ML11342A205

Scoping and Screening Methodology Audit Report Regarding the Limerick Generating Station, Units 1 and 2

ML11342A205
Person / Time
Site:	Limerick
Issue date:	12/09/2011
From:	Robert Kuntz License Renewal Projects Branch 1
To:	Gallagher M Exelon Generation Co
Kuntz R
References
TAC ME6555, TAC ME6556
Download: ML11342A205 (10)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 December 9, 2011 Mr. Michael P. Gallagher Vice President License Renewal Projects Exelon Generation Company, LLC 200 Exelon Way Kennett Square, PA 19348 SUB"IECT:

SCOPING AND SCREENING METHODOLOGY AUDIT REPORT REGARDING THE LIMERICK GENERATING STATION, UNITS 1 AND 2 (TAC NOS. ME6555, ME6556)

Dear Mr. Gallagher:

By letter, dated June 22,2011, Exelon Generation Company, LLC (or the applicant) submitted an application for renewal of operating licenses NPF-39 and NPF-85 for the Limerick Generating Station (LGS) Units 1 and 2. On September 23,2011, the staff of the U.S. Nuclear Regulatory Commission (NRC or the staff) completed the on-site audit of the scoping and screening methodology. The audit report is enclosed.

If you have any questions, please contact me by telephone at (301) 415-3733 or bye-mail at Robert.Kuntz@nrc.gov.

Sincerely, Robert F. Kuntz, enior Project Manager Projects Branch 1 Division of License Renewal Office of Nuclear Reactor Regulation Docket Nos. 50-352 and 50-353

Enclosure:

As stated cc: Listserv

SCOPING AND SCREENING METHODOLOGY AUDIT REPORT FOR THE LIMERICK GENERATING STATION LICENSE RENEWAL APPLICATION I.

Introduction The Division of License Renewal performed an audit of the Limerick Generating Station, Units 1 and 2 (LGS; the applicant), license renewal scoping and screening methodology, developed to support the LGS license renewal application (LRA). The audit was performed during the week of September 19-23, 2011, at the applicant's facility located in Montgomery County, Pennsylvania. The purpose of the audit was to review the applicant's administrative controls governing implementation of the scoping and screening methodology and the technical basis for selected scoping and screening results for various plant systems, structures, and components (SSCs). The audit team also reviewed selected examples of component material and environment combinations, information contained in the applicant's corrective action database relevant to plant-specific age-related degradation, quality practices applied during development of the LRA and the training of personnel who participated in the development of the LRA.

The regulatory bases for the audit were Title 10 of the Code of Federal Regulations, Part 54, "Requirements for Renewal of Operating Licenses for Nuclear Power Plants," (10 CFR Part 54) and NUREG-1800, "Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants," Revision 2 (SRP-LR). In addition, the applicant developed the LRA in accordance with the guidance contained in Nuclear Energy Institute (NEI) 95-10, "Industry Guidelines for Implementing the Requirements of 10 CFR Part 54 - The License Renewal Rule," Revision 6 (NEI95-10), which the NRC has endorsed via Regulatory Guide 1.188, "Standard Format and Content for Applications to Renew Nuclear Power Plant Operating Licenses," (RG 1.188).

II.

Background

10 CFR 54.21, "Contents of Application - Technical Information," requires that each application for license renewal contain an integrated plant assessment (lPA). The IPA must list, for SSCs within the scope of license renewal, the structures and components (SCs) that are subject to an aging management review (AMR). 10 CFR 54.4(a), "Scope," provides the criteria for inclusion of SSCs within the scope of license renewal and 10 CFR 54.21(a)(1) requires that SCs within the scope of license renewal, that are determined to be passive and not periodically replaced, are subject to an AMR.

III.

Scoping Methodology The scoping evaluations for the LRA were performed by the applicant's license renewal project personnel. The audit team conducted detailed discussions with the applicant's management and staff. In addition, the audit team reviewed documentation pertinent to the scoping process.

The audit team assessed whether the scoping methodology outlined in the LRA and implementing procedures was appropriately implemented and consistent with 10 CFR Part 54.

ENCLOSURE

- 2 Verification of Scoping and Screening Results for Portions of Sampled Systems The audit team reviewed a sample of documented scoping results for portions of the safety related service water system and the turbine building. In addition, the staff performed walk downs of selected portions of the following systems:

essential service water

• fuel pool cooling and cleanup system emergency diesel generator system fuel oil transfer and air start subsystems Verification of Scoping and Screening Results for Sampled Components The audit team conducted a review of selected components from the applicant's controlled plant equipment database to confirm the results of the applicant's determination of whether components were within the scope of license renewal and subject to an AMR. The audit team reviewed the selected components, which included mechanical, electrical and structural components, using the Updated Final Safety Analysis Report (UFSAR); system information; and piping and instrumentation drawings to perform its review. The controlled plant equipment database, which provided a list of components, was a primary source of information used during the license renewal scoping and screening process, including scoping and screening reviews, aging management reviews, and assignment of aging management programs (AMP).

The NRC staff independently selected a random sample of eighty-five components from the approximately one hundred and ninety thousand components listed in the plant equipment database and reviewed the component information to determine whether the components were appropriately included within the scope of license renewal and determined to be subject to an AMR. The staff reviewed the component information including the component name, system, function, tag number, location and other documentation. Of the eighty-five randomly selected components, the applicant had included fifty-nine components within the scope of license renewal and determined the components to be subject to an AMR. The applicant had determined twenty-six components were either not within the scope of license renewal or not subject to an AMR (because the component was active or replaced on a periodic basis). The NRC staff reviewed the twenty-six components and confirmed the applicant's conclusion that the twentY-SiX components were not required to be within the scope of license renewal or subject to an AMR, as applicable.

Areas Requiring Additional Information The audit team determined that the applicant's scoping methodology was generally consistent with the requirements of 10 CFR Part 54 for the identification of SSCs that meet the scoping criteria of 10 CFR 54.4(a). However, the audit team determined that additional information was required in order for the staff to complete its review:

• The applicant's procedure CC-MA-304, "Establishing and Maintaining Component Classification," that provides direction on the process to populate the "Q" field in the

- 3 plant equipment database (used, in part, to identify safety-related SSCs within the scope of license renewal) refers to 10 CFR Part 100 as opposed 10 CFR 50.67, although Limerick is an alternate source term plant such that 10 CFR 50.67 is applicable.

Several plant systems discussed in the UFSAR are not identified in the LRA. Systems nomenclature had been organized to correspond with the system information contained in NUREG 1801, "Generic Aging Lessons Learned (GALL) Report," but the process was not described in the LRA.

• The lube oil building, located above the auxiliary boiler pipe tunnel (which contains SR pipe), is not included within the scope of license renewal.

• The applicant did not consistently identify the required supports on all branch connections for nonsafety-related pipe attached to safety-related SSCs.

• The applicant had not included a portion of nonsafety-related pipe, attached to safety-related SSCs, up to and including an anchor or bounding condition within the scope of license renewal. Instead, the applicant identified an anchor directly at the nonsafety-related/safety-related interface (or very close to the interface, on the safety-related side of the interface).

• The applicant did not specifically identify the anchor or bounding condition required for the structural support of non safety-related pipes attached to safety-related SSCs, if the nonsafety-related pipe was included within the scope of license renewal for spatial interaction.

IV.

Screening Methodology The audit team reviewed the methodology used by the applicant to determine if mechanical, structural, and electrical components within the scope of license renewal would be subject to an AMR (screening). The applicant provided the audit team with a detailed discussion of the processes used for each discipline and used the safety-related service water and turbine building as examples in their scoping and screening presentations. The audit team reviewed the applicable implementing procedures and reports and focused on a sample of the documentation for the safety-related service water and the turbine building. The audit team noted that the applicant's screening process was performed in accordance with its written requirements and was consistent with the guidance provided in the SRP-LR and NEI 95-10.

The audit team determined that the screening methodology was consistent with the requirements of 10 CFR Part 54 for the identification of SSCs that meet the screening criteria of 10 CFR 54.21(a)(1).

V.

Component Material and Environment Combinations The staff performed a review to confirm a sample of the component material and environment information contained in the LRA. The staff reviewed the applicant's documentation during the scoping and screening methodology audit and performed the walk-downs during the AMP audit performed during the weeks of October 3 and October 11,2011.

-4 The NRC staff independently selected a random sample of thirty-five components from the "Summary of Aging Management Evaluation" tables (AMR line items) contained in Section 3 of the LRA. The staff verified the information either during a walkdown or through review of the applicant's reference documents. These reference documents included the UFSAR; plant system and design drawings; and component vendor manuals. The staff was able to visually inspect sixteen of the thirty-five selected components.

During the staff review of the thirty-five components, thirty-four of the component material environment combinations were confirmed by the staff.

The staff determined that additional information was required in order for the staff to complete its review.

• The EHC drain tank in the main turbine system (LRA Table 3.4.2-7), exposed to an environment of air/gas-wetted (internal), is listed as having stainless steel as the construction material. This could not be verified by a walkdown or in the documentation provided.

VI.

Site-Specific Operating Experience The SRP-LR provides guidance to the staff on the process to be followed when assessing the ten program elements for each AMP submitted in an LRA. Operating experience (OE) is one of the ten elements and is defined in the SRP-LR and the GALL Report. The site-specific and industry OE also relates to two other AMP elements: detection of aging effects and monitoring and trending. The SRP-LR addresses the importance of the applicant's specific DE in relation to scoping and screening, aging management review, and time-limited aging analysis activities.

During the scoping and screening methodology audit, the staff performed an independent search of the applicant's corrective action report database, using staff selected keywords, to identify occurrences of age-related degradation. This activity was performed independently of the applicant's review of the corrective action report database. The staff identified corrective action reports that contained information concerning age-related degradation that would be used by the staff during the performance of the AMP audit.

VII. Aging Management Program Quality Assurance Attributes The audit team reviewed the AMPs quality assurance elements to verify consistency with the staff's guidance described in SRP-LR, Appendix A, "Branch Technical Positions," Section A.2, "Quality Assurance for Aging Management Programs (Branch Technical Position IQMB-1)."

The AMP quality assurance elements are corrective action, confirmation process, and administrative controls.

The applicant described the AMP quality assurance elements in LRA Appendix A Section A.1.5, "Quality Assurance Program and Administrative Controls," and LRA Appendix B, Section B.1.3, "Quality Assurance Program and Administrative Controls," and the applicant's "Aging Management Program Quality Assurance Elements for License Renewal" document.

LRA Appendices A and B stated that the applicant's existing quality assurance (QA) program will be applied to three AMP elements. The applicant's "Aging Management Program Quality Assurance Elements for License Renewal" document incorporates portions of various QA procedures required to ensure the elements of corrective action program, confirmation process,

- 5 and administrative controls are compliant with the 10 CFR Part 50, Appendix B requirements for all AMPs. The audit team reviewed the AMP basis documents and confirmed that the AMPs incorporate corrective action programs, confirmation processes, and administrative controls as described in the "Aging Management Program Quality Assurance Elements for License Renewal" document.

Based on the audit team's evaluation, review of the AMP basis documents and information contained in LRA Appendix A, Section A.1.5, and Appendix B, Section B.1.3, the staff determined the AMP quality assurance elements to be generally consistent with the staffs position regarding QA for aging management.

VIII. Quality Assurance Controls Applied to LRA Development The staff reviewed the quality controls used by the applicant during development of the LRA, which included:

Performing scoping and screening activities using approved documents and procedures.

Databases were employed to guide and support scoping and screening and generate license renewal documents. These databases were controlled by procedures and included:

o license renewal database - incorporated a list of systems, scoping and screening results, AMRs, LRA generation, implementing procedure tracking, and change control o plant information management system - incorporated the component records list, work planning, and design control o electronic document management system - incorporated procedures, drawings, and controlled design information o maintenance rule database o corrective action program database The audit team performed a review of implementing procedures and guides, examined the applicant's documentation of activities contained in reports, reviewed the applicant's activities performed to assess the quality of the LRA, and held discussions with the applicant's license renewal management and staff. The audit team determined that the applicant's activities provide assurance that the LRA was developed consistent with the applicant's license renewal program requirements.

IX.

Training for License Renewal Project Personnel The staff reviewed the LGS training processes to ensure the guidelines and methodology for the scoping and screening activities were applied in a consistent and appropriate manner. As outlined in procedures, the applicant required training for personnel participating in the development of the LRA and used trained and qualified personnel to prepare the scoping and screening implementing procedures. The training included the following activities:

- 6 Personnel were trained to the applicable project procedures and other relevant license renewal information using LGS procedure LR-LG-1004, "Training of License Renewal Project Team and Site Personnel," as appropriate to their functions.

License renewal and subject matter expert training included:

o 10 CFR Part 54 o relevant NRC and industry guidance documents o lessons learned from other nuclear power plant license renewals o applicable procedures The staff discussed training activities with the applicant's management and staff and reviewed applicable documentation. The audit team determined that the applicant had developed and implemented adequate controls for the training of personnel performing LRA activities.

X.

Final Briefing A final briefing was held with the applicant on September 23, 2011, to discuss the results of the scoping and screening methodology audit. The audit team identified preliminary areas where additional information would be required to support completion of the staff's LRA review.

XI.

Documents Reviewed

1. NUREG-1800, "Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants," Revision 2

2. NEI 95-10, "Industry Guideline for Implementing the Requirements of 10 CFR Part 54 The License Renewal Rule," Revision 6

3. License Renewal Application - Limerick Generating Station, Units 1 and 2

4. Exelon Procedure LS-AA-120 Issue Identification and Screening Process

5. Exelon Procedure LS-AA-125 Corrective Action Program (CAP) Procedure

6. Exelon NO-AA-10 Quality Assurance Topical Report (QATR)

7. Exelon CC-MA-304 Establishing and Maintaining Component Classification

8. LR-LG-1001 License Renewal Process and Definitions

9. LR-LG-1002 Preparation of Basis Documents

10. LR-LG-1 003 License Renewal Document Control

11. LR-LG-1004 Training of License Renewal Project Team and Site Personnel

12. LR-LG-1005 Scoping of Systems and Structures

13. LR-LG-1006 Screening of Systems, Structures and Commodities

14. LR-LG-1007 License Renewal Boundary Drawings

15. LR-LG-1009 Aging Management Reviews

16. LR-LG-1011 Aging Management Program Basis Documents

17. LR-LG-1 012 License Renewal Change Request Process

18. LR-LG-1 015 Assembly, Review, and Verification of the Draft LRA

19. LG-SSBD-A1 10 CFR54.4(a)(1) Safety Related Systems Scoping Basis Document

20. LG-SSBD-A2 10 CFR 54.4(a)(2) System Scoping Criteria Scoping and Screening Basis Document

21. LG-SSBD-AOT Abnormal Operational Transients Scoping and Screening Basis Document

22. LG-SSBD-A TWS 10 CFR 54.4(a)(3) A TWS Systems Scoping and Screening Basis Document

- 7

23. LG-SSBD-E6 Electrical Cable Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Sample Basis Document

24. LG-SSBD-EQ 10 CFR 54.4(a)(3) Environmental Qualification Systems Scoping and Screening Basis Document

25. LG-SSBD-FP 10 CFR 54.4(a)(3) Fire Protection Systems Scoping and Screening Basis Document

26. LG-SSBD-SBO Station Blackout Scoping Basis Document

27. LG-SSBD-SCRN Structures, Component and Commodity Types, With Active, Passive Determinations and Intended Functions Scoping and Screening Basis Document

28. LG-SSBD-SSL License Renewal Systems and Structures Basis Document

29. LG-SSBD-TEA2 Evaluation of Safety-Related Components Located in Nonsafety-Related Structures Scoping and Screening Basis Document

30. System and Structure Scoping Reports (various)

31. Component Summary Screening Reports (various)

32. License Renewal Boundary Drawings (various)

33. LGS Updated Final Safety Analysis Report (UFSAR) Revision 14 XII. NRC Audit Team Members Bill Rogers Stacie Sakai Angela Buford Donald Brittner Edward Smith Gary Armstrong, Jr.

Michael Levine Ogbonna Hopkins Steven Jones Lane Howard Patrick Mackin James Nickolaus NRR/DLR NRR/DLR NRR/DLR NRR/DLR NRR/DSS NRR/DSS NRR/DSS NRR/DSS NRR/DSS DLR Contractor Southwest Research Institute DLR Contractor Southwest Research Institute DSS Contractor Pacific Northwest National Laboratory XIII. Applicant Personnel Contacted During Audit Bill Maguire Patsy Kreamer Pete Gardner Mike Gallagher Dan Doran AI Fulvio Bob Dickinson John O'Rourke Steve Bobyock Chris Wilson John Hunter Nancy Ranek Chris Cooney Gene Kelly Leanne Birkmire Shannon Rafferty-Czincila Joe Szafran Charlotte Geiger Ron Hess Mary Kowalski Jim Jordan Mark Miller Mike Guthrie Deb Spa mer Dave Clohecy Wayne Choromanski Robert Tarr

November 9,2011 Mr. Michael P. Gallagher Vice President License Renewal Projects Exelon Generation Company, LLC 200 Exelon Way Kennett Square, PA 19348

SUBJECT:

SCOPING AND SCREENING METHODOLOGY AUDIT REPORT REGARDING THE LIMERICK GENERATING STATION, UNITS 1 AND 2 (TAC NOS. ME6555, ME6556)

Dear Mr. Gallagher:

By letter, dated June 22,2011, Exelon Generation Company, LLC (or the applicant) submitted an application for renewal of operating licenses NPF-39 and NPF-85 for the Limerick Generating Station (LGS) Units 1 and 2. On September 23, 2011, the staff of the U.S. Nuclear Regulatory Commission (NRC or the staff) completed the on-site audit of the scoping and screening methodology. The audit report is enclosed.

If you have any questions, please contact me by telephone at (301) 415-3733 or bye-mail at Robert.Kuntz@nrc.gov.

Sincerely, IRA!

Robert F. Kuntz, Senior Project Manager Projects Branch 1 Division of License Renewal Office of Nuclear Reactor Regulation Docket Nos. 50-352 and 50-353

Enclosure:

As stated cc: Listserv DISTRIBUTION:

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BC:RPB1 :DLR PM:RPB1:DLR NAME RKuntz SFigueroa DMorey RKuntz DATE 12/9/11 12/9/11 12/9/11 12/9/11 OFFICIAL RIECORD COpy

Letter to Michael Gallagher from Robert F. Kuntz dated November 9, 2011

SUBJECT:

SCOPING AND SCREENING METHODOLOGY AUDIT REPORT REGARDING THE LIMERICK GENERATING STATION, UNITS 1 AND 2 (TAC NOS. ME6555, ME6556)

E-MAIL:

PUBLIC RidsNrrDlr Resource RidsNrrDlrRasb Resource RKuntz DMorey BRogers MSmith,OGC