ML15238A251

Discusses 960426 Visit to Oconee Nuclear Power Station to Review Implementation of NEI Guideline 95-10,Rev 0, Industry Guideline for Implementing 10CFR54 - License Renewal Rule

ML15238A251
Person / Time
Site:	Oconee
Issue date:	05/21/1996
From:	Newberry S NRC (Affiliation Not Assigned)
To:	Hampton J DUKE POWER CO.
References
PROJECT-690 NUDOCS 9605240191
Download: ML15238A251 (39)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 May 21, 1996 Duke Power Company Mr. James Hampton, Vice-President Oconee Nuclear Station P.O. Box 1439 Seneca, SC 29679

SUBJECT:

LICENSE RENEWAL DEMONSTRATION PROGRAM SITE VISIT, OCONEE NUCLEAR POWER STATION TRIP REPORT

Dear Mr. Hampton:

An NRC team visited Oconee Nuclear Power Station from April 22 through April 26, 1996, to review the implementation of the Nuclear Energy Institute guideline (NEI 95-10), Revision 0, "Industry Guideline for Implementing the Requirements of 10 CFR Part 54 - The License Renewal Rule."

Members of the visiting team included Dr. P.T. Kuo (Team Leader), Scott Flanders, Robert Prato, Christopher Regan, and Paul Shemanski.

The objectives for this license renewal demonstration program (LRDP) site visit were to 1) assess the effectiveness of NEI 95-10 to implement an effective license renewal (LR) program, 2) assess the participant's implementation process and supporting information for consistency with NEI 95-10 relating to documentation, controls, consistency, and completeness,

3) assess the level of detail used to describe aging-management activities, time-limiting aging analyses (TLAAs), and Final Safety Analysis Report (FSAR) supplements, 4) assess the use and integration of topical reports, and

5) assess the need for improvements to NEI 95-10. To accomplish these objectives the team performed a review of the implementation of NEI 95-10 by your staff using the LRDP site visit plan. This LRDP site visit did NOT include the review of any plant-specific program for the purpose of determining its adequacy or acceptability in fulfilling the requirements of the Rule.

The team reviewed your general LR process; the aging-management review process for the Core Flood System, Main Feedwater System, Low Pressure Service Water System, Reactor Coolant System, cables, and structures and structural components; the time-limiting aging analyses for cabling and the spent fuel racks; and a sample FSAR Supplement. The team also gathered information relating to consumables, generic communications, unresolved safety issues (USIs) and generic safety issues (GSIs).

The review team discussed their detailed observations daily with members of your staff. In addition, a summary of the team's observations was presented to Oconee management during an exit meeting on April 26, 1996. The observations presented are provided below.

9605240191 960521 PDR ADOCK 05000269 P

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May 21, 1996 In general, your LR program appeared to follow the guidance in NEI 95-10 for scoping, screening, and identifying intended functions and aging effects. Refer to NEI 95-10, Section 3 and § 4.1.

The draft GSI/USI review process appeared reasonable and consistent with NEI 95-10. Refer to NEI 95-10, § 1.5.

The process for performing an aging-management review by grouping structures and components based on material of construction and service environment was consistent with NEI 95-10 and appeared to be effective and efficient. Refer to NEI 95-10, § 4.1.2, and § 4.2.1.1.

The staff was presented a description of the overall aging-management review process as being "component + aging effect + aging-management program = demonstration." This interpretation of NEI 95-10, § 4.2.1, led to inconsistencies between your aging-management and demonstration processes and NEI 95-10, § 4.2.1.2, and § 4.2.1.3, respectively. The staff provided a clarification of the overall aging-management processes as intended by NEI 95-10, § 4.2.1.2, and § 4.2.1.3, as being "component +

aging effect + aging-management program + demonstration = reasonable assurance that intended function will be maintained." Refer to NEI 95-10, § 4.2.1, § 4.2.1.2, and § 4.2.1.3.

Because system level scoping was initially used, a description of the system level scoping process should have been provided to describe the method used to identify mechanical systems' components, to be consistent with the intent of NEI 95-10. Refer to NEI 95-10, § 4.1, 6.2.

Commodity groups were identified but the individual structures and components were not listed in the information presented to the site visit team. To be consistent with the intent of the NEI 95-10, the site visit teams believe that a list of the different groups of components as applied in the participant's program and the numbers and types of components in each group should be provided in the application.

Regardless of the need to submit a list in the application, a list of individual structures and components needs to be maintained on site.

Refer to NEI 95-10, § 4.1.

Specification OSS-0274.00-00-0002, "Oconee Mechanical Component Screening Specification for License Renewal," identified "pressure boundary" as the only intended function for all piping components. It appeared that this conclusion was reached after your staff assessed only a small portion of the systems in the scope of your LR program. All potentially applicable intended functions for each structure, component, or commodity group within the scope of your LR program needs to be assessed independently to ensure all passive intended functions are identified as intended by NEI 95-10, § 4.1.2. During these discussions, heat transfer was identified by your staff as an active function without justification relating to the guidance provided in NEI 95-10. Refer to NEI 95-10,

§ 4.1.2.

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May 21, 1996 Specification OSS-0274.00-00-0005, "Oconee Mechanical Components Aging Management Review Specification for License Renewal," used existing aging-management programs to justify potentially plausible aging effects as not being applicable. This is not consistent with the guidance provided in NEI 95-10. Refer to NEI 95-10, § 4.2.

The need to maintain the intended function under all current licensing basis (CLB) design conditions was not clearly documented in the information presented to the staff. Refer to NEI 95-10, § 4.2.

The Babcox and Wilcock Owners Group (B&WOG) Reactor Coolant System (RCS)

Piping Report was referenced and utilized as the key source of technical justification in the information presented to the staff relating to the RCS. However, your staff did not demonstrate applicability of the information presented in the report to their site. Validation of information regarding key parameters such as materials of construction, temperature, configuration, and other service environments should be provided in the application. Refer to NEI 95-10, § 4.2.2.1.

Because of the extended period of time between topical report approvals and submittal of application, a description of any change (or the absence of any change) in plant conditions, as they relate to the information presented in the report, is needed. Refer to NEI 95-10, § 4.2.2.

Specification OSS-0274.00-00-0005, "Oconee Mechanical Components Aging Management Review Specification for License Renewal," did not contain a demonstration that the applicable aging-management programs will effectively maintain the intended function of the component during the period of extended operation as described in NEI 95-10. Refer to NEI 95-10, § 4.2.1.3.

In a separate effort (developed as a result of observing the first demonstration site visit), your staff produced a demonstration for the erosion/corrosion program which was intended to meet the specific guidance in NEI 95-10, § 4.2.1.3. This attempt resulted in an improved sample of a LR application submittal but lacked "objective evidence" that demonstrated the effectiveness of the aging-management program for the period of extended operation. A summary of the observed results from the implementation of your erosion/corrosion program would have provided the "objective evidence" needed. Refer to NEI 95-10, § 4.2.1.3 and Appendix C, Example 2.

The inspection programs presented by your staff did not specifically address the inspection of components in inaccessible areas.

Refer to NEI 95-10, § 4.3.1.

Specification OSS-0274.00-00-0006, "Oconee Integrated Plant Assessment (IPA) of Electrical Components for License Renewal," included a reference to the Sandia Aging Management Guide but did not discuss the test data contained in the guide relevant to the cable under review. Refer to NEI 95-10, § 4.2.2.1.

4 May 21, 1996 Specification OSS-0274.00-00-0008, "Time-Limiting Aging Analysis (TLAA) of Electrical Components for License Renewal," did not include a discussion of Generic Issue 168, "Environmental Qualification of Electrical Equipment." Refer to NEI 95-10, § 4.2.2.

The pressurized thermal shock (PTS) evaluation presented to the staff stated that the PTS TLAA has been projected to 40 years and will be monitored continuously during the period of extended operation. The PTS evaluation needs to be projected to 60 years prior to application. Refer to NEI 95-10, § 5.1.4.

The draft FSAR Supplement presented to the staff did not contain a summary description of the appropriate aging-management program. Refer to NEI 95-10, § 6.3.

In addition to observations relating to your LR program, some areas of NEI 95-10 that may need improvement were presented during the exit meeting.

The staff will continue to assess the adequacy of the NEI guideline in these and other areas throughout the demonstration program. The areas of the guideline that may require additional guidance are described below.

The current NEI 95-10 guidance that describes the "demonstration" of an effective aging-management program may need additional guidance to assist applicants in meeting the intent of Title 10 of the Code of Federal Regulation, Part 54 (10 CFR Part 54).

Refer to NEI 95-10, § 4.2.1.3,

§ 4.2.2.1, § 4.2.2.2, and § 4.2.3.2.

The relationship between the licensee's aging-management review process and the demonstration process needs clarification. Refer to NEI 95-10,

§ 4.2.1, § 4.2.1.2, and § 4.2.1.3.

Determining the level of detail for many areas of the LR process is a primary objective of the LRDP. Concerns have been identified with the information used to describe the aging-management and demonstration processes. During the site visit, attempts to better implement NEI 95-10 were clearly evident by the information presented. The staff will continue to assess these concerns and build on our observations from the LRDP to determine the need for additional guidance in this area.

Refer to NEI 95-10, § 4.2.1.2, § 4.2.1.3, and § 6.0.

Additional guidance for developing a LR FSAR Supplement is needed. Refer to NEI 95-10, § 6.3.

Additional guidance is needed to clarify the requirements for listing structures and components relating to LR. Refer to NEI 95-10, § 4.1, and § 4.4.1.

Additional details on the staff's observations are provided in Enclosure 1 to this site visit report. A list of those who attended the entrance meeting of April 22, 1996, and the exit meeting of April 26, 1996, are provided in of this report.

5 -May 21, 1996 The team would like to note that your staff was cooperative and open throughout the demonstration which helped the team meet its objective.

Sincerely, Original signed by Scott F. Newberry, Director License Renewal Project Directorate Division of Reactor Program Management Office of Nuclear Reactor Regulation Project No.

690 Docket Nos.: 50-269, 50-270, and 50-287

Enclosures:

1. Staff's Observations from LRDP Site Visit at Oconee Nuclear Power Station

2. Entrance Meeting and Exit Meeting Attendance List cc:

See attached lists DISTRIBUTION:

w/o attachments w/attachments WRussell/FMiraglia, 0-12G18 Central File RZimmerman, O-12G18 PUBLIC GHolahan, 0-8E2 PDLR R/F

AThadani, O-12G18 SHoffman BSheron, 0-7D26 DCrutchfield, O-11H21 BGrimes, 0-11H21 ACRS (4)

EJordan, T-4D18 JMoore/EHoller, 0-15B18 DMcDonald 0-14B2 DISTRIBUTION: via E-Mail w/o attachments JMitchell, EDO CSerpan,.RES LShao, RES MMayfield, RES JVora, RES SDroggitis, OSP AMurphy, RES RWessman, NRR SPeterson, NRR

GBagchi, NRR

HBrammer, NRR JStrosnider, NRR RCorreia, NRR

.GMizuno, 0CC RFrahm, Jr., NRR PDLR Staff See previous concurrence DOCUMENT NAME:

A:\\TRIP2REP.MEM (DISK 10)

To receive a copy of tis document, Indlicate, in the box: "C" = Copy without attachment/enclosure "E" =Copy with attachment/enclosure "N"

No copy OFFICE ME:PDLR*

LA:PDLR*

H SC:PDLR*

H PM: DRPE*

PD:PDLR NAME RPrato:ng LLuther PKuo DLaBarre aSNewmNrry 196 h2a V96 DATE ~~~~

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Srggts OSP/615/49 52/9 0/59

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May 21, 1996 The team would like to note that your staff was cooperative and open throughout the demonstration which helped the team meet its objective.

Sincerely, Scott F. Newberry, Direc r License Renewal Project ctorate Division of Reactor Program Management Office of Nuclear Reactor Regulation Project No. 690 Docket Nos.: 50-269, 50-270, and 50-287

Enclosures:

1. Staff's Observations from LRDP Site Visit at Oconee Nuclear Power Station

2. Entrance Meeting and Exit Meeting Attendance List cc: See attached lists

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NUCLEAR ENERGY INSTITUTE (NEI) may 21, 1996 Project No. 690 cc:

Mr. Dennis Harrison U.S. Department of Energy NE-42 Washington, DC 20585 Mr. Douglas J. Walters Nuclear Energy Institute 1776 I Street, NW Suite 300 Washington, DC 20006 Mr. Richard P. Sedano, Commissioner State Liaison Officer State of Vermont Department of Public Service 112 State Street Drawer 20 Montpelier, Vermont 05620-2601

DUKE POWER May 21, 1996 Oconee Nuclear Power Station Unit 1 Docket No. 50-269 Unit 2 Docket No. 50-270 Unit 3 Docket No. 50-287 cc:

Mr. Paul R. Newton Mr. Ed Burchfield Legal Department (PBO5E)

Compliance Duke Power Company Duke Power Company 422 South Church Street Oconee Nuclear Site Charlotte, North Carolina 28242-0001 P. 0. Box 1439 Seneca, South Carolina 29679 J. Michael McGarry, III, Esquire Winston and Strawn Ms. Karen E. Long 1400 L Street, NW.

Assistant Attorney General Washington, DC 20005 North Carolina Department of Justice Mr. Robert B. Borsum P. 0. Box 629 B&W Nuclear Technologies Raleigh, North Carolina 27602 Suite 525 1700 Rockville Pike Mr. G. A. Copp Rockville, Maryland 20852-1631 Licensing -

ECO50 Duke Power Company Manager, LIS 526 South Church Street NUS Corporation Charlotte, North Carolina 28242-0001 2650 McCormick Drive, 3rd Floor Clearwater, Florida 34619-1035 Dayne H. Brown, Director Division of Radiation Protection Senior Resident Inspector North Carolina Department of U. S. Nuclear Regulatory Commission Environment, Health and Route 2, Box 610 Natural Resources Seneca, South Carolina 29678 P. 0. Box 27687 Raleigh, North Carolina 27611-7687 Regional Administrator, Region II U. S. Nuclear Regulatory Commission 101 Marietta Street, NW. Suite 2900 Atlanta, Georgia 30323 Max Batavia, Chief Bureau of Radiological Health South Carolina Department of Health and Environmental Control 2600 Bull Street Columbia, South Carolina 29201 County Supervisor of Oconee County Walhalla, South Carolina 29621

0 PROCESS REVIEW Material Reviewed OSS-0274.00-00-0000 -

License Renewal Basis Specification Writer's Guide OSS-0274.00-00-0001 -

Oconee Mechanical System Scoping Specification for License Renewal OSS-0274.00-00-0002 -

Oconee Mechanical Component Screening Specification for License Renewal OSS-0274.00-00-0005 -

Oconee Mechanical Component Aging Management Review for License Renewal OSS-0274.00-00-0006 -

Oconee Integrated Plant Assessment (IPA) of Electrical Components for License Renewal OSS-0274.00-00-0011 -

Identification and Evaluation of Exemptions to 10 CFR for Oconee Nuclear Station OSS-0274.00-00-0012 -

Identification and Evaluation of ime Limited Aging Analyses Per 10 CFR 54.21 BAW-2270, Rev. 0' -

Non-Class 1 Mechanical Implementation Guideline and Mechanical Tools P&IDs Various site approved drawings Observations ScoOMine n

Process In general the scoping process was documented and controlled consistent with the guidance provided in NEI 95-10, § 3.3, "Documenting the Scoping Process," and was consistent with site approved procedures and programs. 0SS-0274.OO-00-0001 described a scoping process/methodology consistent with NEI 95-10, § 3.1.1, § 3.1.2, and § 3.1.3, with one exception (discussed in the next paragraph), and used scoping criteria consistent with NEI 95-10, § 3.1, to identify those plant systems, structures, and components that are safety-related, nonsafety-related (including seismic II/I) that affect safety related systems, and relied on to demonstrate compliance with specified Commission regulations.

The process for identifying system intended function appeared to be consistent with NEI 95-10, § 3.2. The information presented appeared to be of sufficient detail to allow the staff to assess the scoping process.

0si-0274.00-00-0001 did not include a step to evaluate safety related systems, that did not meet the 10 CFR 1B&WOG Proprietary saey eaedssemad eie-ntodmns-t 54.4(a)(1) criteria, under scoping criteria 10 CFR 54.4(a)(2) and 54.4(a)(3) as required NEI 95-10, § 3.1.1.

This item is further discussed in the Issues Section below.

The results of the system level scoping process for safety related systems and those relied on to demonstrate compliance with Commission regulations were provided in OSS-0274.00-00-0001 with no notable omissions. The applicable nonsafety-related systems were being identified by an independent effort, the Oconee Safety Related Designated Clarification Project and were not available for staff review.

Aqinq-management Process The aging-management process, including screening of structures and components, identifying aging effects, identifying aging-management programs, and demonstrating the effectiveness of aging-management programs, appeared to be documented and controlled consistent with the guidance provided in NEI 95-10, § 4.4, and consistent with site approved procedures and programs.

Participant's specification, OSS-0274.00-00-0002, described a screening process for identifying structures and components that appeared consistent with NEI 95-10, § 4.1.

Evaluation boundaries consistent with system boundaries were identified using marked-up site approved drawings as described in NEI 95-10, § 4.1.1. The long-lived/passive structures and components selected for the LRDP, that were identified using the method described in OSS-0274.00-00 0002, were reviewed with no notable omissions.

Commodity groups were developed for long-lived/passive structures and components with common characteristics that appeared consistent with the guidance provided by NEI 95-10,

§ 4.1.2 (e.g., design, materials, environment, function, etc.).

The commodity groups developed for the LRDP were documented in OSS-0274.00-00-0002 and reviewed with no notable omissions.

Specification OSS-0274.00-00-0002, § 4.2, stated that "The component intended function for all mechanical components and commodity groups is pressure boundary integrity."

Concerns with this broad categorization of intended functions for mechanical components are discussed in the issues section below.

For this LRDP site visit, the scope for electrical components was limited to cables (power, instrument and control, and communication). The component level intended function was reasonable and appeared consistent with NEI 95-10, § 4.1.2.

The participant had a reasonable approach for considering USIs and GSIs that appeared consistent with the guidance provided in NEI 95-10, § 1.5.

In a final step under the screening process, the participant identified the material of construction and the environment (internal and external) for each component of a commodity group for the purpose of determining applicable aging effects.

OSS-0274.00-00-0005, § 4.1, stated that the participant's assessment of aging effects was based on the initial assumption that "materials will experience the same aging effects throughout the bulk environment regardless of the location or component."

The participant's process recognized that "not all the systems containing the same bulk environment, such as borated water, are exactly the same environment."

These variances were said to be considered when identifying applicable aging effects under OSS-0274.00-00-0005, § 4.1, but were not discussed in sufficient detail when applicable. Based on the initial assumption, the potential aging effects that were identified appeared to be consistent with NEI 95-10, § 4.2.1.1.

The participant did utilize operating experience to identify aging effects as intended under NEI 95-10, § 4.2.1.1.

A similar screening approach was used to identify the aging effects associated with cables using exterior environmental conditions. This process, referred to as the plant space approach, was documented and controlled by plant specification OSS-0274.00-00-0006, and appeared to be consistent with the guidance in NEI 95-10, § 4.2.1.1. More information on this approach is discussed under the Aging management Process for cables.

Mechanical "Tools"' were developed for these potential aging effects for the different materials of construction and environments. As part of each "tool," environment conditions necessary for an aging effect to occur were documented. These "tools" were then applied to the materials of construction and environments to determine the applicable aging effects. As suggested under NEI 95-10, 2

Reference BAW-2270, B&WOG proprietary information.

§ 4.2, the participant used specific reviews of structures, components, and/or commodity groups to determine applicable aging effects and summarize the results of this review by system and commodity group. The overall process appeared to be consistent with NEI 95-10, § 4.2.1.1 and § 4.2.2.2, and documented consistent with the guidance provided by NEI 95-10, § 4.4.1, at a level of detail in the site program documentation that appears sufficient for staff evaluation.

Due to the component and environmental complexity of heat exchangers and bolted closures, the identification of applicable aging effects were performed individually with the aid of mechanical "tools."

Most of the participant's mechanical piping systems have internal environments that are required to be controlled by a chemistry program as part of their original license (FSAR and technical specifications) and have been in place since initial operation. The participant considers their chemistry control program as a design element of the plant and therefore does not consider the maintaining of internal environmental chemistry as an aging-management program.

This allows them to determine many of the potentially plausible aging effects as not being applicable, eliminating the need to demonstrate the effectiveness of the chemistry program as an aging-management program to control aging effects during the period of extended operation. This item is discussed further in the Issues Section below.

The participant's aging-management program, as described under OSS-0274.00-00-0005, § 4.2, "Aging Management Demonstration Methodology," appeared to combine the aging management process and the demonstration process into a single step. The combining of these two processes led to a number of inconsistencies between the participant's aging management and demonstration processes and the industry guideline.

This concern was further clarified during discussions with the participant. They described their overall aging management process in the following terms:

"component + aging effect + aging-management program = demonstration" This overall process is specifically discussed under NEI 95-10, § 4.2.1. As a result of this interpretation, the participant's implementation of the aging-management and demonstration processes was not consistent with the guidance in NEI 95-10, § 4.2.1.2, and § 4.2.1.3, respectively.

Therefore, the staff provided a clarifying description of the intended overall aging-management process in the following terms:

"component + aging effect + aging-management program + demonstration

= reasonable assurance of functionality" Review of the applicable guidance led to the conclusion that changes/enhancements to NEI 95-10 may be necessary to clarify the distinction and relationship between the aging management and demonstration processes as discussed under NEI 95-10, § 4.2.1, § 4.2.1.2, and § 4.2.1.3.

The participant mentioned the use of refurbishment as a corrective action but did not discuss any specifics relating to the application of refurbishment with respect to LR.

TLAA Process

.The TLAA scoping process described in OSS-0274.00-00-0012 appears consistent with NEI 95-10, § 5.1.

The information presented in the participant's specification appeared to be at a level of detail that will allow the staff to evaluate the scoping of TLAAs.

The results of the TLAA scoping process appeared reasonable.

The information describing the process used to justify continued operation beyond year 40 is presented in table format. This information appeared to provide the information necessary in sufficient detail to allow the staff to assess the participant's TLAA process and results.

The participant verbally stated that they intend to complete all TLAAs prior to submitting their application, and therefore did not discuss the delayed submittal of TLAAs after the date of application as allowed by the guidance in NEI 95-10, § 5.1.4, "Timing for Evaluation of TLAA."

The scoping process for exemptions based on TLAAs, as described in OSS-0274.00-00-0011, appeared consistent with NEI 95-10, § 5.3. The information presented in the participant's specification appeared to be at a level of detail that will allow the staff to evaluate the scoping process for 10 CFR 50.12 exemptions relating to TLAAs. The exemption scoping results appeared reasonable. The results of the participant's search did identify several exemptions but through an analysis of each exemption, no exemption based on a TLAA was identified.

Issues

1.

As explained under NEI 95-10, § 3.1.1, some licensees prefer to categorize selected nonsafety-related systems, structures, and components as safety-related. These nonsafety-related systems, structures, and components may not meet the safety-related criteria (10 CFR 54.4[a][1]) identified under NEI 95-10, § 3.1.

Therefore, systems, structures, and components categorized as safety-related that do not meet the safety-related criteria would still need to be evaluated for inclusion in the scope of LR using the remaining criteria identified (10 CFR 54.4[a][2] and 54.4[a][3]) under NEI 95-10, § 3.1.1.

OSS-0274.00-00-0001 did not include the evaluation of all safety related systems, structures, and components under the remaining scoping criteria (10 CFR 54.4[a][2] and 54.4[a][3]) as required by NEI 95-10, § 3.1.1.

2.

Specification OSS-0274.00-00-0002, § 4.2, stated that "The component intended function for all mechanical components and commodity groups is pressure boundary integrity."

This broad categorization was made based on the screening of only a few systems. This determination can result in a limited assessment of future screening activities and therefore needs to be corrected.

In addition, the participant did not consider the heat transfer function of an heat exchanger as passive. This position was presented without performing an assessment of the heat transfer function under guidance provided in NEI 95-10, § 4.2.1.

3.

The participant's screening process groups components based on materials of construction and interior environment to determine aging effects. Their process recognizes that "not all the systems containing the same bulk environment, such as borated water, are exactly the same environment."

These variances were said to be considered when identifying applicable aging effects under OSS-0274.00-00-0005, § 4.1, but were not discussed in sufficient detail in all applications. A discussion as to the differences in bulk environments at a sufficient level of detail should be provided as described under NEI 95-10, § 4.2.1.1 and § 6.2.

4.

The participant considers their chemistry control program as a design element of the plant, and therefore did not consider the maintaining of internal environmental chemistry as an aging management program. This allows them to determine many of the potentially plausible aging effects as not being applicable, and therefore eliminates the need to demonstrate the effectiveness of the chemistry program as an aging-management program to control the applicable aging effects during the period of extended operation. This approach was not consistent with the guidance provided under NEI 95-10, § 4.2.1.1 and § 4.2.1.2.

5.

The participant's aging-management program, as described under OSS-0274.00-00-0005, § 4.2, "Aging Management Demonstration Methodology," appeared to combine the aging-management process and the demonstration process into a single step. The combining of these two processes led to a number of inconsistencies between the participant's aging-management and demonstration processes and the industry guideline.

This overall process is specifically discussed under NEI 95-10,

§ 4.2.1. Review of the applicable guidance led to the conclusion that changes/enhancements to NEI 95-10 will be necessary to clarify the distinction and relationship between the aging management and demonstration processes as discussed under NEI 95-10, § 4.2.1, § 4.2.1.2, and § 4.2.1.3.

Aqinq-management REVIEW MAIN FEEDWATER SYSTEM Material Reviewed OSS-0274.0O-O0-0001 -

Oconee Mechanical System Scoping Specification for License Renewal OSS-0274.00-OO-0002 -

Oconee Mechanical Component Screening Specification for License Renewal OSS-0274.O0-00-0005 -

Oconee Mechanical Component Aging Management Review for License Renewal BAW-2270, Rev. 0' Non-Class 1 Mechanical Implementation Guideline and Mechanical Tools P&IDs Main Feedwater site approved drawings Observations Scoping The scoping process used to include the Main Feedwater (MFW)

System within the scope of LR appeared to be consistent with NEI 95-10, § 3.1, and consistent with site approved procedures and programs. The scoping criteria applied for including the MFW System was consistent with scoping criteria provided under NEI 95-10, § 3.1. The process for identifying system intended function appears to be consistent with NEI 95-10, § 3.2.

Aging-management Process The aging-management process, including screening of structures and components, identifying intended functions, and identifying aging effects appeared to be documented and controlled consistent with the guidance provided in NEI 95-10, § 4.4, "Documenting the Integrated Plant Assessment."

OSS-0274.00-00-0002 described the screening process used to identify the MFW components' requiring an aging-management B&WOG Proprietary 4

The scope of the LRDP site visit did not include structures for the Main Feedwater System.

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review. The screening process applied appeared consistent with guidance provided under NEI 95-10, § 4.1.

Evaluation boundaries, consistent with system boundaries, were identified using marked-up site approved drawings as described under NEI 95-10, § 4.1.1. The screening of long lived/passive components for the MFW System were identified using the method described in OSS-0274.00-00-0002. The staff reviewed the MFW components selected by the participant. No notable omissions were identified.

Commodity groups were developed for long-lived/passive components, identified during the screening process, that had common characteristics consistent with the guidance provided by NEI 95-10, § 4.1.2 (e.g., design, materials, environment, function, etc.).

The commodity groups developed for the MFW System were documented in OSS-0274.00 00-0002 and reviewed with no notable omissions.

The MFW System intended functions for the commodity groups selected were consistent with the guidance provided under NEI 95-10, § 4.1.2.

The participant's screening process groups components based on materials of construction and interior environment to determine aging effects. This approach appeared reasonable, efficient, and consistent with NEI 95-10, § 4.2.1.1.

The participant determination of applicable aging effects appeared consistent with NEI 95-10, § 4.2.1.1 with one notable exception. Chemistry control of MFW piping system internal environment was considered a plant design element of the plant, and an aging-management program. As a result, a number of plausible aging effects were determined to be not applicable as a result of system design. This eliminated the need to demonstrate the effectiveness of the chemistry program as an aging-management program.

The chemistry control program meets the features for an aging-management program under NEI 95-10, § 4.2.1.2, and should be considered as an existing aging-management program used to control the applicable aging effects. Because chemistry control programs are considered to be aging management programs under NEI 95-10, the participant needs to demonstrate its effectiveness under all CLB design conditions during the period of extended operation. This concern was also discussed under the Process Review above.

The aging-management program selected for the aging effect that was determined to be applicable to the MFW System, erosion/ corrosion, appeared to be consistent with the guidance provided in NEI 95-10, § 4.2.1.2.

The participant, within the content of their program, failed to demonstrate the effectiveness of the erosion/corrosion program to maintain the intended function under all CLB design conditions for the period of extended operation as described under NEI 95-10, § 4.2.1.3.

The participant did prepare an example of a sample LR application that was intended to describe an erosion/corrosion aging-management program for piping systems. This example contained all six features for identifying an effective aging-management program as described under NEI 95-10, § 4.2.1.2, but lacked the information needed by the staff to fully assess the demonstration of the erosion/corrosion program as described under NEI 95-10, § 4.2.1.3. The information missing from the LR application example included the following two items:

Their reference to maintaining the intended function failed to include reference to "under all CLB design conditions."

Their demonstration process failed to include the description of observed results from implementing their erosion/corrosion program as described under NEI 95-10, § 4.2.1.3 and NEI 95-10, Appendix C, Example 2.

Issues No issues unique to the MFW System were identified.

10 -

LOW PRESSURE SERVICE WATER SYSTEM (LPSW)

Material Reviewed OSS-0274.00-00-0000 -

License Renewal Basis Specification Writer's Guide OSS-0274.00-00-0001 -

Oconee Mechanical System Scoping Specification for License Renewal OSS-0274.00-00-0002 -

Oconee Mechanical Component Screening Specification for License Renewal OSS-0274.00-00-0005 -

Oconee Mechanical Component Aging Management Review for License Renewal BAW-2270, Rev. 0' -

Non-Class 1 Mechanical Implementation Guideline and Mechanical Tools ONS UFSAR Updated Final Safety Analysis Report, Section 9.2.2.2.3 P&IDs -

Low Pressure Service Water System site approved drawings Other Materials Miscellaneous Application Materials Observations ScoSinca The scoping process used to include the Low Pressure Service Water (LPSW) System Within the scope of LR was consistent with NEI 95-10, § 3.1, and consistent with site approved procedures and programs. The scoping criteria applied for including the LPSW System was consistent with scoping criteria provided under NEI 95-10, § 3.1.

The process for identifying system intended function appears to be consistent with NEI 95-10, § 3.2.

AMiing-management Process The aging-management process, identifying the LPSW components requiring an aging-management review, identifying intended functions and aging effects appeared to be documented and controlled consistent with the guidance provided in NEI 95-10, § 4.4, "Documenting the Integrated Plant Assessment."

BWOGProprietary The copig prces use toicueteLwPesr-evc OSS-0274.00-00-0002 described the screening process used to identify the LPSW components' requiring an aging-management review. The screening process applied appeared to be consistent with guidance provided under NEI 95-10, § 4.1.

To establish the LPSW evaluation boundary, the participant relied on the plant specific CLB, plant specific experience, and existing engineering evaluations to mark up site approved drawings as described under NEI 95-10, § 4.1.1.

The participant determined the LPSW components requiring an aging-management program by using the method described in OSS-0274.00-00-0002. The staff reviewed the LPSW components selected by the participant. No notable omissions were identified.

The participant reviewed each component in the LPSW evaluation boundary and grouped them according to the commodity groups identified in Appendix B of NEI 95-10. The participant then used the passive/active determination for each commodity group provided in NEI 95-10, Appendix B. For components that did not fit one of the commodity groups described in Appendix B, then the component was evaluated to determine if it was long-lived or passive.

For intended function, the participant's specification, OSS-0274.U0-00-0002, § 4.2, stated that "The component intended function for all mechanical components and commodity groups is pressure boundary integrity."

This concern is discussed in more detail in the Issue Section below.

The participant's aging-management review process groups components based on materials of construction and interior environment to determine aging effects. In general, this approach appeared reasonable, efficient, and consistent with NEI 95-10, § 4.2.1.1.

The participant considers their chemistry control program as a design element of the plant and therefore did not consider the maintaining of internal environmental chemistry as part of the aging-management program. This concern was discussed in more detail in the Process Review Section above.

6 The scope of the LRDP site visit did not include structures for the Low Pressure Service Water System.

12 -

0 The participant's process as described under OSS-0274.00-00-0005, § 4.2, "Aging Management Demonstration Methodology," appeared to combine the aging-management process, and the demonstration process which is inconsistent with the guidance provided in the NEI 95-10, § 4.2.1.2.

This concern was discussed in more detail in the Process Review Section above.

For the LPSW System, the participant did not demonstrate the effectiveness of the aging-management programs to maintain the intended function under all CLB design condition for the period of extended operation as described under NEI 95-10,

§ 4.2.1.3. This concern was discussed in more detail in the Process Review Section above.

Issues

1.

The participant's specification, OSS-0274.00-00-0002, § 4.2, stated that "The component intended function for all mechanical components and commodity groups is pressure boundary integrity."

The participant also stated that they currently do not recognize heat transfer as a passive function. These intended function generalizations were not.

consistent with NEI 95-10, § 4.1 and § 4.1.2, for the following reasons:

NEI 95-10, § 4.1, states that "Structures and components subject to an aging-management review shall encompass the structures and components -- (I) that perform an intended function, as described in § 54.4, without moving parts or without a change in configuration or properties."

The cooling requirements of the LPSW System performs its heat transfer function without any moving parts or a change in configuration or property.

NEI 95-10, § 4.1.2, states that "The structure or component intended function(s) is the specific function of the structure or component that supports the systems intended function."

In specification OSS 0274.00-00-0001, the participant states that the LPSW System function is to "provide cooling water from the CCW intake..." and "provide Reactor Coolant Pump Motor, Main Turbine Oil Tank, and Component Cooling System cooling water."

Because the heat transfer function of the LPSW meets the guidance in NEI 95-10, § 4.1, the heat transfer system function should be recognized as a heat exchanger intended function under the participant's program or a justification 13 -

that explains why the heat transfer function is not an applicable intended function should be provided to meet the guidance under NEI 95-10, § 4.1.2.

14 -

Core Flood System Material Reviewed OSS-0274.00-0O-0001 -

Oconee Mechanical System Scoping Specification for License Renewal OSS-0274.00-00-0002 -

Oconee Mechanical Component Screening Specification for License Renewal OSS-0274.00-00-0005 -

Oconee Mechanical Component Aging Management Review for License Renewal BAW-2270, Rev. 0' -

Non-Class 1 Mechanical Implementation Guideline and Mechanical Tools ONS UFSAR Updated Final Safety Analysis Report, Section 9.2.2.2.3 P&IDs Low Pressure Injection System (Pump Discharge) site approved drawings, DWG. No. OFD-102A-1.2, Rev. 15 Low Pressure Injection System (Core Flood) site approved drawing, DWG.

NO. OFD-102A-1.3, Rev. 11 Reactor Coolant System site approved drawing, DWG. No. OFD-100A-1.1, Rev. 14 Observations ScoUing The scoping process used to include the Core Flood (CF)

System within the scope of LR was consistent with NEI 95-10,

§ 3.1, and consistent with site approved procedures and programs. The scoping criteria applied for including the CF System was consistent with scoping criteria provided under NEI 95-10, § 3.1.

The process for identifying system intended function appeared to be consistent with NEI 95-10,

§ 3.2.

In specification OSS-0274.00-00-0002, Appendices A and B, as well as in other areas of the participant's program, abbreviations and acronyms were used without a legend to define them.

Aihng-management Process B&WOG Proprietary

-15 The aging-management process, including screening of structures and components, identifying intended functions, and identifying aging effects appeared to be documented and controlled consistent with the guidance provided in NEI 95-10, § 4.4, "Documenting the Integrated Plant Assessment."

OSS-0274.00-00-0002 described the screening process used to identify the CF components requiring an aging-management review. The screening process applied appeared consistent with guidance provided under NEI 95-10, § 4.1.

The use of information contained in the P&IDs was effective in identifying evaluation boundaries that included the CF components that needed to be addressed for LR. The process used by the participant to identify the evaluation boundaries appeared to be consistent with NEI 95-10,

§ 4.1.1.

The screening of long-lived/passive components for the CF System were identified using the method described in OSS-0274.00-00-0002. The staff reviewed the CF System components selected by the participant. No notable omissions were identified.

Commodity groups were developed for long-lived/passive components, identified during the screening process, that had common characteristics that appeared consistent with the guidance provided by NEI 95-10, § 4.1.2 (e.g., design, materials, environment, function, etc.). The commodity groups developed for the CF System were documented in OSS-0274.00-00-0002 and reviewed with no notable omissions.

The CF System intended function selected appeared consistent with the guidance provided under NEI 95-10, § 4.1.2.

The participant's screening process groups components based on materials of construction and interior environment to determine aging effects. In general, this approach appeared reasonable, efficient, and consistent with NEI 95-10,

§ 4.2.1.1.

No aging effects were determined to be applicable for the CF System; therefore, no aging-management program was described, and no program demonstration was provided.

16 -

Issues

1.

In BAW-2270, § 2.2.1, "Heat Exchangers," stated that the heat transfer function of heat exchangers was not an intended function that requires an aging-management review because heat transfer degradation may be detected by performance or condition monitoring. This statement does not appear to be consistent with the guidance provided under NEI 95-10, § 4.1.2. In addition, performance and condition monitoring are considered aging-management programs under NEI 95-10, § 4.2.3. Regardless, a basis for this position should be provided at a level of detail that will allow the staff to assess this position.

.0 Reactor Coolant System Material Reviewed OSS-0274.00-00-0004 -

Oconee Reactor Coolant System Aging Management review for License Renewal BAW-2243, Rev. 1 Demonstration of the Management of Aging Effects for the Reactor Coolant System Piping SE, BAW-2243, Rev.1 -

NRC staff Safety Evaluation concerning B&WOG Report, BAW-2243 P&IDs Reactor Coolant System approved drawing Other Materials Miscellaneous application materials Observations Scoping The participant's Reactor Coolant System (RCS) aging management review for LR, OSS-0274.00-00-0004, focused primarily on the RC System piping. The aging-management review for the remaining portions of the RC System was still under development and unavailable for staff review.

The scoping process used to include the RCS piping within the scope of LR appeared to be consistent with NEI 95-10,

§ 3.1, and consistent with site approved procedures and programs. The scoping criteria used to include the RCS piping was consistent with scoping criteria provided under NEI 95-10, § 3.1. The process for identifying system intended function also appeared to be consistent with NEI 95-10, § 3.2.

Aqing-management Process The intent of the participant's process, as it related to RCS piping, was to utilize the technical information contained in the B&WOG RCS Piping Topical Report, BAW-2243, and the associated NRC staff SER. NEI 95-10, § 4.2, states that one method of evaluating individual structures and components can be to "reference the results of previous reviews of a similar structures or components which have been found acceptable by the NRC."

To demonstrate the applicability of a selected reference, NEI 95-10, § 4.2.2.1, guides the applicant to identify and demonstrate the applicability of the referenced report and then demonstrate that the results and conclusions are applicable to that particular plant.

18 -

0 For the RCS piping, the participant referenced the B&WOG topical report that specifically identified the participant as being bounded by the review. The staff previously reviewed the topical report and issued a safety evaluation for the topical report, finding it acceptable. Regardless of report references and staff approvals, a burden still remains on all applicants to demonstrate that a particular topical report is applicable to the specific facility. The need to demonstrate this applicability is described under NEI 95-10, § 4.2.2.1.

In addition, the information contained in any topical report is dated material and an applicant must reaffirm that the information in a topical review is applicable at the time of application. For this site visit, the participant should have included the applicable elements cited in the NEI 95-10, § 4.2.2.1, to demonstrate the applicability of the referenced topical report. Although the participant stated that the report was applicable, they did not provide any information that allowed the site visit team to assess the applicability of BAW-2243.

The participant did note deviations from BAW-2243 and identified them as outliers. The participant provided a discussion on why each outlier was different from the topical report information. This information was helpful to the staff in performing their review.

The participant presented the results of their aging management review in a table that provided a one-to-one correlation between the aging effects identified in BAW-2243 and the aging-management programs in place at the participant's site. The staff found this table to be an effective summary of the programs that the participant considers acceptable for managing the effects of aging at the participant's plant. It was particularly helpful in identifying the aging-management programs that have already been found acceptable by the staff in the referenced SER.

However, as discussed previously, the participant should demonstrate, as described under NEI 95-10, § 4.2.2.1, that the programs identified in the topical report are applicable to their site at the time of application.

OSS-0274.00-00-0004, Tables 3.4-3, was not referenced in the related text in Section 3 of the specification. These tables provided a beneficial summary of the programs needed to adequately manage the effects of aging for the period of extended operation. Also, it appeared that the conclusions reached in the text portion of the specification were not consistent with the information contained in Section 3 19 -

tables. The participant needs to review and adjust the applicable specification to address these concerns.

Issues

1.

The participant provided summary descriptions of programs needed to manage the effects of aging. The summary descriptions of the programs and the associated demonstrations that the effects of aging will be adequately managed may be sufficient for the programs that were described in more detail in the referenced topical report.

However, for those programs that were not described in the topical report, additional description of the program and demonstration as described under NEI 95-10, § 4.2.1.3, may be needed in the application. For example, additional details to describe the demonstration of programs committed to in response to Generic Letter 88-05 were needed for the staff to adequately assess the effectiveness of the aging management programs to manage the effects of aging under all CLB design conditions for the period of extended operation.

This additional description should have included observed results from implementing an aging-management program that show the key elements of the program were effectively controlling aging.

2.

The application information relating to the RCS piping provided descriptions of the programs necessary to manage the effects of aging for the period of extended operation.

A number of items relating to the safety evaluation prepared by the staff that were noted in the participant's application were characterized incorrectly. For example, the participant's specification OSS-0274.00-00-0004,

§ 3.4.1.3, "Oconee Technical Specifications," states that "It is concluded that the Oconee Technical Specifications are effective in managing any adverse effects of pipe cracking that may occur." This conclusion was insufficient and needs additional clarification and discussion as to what programs effectively manage pipe cracking. In addition the participant's specification, OSS-0274.00-00-0004,

§ 3.4.4.1.1, "Piping," stated that "The NRC has found that the continuation of this program is adequate to manage the loss of material on the external surfaces of carbon steel reactor coolant pressure boundary for the period of extended operation." This statement was also incorrect, the NRC safety evaluation states that "...the staff finds the programs committed to by licensees in response to Generic Letter 88-05, in conjunction with leakage detection conducted under "Examination B-P" and technical specification RCS leakage limits, adequate for managing the loss of material on the external surfaces of carbon steel 20 -

reactor coolant pressure boundary components for the period of extended operation." Similar inaccurate characterizations existed in other areas of the participant's LR materials.

21 -

g 0

Structures and Structural Components Material Reviewed OSS-0274.00-00-0007 -

Oconee Structures and Structural Component Specification for License Renewal Other Materials Miscellaneous Application Materials; i.e., Chemistry procedure, Quality Manual, various site drawings, Demonstration Sample Observations Scooina The participant structure scoping methodology begins with identification of all structures on site using Oconee FSAR, site Quality Manual, NSD 307, Oconee Site General Arrangement Drawings, and Oconee Commodities and Facilities Drawings. The scoping process appeared consistent with the guidance provided by NEI 95-10, § 3.1.1, 3.1.2, and 3.1.3.

The process for identifying system intended function also appeared to be consistent with NEI 95-10, § 3.2.

Aqing-management Process For screening of structural components, the participant uses a generic listing of structural components provided in NEI Industry Reports, NEI 95-10 Appendix B, design basis specifications, plant civil/structural drawings, and commitments for regulated events. Each structure identified during the initial screening process was reviewed against the generic list to identify the components contained in that structure. This process appeared to be consistent with the NEI 95-10, § 4.1.

The structures and structural components were put into commodity groups based on similar design, material, environment, and function. The intended functions for each structure and structural component group were identified and documented in tabulated form. This approach appeared consistent with the NEI 95-10, § 4.1.2.

The aging effects, based on available information including NEI Industry Reports, NRC generic communications, licensee event reports, and NPRDS, were identified for each structure and structural component group consistent with NEI 95-10,

§ 4.2.1.1. Existing programs were then reviewed for applicability or new program considering attributes 22 -

necessary to manage the aging effects were developed. This process appeared to be consistent with the NEI 95-10,

§ 4.2.1.2.

The participant selected the spent fuel storage rack to provide a demonstration of their process. Three component assemblies were identified for the spent fuel storage rack, i.e., rack support assembly, lower and upper grid assembly, and cell assembly. Component functions and component boundaries were identified. An aging-management review was provided by referencing a B&WOG generic report which is still in a draft form.

The B&WOG generic report identified stress corrosion cracking and intergranular attack as applicable aging effects. The report describes a chemistry program together with a liner leak chase system to manage these effects. The participant reviewed its chemistry program and concluded that it did not provide acceptance criteria and corrective actions for sulfates. It also concluded that stress corrosion cracking and intergranular attack were not applicable aging effects. To ensure that sulfates were maintained below threshold values, the participant will enhance its chemistry program to include acceptance criteria and corrective actions for sulfates. The elements of the aging-management program, despite incorrect assessment of aging effects (see Issue 1.

below), appeared to be consistent with the NEI 95-10, § 4.2.

Issues

1.

By having the chemistry program in place to manage an identified aging effect, the participant asserted that there was no aging effects and that no aging-management program was required. This conclusion was not consistent with the intent of NEI 95-10, § 4.2. The chemistry program should be part of the application as an aging-management program and its effectiveness demonstrated. A summary description should be provided in the FSAR Supplement.

23 -

ELECTRICAL COMPONENTS Material Reviewed OSS-0274.0O-00-0006 -

Oconee Integrated Plant Assessment (IPA) of Electrical Components for License Renewal SAND 96-0344 AMG for Electrical Cable and Terminations P&IDs Various electrical drawings including KEE-0-8, KEE-40-2, KEE-40 3, KEE-40-4, and KEE-40-5 Generic Communication-Miscellaneous generic communication for Cables, Penetrations, Connectors, and Terminations Photographs Turbine Building Walk-down photographs Observations Scopinq In general, the scoping process used for electrical components appeared to be consistent with NEI 95-10, § 3.0 and § 4.1. The screening of electrical components for an aging-management review was performed by identifying all structures that contain electrical components. Those structures that were identified as having electrical components were included in the screening process bounding all electrical components in the plant within the scope of LR by location. The environmental conditions under normal plant conditions and all acute environments were then identified. These locations, environmental conditions, and all the electrical components within these locations were fed into the aging-management review process.

Aqing-management Process In general, the cable aging-management review process appeared to be consistent with the guidance in NEI 95-10,

§ 4.2. Cables were reviewed for normal plant environmental influences such as radiation and temperature as it relates to long term aging and other acute factors such as chemicals, moisture, radiation, and thermal hot spots that can age components at a faster rate. Cable construction, function, material, and aging effects were then identified.

The aging-management review for all electrical components was based on the "plant spaces approach" (SAND 96-0344, Cable AMG, Aging Management Guideline for Commercial Nuclear 24 -

Power Plants - Electrical Cable and Terminations). If an electrical component was in an area with an environmental stressor of concern, and was associated with a system within the scope of LR, then additional actions would be taken.

These actions may include, but were not limited to additional monitoring, additional inspections, and replacement when appropriate.

Following the development of the criteria for the environmental stressors of concern, walkdowns were performed in all the structures identified as containing electrical components to identify specific areas of concern. The results of the walkdown have been documented and the review of the temperature survey were still in progress.

Issues The methodology used to identify the electrical components subject to an aging-management review was based on the plant spaces approach for evaluation aging of cables and its terminations as described in SAND 96-0344. This document contained information on industry wide experience from NRC generic communications applicable to the failure or aging of electrical cable and terminations. OSS-0274.00-00-0006, can be enhanced by including applicable operating experience from SAND 96-0344. For example, cable failures listed in NUREG/CR-5772 and NUREG/CR-6095 could be discussed in OSS-0274.00-00-0006 for applicability of corrective actions to avoid similar problems during the period of extended operation, as appropriate.

25 -

TLAAs ENVIRONMENTAL OUALIFICATION -

OKONITE EPR/NEOPRENE CABLES AND VIKING ELECTRICAL PENETRATION ASSEMBLIES Material Reviewed LR Basis Documents LR Technical Information (working draft)

OSS-0274.00-00-0008 -

TLAA of Electrical Components EQMM-1393.01, Rev. 35-EQ Maintenance Manual EQ Master List ONS UFSAR Updated Final Safety Analysis Report, Section 3.11 Other Materials EQ Safety Evaluation Report, March 28, 1985, and License Renewal and GSI/USI Report, April 4, 1996 Observations Scoping Environmental qualification (EQ) of electrical equipment under 10 CFR 50.49 was identified as a TLAA by the participant. The selection of EQ as a TLAA appeared consistent with the scoping criteria set forth in NEI 95-10, § 5.1.

TLAA The documentation reviewed for the TLAAs associated with the reanalysis of Okonite EPR/Neoprene Cables was consistent with the guidance provided under NEI 95-10,

§ 5.1.2. The thermal aging demonstration analysis was reanalyzed and said to be projected to the end of the period of extended operation. The radiation aging demonstration analysis was reviewed and said to remain valid for the period of extended operation consistent with NEI 95-10, § 5.1.1.

The documentation reviewed for the TLAA associated with Viking Electrical Penetrations Assemblies appeared to be consistent with the guidance provided by NEI 95-10, § 5.1.1. The thermal aging demonstration analysis and the radiation aging demonstration analysis were reviewed, and said to remain valid for the period of extended operation consistent with NEI 95-10, § 5.1.1.

26 -

Issues GSI 168, "Environmental Qualification of Electrical Equipment," was not discussed in the participant's specification, OSS-0274.00-00-0008. This specification should have included a discussion to describe the option(s) that would be appropriate to resolve GSI 168 as described under NEI 95-10, § 1.5.

27 -

BORAFLEX Material Reviewed LR Basis Documents LR Technical Information (working draft)

OSS-0274.00-00-0012 -

Identification and Evaluation of Time Limiting Aging Analyses Per 10 CFR 54.21 ONS UFSAR Updated Final Safety Analysis Report Observations The participant identified Boraflex and its aging effect in the Spent Fuel Pool as a TLAA issue based on its search of Licensing documents. This issue was determined to be within the scope of LR because the conclusion in the staff's safety evaluation referred to a 40 year license term. This is consistent with NEI 95-10, § 5.1.

In evaluating the aging effect, the participant appeared to have provided.a discussion of relevant information at an appropriate level of detail to allow the staff to assess their disposition of the issue. The participant also indicated that with possibly few exceptions, evaluations of all TLAA issues, including Boraflex, will be completed and submitted at the time of renewal application. This is consistent with NEI 95-10, § 5.1.4.

Issues No issues unique to the MFW System were identified.

28 -

ADMINISTRATIVE REVIEW Material Reviewed ONS Specifications OSS-0274.00-00-0001 through OSS-0274.00-00-0012 ONS UFSAR Draft Updated Final Safety Analysis License Renewal Supplement Formal Application Not within the scope of the LRDP.

Technical Information -

Exhibit A In general, the level of detail presented in the technical material appeared to be sufficient to allow the staff to assess the participant's program with some exceptions as noted throughout this enclosure. In particular, the demonstrations of aging management programs effectiveness were lacking the information called for by NEI 95-10. The participant did prepare an example of a sample LR application that described the erosion/corrosion aging-management program for piping systems. This example appeared to have touched on the basic guidance provided under NEI 95-10, § 4.2.1.2 but lacked the information that would allow the staff to assess the effectiveness of the aging-management program described under NEI 95-10, § 4.2.1.3. The information missing from the example included a reference to maintaining intended function under all CLB design conditions and a lack of observed results from the implementation of the erosion/corrosion program as described in NEI 95-10, § 4.2.1.3 and NEI 95-10, Appendix C, Example 2.

FSAR Supplement The draft FSAR supplement appeared to be consistent with basic guidance provided in NEI 95-10, § 6.3 but was not presented at an adequate level of detail.

Issues Level of Detail - Determining the level of detail for an application for LR is a key objective of the LRDP. In general, the application and supporting technical information presented during the site visits failed to document the demonstration process at a level of detail sufficient for the staff to assess the effectiveness of aging-management programs.

29 -

4.

The draft FSAR Supplement examples presented during the site visits did not contain sufficient detail to provide continuing regulatory assurance of actions to be taken under 10 CFR 54.29, and 54.37.

30 -

Entrance Meeting -

April 22, 1996 Douglas Walters NEI Micheal Bailey Duke Paul Harmon NRC David Nix Duke Scott Flanders NRC Robert Knoerr Duke Robert Prato NRC Noel Clarkson Duke Christopher Regan NRC Bill Foster Duke P.T. Kuo NRC Joe Darn Duke Paul Shemanski NRC J.W. Hampton Duke Robert Gill Duke G. D. Robinson Duke Paul Colaianni Duke Exit Meeting - April 26, 1996 Douglas Walters NEI Micheal Bailey Duke Paul Harmon NRC David Nix Duke Scott Flanders NRC Terry Cox Duke Robert Prato NRC Steve Graham Duke Christopher Regan NRC T Al-Hussaini Duke P.T. Kuo NRC William Burrus Duke Paul Shemanski NRC Micheal Semmler Duke Scott Newberry NRC G. D. Robinson Duke Don Croneburger GPUN Paul Colaianni Duke Dana Covill GPUN Robert Gill Duke Joseph Mancinelli GPUN J. W. Hampton Duke Bob Locke GPUN Mel Arey Duke Ray Baker SNC Debbie Ramsey Duke Barry tilden BGE Mitch Baughman Duke Don Eggett CECo Paul Newman Duke Peter Kuzora WEP Bill Foster Duke R. J. Baker FTI