GO2-11-180, Response to Request for Additional Information Regarding the License Renewal Application
| ML11318A280 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 11/10/2011 |
| From: | Swank D Energy Northwest |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| GO2-11-180 | |
| Download: ML11318A280 (17) | |
Text
David A. Swank ENERGY Engineering General Manager P.O. Box 968, Mail Drop PE23 Richland, WA 99352-0968 Ph. 509-377-2309 F. 509-377-4173 daswank@ energy-northwest.com November 10, 2011 G02-11-180 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001
Subject:
COLUMBIA GENERATING STATION, DOCKET NO. 50-397 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION
References:
- 1) Letter, G02-1 0-11, dated January 19, 2010, WS Oxenford (Energy Northwest) to NRC, "License Renewal Application"
- 2) Letter dated May 24, 2011, NRC to DA Swank (Energy Northwest),
"Request for Additional Information for the Review of the Columbia Generating Station, License Renewal Application," (ADAMS Accession No. ML11138A323)
- 3) Letter dated June 23, 2011, DA Swank (Energy Northwest) to NRC, "Response to Request for Additional Information License Renewal Application," (G02-11-112)
- 4) Letter dated July 11, 2011, DA Swank (Energy Northwest) to NRC, "Response to Request for Additional Information License Renewal Application," (G02-11-117)
- 5) Letter dated August 10, 2011, DA Swank (Energy Northwest) to NRC, "Response to Request for Additional Information License Renewal Application," (G02-11-136)
- 6) Letter dated September 30, 2011, NRC to DA Swank (Energy Northwest), "Request for Additional Information for the Review of the Columbia Generating Station, License Renewal Application," (ADAMS Accession No. ML11272A124)
Dear Sir or Madam:
By Reference 1, Energy Northwest requested the renewal of the Columbia Generating Station (Columbia) operating license. Via Reference 2, the Nuclear Regulatory A)KrL-Vý
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 2 of 2 Commission (NRC) requested additional information related to the Energy Northwest submittal. In Reference 3, Energy Northwest responded to Reference 2. Following conversations with Mr. Arthur Cunanan, NRC License Renewal Project Manager, and other NRC staff members, Energy Northwest decided to revise the response to RAI B.1.4-1 provided in Reference 3 via Reference 4. Following further conversations with Mr. Arthur Cunanan, NRC License Renewal Project Manager, and other NRC staff members, Energy Northwest further revised the response to RAI B.1.4-1 provided in Reference 4 via Reference 5. The NRC requested additional information to the information provided in References 3, 4, and 5 via Reference 6.
Transmitted herewith in the Attachment is the Energy Northwest response to the Request for Additional Information (RAI) contained in Reference 6. This letter contains no new commitments. contains Amendment 47 to the Columbia License Renewal Application.
If you have any questions or require additional information, please contact Abbas Mostala at (509) 377-4197.
I declare under penalty of perjury that the foregoing is true and correct. Executed on the date of this letter.
Respectfully, Engineering General Manager
Attachment:
Response to Request for Additional Information
Enclosure:
License Renewal Application Amendment 47 cc: NRC Region IV Administrator NRC NRR Project Manager NRC Senior Resident Inspector/988C EFSEC Manager RN Sherman - BPA/1 399 WA Horin - Winston & Strawn AD Cunanan - NRC NRR (w/a)
John Daily - NRC NRR (w/a)
BE Holian - NRC NRR MA Galloway - NRC NRR RR Cowley - WDOH
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 1 of 12 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION "Request for Additional Information for the Review of the Columbia Generating Station, License Renewal Application,"
(ADAMS Accession No. ML11272A124)
RAI B.1.4-2
Background:
In request for additional information (RAI) B.1.4-1 issued on May 24, 2011, the staff asked the applicant to describe the programmatic activities that will be used to continually identify aging issues, evaluate them and, as necessary, enhance the aging management programs (AMPs) or develop new AMPs for license renewal. In its response dated June 23, 2011, and later revised in a letter dated July 11, 2011, the applicant stated that it will use its current corrective action program (CAP) and operating experience program (OEP) to continually monitor and evaluate plant-specific and industry operating experience related to aging.
Issue:
In its response, as revised, the applicant provided a general description of the processes used to evaluate operating experience on an ongoing basis; however, the applicant did not provide specifics on how aging-related issues are addressed under these processes. Specifically, the applicant did not address the following items:
(a) The applicant did not describe a means for identifying and categorizing operating experience items as related to aging.
(b) The applicant did not describe how evaluations of operating experience items related to aging consider the fundamental components of an aging management review, which are the following:
- Systems, structures, or components
- materials
" environments
- aging effects
- aging mechanisms
" AMP(s)
(c) The applicant did not describe training requirements specific to aging issues for those plant personnel responsible for screening, evaluating, and submitting operating experience items.
(d) The applicant did not describe how it will consider as operating experience the results of the AMP inspections.
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 2 of 12 (e) The applicant stated that it does not consider certain guidance documents to be sources of operating experience. However, the staff believes that the content of the document, not the source, is the most important consideration. Guidance documents, such as NUREG-1801, "Generic Aging Lessons Learned (GALL) Report," provide a convenient source of operating experience information, useful recommendations, and best practices. As such, the staff believes there is significant value in considering new guidance applicable to aging management. An effective operating experience program should include a broad range of inputs and, therefore, it is inappropriate to exclude consideration of specific issues in guidance documents.
(f) The applicant stated that, under the OEP, supervisors are responsible for ensuring the timely completion of operating experience evaluations; however, the applicant provided no additional detail on what constitutes a timely evaluation.
Request Respond to each item below for both the CAP and OEP:
(a) Describe how operating experience issues will be identified and categorized as related to aging.
(b) Describe how evaluations of operating experience issues related to aging will consider the following:
- systems, structures, or components
" materials
- environments
- aging effects
- aging mechanisms
- AMP(s)
(c) Describe the training requirements on aging issues for those plant personnel responsible for screening, evaluating, and submitting operating experience items.
(d) Describe how the results of the AMP inspections will be reviewed.
(e) Provide a plan for considering the content of guidance documents, such as the GALL Report, as operating experience applicable to aging management programs.
(f) Describe what constitutes a timely evaluation under the OEP.
Energy Northwest Response:
Refer to the below attached Flowchart for a high level overview of the Corrective Action Program (CAP) and Operating Experience Program (OEP) process as it relates to aging
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 3 of 12 management process and how each of the NRC requests for additional information are addressed:
High Level Overview of OE Process
0
- 1. Internal Operating Experience Identification All employees are required by the governing corrective action procedure to promptly document into condition reports (CRs) discovered degraded and non-conforming conditions (i.e., via an electronic form). The definition of degraded includes the effects of aging. By procedure, it is the responsibility of all employees to identify any issue or condition that doesn't look as if it is right using the AR-CR process.
Examples of plant issues cited in the procedure that requires initiation of a CR include:
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 4 of 12
- Broken/damaged or failed equipment
- Degraded equipment or equipment not performing as expected or per design
- Visual signs of excessive wear or corrosion
- Leaks (oil, water, packing, steam, etc.)
Degraded and non-conforming conditions identified during Aging Management Program (AMP) inspections or program activities are entered as CRs into the CAP. The license renewal implementation procedure, which is currently being issued, requires that the AMP owner review data collected by the program, initiate CRs for any conditions that are unsatisfactory to ensure they will be addressed and corrected, maintain required records for the program (electronic or hardcopy) and maintain the program current and implement revisions as needed based on program results and internal or external operating experience.
In addition to observations made by other employees, system engineers are required by procedure to conduct routine walk downs on at least a quarterly basis of the systems under their responsibility. These walk downs include specific evaluation of mechanical, electrical, and structural conditions. Checklists are used that include numerous material conditions to look for. Just a few examples from the checklist include:
" Inspect equipment pedestal for cracking (concrete) or other signs of deterioration
- Check for Pumps/Fans Mounting/Grouting in good condition
" Check surface condition of exposed structural welds
- Check fasteners/Bolts/Studs (loose, stripped, missing, insufficient thread engagement)
" Check for evidence of Bolt Torque relaxation
" Check for Leaks (water, steam, lubricant, chemical, air, compressed gas, etc.)
" Check for degraded paint and rusted piping, components, hangers, baseplates
" Check cables or leads (unsecured, worn/frayed insulation, improper terminations, etc.)
- Inspect for condition of Insulation (Discolored, missing, loose)
" Inspect for Evidence of Corrosion Specific aging management training has been provided to all system engineers as well as other engineering personnel on the identification and detection of aging issues. EPRI guidance on aging identification was provided in this course.
Subsequent training is planned for the Engineering staff on a recurring basis as determined using the Systematic Approach to Training process.
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 5 of 12 Periodic training on identifying aging issues to equipment operators, maintenance personnel and other plant personnel that access the plant on a routine basis is being planned for.
- 2. Corrective Action Program The CAP ensures the following: A broad range of issues or conditions can be documented and coded to enable trending for the purpose of addressing broader programmatic or process weaknesses. In accordance with plant procedures, Conditions Adverse to Quality (CAQs) and Significant Conditions Adverse to Quality (SCAQs) are identified, reported to the appropriate level of management, and subsequently corrected. The cause of the condition is determined and corrective actions are taken to preclude recurrence. The CAP implements the requirements of 10 CFR 50, Appendix B, Criterion XVI. As such, the CAP is used to monitor plant-specific OE, which includes aging related conditions identified during AMP inspections and other program activities.
- 3. Department Reviews Each working day, the CRs that were generated from the previous day (or previous days if on a Monday) are compiled in a report for individual department reviews. A corrective action review group assigns priorities and owners to each CR. They receive input from departmental reviews.
Management reviews of newly issued CRs are conducted to ensure that the correct responsible owner and significance are identified.
For defense in depth, and as part of the roles and responsibility of the License Renewal Implementation Coordinator (LRIC), all CRs are evaluated by the LRIC to identify failures or degradations that may be related to aging effects on long lived passive system, structures, and components (SSC). LRIC is currently a License Renewal Project team member who provides this function and the LRIC will take over this role during the implementation phase and continue through the period of extended operation (PEO).
- 4. Condition Report Resolution CRs identified by the LRIC reviews as being, or potentially being, aging related are tagged with the key word "Aging." They are then evaluated (aging assessment) by the LRIC for SSC, materials, environments, aging effects, and aging mechanisms and determine if there is an existing AMP that covers the aging issue or if a new AMP may be required. The LRIC determines if the applicable AMP owner(s) needs to perform a more detailed review. The applicable AMP owner(s) reviews the issue for affected SSC, materials, environments, aging effects, and aging mechanisms. This review determines if any of the following are required: adjustment to the frequency of future
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 6 of 12 inspections, new inspections, and a detailed review is performed of component, material, environment, and aging effect combinations. These reviews are maintained in a retrievable and auditable form in an electronic database. The roles and responsibilities of the LRIC are spelled out in the implementation procedure and are based on guidance from the License Renewal Implementation Working Group and industry best practice.
The LRIC is required to have completed the following training:
Identification of SSC and their materials, environments, aging effects, aging mechanisms, and associated AMPs as identified in NUREG-1801 and the Scoping, Screening and Aging Management Review criteria as contained in NEI 95-10. This training will be documented and retrievable.
The LRIC is also responsible for maintaining involvement in NEI License Renewal Task Force (LRTF) and License Renewal Implementation Working Group (LRIWG).
This position is currently staffed by a member of the License Renewal Project team. All members of the team have had the training listed above.
Documentation of this training is retrievable.
The current AMP owners for existing and new AMPs were selected based on educational background and job experience or duties. In addition, those that are in the Engineering Support Personnel (ESP) population have received classroom training on component aging. Documentation of this training is retrievable. The current AMP owners that are not within the ESP population are trained due to their job position such as being qualified riggers, in the NDE group, or Chemistry group.
The AMP owner training will address identification of structures and components and their materials, environments, aging effects, aging mechanisms, associated with their particular AMP as discussed in NUREG-1801 and the LRA and the Scoping, Screening and Aging Management Review criteria as contained in NEI 95-10 and the applicable EPRI tools for the AMPs discipline. This training will be documented and retrievable. Training to their specific AMP is acceptable as the LRIC is required to be trained to all AMPs and aspects of license renewal as the LRIC maintains oversight for the entire program of license renewal. Currently, each AMP has a primary and backup owner identified. Both owners are subject to the above mentioned training requirements which provide defense in depth should either be away for an extended period of time or leave the position. New owners will also be subject to these training requirements.
Currently, departments assigned with responsibility to respond to condition reports have 30 days to initially address the identified conditions. Further
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 7 of 12 responses to CRs are managed in accordance with the safety significance of each identified condition.
- 5. Lessons Learned Shared with the Industry Noteworthy internal operating experience (OE) is shared with the industry. The implementation procedure is currently being issued to provide guidance on sharing internal OE related to License Renewal issues such as aging effects or mechanisms not previously identified, changes to aging management programs that would be of interest to the industry such as new testing methods, acceptance criteria, or preventative measures and results of inspections performed that would be of interest to the industry.
The LRIC is responsible to identify internal OE that should be shared with the industry and to work with the OE Coordinator to report these issues to the industry.
- 6. Industry Operating Experience The industry OEP uses various source documents (e.g., INPO, NRC, or NEI websites) for applicable OE reports, but does not limit what documents may be used as sources. The procedure has been revised to include License Renewal Interim Staff Guidance documents and revisions to NUREG-1801 as source documents as well. Also, AMPs are covered by a plant procedure requiring periodic self assessments. This procedure states if a benchmark or self-assessment finds areas, programs, or processes which require further investigation to determine if a gap to industry standards exists then the Corrective Action Program is used to address the gap.
- 7. Operating Experience program The goal for the OEP is to use lessons learned from industry and station OE effectively and efficiently to improve plant safety and reliability and to reduce the number and consequence of events. Aging issues can play a part in these elements of the OEP.
- 8. OE Team Review Weekly screening meetings with select OE department leads are held to review and discuss the OE source documents within the context of criteria described in the plant procedure for the purpose of identifying any susceptibility at Columbia to occurrence of a similar event.
For defense in depth, and as part of the roles and responsibility of the LRIC, the LRIC is a member of the OE review team and evaluates the source documents for effects on AMPs. The LRIC has the primary responsibility for ensuring that
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 8 of 12 external OE is evaluated for making necessary changes to AMPs. OEs identified as potentially involving an aging issue will be coded as "Aging" which will allow them to become easily retrievable in the database. The implementation procedure is currently being issued and the OEP procedure has been revised to formalize this function.
- 9. OE Resolution All OEs are evaluated by the LRIC to identify failures or degradations that may be related to aging effects on long lived passive SSC. OEs identified by these reviews as being, or potentially being, aging related will be key worded "Aging" They are then evaluated (aging assessment) by the LRIC for SSC, materials, environments, aging effects, and aging mechanisms and determine if there is an existing AMP that covers the aging issue or if a new AMP may be required. The LRIC determines if the applicable AMP owner(s) needs to perform a more detailed review. The applicable AMP owner(s) reviews the issue for affected SSC, materials, environments, aging effects, and aging mechanisms. This review determines if any of the following are required: adjustment to the frequency of future inspections, new inspections, and a detailed review is performed of component, material, environment, and aging effect combinations.
These reviews are maintained in a retrievable and auditable form in an electronic database. The roles and responsibilities of the LRIC are spelled out in the implementation procedure, which is currently being issued, are based on guidance from the License Renewal Implementation Working Group and industry best practice.
OE evaluations are assigned with a due date 60 days from initiation. Actions identified out of the evaluation are given a due date of 180 days or less if warranted. Exceptions are controlled by procedure.
Summary The current CAP and OEP provide reasonable assurance that internal and external issues associated with material, environment, aging effects, aging mechanisms, and AMPs are adequately reviewed and incorporated into existing, new, and potential future AMPs. However, to provide further assurance that programmatic activities will be used to continually identify aging issues, evaluate the issues, and as necessary, enhance the AMPs or develop new AMPs, the OEP procedure has been revised and the license renewal implementation procedure is being issued. The license renewal implementation procedure provides additional guidance on review of OE and formalizes roles and responsibilities of the LRIC and AMP Owners and outlines required training for these positions.
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 9 of 12 The following is a summary of the response for each question.
(a) Describe how operating experience issues will be identified and categorized as related to aging.
Refer to 3. Department Reviews, 4. Condition Report Resolution, 8 OE Team Review, and 9. OE Resolution.
The LRIC reviews all internal operating experience and is part of the team that screens external operating experience. The LRIC determines if operating experience is associated with aging of long lived passive structures or components. OEs identified by these reviews as being, or potentially being, aging related will be key worded "Aging".
(b) Describe how evaluations of operating experience issues related to aging will consider the following:
" systems, structures, or components
" materials
" environments
" aging effects
- aging mechanisms
- AMP(s)
Refer to 4. Condition Report Resolution and 9. OE Resolution.
The LRIC reviews (aging assessment) the internal or external OE for SSC, materials, environments, aging effects, and aging mechanisms and determine if there is an existing AMP that covers the aging issue or if a new AMP may be required. The LRIC determines if the applicable AMP owner(s) needs to perform a more detailed review. The applicable AMP owner(s) reviews the issue for affected SSC, materials, environments, aging effects, and aging mechanisms. This review determines if any of the following are required: adjustment to the frequency of future inspections, new inspections, and a detailed review is performed of component, material, environment, and aging effect combinations. These reviews are maintained in a retrievable and auditable form in an electronic database.
(c) Describe the training requirements on aging issues for those plant personnel responsible for screening, evaluating, and submitting operating experience items.
Refer to 1. Internal Operating Experience Identification, 4. Condition Report Resolution, and 5. Lessons Learned Shared with the Industry
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 10 of 12 Specific aging management training has been provided to all system engineers as well as other engineering personnel on the identification and detection of aging issues. EPRI guidance on aging identification was provided in this course. Subsequent training is planned for the Engineering staff on a recurring basis as determined using the Systematic Approach to Training process.
Periodic training on identifying aging issues to equipment operators, maintenance personnel and other plant personnel that access the plant on a routine basis is being planned for.
The LRIC is required to have completed the following training:
Identification of SSC and their materials, environments, aging effects, aging mechanisms, and associated AMPs as identified in NUREG-1801 and the Scoping, Screening and Aging Management Review criteria as contained in NEI 95-10. This training will be documented and retrievable.
The LRIC is also responsible for maintaining involvement in NEI License Renewal Task Force (LRTF) and License Renewal Implementation Working Group (LRIWG).
This position is currently staffed by a member of the License Renewal Project team. All members of the team have had the training listed above.
Documentation of this training is retrievable.
The current AMP owners for existing and new AMPs were selected based on educational background and job experience or duties. In addition, those that are in the Engineering Support Personnel (ESP) population have received classroom training on component aging. Documentation of this training is retrievable. The current AMP owners that are not within the ESP population are trained due to their job position such as being qualified riggers, in the NDE group, or Chemistry group.
The AMP owner training will address identification of structures and components and their materials, environments, aging effects, aging mechanisms, associated with their particular AMP as discussed in NUREG-1 801 and the LRA and the Scoping, Screening and Aging Management Review criteria as contained in NEI 95-10 and the applicable EPRI tools for the AMPs discipline. This training will be documented and retrievable. Training to their specific AMP is acceptable as the LRIC is required to be trained to all AMPs and aspects of license renewal as the LRIC maintains oversight for the entire program of license renewal.
Currently, each AMP has a primary and backup owner identified. Both owners are subject to the above mentioned training requirements which provide defense in depth should either be away for an extended period of
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 11 of 12 time or leave the position. New owners will also be subject to these training requirements.
Noteworthy internal operating experience (OE) is shared with the industry.
The implementation procedure is currently being issued to provide guidance on sharing internal OE related to License Renewal issues such as aging effects or mechanisms not previously identified, changes to aging management programs that would be of interest to the industry such as new testing methods, acceptance criteria, or preventative measures and results of inspections performed that would be of interest to the industry.
The LRIC is responsible to identify internal OE that should be shared with the industry and to work with the OE Coordinator to report these issues to the industry.
(d) Describe how the results of the AMP inspections will be reviewed.
Refer to 1. Internal Operating Experience Identification and 4. Condition Report Resolution.
Degraded and non-conforming conditions identified during Aging Management Program (AMP) inspections or program activities are entered as CRs into the CAP. The license renewal implementation procedure, which is currently being issued, requires that the AMP owner review data collected by the program, initiate CRs for any conditions that are unsatisfactory to ensure they will be addressed and corrected, maintain required records for the program (electronic or hardcopy) and maintain the program current and implement revisions as needed based on program results and internal or external operating experience.
CRs identified by the LRIC reviews as being, or potentially being, aging related are tagged with the key word "Aging." They are then evaluated (aging assessment) by the LRIC for SSC, materials, environments, aging effects, and aging mechanisms and determine if there is an existing AMP that covers the aging issue or if a new AMP may be required. The LRIC determines if the applicable AMP owner(s) needs to perform a more detailed review. The applicable AMP owner(s) reviews the issue for affected SSC, materials, environments, aging effects, and aging mechanisms. This review determines if any of the following are required:
adjustment to the frequency of future inspections, new inspections, and a detailed review is performed of component, material, environment, and aging effect combinations. These reviews are maintained in a retrievable and auditable form in an electronic database
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 12 of 12 (e) Provide a plan for considering the content of guidance documents, such as the GALL Report, as operating experience applicable to aging management programs.
Refer to 6. Industry Operating Experience.
The industry OEP uses various source documents (e.g., INPO, NRC, or NEI websites) for applicable OE reports, but does not limit what documents may be used as sources. The procedure has been revised to include License Renewal Interim Staff Guidance documents and revisions to NUREG-1801 as source documents as well. Also, AMPs are covered by a plant procedure requiring periodic self assessments. This procedure states if a benchmark or self-assessment finds areas, programs, or processes which require further investigation to determine if a gap to industry standards exists then the Corrective Action Program is used to address the gap.
(f) Describe what constitutes a timely evaluation under the QEP.
Refer to 9. OE Resolution.
OE evaluations are assigned with a due date 60 days from initiation.
Actions identified out of the evaluation are given a due date of 180 days or less if warranted. Exceptions are controlled by procedure.
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 1 of 1 LICENSE RENEWAL APPLICATION AMENDMENT 47 Section Page RAI Number Number Number A.2.1 A-8a B.1.4-2 A.2.1 A-8b B.1.4-2
ISection A.2.1 Columbia Generating Station License Renewal Application Technical Information Insert A:
Intern-al and external operating exeinei9eiwdi codnewt h OQAPD. ThA reView asurAes the existin, new,, and any future required aging management programs niecessary to provid@ reassoniabis assurance that components within the scope of lificense renewaI;l wi ll rontinuo to perform their intended functions consistent With the current licensing basis (rLB) for the period of extend-ed operation.
L The existing Corrective Action Program and the Operating Experience Program ensure, through the continual review of both plant-specific and industry operating experience, that the license renewal aging management programs are effective to manage the aging effects for which they are credited. The aging management programs are either enhanced or new programs are developed when the review of operating experience indicates that the aging management programs may not be effective. For each aging management program listed in this section, operating experience is reviewed on a continuing basis.
Insert A from page A-8bI Final Safety Analysis Report Supplement Page A-8a m e I'me -'ent' 1. ;.1ýý .Amen~dment ý47
Columbia Generating Station License Renewal Application Technical Information Insert A:
The processes and procedures for the review of operating experience address the following points:
All operating experience is screened for aging of long lived passive structures or components and further evaluation as applicable is performed by personnel trained in the requirements of license renewal scoping, screening, and aging management reviews (aging effects and mechanisms). The evaluation is completed and prioritized commensurate with the potential significance of the issue. Such evaluations are documented and retained in an auditable and retrievable form.
- When it is determined that enhancements are necessary to adequately manage the effects of aging, the enhancements are entered into and implemented consistent with the plant corrective action program or operating experience program, as applicable. Enhancements can include, as appropriate, modifications to AMPs or the creation and implementation of new AMPs.
" Operating experience that is related to aging of long lived passive structures or components is keyword tagged "Aging."
- The processes are adequate so as to not preclude the consideration of operating experience related to aging management. The processes appropriately gather information on all structures and components within the scope of license renewal, and their materials, environments, aging effects, and aging mechanisms. In addition, the processes include the AMPs credited for managing the effects of aging, and the activities under these AMPs (e.g., inspection methods, preventive actions, evaluation techniques, etc.).
- While the programs and procedures may specify reviews of certain sources of information, such as NRC generic communications and Institute of Nuclear Power Operations reports, they allow for any potential source of relevant plant-specific or industry operating experience information.
" AMP owners review data collected by the AMPs, utilize the corrective action program for any conditions that are unsatisfactory to ensure they will be addressed and corrected, maintain required records for the program and maintain the program current and implement revisions as needed based on program results and internal or external operating expectance.
- Provide guidance on sharing internal operating experience related to license renewal issues with the industry.
Final Safety Analysis Report Supplement Page A-8b Amendment 47