversion
___________systems 3-8
PNPAMP,,
":,GALL Report I'GALLReport "LR Systemsor Structures Staffs "LRA Section)",
mparison"'
"AMPs
'" 'That Credit the AMP.
SER Section Water Chemistry Plant-specific auxiliary systems 3.0.3.3,6 Control - Auxiliary Systems Program (B.1.32.1)
Water Chemistry Consistent XI.M2 reactor vessel, internals, and 3.0.3.1.13 Control - BWR reactor coolant system /
Program engineered safety features (B. 1.32.2) systems / auxiliary systems I steam and power conversion systems Water Chemistry Consistent with XI.M21 reactor vessel, internals, and 3.0.3.2.19 Control - Closed exception reactor coolant system I Cooling Water Program engineered safety features (B.1.32.3) systems / auxiliary systems New AMPs Buried Piping and Consistent with XI.M34 engineered safety features 3.0.3.2.1 Tanks Inspection exception systems / auxiliary systems /
Program steam and power conversion (B.1.2) systems Heat Exchanger Plant-specific, engineered safety features -
3.0.3.3.1 Monitoring Program systems / auxiliary systems (B.1.,15)
I Metal-Enclosed Bus Consistent with XL.E4 electrical and instrumentation 310.3.2.12 Inspection Program exceptions and controls (B.1.18)
Non-EQ Inaccessible Consistent XI.E3 electrical and instrumentation 3.0.3.1.5 Medium-Voltage Cable and controls Program (B.1.19)
Non-EQ Consistent XI.E2 electrical and instrumentation 3.0.3.1.6 Instrumentation Circuits and controls Test Review Program (B.1.20)
Non-EQ Insulated Consistent XI.E1 electrical and instrumentation 3.0.3,1.7 Cables and and controls Connections Program (8.1.Z1)
One-Time Inspection Consistent XI.M32 reactor vessel, internals, and 3.0.3,1.8 Program XI.M35 reactor coolant system /
(5.1.23) engineered safety features systems / auxiliary systems Selective Leaching Consistent XI.M33 engineered safety features 3.0.3.1.9 Program systems / auxiliary systems /
(B, 1.27) steam and power conversion systems