ML20217A086

Ei Hatch Nuclear Plant,Units 1 & 2,Process for Implementing Technical Requirements of 10CFR54,License Renewal Rule

ML20217A086
Person / Time
Site:	Hatch
Issue date:	04/30/1998
From:	SOUTHERN NUCLEAR OPERATING CO.
To:
Shared Package
ML20217A078	List: HL-5594, Forwards Ei Hatch Nuclear Plant,Units 1 & 2,Process for Implementing Technical Requirements of 10CFR54,License Renewal Rule. Rept Clarifies Certain Issues W/Nrc & Identifies Successful Resolution Pathways ML20217A086
References
PROC-980430, NUDOCS 9804220152
Download: ML20217A086 (72)

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l Edwin I. Hatch Nuclear Plant l Unit 1 and Unit 2 l Process for Implementing the

Technical Requirements of 10 CFR 54 The License Renewal Rule l

April 1998 l

Southern Nuclear Operating Company, Inc. {

40 Inverness Center Parkway Post Office Box 1295 ,

i Birmingham, Alabama 35201 9804220152 980413 PDR sDOCK 05000321 P PDR i

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Plant IIatch 10 CFR 54 Process EDWIN I. liATCH NUCLEAR PLANT PROCESS FOR IMPLEMENTING THE TECIINICAL REQUIREMENTS OF 10 CFR 54 THE LICENSE RENEWAL RULE TABLE OF CONTENTS Pajte Definitions 1 Acronyms 5 References 7 i

l 1.0 Introduction 8 L

1.1 Background 8 1.2 Purpose 9 l 1.3 Scope 9 l 1.4 Quality Assurance Requirements 10 l

l 2.0 Process Bases and Overview 12 1

3.0 Identification of System and Structure Functions Within the Scope of 15 i

License Renewal l 3.1 Identification of Plant Hatch System and Structure Functions 18 l Within the Scope of License Renewal l

3.2 Systems and Structures Not Considered in the Plant Hatch Process 21 3.3 Safety-Related System and Structures 21 3.4 Nonsafety-Related Systems and Structures Whose Failure Could 22 Prevent Safety-Related Systems and Structures From Accomplishing Their Function l 3.5 Systems and Structures Relied Upon to Demonstrate Compliance 23

with Certain NRC Regulations l 3.6 Documentation of the Scoping Process 24 4.0 Integrated Plant Assessment 25 4.1 Process for Identifying Structures and Components Subject to an 25 Aging Management Review 4.1.1 Process Overview 26 i

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Page 4.1.2 Mechanical and Civil Evaluation Boundaries of Systems and 28 Structures Within the Scope of the Rule 4.1.3 Mechanical and Civil Commodity Groups and Unique SCS 30 and Their Principle Functions 4.1.4 Passive Mechanical and Civil Structures, Components, and 33 Commodity Groups 4.1.5 Electrical Component Screening 33 4.1.6 Electrical Evaluation Boundary Screening 34 4.1.7 Components Subject to Periodic Replacement at a Set Frequency 34 or Qualified Life 4.1.8 Documentation of the Screening Process 35

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4.2 Process for Assuring Management of the Effects of Aging 36 4.2.1 Aging Management Review of a Structure, Component, or 37 )

Commodity Group 4.2.2 Identification and Assessment of Aging Effects 38 4.2.3 Plant Aging Management Programs 40 4.2.3.1 Preventive or Mitigative Aging Management Programs 42 4.2.3.2 Condition Monitoring Aging Management Programs 43 4.2.3.3 Performance Monitoring Aging Management Programs 43 4.2.3.4 License Renewal Inspection Programs 44 ,

4.2.4 Demonstration That Programs Will Manage Aging 44 4.2.5 Existing or Previous Reviews Approved by NRC 46 4.2.6 Electrical Component Specific Demonstration 47 4.2.7 Documentation of the Aging management Review 51 5.0 Time-Limited Aging Analysis 52 5.1 Process for Identifying and Evaluating Time-Limited Aging Analysis 52 5.1.1 Process Overview 53 5.1.2 Identification of the Time-Limited Aging Analysis 53 5.1.3 Evaluation and Resolution of the Time-Limited Aging Analysis 54 1

1 5.2 Process for Identifying and Evaluating Exemptions Containing 56 Time Limited Aging Analysis l

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M 5.2.1 Identification of the Exemptions in Effect 56 5.2.2 Evaluation of the Exemptions 57 Appendix A List of Structure and Component Types, Commodity Types, 59 Commodity Groups, and Associated Active / Passive Determinations for the Integrated Plant Assessment i

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Plant Hatch 10 CFR 54 Process 1

l TABLE OF CONTENTS (Continued)

I l LIST OF TABLES l l

Table No. Title Page 3-1 Comparison of Requirements in the License Renewal Rule and 20 the Maintenance Rule 4-1 List of Potential SCC Principle Functions 32 5-1 Disposition of Potential TLA.A and the Basis for Disposition 58 i

LIST OF FIGURES  ;

i Figure I No. Title Page 1-1 License Renewal Implementation Process 11 3-1 Process Flow Diagram for Plant Hatch license Renewal Scoping 17 4-1 Identification of Structures and Mechanical Components subject to 27 Aging management Review 4-2 Electrical Aging Management Review Flow Chart 50 l

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Plant Hatch 10 CFR 54 Process DEFINITIONS 1

I The Southern Nuclear Operating Company (SNC) terminology used in this document is defined below. In addition, definitions for the terms " current licensing basis,"" integrated plant assessment," and " time-limited aging analyses" are provided in 10 CFR 54.3.

Active: As used in relation to a structure, component, or commodity group, the performance of a function with either moving parts or a change in configuration or properties.

Aging Effects: A change in a system, structure, or component's performance, or change iri physical or chemical properties resulting in whole or part from one or more aging mechanisms.

Examples include loss of material, cracking, changes in ductility, fatigue resistance, fracture toughness, mechanical strength, polymerization, viscosity, and dielectric strength.

l Aging Mechanisms: The physical or chemical processes that result in degradation. These mechanisms include, but are not limited to fatigue, erosion, corrosion, erosion corrosion, thermal embrittlement, radiation embrittlement, microbiologically induced corrosion, creep, and shrinkage. Aging mechanisms produce aging effects.

Commodity Group (CG) (also Commodity): A grouping of a select number of structures, components, or commodities, based upon considerations such as physical configuration, application, materials of construction, environment, management programs, or common aging effects. Commodity groups may be addressed by a single aging management review, when applicable, to achieve efficiency in the aging management review process.

Component: The major structural, mechanical, and/or electrical elements of a system or structure.

Consumables: Piece parts of components that are replaced as a normal part of ongoing maintenance activities. Examples include packing, gaskets, sealing material, and 0-rings.

Equipment Location Index (ELI): A Plant Hatch controlled and periodically updated list of major plant equipmeat that gives the equipment Master Parts List (MPL) number, a brief description, location by column line and elevation, major drawings associated with the equipment, quality classification codes, vendor, specifications, and purchase orders.

Environmental Qualification Master List: The Plant Hatch list of all equipment included in the 10 CFR 50.49 Environmental Qualification Program. The list includes equipment with l individual MPL numbers, as well as commodity items such as cables, splices, and seals.

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! Evaluation Houndary: The portion of a system or structure, and its related components, that are l necessary to accomplish an intended function defined by the Rule on the basis that it meets one or more of the requirements in Q54.4(a). The intent in defining an evaluation boundary is to quickly focus the aging management review on the set of structures and components that directly contribute to the successful completion of system or structure intended function. This boundary may or may not match the system or structure boundary traditionally described in plant documents.

Function: The defined action (s) or condition (s) that a system, structure, component, or commodity must accomplish. A variety of terms is used in this document to characterize the function of a system, structure, component, or commodity. These terms are defined below.

Intended Function: The intended function (s) of a system or structure is the function (s) that is the basis for including the system or structure within the scope of the Rule as specified in 54.4(a). This definition is unique and only applies to implementing the requirements of the

Rule.

Principal Function: An action or condition that a structure, component, or commodity group performs or preserves to accomplish an intended function.

Safety Function: A structure, system, or component function (s) required for design basis events that ensures the integrity of the reactor coolant pressure boundary, the capability to shut down the reactor and maintain it in a safe shutdown condition, or the capability to ,

l prevent or mitigate the consequences of accidents that could result in potential offsite l

l exposure comparable to the 10 CFR 100 guidelines.

I System Function: A function performed by either a system or a combination of systems and related components or equipment.

l l In-Scope: A term applied to structures, systems, components, or commodities determined to be subject to the requirements of 10 CFR 54.

License Renewal (LR): The process of obtaining a renewed operating license to extend the operating term for a nuclear power plant, including: preparing an integrated plant assessment and license renewal application, submitting the application to the NRC, and responding to questions and comments during regulatory review of the application. The requirements of the process are provided in 10 CFR 54.

License Renewal Services (LRS): The SNC organization that has the lead for developing the application for a renewed license and developing the analysis and research to support the application.

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! Plant Hatch 10 CFR 54 Process Long-Lived: An item that is not subject to replacement based on a qualified life, specified time l period or is not replaced periodically by defined performance or condition criteria that can be l demonstrated to result in a life less than 40 years.

Maintenance: The aggregate of activities required to preserve and/or restore safety, reliability, and availability of plant structures, systems, and components. Maintenance includes activities traditionally associated with identifying and correcting actual or potential degraded conditions (i.e., repair, surveillance, diagnostic exammations, and preventive measures).

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Maintenance Rule Scoping Manual: The Plant Hatch document that identifies all system's and j system functions included in the scope of the Maintenance Rule,10 CFR 50.65, as well as

system functions that are risk signiscant.

Operating Term: 40 years or as otherwise specified in the plant's operating license.

! Passive: As used in relation to a structure, component, or commodity group, the performance of a function without moving parts or without a change in configuration or properties.

l Shall (Will), Should, and May (Can): This document uses a specific convention to denote i requirements, recommendations, and options. The word "shall""will") is used when it is to be I understood that the statement is a requirement and leaves no decision to be made by the reader. l l Implementing the specific provisions of the Rule are considered requirements. The word l "should" indicates that a statement is a recommendation. The applicability of the

! recommendation depends upon the facts in each situation, and, with supporting justification, an alternate approach may be used. Interpretations of the Rule provided in the SOC are considered recommendations. The word "may"("can") conveys that the statement is to be taken entirely at the reader's option.

Short-Lived: An item that is either subject to replacement based upon a qualified life, specified time period or replaced periodically by defined performance or condition criteria that can be demonstrated to result in a life < 40 years.

Spaces: A term used in the electrical component and commodity evaluation process that describes a plant room or boundary for an electrical aging management review. " Spaces" also l refers to the evaluation approach described more fully in Sandia National Laboratory Report l SAND 96-0344.

i l Structure: A building or structural assembly that supports and/or encloses systems and/or components.

System: Any collection of equipment that is configured and operated to serve one or more functions (e.g., provide water to the torus, spray water into the containment, inject water into the primary pressure boundary) as defined by the terminology of each plant (e.g., feedwater system, containment spray system, high pressure coolant system).

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j System Evaluation Document (SED): A Plant Hatch controlled design document issued for the purpose of defining safety-related equipment. It is composed of a written description of safety-related systems, including identification of primary system operating modes, and the Safety-

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1 l Related Components List (SCL).

System Scoping Notes: A set of notes that defines the grouping of systems, structures, and/or components for all identified functions used in performing scoping evaluations.

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- . Plant Hatch 10 CFR 54 Process ACRONYMS The acronyms used in this document are based upon common aging terminology. The following - !

are common acronyms used in this document.

I AMR Aging Management Review ATWS Anticipated Transient Without Scram ]

BWR Boiling Water Reactor .

CFR Code of Federal Regulations CLB Current Licensing Basis CG Commodity Group DBA Design Basis Accident DBE Design Basis Event DOE U.S. Department of Energy ECCS Emergency Core Cooling System ELI Equipment Location Index EPRI Electric Power Research Institute EQ Environmental Qualification FHA Fire Hazards Analysis and Fire Protection Program IIELB High Energy Line Break ,

'rIVAC Heating, Ventilation, and Air-Conditioning  !

I IPA Integrated Plant Assessment  ;

ISI Inservice Inspection  !

IST- Inservice Testing LRS License Renewal Services l LOCA Loss of Coolant Accident <

MCC Motor Control Center  !

MOV Motor-Operated Valve MPL Master Parts List MRSM Maintenance Rule Scoping Manual NEI Nuclear Energy Institute NRC U.S. Nuclear Regulatory Commission NSSS Nuclear Steam Supply System 5

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1 ACRONYMS (Continued)

P&lD Piping and Instrumentation Diagram PTS Pressurized Thermal Shock

QA Quality Assurance RCPB Reactor Coolant Pressure Boundary RTD Resistance Temperature Detector l'

SBO Station Blackout SC Structure and Component SCC Structure, Component, and/or Commodity Group SED System Evaluation Document SER Safety Evaluation Report SOC Statement of Considerations i SSC System, Structure, and Component  ;

SSF System or Structure Function i SRP-LR Standard Review Plan - License Renewal TLAA Time-Limited Aging Analyses FSAR Updated Final Safety Analysis Report a

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f REFERENCES l

1. 10 CFR 54," Requirements for Renewal of Operating Licenses for Nuclear Power Plants," I l 56 FR 64976, December 13,1991.

l 2. 10 CFR 54, " Requirements for Renewal of Operating Licenses for Nuclear Power Plants,"

60 FR 22491, May 8,1995.

3. "NEI 95-10, Revision 0, Industry Guideline on implernenting the Requirements of 10 CFR l

Part 54 - The License Renewal Rule," March 1996.

4. 10 CFR 50.65," Requirements for monitoring the effectiveness of maintenance at nuclear i power plants," 56 FR 31324, July 10,1991.

l S. 10 CFR 50, Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants.

6. " License Renewal Demonstration Program

NRC Observations and Lessons Learned,"

l NUREG 1568, December 1996.

! 7. NEI/NRC License Renewal Work Shop, Reference Documents, October 29,1997. l

8. " License Renewal Demonstration Program Site Visit, Hatch Nuclear Power Plant Trip Report," July 9,1996.

9. " Standard Format and Content for Applications to Renew Nuclear Power Plant Operating i Licenses," Draft Regulatory Guide DG 1047.  ;

10. 10 CFR 50.48, Fire protection. l

11. 10 CFR 50.49," Environmental qualification of electric equipment important to safety for nuclear power plants," 48 FR 2733, January 21,1983, as amended by 49 FR 45576, November 19,1984; 51 FR 40308, November 6,1986; 51 FR 43709, December 3,1986; 52 FR 31611, August 21,1987; 53 FR 19250, May 27,1988; 61 FR 39300, July 29,1996; 61 FR 65173, December 11,1990; 62 FR 47271, September 8,1997,

12. 10 CFR 50.62," Requirements for reduction of risk from anticipated transients without scram (ATWS) events for light-water-cooled nuclear pr.,wer plants," 49 FR 26044, June 26, 1984; 49 FR 27736, July 6,1984, as amended by 51 FR 40310, November 6,1986 and

'54 FR 13362, April 3,1989.

13. 10 CFR 50.63," Loss of all alternating current power," 53 FR 23215, June 21,1988.

14. 10 CFR 50.61, " Fracture toughness requirements for protection against pressurized thermal shock events", 56 FR 22304, May 15,1991. ,

15. " Format and Content of Plant-Specific Pressurized Thermal Shock Safety Analysis Reports

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for Pressurized Water Reactors," Regulatory Guide 1.154.  !

16. Standard Review Plan for the Review of License Renewal Applications for Nuclear Power l Plants, Working Draft, September 1997.

17. " Aging Management Guideline for Commercial Nuclear Power Plants - Electrical Cables  ;

and Terminations," SAND 96-0344, United States Department of Energy.

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1.0 INTRODUCTION

I This document describes the Plant Hatch process that implements the requirements of  ;

Title 10 Code of Federal Regulations (CFR) Part 54, " Requirements for renewal of operatmg I licenses for nuclear power plants, the license renewal rule," (Ref. 2), hereafter referred to as the l

" Rule." SNC has incorporated the requirements of the Rule, the Statement of Considerations l

(SOC) for the Rule, and the guidance provided by NEI 95-10, Revision 0, Industry Guideline on l Implementing the Requirements of 10 CFR Part 54 - The License Renewal Rule,"(Ref. 3) in the development of the Plant Hatch process.

1.1 BACKGROUND

In December 1991, the Nuclear Regulatory Commission (NRC) published 10 CFR 54 (Ref.1) to establish the procedures, criteria, and standards governing nuclear plant license renewal. Since publishing the Rule, the NRC and the industry have been working to implement the requirements of the Rule. These efforts led to a revision of the Rule in May 1995 (Ref. 2).

l The Nuclear Energy Institute (NEI), on behalf of the nuclear industry, developed a generic guidance document, NEl 95-10, Revision 0, to provide the industry with a consistent  !

implementation process for the Rule. The industry used a demonstration program to further l verify that the use of this generic guidance document in the development of a license renewal application would satisfy the requirements of the Rule. SNC's Plant Hatch participated in this process by volunteering to be one of the demonstration plants. The NRC reviewed SNC's 1 application of the guidance on selected Plant Hatch systems and structures in May 1996 (Ref. 8).

NRC and industry interaction during and following the demonstration program identified issues {

requiring additional guidance (Ref. 6). In August of 1996, the NRC issued a draft regulatory guide DG 1047 (Ref. 9), endorsing NEl 95-10, Revision 0, with specific caveats, as an acceptable basis for preparing a license renewal application. In addition, botb the NRC and NEI hosted workshops in October 1996, which provided additional guidance to interested utilities.

l Many issues identified by the foregoing activities are currently being addressed by utilities pursuing a renewal application. Eventually, these issues should be resolved on a generic basis and should result in a revision to NEI 95-10 and related regulatory documents. In addition, the ,

NRC has issued a revised draft (September 1997) Standard Review Plan-License Renewal (SRP-LR)(Ref.16). The NRC has stated that it intends the SRP-LR to be a living document that will be periodically updated to incorporate the latest guidance as issues are resolved.

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1.2 PURPOSE l The purpose of the Plant Hatch process methodology document is to provide a description of the Plant Ratch process SNC will use in developing the technical basis for an application for a

( renewed license. The document provides a vehicle for addressing key license renewal issues, l identifying and resolving any potential issues that could significantly impact work performed to l support development of an application for a renewed license.

The Plant Hatch process methodology document is not intended to serve as the methodology

[ recuired by the Rule in 10 CFR 54.21(a)(2) as part of a license renewal application. However, as  ;

j modified by the resolution of the license renewal issues addressed by SNC and the NRC during the review process, this document can serve as a principal source ofinfom1ation in the development of the methodology document required by 10 CFR 54.21(a)(2).

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l 1.3 SCOPE The Plant Hatch process methodology document describes the activities involved in satisfying j the technical requirements of the Rule. Specifically, the Plant Hatch processes for identifying the systems and structures within the scope of the Rule; performing the Integrated Plant Assessment I (IPA); and identifying and evaluating time-limited aging analyses (TLAAs) are presented in detail. The major processes discussed are as follows:

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Identification of the systems and structures within the scope of the Rule [{54.4].

l l . Identification of the intended functions of systems and structures determined to be within the scope of the Rule [sS4.4 and {54.21].

. Identification of the structures, components, and commodities subject to aging management review [s54.21(a)(1)].

l . Identification of the principal functions of structures, components, and commodities.

i . Demonstrating that the effects of aging will be managed [ 54.21(a)(3)].

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Identification and evaluation of time-limited aging analyses [s54.21(c)(1)].

. Identification and evaluation of exemptions [s54.21(c)(2)].

The relationship between the scope of this document and the requirements of the Rule is j illustrated in Figure 1-1.

Direction and guidance are provided so that the process results are consistent with the NEl Industry Guideline, NEl 95-10, Revision 0 (Ref 3). This document is also written with the, knowledge that some provisions of the License Renewal Rule may be satisfied by the plant's 9

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Plant Hatch 10 CFR 54 Process action to comply with the Maintenance Rule,10 CFR 50.65 (Ref. 4). Unless otherwise clarified or modified in the SOC accompanying the 1995 amendment to 10 CFR 54 (Ref. 2), the SOC for the original (1991) Part 54 (Ref.1) rulemaking remains valid. Therefore, both SOCs were consulted in developing the Plant Hatch process. The SOC for the current Rule took precedence when the SOC of the current Rule conflicted with the SOC of the previous Rule.

l For the portions of the program not yet underway, SNC's plans to implement the Rule are described. Obviously, as SNC and the NRC agree upon the key licensing issues, the description of the process being used by Plant Hatch to implement the Rule will, of necessity, change.

This Plant Hatch process methodology document does not address the development of the format or content of the application. Therefore, several items required in the application; i.e.,

f Environmental Report supplements, Updated Final Safety Analysis Report (FSAR) supplements, Technical Specifications changes, and Current Licensing Basis (CLB) changes made during the application evaluation period, are not discussed. t t l l

1.4 QUALITY ASSURANCE REQUIREMENTS The license renewal process and application documents are subject to the requirements of 10 CFR 50, Appendix B (Ref. 5). The License Renewal Services internal procedures provide for

the control of documents and records, consistent with quality assurance requirements, during the l performance of scoping, boundary evaluations, screening, aging management reviews, TLAA and exemption evaluations. The technical data and results will be maintained in an auditable format and stored in an approved record storage facility.

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. Plant Hatch 10 CFR 54 Process FIGURE 1-1 LICENSE RENEWAL IMPLEMENTATION PROCESS -

wnwy ersieme. sinactur.s. .nd compo ts, thew intended funcbons, within the scope of Ident#y TLAAs and 10 CFR 5012 hcense renewel[$ 54 4](Section 3.0) [$ 54.3](SecGon 5.0)

N 1r ident#y structures and components subt ect to aging managewnt review

[$ 54.21(aX1XI) & (section 4.1) 1r 1r Demonstrate that the eNects of aging wel be Evaluate TLAAs and 10 CFR 5012 exemphons adequawy managed [$ 54 21(aX3))  ; [$ 54.21(cX1) & (2)] (Secuon 5.0)

(6ection 4.2)

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+.y v n./ w :; y W W Content of Apphcation -

Technical informabon Identify longlived possive SCs [$

- Describe 4 justify methods [$

- Demonstrate aging eMeets managed [$

- Evaluate TLAAa [$ 54 21(c)]

wem.- may1_ @

1r CLB Changes aNechng LRA FSAR Supplement Technical Spec #caton

[$ 54.21(b)] [$ 64 21(d)] charige:[$ 54 22]

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l 2.0 PROCESS BASES AND OVERVIEW I

l The Rule (Ref. 2) provides a general framework, not a prescriptive methodology, for preparmg a l license renewal application or performing the required IPA. Thus, the Rule provides flexibility in developing the most appropriate methodology. NEI 95-10, Revision 0, provides a l methodology and guidance that, when followed, are expected to produce technical documents and a license renewal application supporting the NRC's issuance of a renewed license. The NEl l guideline acknowledges that other suitabh. methods or approaches for satisfying the Rule's l requirements may be used. SNC applied NEI 95-10, Revision 0, and 10 CFR 54 and its related

! SOCs to develop the Plant Hatch process for fully implementing the Rule. Section 2.1 identifies certain approaches that may be unique to the Plant Hatch process, and also describes areas where SNC's implementation of the Rule uses a different approach from the guidance provided by NEI 95-10, Revision 0 or the SRP-LR. However, for those areas where a different approach is used, l the results obtained are expected to be consistent with the results that would have been obtained using the approach described in NEI 95-10, Revision 0.

l Plant Hatch-Specific Process Approaches l

Early in discussions with the NRC, SNC plans to address the following specific approaches or .

process elements to resolve any license renewal issues.

1. NEI 95-10, Revision 0, Section 3.0, guidance applies the scoping process to the plant systems l and structures to determine those that are within the scope of the Rule. The system and structure functions are then identified and processed to identify the intended functions. SNC has elected to first identify all the system and structure functions, and then apply the 54.4(a) scoping criteria to identify the intended functions and, thereby, the systems and structures within the scope of the Rule. SNC elected to take this approach, because the criteria in Q54.4 (a) are functional in nature, regardless of what system or structure accomplishes or supports l the accomplishment of the criteria. Plant Hatch had previously developed this functional l approach as part of the implementation of the Maintenance Rule (Ref. 4). These functions l were used and expanded, when necessary, to develop the functions to be evaluated for license renewal scoping.

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2. The Rule is a component-based rule. That is, an aging management evaluation down to the component level is required. In addition, the Rule is function oriented. To arrive at the component level, SNC chose to scope at a function level, not at a component level, and I

screen at the component level. This approach provides for a consistent use of the defined term intended function. To distinguish between the functions which are brought into the L scope of the Rule as intended functions and the functions structures, components or

! commodity groups perform to support maintenance of those intended functions, SNC has ,

elected to use the term " principal function" when referring to the specific structure, component, or commodity group (SCC) functions needed to support an intended function.

This approach was chosen to focus the aging management specifically on maintaining the l

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. Plant Hatch 10 CFR 54 Process SCC principal function (s) to demonstrate that the effects of aging will be adequately managed so that the intended function (s) will be maintained consistent with the CLB for the  ;

period of extended operation.

3. The list of plant systems and structures to be included in the scoping process is intended to be comprehcnsive; however, processing every aspect of the plant is beyond the intent of the Rule. Some practical considerations are used in addressing buildings and structures outside the Plant Hatch power block to limit the scoping process. Those considerations are described in Section 3.1.

4. The Plant Hatch process defines evaluation boundaries for intended functions associated with structures and screens the boundaries to determine the passive and long-lived SCCs of the

- structures. Figure 4.1-1 of the NEI 95-10, Revision 0, guideline does not include structures in the screening process. SNC elected to screen the intended functions associated with structures for completeness and to facilitate the aging management reviews for passive and long-lived structural commodities at a component level.

5. The Plant Hatch process defines the evaluation boundaries for intended functions. As part of the screening process, all structures, components, and commodities included in the evaluation

, boundary are grouped, when practical, and screened. The approach in NEl 95-10, Revision 0, establishes commodity groupings after the screening process is completed.

6. Consumables are considered piece parts and, as stated in the SOCs, it is not intended that aging management review be performed at a piece part level. Normal maintenance activities require repair, replacement, or refurbishment of the parent component if the condition of the consumable part is degraded. (An example is steam cutting due to a packing or gasket leak.)

The Plant Hatch process also considers consumable piece parts to be short lived; thus, no aging management review is planned in addition, the Plant Hatch process does not identify intended or principal functions at a piece-part level. This approach differs from Section 2.2111 B of the draft SRP-LR, which identifies consumables as items that potentially perform intended functions that would require an aging management review.

7. Complex assemblies are identified, as applicable, within intended function evaluation boundaries. Heat exchangers, hydrogen recombiners, and panels are examples of complex assemblies. Textual and/or graphical information will be provided to identify the interface of the complex assembly with other components and/or structures within the evaluation boundary. The Plant Hatch screening process classifies the complex assemblies as being either active or passive. For active complex assemblies (e.g., panels, racks, post-loss-of-coolant accident (LOCA) hydrogen recombiner) the aging management review only addresses structural integrity or pressure boundary functions that support the intended  !

function. The aging management review of passive complex assemblies (e.g., heat i exchangers) evaluates the various materials of the components that make up the complex assembly and the relevant aging effects. This approach to evaluating complex assembles is i consistent with the manner in which the SOC at 60 FR 22472 dispositioned diesel generators. l l

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Ilowever, this approach appears to differ with the position on complex assemblies presented in Section 3.0 III A of the draft SRP-LR.

8. The Plant Hatch process provides general criteria to be considered when evaluating the effectiveness of existing programs and determining whether the programs demonstrate adequate aging management for identified aging effects. Each aging management program I will be evaluated to determine ifit provides reasonable assurance that intended function will be maintained, in accordance with the CLB for the period of extended operation. This appears to be different from the guidance provided in Section 3.011 C of the SRP-LR, which appears to establish 10 criteria that must be met for the program to bejudged adequate.

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. Plant Hatch 10 CFR 54 Process 3.0 IDENTIFICATION OF SYSTEM AND STRUCTURE FUNCTIONS WITHIN THE SCOPE OF LICENSE RENEWAL 10 CFR 54.4 dermes the requirements for identifying the systems and structures, and their intended functions within the scope of the Rule as follows:

54.4

"(a) Plant systems, structures, and components within the scope of this part are--

(1) Safety-related systems, structures, and components which are those relied upon to remain functional during and following design basis events (as defined in 10 CFR 50.49(b)(1)) to ensure l

the following functions-l (i) The integrity of the reactor coolant pressure boundary; (ii) The capability to shut down the reactor and maintain it in a safe shutdown condition; or (iii) The capability to prevent or mitigate the consequences of accidents that could result in potential offsite exposure comparable to the guidelines in {50.34(a)(1) or 100.11 of this chapter as applicable.

(2) All nonsafety-related systems, structures, and components whose failure could prevent satisfactory accomplishment of any of the functions identified in paragraphs (a)(1)(i), (ii), or (iii) i of this section.

l (3) All systems, structures, and components relied on in safety analyses or plant evaluations l to perform a function that demonstrates compliance with the Commission's regulations for fire

protection (10 CFR 50.48), environmental qualification (10 CFR 50.49), pressurized thermal

! shock (10 CFR 50.61), anticipated transients without scram (10 CFR 50.62), and station blackout

! (10 CFR 50.63)."

As provided in {54.4(a)(1) above, design basis events for license renewal are applied as defimed l in 10 CFR 50.49(b)(1) below:

1 50.49

"(b) Electric equipment important to safety covered by this section is:

(1) Safety-related electric equipment.

(i) This equipment is that relied upon to remain functional during and following design basis l events to ensure--

l (A) The integrity of the reactor coolant pressure boundary;

! (B) The capability to shut down the reactor and maintain it in a safe shutdown condition; and (C) The capability to prevent or mitigate the consequences of accidents that could result in potential offsite exposures comparable to the guidelines in @50.34(a)(1) or {l00.11 of this chapter, as applicable.

(ii) Design basis events are defined as conditions of normal operation, including anticipated operational occurrences, design basis accidents, external events, and natural phenomena for which the plant must be designed to ensure functions (b)(1)(i)(A) through (C) of this section."

15

. Plant Hatch 10 CFR 54 Process I l The Plant Ilatch process for applying the requirements of 54.4(a) is described in th:s section.

1. All systems and structures, and their functions are identified to assure a thorough scoping process.

2. Each system and structure function is reviewed, with respect to the functional requirements in {54.4(a), using internal procedures to assure process consistency.

If the function is required to accomplish one or more of these requirements, the system or l structure function is within the scope of the Rule and is considered to be an intended l function as identified in 54.4(b). In most cases, the intended functions of a system or structure are a subset of all the system and structure functions. The portions of the systems or structures required to support the intended functions are within in the scope of the Rule. I i

3. Evaluation boundary drawings for system and structure intended functions will be developed, as described in Section 4.1.2. The evaluation boundary drawings will identify .

j the portions of the systems and structures within the scope of the Rule.

I l The Plant Hatch process and the implementation sequence are shown in Figure 3-1.  !

l l

l l

l l

l-l l 16

f Plant Hatch 10 CFR 54 Process t

t I

i FIGURE 3-1 l PROCESS FLOW DIAGRAM FOR PLANT HATCII LICENSE RENEWAL SCOPING l

For each system or structure function (SSF) in the plant, identify applicable infom ation l (Process the SSF through each path)

I M i_ ~( r, .;.7 ; n__*. ' ' ; "y;; ; n_.y; g-_ ; 77_ y 3(; 7+y 7, , ;.;y_: ._ q;3.e

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l 1f 1f

! is the g,

is the SSF Could failure No No SSF relied on to 1

safety related? of the SSF prevent a safe emonstrate compliance

[@ 54.4(a)(1)] related function? with certain NRC 54.4(a)(2)]

- egulations?

54.4(a)(3)

Yes Yes Yes lfIf f both inputs are "No,"

SSF is not in the scope of l

the license renewal rule

--w-If If )f identify the function (s) that meet (s) the requirements of $ 54.4(a)(1), (2) or demonstrates compliance I with (3)

....,_..___._..-.__m..._.:-_-_--_-m.. .. -

_ = . = _ - _ _ . . _ . - , . _ , .

lf j SSFs within the scope of license renewal are identified I 1

mm. __._._,..,;,,-_...m= --. . . _ _ < m._ . J l

{

1 l 17 l ,

l l

I

. Plant flatch 10 CFR 54 Process l '

3.1 IDENTIFICATION OF PLANT IIATCII SYSTEM AND STRUCTURE l FUNCTIONS WITIIIN TIIE SCOPE OF LICENSE RENEWAL The scoping requirements of the Rule and the Maintenance Rule overlap. The overlapping l requirements are illustrated by the comparison presented in Table 3-1. The requirements l [{54.4(a)(1) and 50.65(b)(1)] for identifying safety-related system and structure functions are l the same. The wording of the requirement in 54.4(a)(2) for identifying nonsafety-related i

system and structure functions within the scope of the Rule is the same as the corresponding j l requirement [{50.65(b)(2)(ii)] in the Maintenance Rule. Therefore, the Plant flatch Maintenance  !

l Rule Scoping Manual (MRSM) was used to establish an initial listing of plant system and structure functions. The Equipment Location Index (ELI) was also reviewed to assure all plant I

systems were included. The final list of functions to be evaluated addresses all plant systems and structures. The functions identified in the plant listing may not necessarily follow traditional system boundaries, and may include items with different system Master Parts List (MPL) numbers that perform or support the identified function. System Scoping Notes will be prepared, as necessary, to clarify the systems or structures associated with the listed functions.  ;

The NRC Safety Evaluation Reports (SERs) and associated docketed correspondence associated with the regulated events will be reviewed to identify the system and structure functions credited with satisfying the requirements associated with four of the five Commission regulations in

{54.4(a)(3). The four regulated events are:

. 10 CFR 50.48," Fire protection."

1 10 CFR 50.49," Environmental qualification of electric equipment important to safety for nuclear power plants."

. 10 CFR 50.62," Requirements for reduction of risk from anticipated transients without scram (ATWS) events for light-water-cooled nuclear power plants."

. 10 CFR 50.63," Loss of all alternating current power."

The fifth regulation,10 CFR 50.61, " Fracture toughness requirements for protection agamst pressurized thermal shock events," does not apply to Plant IIatch, because, as specified in the regulation, an evaluation in accordance with Regulatory Guide 1.154 (Ref.16) for boiling water reactor (BWR) plants is not required. The Environmental Qualification Master List (EQML) will be used to identify the systems relied upon to comply with 10 CFR 50.49. During the review of the EQML, SERs, and docketed correspondence, it will be confirmed that the credited ftmetions, and the systems and structures that specifically contribute to accomplishing the functions, are l included in the plant functions list.

( 18  ;

! l t

. Plant Hatch 10 CFR 54 Process l

I l The list of plant system and structure functions is intended to be comprehensive. However,

! processing every aspect of the plant is beyond the intent of the Rule. Some practical

. considerations are used in the Plant Hatch process to limit the scoping process. That is, some facilities, structures, and equipment are excluded without formal scoping. Typical examples of excluded facilities, structures, and equipment include the following:

. Driveways and parking lots that provide access to and from the plant.

. Office and warehouse facilities.

l

. Temporary equipment.

. - Health physics equipment.

. Portable radios.

l

. Portable measuring and testing equipment and tools.

l . Spare parts.

I

. Motor vehicles.

l SNC maintains excluded items; however, they are not associated with a plant system or structure.

1 l

19

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{

Plant Hatch 10 CFR 54 Process l  ;

I 3.2 SYSTEMS AND STRUCTURES NOT CONSIDERED IN THE PLANT HATCH PROCESS t

' i l

! In the SOC (Ref. 2), Section IV[s], the NRC determined that regulatory requirements provide '

l reasonable assurance that an acceptable level of emergency preparedness exists at any operating reactor at any time in its operating lifetime. Similarly, in the SOC (Ref. 2), Section IV[t], the l NRC determined that regulatory requirements for physical protection provide reasonable l

assurance that an adequate level of physical protection exists at any operating reactor at any time in its operating lifetime. As such, the Commission will make no new finding on emergency i

preparedness or physical protection (security) as part of a license renewal decision. Thus, Plant l Hatch systems and structures that only provide emergency preparedness or physical protection functions are not evaluated in the Plant Hatch process.

3.3 SAFETY-RELATED SYSTEMS AND STRUCTURES l

The criteria of s54.4(a)(1)[i, ii, and iii] provide the bases for determining the functions of safety-related systems and structures that are within the scope of the Rule. Each system and structure function in the plant listing (Section 3.1) will be reviewed with respect to these requirements by l asking the following questions:

1

l. Is the system or structure function identified as safety-related because it is relied upon dunng and following design basis events to ensure the integrity of the reactor coolant pressure -

l boundary? l

2. Is the system or structure function identified as safety related because it is relied upon during and following design basis events to ensure the capability to shut down the reactor and l maintain it in a safe shutdown condition?

3. Is the system or structure function identified as safety related because it is relied upon during and following design basis events to ensure the capability to prevent or mitigate the consequences of accidents that could result in potential offsite exposure comparable to the guidelinesin 50.34(a)(1)or 100.1I?

The ELI, SEDs, updated Final Safety Analysis Reports (FSARs) and MRSM will be used to answer these questions. The FSARs, and the applicable references, will be used as the basis for Plant Hatch design basis events. If the answer to one or more of these questions is "YES," the

, corresponding system and structure function will be within the scope of the Rule and will be an j intended function as identified by 54.4(b).

(

Plant Hatch, in certain cases, has conservatively chosen to designate some systems whose functions may not meet any of the criteria of @54.4(a)(1) as safety related. In such cases, it will 21

1

• l Plant Hatch 10 CFR 54 Process be documented that the system function does not meet the criteria of 54.4(a)(1). These system functions will be reviewed as described in Sections 3.4 and 3.5 to determine whether they perform the requirements of s54.4(a)(2) or s54.4(a)(3). In addition, due to the way Plant Hatch developed the System Scoping Notes to define items included in the scope of each structure and i system function, in a few cases, the functions include both safety related and nonsafety-related 1 items. In those cases, a system or structure function could be identified as meeting the criteria l for items 1,2, or 3 above and also as meeting the requirement for 54.4(a)(2) as described in the following Section 3.4. i 3.4 NONSAFETY-RELATED SYSTEMS AND STRUCTURES WHOSE FAILURE COULD PREVENT SAFETY-RELATED SYSTEMS AND STRUCTURES FROM ACCOMPLISHING THEIR FUNCTION The criterion of Q54.4(a)(2) will be used to identify the functions of nonsafety-related systems and structures that are within the scope of the Rule. The Plant Hatch design process, in general, i resulted in systems and structures supporting safety-related systems and structures being

! designated as safety-related. Therefore, few system and structure functions meet this criterion at Plant Hatch. Each of the system and structure functions in the plant listing (Section 3.1) that do not meet one of the three criteria described in Section 3.3 will be reviewed with respect to this requirement 1 y asking the following question:

Is the system or structure function identified as nonsafety-related whose failure could prevent satisfactory accomplishment of any of the functions identified in {54.4(a)(1)[i, ii, and iii]?

The ELI, the SEDs, the FSARs and MRSM will be used to answer this question.

Based upon a review of the FSARs, issues or events that need to be considered in association

! with this question for Plant Hatch will include Seismic II/1, flooding, jet impingement, pipe i whip, and missiles.

Consideration of actual plant-specific experience, industry-wide operating experience, and existing plant-specific engineering evaluations was originally addressed by the controlled MRSM determinations. This manual is periodically updated to incorporate plant-specific and industry-wide experience. Hypothetical failures that result from postulated system functional interdependencies that are not part of the Plant Hatch safety analyses or effects evaluations will not be considered. If a function is used to mitigate the event, the answer to the above question is "YES," the corresponding system or structure is within the scope of the Rule, and the function is an intended function per s54.4(b).

22 l

. l I

Plant Hatch 10 CFR 54 Process 3.5 SYSTEMS AND STRUCTURES RELIED UPON TO DEMONSTRATE ,

COMPLIANCE WITH CERTAIN NRC REGULATIONS The criteria of 54.4(a)(3) will be used to identify the functions of systems and structures that are relied upon in safety analyses or plant evaluations to demonstrate compliance with certain regulations [ fire protection (10 CFR 50.48), environmental qualification (10 CFR 50.49),

anticipated transients without scram (10 CFR 50.62), and station blackout (SBO)(10 CFR 50.63)]. As a BWR, Plant Hatch was not required to submit an evaluation in accordance with Regulatory Guide 1.154 (Ref.15). Therefore, a review of the pressurized thermal shock (10 CFR 50.61) event is not required. Each system and structure function in the plant list (Section 3.1) will be reviewed with respect to these criteria by asking the following questions:

1. Is the system or structure function relied upon in safety analyses or plant evaluations to-demonstrate compliance with the Commission's regulation for fire protection (10 CFR 50.48)?

2. Is the system or structure function relied upon in safety analyses or plant evaluations to demonstrate compliance with the Commission's regulation for environmental qualification (10 CFR 50.49)?

3. Is the system or structure function relied upon in safety analyses or plant evaluations to demonstrate compliance with the Commission's regulation for ATWS events (10 CFR 50.62)?

4. Is the system or structure function relied upon in safety analyses or plant evaluations to demonstrate compliance with the Commission's regulation for SBO (10 CFR 50.63)?

For question 2, if system or structure components are listed in the EQML, the system or structure function (s) that required environmental qualification of the components will be designated as relied upon to demonstrate compliance with 10 CFR 50.49. These system or structure functions are within the scope of the Rule and they are intended functions as identified by @54.4(b).

If the answer to questions 1,3, or 4 is "YES," the corresponding system or structure function (s) are within the scope of the Rule, the function (s) is designated as relied upon to demonstrate compliance with the applicable regulation, and the function (s) is an intended function as identified by 54.4(b). The NRC SERs and the associated docketed correspondence identified in the Section 3.1 review will be used to answer these questions. Reference to a system, structure, or function in the SER or Section 3.1 correspondence will be evaluated to determine whether the system, structure, or function is required to comply with the regulation. Functions, and the associated systems and structures, may be excluded if they are not specifically used in the analyses or evaluations to assure compliance with the regulation. If a system or structure is designated in the SERs or Section 3.1 correspondence to be required to achieve and maintain 23

L.

l Plant Hatch 10 CFR 54 Process i reactor safe shutdown as part of the response to a regulated event, then the answer to the l associated question will be "YES." However, as indicated in NEI 95-10, Revision 0, new evaluations which consider additional systems and structures required to support operability of l these systems and structures will not be perfonned, nor will hypothetical failures that could result i

from system interdependencies that are not part of the SERs or Section 3.1 correspondence and i have not been previously experienced be considered.

l l

l 3.6 DOCUMENTATION OF THE SCOPING PROCESS Section 54.37(a) of the Rule requires all information and documentation required, or otherwise necessary, to document compliance with the provisions of the Rule to be retained in an auditable

and retrievable form.

The infonnation that will be documented for the scoping process includes:

l l 1. The information sources used to: I

. Identify the list of all plant system and structure functions.

l 4 l .- Perform the scoping process.

l

! . System Scoping Notes used for clarification of scoping boundaries.

l

[ 2. A designation of the plant system and structure functions that meet one or more of the criteria .

of @54.4(a)(1)-(3).

! I

3. Identification ofintended functions - those system and structure functions that meet the l requirements of 54.4(b).

l-24

! Plant Hatch 10 CFR 54 Process I 4.0 INTEGRATED PLANT ASSESSMENT l The Rule requires a review of plant systems, structures, and components to determine if the l effects of aging are adequately managed for certain structures and components in the period of l extended operation. The process in Section 3.0 is used to identify the Plant Hatch system and structure functions that are within the scope of the Rule. An IPA is applied to those systerns and structures pursuant to 54.21(a). The IPA process requires an initial review of systems and structures within the scope of the Rule to identify the structures and components that require an aging management review. The aging management review will be performed in such a manner that a demonstration will be made, as required by Q54.21(a)(3), that the effects of aging will be adequately managed so that the intended function (s) will be maintained consistent with the CLB l for the period of extended operation. This review will provide the necessary assurance the SCs will perform their principal functions. This approach was chosen to focus the aging management specifically on maintaining the SCC principal function (s) in order to make the demonstration.

The Plant Hatch process for each part of the IPA process is presented in Sections 4.1 and 4.2, respectively.

4.1 PROCESS TO IDENTIFY STRUCTURES AND COMPONENTS SUBJECT TO AN AGING MANAGEMENT REVIEW i

The Rule, at 10 CFR 54.21(a)(1), specifies the requirements for identifying the structures and l components subject to an aging management review.

{54.21(a)(1)(i) and (ii)

"(1) For those system, structures, and components within the scope of this part, as delineated in s54.4, identify and list those structures and components subject to an aging management review. Structures and components subject to an aging management review shall encompass those 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. These structures and components include, but are not limited to, the reactor vessel, the reactor coolant system pressure boundary, steam generators, the pressurizer, piping, pump casings, valve bodies, the core shroud, component supports, pressure retaining boundaries, heat exchangers, ventilation ducts, the containment, the containment liner, electrical and mechanical penetrations, equipment hatches, seismic Category I structures, electrical cables and connections, cable trays, and electrical cabinets, excluding, but j not limited to pumps (except casing), valves (except body), motors, diesel generators, air l

compressors, snubbers, the control rod drive, ventilation dampers, pressure transmitters, pressure indicators, water level indicators, switchgears, cooling fans, transistors, batteries, breakers, relay switches, power inverters, circuit boards, battery chargers and power supplies, and 25

1 1

l .

l .

l Plant IIatch 10 CFR 54 Process i

i l (ii) That are not subject to replacement based on a qualified life of specified time period."

[ .

l

- \

- 1 l Section 4.1 defines a " screening" process whereby the passive, long-lived SCs that are subject to j an aging management review will be identified. Once identified, these SCs will receive further i evaluation as discussed h Section 4.2 to demonstrate that the effects of aging will be managed so L - that the intended function will be maintained for the period of extended operation. The SCs that l are not subject to aging . management review require no further evaluation in the IPA process.

l )

l l 4.1.1 Process Overview l

The screening process first identifies the evaluation boundary of the system or structure that is required to accomplish the intended functions. Then the systems and structures progress through l- several component level screening steps to identify the passive, long-lived structures and j components subject to an aging management review. Figure 4-1 describes the screening process for the mechanical and civil attributes of the intended functions. The screening process and l boundary determinations for electrical attributes of the intended functions are described in

l. Sections 4.1.5 and 4.1.6.

)

l 1

l l

26

( .

l l Plant Hatch 10 CFR 54 Process I

i FIGURE 4-1 i

t IDENTIFICATION OF STRUCTURES AND MECIIANICAL COMPONENTS SUBJECT TO AGING MANAGEMENT REVIEW I

l l

l

! From LRS 14, Boundary Procedure For each function boundary i estabiWed by LRS 14 ldentify all om ndary I

i i

f Group all common items into a nk oNponent or eh (atep 1.01 Note: LRS 14 and LRS 14 are i references to I internal procedures N

j identify by listing, reference

! drawings, or MPL numbers all n item i t p )

i 1

I is the component I la the SCC Yes subject to periodic No l g considered passive in u replacement at a set i the IPA process?

[l M.21(a)(1)(l)]

F frequency or specified time period?

M*NCMI(Step 4.08 (Step 3.0) [l H.21(a)(1)(ll)]

(Step 3.0)

No yee f 0 Scc e Metettal C . " - (Steps 0) etemal Environment (Step s.0)

Estemal Environment (Step 7.0) lf 9'"9 Aging knagemeM Review is muired Man ment Review la Perform LRS 14, AMR Procedure required 27 l

Plant Hatch 10 CFR 54 Process 4.1.2 Mechanical And Civil Evaluation Houndaries of the System and Structures Within the Scope of the Rule This step of the screening process defines the evaluation boundary for the system and structure functions determined to be within the scope of the Rule (Section 3.0). Defining the evaluation boundary focuses the screening process on the portions of systems and structures that directly contribute to the performance of one or more intended functions. Evaluation boundaries may be established such that multiple, in-scope functions are included in one evaluation boundary description whenever practical.

The license renewal evaluation boundary may, or may not, match boundaries that are defined in existing documents such as the FSAR and the piping and instrumentation diagrams (P&lDs).

For example, the evaluation boundary of a system whose only intended function is containment isolation may be significantly different from the description of the system boundary used by the plant. In this example, the license renewal evaluation boundary may include the containment isolation valves, process piping segment, and appurtenant components associated with a number of systems. Defining evaluation boundaries for license renewal will not require the plant to change or redefine existing boundaries. In addition, when a functional boundary is defined by the CLB, the CLB-defined boundary will be used. For example, a boundary definition may typically extend to include a second isolation valve in a run of piping. Ilowever, the CLB may specifically describe the function and define the boundary at the first isolation valve. In this example, the CLB-defined boundary would be used to define the License Renewal functional boundary.

The method of describing the evaluation boundary relies upon plant drawings. The set of drawings that are the most appropriate to illustrate the boundary information will be marked up with boundary designations that clearly indicate the portions or areas of the system or structure that are inside or outside the evaluation boundary. For example, system P&lDs should be used to illustrate the evaluation boundary ofintended functions from a mechanical perspective.

Likewise building floor plans, elevations and/or sections may be used to illustrate the evaluation

, boundary of the intended function from a civil / structural perspective. In the process of defining l evaluation boundaries, emphasis is placed on assuring all interfaces are adequtely considered.

As necessary, other references, prepared lists, and written descriptions may be used to supplement or further clarify the boundary designations on the marked-up drawings. The final set ofillustrated mechanical, electrical and/or civil / structural drawings, references, and written I

descriptions will form the " boundary package."

Some guidance for designating boundaries and interfaces is as follows:

28

V i

l

-o  !

l l

l Plant Hatch 10 CFR 54 Process e i

Mechanical

, 1. Where nonsafety-related piping is attached to safety-related in-scope piping (e.g. vent, drain, pressure relief, and test connections), the boundary should end immediately downstream of the relief or isolation valves. The downstream weld in the boundary shall not be included.

The downstream weld is not essential in maintaining the pressure boundary of the system. i l

l 2. The functional evaluation boundary shall include any branch lines (including instrument tubing  ;

and drain lines) associated with the in-scope function under consideration. ,

1

3. The boundary for pneumatic systems supplying air to air-operated components shall include l piping and tubing up to the component. ' Fittings and screwed connections between tubing and i component shall be considered part of the component.  ;

l

4. The NRC-approved Inservice Inspection (ISI) boundary diagrams shall be used to ensure the

( ASME Class 1,2, and 3 piping shown on the boundary diagrams are consistent with the ISI boundary diagrams. l

5. Service water for component cooling shall be considered a separate function from the component that it cools. On the service water evaluation boundary drawing, the interfacing service water function shall be shown before the weld of the piping to the cooled component  !

(if a welded connection is used) or at the service water piping flange (if a tlanged connection j l

is used). The service water evaluation boundary drawing shall show the function of the i cooled component, as well The cooled component function shall extend through the weld or j the cooled component flange.

Mechanical to Electrical Interface l 1. Mechanical system PalDs will be marked to show the piping, tubing, instruments and  !

components for each function determined to be in scope. The marked P&lDs will only l indicate the piping / tubing / components that are included in the pressure boundary or process

! flow path. Electrical and instrumentation components that do not provide a pressure

boundary, including power supply, process signals, or other electrical connections, will be i

treated separately. (See Sections 4.1.5 and 4.1.6.)

- 2. . Components that can be constmed to be either electrical or mechanical, such as an motor-operated valve (MOV), shall be included in the mechanical boundary designation and evaluated as an electrical component type.

/

29

l.

i Plant Hatch 10 CFR 54 Process Mechanical to Civil / Structural Interfacc l

l

1. The mounting details of the support structure shall be evaluated on a case by case basis to l determine if they should be included with the component on the evaluation boundary diagram.

l. In general, bolting connections for supports that are an integral part of the component shall be

! considered within the evaluation boundary of the component.

2. The structural elements of the support (i.e., struts, straps and bolts) shall be included with the support evaluation boundary. The civil / structural evaluation boundary for the building or other structure to which the support is attached shall include the connection devices l (embedded plates or structural members).

l l- Civil / Structural l

l . The evaluation boundary of the civil / structure that is a building will include the entire building, 3 l including slabs, external and internal walls, roof and internal concrete, and steel columns and 1 beams. Miscellaneous steelitems, such as base plates and embedded plates, are also included.

, Evaluation boundary diagrams shall also include structural items (e.g., blow-out panels, tornado l' vents, pedestals, rigid doors, grating, internal platforms doors, curbs for flooding control, jet impingement shields, and fire barriers) necessary to ensure proper mechanical and electrical system performance under accident conditions and during the regulated events.

l l 4.1.3 Mechanical and Civil Commodity Groups and Uniaue SCs and Their Principal Functions j For the purpose of efficiency, components within an evaluation boundary will be identified in j commodity groups to the maximum extent possible. The resulting contents of an evaluation

! boundary will be a listing ofits commodity groups and, a few unique structures or components.

Components that have similar material and environment and perform a similar principal function should be grouped. The list of structure and component types provided in Appendix A should be  ;

used to define the commodity groups. Principal functions for the passive and long-lived commodity groups and unique SCs will be defmed.

. Items included in a commodity group (CG) will be defined by one of the following methods:

. Establishing a list of the MPL numbers.

. Listing the reference drawings.

30

r Plant Hatch 10 CFR 54 Process l

l . Describing the component or system.

l l When establishing a passive and long-lived com.modity group, specific parameters that )

l accurately describe the principal function, material composition, internal and external environments for the components included in the commodity group will also be recorded. In addition, the applicable drawings, system descriptions, design information, material specifications, and/or other information that could aid in performing an aging management  !

review will be recorded. l l

l Unique structures or components that do not fit into a commodity grouping will be separately i listed.' The information recorded for these passive and long-lived structures or components will include a principal function, the material designation (s), internal / external environmental

conditions, design information, and pertinent drawings / documents that could aid in performing l an aging management review. 1

, Principal function (s) for SCCs subject to an aging management review are identified on the basis

! of how the SCC functions to support maintenance ofintended functions consistent with the CLB, l

without reliance on redundancy or probabilistic considerations. Table 4-1 provides a list of some  !

principal functions.

l l \

l l

I l

m

i o,

Plant Hatch 10 CFR 54 Process l TABLE 4-1 l

LIST OF POTENTIAL SCC PRINCIPAL FUNCTIONS

. Provide structural support to safety-related equipment.

. Provide shelter / protection to safety-related equipment.

l l . Provide pressure boundary or fission product retention barrier to protect public health and l safety in the event of any postulated design basis events (DBE).

. Provide pressure retaining boundary so that sufficient flow and adequate pressure is l delivered.

f . Provide missile barrier (internally or externally generated). 1 l l l

. Provide structural support to nonsafety-related equipment whose failure could directly 1 prevent satisfactory accomplishment of any of the required safety-related functions.

. Provide pipe whip restraint.

l Provide rated fire barrier to confine or retard a fire from spreading to or from adjacent areas

of the plant.

. Provide flood protection barrier (internally or externally generated).

. Provide spray shield, or curbs for directing flow (e.g., safety injection flow to containment sump).

l i l . Provide shielding against high energy line breaks and moderate energy line cracks credited in i the CLB.

. Provide shielding against radiation.

. Provide flow restriction, pressure reduction, or fixed throttling of process flow.

. Provide environmental contiol of plant areas not to exceed equipment limitations. l

. . Provide exchange of heat from one fluid medium to another.

32 r

l-l l

l

T i

l

[ Plant Hatch 10 CFR 54 Process )

l l

l .

j 4.1.4 Passive Mechanical and Civil Structures, Components, and Commodity Groups Having considered the effectiveness of existing plant programs which monitor the performance and condition of SSCs that perform active functions, the NRC concluded in the SOC of the Rule that active components can be excluded from a license renewal aging management review. This is because functional degradation resulting from the effects of aging on active components is i more readily determined, and existing programs and requirements are expected to directly detect and correct the effects of aging.

l Per 54.21(a)(1)(i), passive components are those which support an intended function, as i l described in j54.4, without moving parts or without a change in configuration or properties. The l l Plant Hatch process uses the listing in Appendix A to make the determination of whether or not a i commodity group or a unique structure or component is active or passive. Items not contained in the Appendix A listing will be evaluated to determine if their principal function is accomplished j without moving parts or without a change in configuration or properties. Subsequent additions to l the Hatch list will be evaluated by the use of the examples in the regulation. The basis of the

active / passive decision will be documented. Appendix A was initially developed as part of NEl 95-10, Revision 0. The listing in that document has subsequently been expanded and further modified by a subcommittee within the NEI License Renewal Task Force. At the time of l preparation of this document, NEI had not formally proposed to include the expanded list in a subsequent revision ~of NEl 95-10. l l i I

4.1.5 Electrical Component Screening l

The screening process for electrical components will be accomplished in the following two' steps: .

I

1. A generic list of all electrical component types in use at Plant Hatch will be compiled. Die l NEI License Renewal Task Force has developed a generic electrical component list compiled l from 10 CFR 54.21 and NEI 95-10, Rev. O, Appendix B. A design review of this generic list  ;

will be performed to determine completeness and applicability to Plant Hatch. The design i review will evaluate the generic industry list and plant-specific design to develop a i comprehensive list of all electrical components types at Plant Hatch. This list will  !

encompass all structures and components required for the performance of the electrical l

' intended functions identified in the scoping process described in Section 3.0.

l

' 2. The electrical component-type list developed in step one will be screened against

{54.21(a)(1)(i) and (ii) criteria to determine the passive and long-lived items in the list. The results of this screening will be a list of electrical component types that require an aging  !

management review. This list will be composed mainly of commodity groups. Unique component identification will be used if an item is not included in a commodity group. The l

L 33

Plant Hatch 10 CFR 54 Process principal functions of the screened commodities and components types listed will be  !

identified.

1 Typical principal functions for electrical commodities and components will include the l following:  ;

. Provide a uniform ground potential for circuits and equipment. I

. Provide an electrical current path connection between conductors of one circuit or transmission element and another circuit or transmission element.

l l

4.1.6 Electrical Evaluation Boundary Determinations Evaluation boundary determinations for electrical components are based upon a plant locahon or

" spaces" approach for aging management as described in Section 4.2.5. Evaluation boundaries are established for all structures or buildings that have identified intended function (s). The in-scope building and structures electrical evaluation boundaries are established using the areas or spaces defined by the Fire Hazards Analysis and Fire Protecti.on Program (FHA) drawings.

The FHA drawings provide a convenient format for the use of the plant "spces" approach for aging management. Each space may include electrical items necessary to support one or more intended functions. An aging management review will be performed which bounds all electrical items contained in the evaluation boundary. Spaces that do not contain electrical items requiring an aging management review (AMR) will not be considered.

4.1.7 Components Subject to Periodic Replacement at a Set Frequency or Qualified Life The detrimental effects of aging may increase as service life is extended, assuming no replacement of components. One way of effectively managing these effects is to replace selected i SCCs on a specified time interval based upon the qualified life of the SCCs, or periodically in

)

accordance with a specified time period to prevent performance degradations leading to a loss of intended function during the period of operation. Consistent with the SOC of the Rule, it is not necessary to justify or prove that the frequency of replacement is adequate since the existing i regulatory processes are credited with ensuring their adequacy.

In this step of the screening process, the passive SCCs are reviewed to determine if they are I

subject to replacement based upon a qualified component life or a specified time period. SCCs that are not subject to such replacement are classified as "long-lived." An SCC's replacement life must be < 40 years for the SCC to be considered "short-lived." SCCs with replacement lives

> 40 years shall be considered long-lived in some instances, the qualified life of a SCC may be based upon variables other than calendar time. For example, component run time, number of operating or loading cycles rather than actual calendar time may dictate component replacement l

l 34

I Plant Hatch 10 CFR 54 Process

! if the resultant replacement frequency can reasonably be demonstrated to be < 40 years. In either 1 case (calendar time replacement or applicable qualified life replacement), SCCs subject to replacement will not be subject to aging management review.

l 4.1.8 Documenting the Screening Process Paragraphs 54.21 and 54.37 detail the requirements of the Rule for documenting the IPA process.

1 54.21 Contents of application - technicalinformation.

"Each application must contain the following information:

l (a) An integrated plant assessment (IPA) must-(1) For those systems, structures, and components within the scope of the part, as delineated 54.4, identify and list those structures and components subject to an aging management review..."

g54.37 Additional records and recordkeeping requirements (a) The licensee shall retain in an auditable and retrievable from for the term of the renewed operating license all information and documentation required by, or otherwise necessary to document compliance with, the provisions of this part. .

(b) After the renewed license is issued, the FSAR update required by 10 CFR 50.71(e) must include any systems, structures, and components newly identified that would have been subject to an aging management review or evaluation of time-limited aging analysis in accordance with l

s54.21. This FSAR update must describe how the effects of aging will be managed such that the intended function (s) in 54.4(b) will be efTectively maintained during the period of extended operation."

The results of the screening process that identify the SCCs requiring an aging management review will be documented in the application. The following elements, as applicable, will be documented during the screening process and maintained on site or in an approved Quality l Assurance record storage location as required by {54.37.

. Evaluation boundary number, which provides a means to identify system and structure numbers.

. Evaluation boundary description.

35

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. 1 L

l Plant Hatch 10 CFR 54 Process. j l

. In-scope License Renewal Rule intended function (s) associated with the evaluation boundary.

. Reference to drawing (s)/information that establish the evaluation boundary of the function (s) .

(boundary evaluation package).

l . Electrical IPA boundaries (spaces).

l

. Electrical IPA component and commodity list.

l l . Commodity groups and their bases, components not a part of a commodity group, and l ' structures within in-scope evaluation boundaries.

l . " Active" or " Passive" designation for each commodity group or component within the l evaluation boundary.

l l

. "Long-lived" or Short-Lived" designation for each commodity group or component within the evaluation boundary.

. Statement of the principal function (s) of each passive and long-lived commodity group or l component within the evaluation boundary.

p . Any relevant reference material that establishes an SCC 's material, principal function, and internal and external environment.

I 4.2 PROCESS FOR ASSURING MANAGEMENT OF THE EFFECTS OF AGING The screening process described in Section 4.1 identifies the individual SCCs that require aging management review. This section describes the process and guidance for performing the aging management reviews of those SCCs to demonstrate that aging effects on their functionality during the period of extended operation will be adequately managed.

I 54.21(a)(3) of the Rule requires an aging management review to demonstrate, for each structure and component identified in Q54.21(a)(1), that the effects of aging will be adequately managed so that the intended ftmetion(s) will be maintained consistent with the CLB for the period of extended operation.Section III.f.(ii) of the SOC (Ref. 2) states that the demonstration should include a description of activities, as well as any changes to the CLB and plant modifications that are relied upon to demonstrate that the intended function (s) is (are) adequately maintained despite the effects of aging.

Although there are several viable approaches to performing an aging management review, two 36

I Plant Hatch 10 CFR 54 Process "

general methods are' described in the Plant Hatch process. Each method can be used to demonstrate that the effects of aging are being managed such that the principal function of the SCC preserved such that the supported intended function is maintained consistent with the CLB for the period of extended operation. Either method in this section may be applied to evaluations ofindividual SCCs. Although only two methods are described, other methods may also be used -

provided that the demonstration rec dred by Section 54.21(a)(3) is accomplished.

The first method is an aging management review of a specific SCC. This method is described in Section 4.2.1. A variation of this method has been developed and will be applied for the electrical components as described in Section 4.2.6. The second method, which is described in Section 4.2.5, utilizes the results of previous aging management reviews of a similar component

j. or structure. Examples of aging management reviews found acceptable by the NRC include certain license renewal topical reports developed by the nuclear steam supply system (NSSS)

Owners' Groups and previous plant-specific applications. Documentation of the aging management review is discussed in Section 4.2.7.

. If aging effects requiring management are identified, the aging management review will typically identify one or more aging management programs, either existing or new, to be credited in order to meet the requirements of 10 CFR Q54.21(a)(3).

4.2.1 Aging Management Review of a Structure, Component, or Commodity Group p The aging management review includes the following:

l l A. Understand how the structure, component, or commodity grouping performs its principal function (s)(Section 4.2.2).

l l B. Identify the aging effects associated with the SCC (Section 4.2.2).

i-C. Determine whether the analysis can be used to demonstrate that available design margins and/or material properties are sufficient under design basis conditions to ensure aging effects will not degrade the capability to maintain intended functions during the period of extended operations (Section 4.2.2).

l D. If needed, identify the applicable plant programs and review their ability to detect, mitigate, I or prevent the aging effects (Section 4.2.3).

E. In some cases, enhancing existing programs or developing new aging management programs may be necessary if existing programs are not adequate for managing the effects of aging for 37

l I

Plant Hatch 10 CFR 54 Process the period of extended operation.

F. Using the results of the reviews, demonstrate he effects of aging will be managed so that the SCC can perform its principal function such that the intended function (s) will be maintained for the period of extended operation (Section 4.2.4).

G. Document the aging management review process (Section 4.2.7).

4.2.2 Identification and Assessment of Aging Effects In Section 3.0 of the process, the intended functions were identified, and in Section 4.1.3 the SCC's principal function (s) were determined. The level of understanding of the factors that contribute to the aging process need not be the same for all SCCs to demonstrate that the aging effects will be managed. The practical experience from operating, maintaining, and monitoring the Plant Hatch SCCs should be appropriately considered in the aging management review process. There are various techniques used to identify and assess aging effects. For some SCCs, design margins and/or material properties are known and can be reviewed. In such cases, an analysis may be sufficient to demonstrate that the effects of aging are managed. For other SCCs, performance or maintenance history is available and can be reviewed to assist in demonstrating that the effects of aging are managed. These and other considerations point to the need to determine the appropriate level of review for each structure, component, or commodity grouping.

Determining the appropriate level of review involves examining information from various investigations and assessments of the SCC principal functions, design features, operating conditions and history and aging effects. As appropriate, the assessment may include the following activities:

1. Perform an assessment that evaluates how the SCC principal functions affect the intended function (s). Determining how the failure of the principal function (s) is manifested and/or detected is of particular interest. The assumptions used in the normal, transient and accident analyses should be reviewed to determine the applicable loading conditions and the conservatism that can be considered in the review of the aging affects.

2. Perform a review of the pertinent design information, codes, standards, licensing, and other CLB documents.

3. Assemble information relative to the SCC material and service environment. If the components are made from different materials or are subject to distinctly different aging effects, the review may need to separately address each combination of material, service duty, and environment.

38

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Plant Hatch 10 CFR 54 Process

4. Identify the aging effects potentially affecting the SCCs' ability to perform their principal function (s). This activity is intended to identify potential aging effects on the basis of 4 assembled industry information, as well as plant-specific determinations (e.g., from maintenance histories). The review should draw from the significant amount ofindustry information that has been assembled which provides for the systematic determination of a set of potential aging effects, given specific details about the SCC's materials, external and internal environments, and service duty.

5. Review the design or material properties to determine if analysis can demonstrate that the effects of aging are sufficiently managed to maintain the capability of the SCC to perform its principal function during the period of extended operation. Of particular interest are parameters such as corrosion allowance, fatigue cycles, loading conditions, fracture toughness, tensile strength, dielectric strength, radiation exposure, and environmental exposure. An analysis demonstration should conclude that there is reasonable assurance that the CLB will be maintained for the period of extended operation, and therefore, that the effects of aging need not be managed. An inspection for license renewal, as discussed in Section 4.2.3.4, may be utilized to verify specific design values, demonstrate that an aging effect is occurring as anticipated, or that an aging effect is not significant. Monitoring industry experience, such as the results ofinspections for license renewal at other plants, may also contribute to the demonstration in these cases.

6. Determine whether the SCC is addressed by a TLAA. TLAAs will be evaluated by the process described in Section 5.0.

7. Review and assess the recent operating and maintenance history for the SCCs at Plant Hatch.

The focus of the review may include the service duty, operational transients, past failure, or unusual conditions that affect the performance or condition of the SCC. Of particular interest is how the performance or degraded condition of the SCC affects the capability of the SCC to perform its principal function, and its safety significance. The review also may include an examination of repairs, modifications, or replacements for relevance to aging considerations.

8. Identify design features that prevent or mitigate aging of the SCC. These design features mcy be used as part of an analysis to show that specific aging effects need not be considered.

In addition to industry published sources, industry operating experience with respect to aging effects and management processes is documented ia a large assortment of regulatory documents.

The tools that will be used to facilitate identification of applicable aging effects have examined the body ofliterature available regarding aging effects as part of the tool development process.

This review will be supplemented by a plant-specific review of the NRC generic communications subsequent to those reviewed during tool development.

39 i

i

o Plant Hatch 10 CFR 54 Process To determine the potential aging effects, the materials, environment, stressors, and industry operating experience that are associated with each SCC under review should be considered and

. addressed as appropriate. In many instance , the proper selection of materials for the operating environment results in few, if any, potential aging effects. For example, uncoated carbon steel pipe is subject to loss of material due to general corrosion in a raw water environment, whereas

, 'certain stainless steels are not subject to the same effect. I In addition to the consideration of materials, environment, and stressors, the plant-specific CLB, plant operating experience, plant design features, plant maintenance practices, and existing engineering evaluations should be considered in order to identify the potential aging effects for the SCC subject to an aging management review. The potential aging effects are those that have been identified using the considerations described above, and that adversely affect the SCC such that the principal function (s) may not b: maintained in a manner to assure that the intended function is maintained consistent with the CLB for the period of extended operation. Some Aging effects may not be plausible at Plant Hatch due to unique circumstances. For example, freeze-thaw damage may be identified based upon the considerations discussed above as a potential aging effect for concrete. However, due to Plant Hatch's regional location, freeze-thaw

. damage may bejudged plausible. In addition, aging effects may not be plausible because of inherent design features or designed environmental conditions. For example, temperature in a given area is limited by design to prevent aging to SCCs due to temperature. The use of stainless steel in designing SCCs in a raw water environment would be an example of an inherent design feature that prevents aging due to general corrosion.

l 4

Conversely, water chemistry control practices, while efTective at preventing loss of material due  !

to corrosion on the inside wall of pipe, are credited as a plant program to manage the effects of j aging, but are not considered an inherent design feature. Although water chemistry control practices may be required by Technical Specifications and have been implemented for the life of  ;

the plant, they require positive actions by personnel and equipment to maintain the water chemistry within specified limits. General corrosion could occur if water chemistry parameters are outside of the allowed operating ranges. Thus, in this example, the water chemistry control program would be credited as an aging management program because the aging effect (corrosion) could potentially occur if the program was not in place.

Potential aging effects determined not to be plausible for Plant Hatch will have an evaluation  ;

with a technical justification documented as part of the IPA. l 4.2.3 Plant Aging Management Programs .

When the Section 4.2.2 review has identified that one or more potential aging effects for a SCC, plant programs applicable to the SCCs should be reviewed to determine if they include actions to detect, mitigate or prevent the effects of aging. The Rule does not contain specific criteria defining the acceptability of aging management programs. These elements will vary depending 40

O Plant Hatch 10 CFR 54 Process upon the SCC. The four types of aging management programs described in this document are:

. Those that prevent or mitigate aging effects.

I I

. Those that monitor the condition of the structure or component.

{

I

. Those that monitor the perfonnance of the' structure or component. {

. Specific license renewal inspections for aging effect determinations. j l

These aging management program types are described in Sections 4.2.3.1,4.2.3.2,4.2.3.3, and 4.2.3.4, respectively. Plant programs that manage aging could be one or more of the four

]

1 programs described in this process. Aging management programs that do not fit into one of these I four types may also be acceptable, as long as the programs are effective in managing the effects of aging. Programs credited as aging management programs for license renewal will be implemented in accordance with the plant's administrative procedures. Corrective actions l resulting from the aging management program will be controlled by the plant's existing

. Corrective Action Program.

The Plant Hatch programs that apply to the SCC and which manage aging efTects will be

(

identified. The features of these programs will be reviewed to establish how the aging effects will continue to be managed during the extended period of operation. Some elements ofinterest tha current programs could include are listed below, it should not be inferred that all programs will need to have all the following programmatic features. Existing programs are effective if there is reasonable assurance he aging effect will be managed in the period of extended operation l consistent with the CLB.

1. Preventive actions that mitigate or prevent the onset of degradation or aging effects, and their effectiveness is periodically verified are .in effect.

, 2. Parameters that provide information about the relevant aging effect(s) are monitored, l inspected, and/or tested.

3 There is an action, alert value or parameter to determine the need for corrective action.

4. The program is administratively controlled.

A final action in evaluating existing programs is to review the monitoring, inspection, and testing frequency. This should be done by examining the Plant Hatch and/or industry-wide operating experience and confirming that the frequency of the action (s) is appropriate for timely detection of the aging effects during the period of extended operation.

i 41

4 Plant Hatch 10 CFR 54 Process 4.2.3.1 Preventive or Mitigative Aging Management Programs A preventive aging management program is one that will limit the degradation of the SCC to such ~small quantities that the degradation is not detectable. A preventive aging management program may also be referred to as a program that precludes degradation due to aging efTects.

A mitigative aging management program is one that will limit the degradation of the SCC to quantities that are detectable, but sufficiently small that the SCC principal function will not be challenged during the lifetime of the plant. A mitigative aging management program may also l be referred to as a program that inhibits degradation due to aging effects.

• Other than the difference that aging is detectable in a mitigative program, as compared to a preventive program, both types will have the same characteristics and attributes. They are generally existing programs that have been in effect since initial operation, but may also be new .

programs or enhancements to existing programs.

These programs can be demonstrated to be effective because they control the environment of the SCC so that the environmental conditions needed for aging to occur do not exist. The environment of concern can include chemistry conditions inside a pipe, external environments, or use of coatings to prevent the aging from occurring. An assessment should be performed of the

. aging effects and operating history to determine that degadation due to aging effects can only be caused by adverse process fluid properties or other environmental conditions. The program must identify parameters of the environment (e.g., secondary water chemistry oxygen level) which are monitored periodically, and for which action and alert values have been established to restore the f

environment to within specified limits in a timely manner when deviations from acceptable values occur. The parameter that is monitored may either provide direct or indirect indication of the condition of the SCC. Indirect indications are used when the environment being controlled l _ cannot be visually observed or directly monitored (e.g., inside of pipe). Indirect indications monitor chemical properties of the fluid or environmental conditions that are related to the potential aging effect. Direct indications are used when the environment can be visually observed or directly monitored (e.g., external surfaces or internal surfaces during maintenance activities).

An example of a preventive aging management program is the existing program used by the plant to control the chemistry of the sodium pentaborate solution in the standby liquid control system to prevent corrosion of the storage tank, piping, valves, and pumps.

Another example of a preventive aging management program is the application of coatings or paint to prevent degradation due to general corrosion. Specifically, a preventive aging management program could be the painting of the exterior of a heat exchanger that might experience external corrosion due to condensation caused by cold cooling water on the shell side of the heat exchanger.

42

)

i I

Plant Hatch 10 CFR 54 Process In some cases, a verification of the effectiveness of the preventive or mitigative aging management program may be needed. Some manner of condition monitoring, such as an inspection to measure wall thickness of a pipe, may be needed in conjunction with the preventive or mitigative aging management program to demmtrate that the effects of aging are being adequately managed. An example of this might be a feedwater chemistry control program, along with a one-time inspection to determine wall thickness of the featvater piping.

4.2.3.2 Condition Monitoring Aging Management Programs  !

A condition monitoring program is one which monitors, inspects, tests, or measures the physical condition of the SCC to detect from direct information degradation due to the effects of aging. A 1 condition monitoring program performs an inspection of the physical property of the SCC. The inspection may or may not be intrusive. The inspection technique used by the condition monitoring program may be any one of a wide range, including visual, ultrasonic measurement, physical measurement of size, hardness measurement, and radiographs. The technique used must be appropriate for the potential aging effect, the SCC being considered, the significance of the  ;

aging effect, the rate of degradation, and the frequency of the inspection. The program may use a i sampling approach. An example of an aging management program that demonstrates how these l considerations are properly factored into the program is an erosion / corrosion program that  ;

monitors for loss of material in piping. The structural monitoring program implemented in

compliance with the Maintenance Rule is another example.

Condition monitoring programs may range from sophisticated inspection techniques to very simple inspections. Ultrasonic iupection for pipe cracking is an example of a sophisticated, technically complex, condition monitoring program. Visual inspection of piping supports under ASME Code Section XI, Subsection IWF, is an example of a condition monitoring program using relatively simple techniques.

I 4.2.3.3 Performance Monitoring Aging Management Programs l

l A performance monitoring program is one that monitors process parameters to provide an

indication of the condition of the system, structure, or component with respect to the aging effect j ofinterest. The performance monitoring program may be an aspect of normal plant operations, j or it may be a test that is performed periodically to ascertain the performance of a SCC. A ]

performance monitoring program must include action or alert values, or the trending of changes in parameter values, which will result in corrective action being initiated such that the intended function is maintained. Typically, degradation of the principal function will need to be a progressive process in which the failure of the intended function is not an immediate consequence and/or the intended function can be restored in a timely manner by Technical j Specification LCOs or alternate means (e.g., redundant trains or bypass configurations that 43 i i

'4 Plant Hatch 10 CFR 54 Process include spare pumps, compressors, control features, etc.) that are subject to administrative controls.

An example of an existing performance monitoring program is the Technical Specification required testing of the control room ventilation system to verify its flow capacity.

4.2.3.4 License RenewalInspection Programs I'

l A liceuse renewal inspection program is typically a one-time inspection to support an AMR for a p ' SCC. Several scenarios may require inspections to support the aging management review for a j particular structure, component or commodity group:

. To verify that sufficient design margins exist so that intended functions are maintained for j the period of extended operation.

. ' To verify that aging management programs will provide reasonable assurance that intended l functions will be maintained for the period of extended operation.

l

. To verify the practicality of augmented inspections as part of an existing aging management f

program.

In general, the demonstration required by the Rule is not intended to be a reverification of the l SCC design basis. However, in some cases, verification of a particular design basis parameter may be necessary if that parameter or condition is directly affected by some aging effect and which could potentially result in a loss of principal function (e.g., pipe wall thinning due to.

corrosion or erosion / corrosion could result in loss of structural integrity under design loads). In these cases, verification can be a physical measurement at susceptible locations or on a sampling i basis.

'4.2.4 Demonstration That Programs Will Manage Aging The Rule requires that a demonstration be made that the effects of aging will be managed.

Management of each identified aging effect for a commodity or SC will be demonstrated through an evaluation of existing or new programs. Those preventive, mitigative, performance monitoring, or inspection programs needed to manage the aging effect, per 10 CFR 54, will be identified. An evaluation checklist will be developed that includes all the elements listed below.

This checklist will be used for all programs except those current term programs subject to regulatory oversight. It is not necessary for each program to meet all the elements of the checklist in order to be considered adequate. The overall adequacy of the program (s) to manage the effect 44

1

. i

' Plant Hatch 10 CFR 54 Process will be determined based upon a collective review of how it meets the specific criteria to reasonably assure public health and safety.

The checklist elements are:

1. The scope of the applicable plant program (s) includes the specific SCC subject to aging l

management review.

2. The aging effect(s) is detected by one or more of the applicable programs.

3. The program (s) contains acceptance criteria against which the need for corrective action will i be evaluated, and it ensures that timely corrective action will be taken when those acceptance criteria are not met.

4. The program (s) will mitigate the aging effects of the SCC ensuring that the system and/or structure intended function (s) will be maintained, consistent with the CLB under design basis conditions.

5. Monitoring and trending will provide adequate predictability to permit timely corrective or mitigative actions.

i

6. The program (s) is subject to administrative controls.

Some existing programs are subject to NRC oversight due to the component function in support of plant analyses or license commitments. Some examples of this oversight process include the Maintenance Rule and Technical Specifications. When a program of this type is subject to the NRC's oversight in the current term, that program should also be adequate for renewal because the focus of the program is to maintain component functionality commensurate with the plant design basis regardless of the age of the component. Therefore, such programs will be credited l for renewal through a demonstration process which will not be as detailed as the demonstration i process for other programs. The demonstration process for existing programs will include a

! summary description of the program and the identification of the program in the CLB and

- showing that the program has been established to monitor a specific aging effect. More detail is expected for programs implemented in response to some NRC generic communications because of the limited regulatory involvement in either the development of the initial program or in the ongoing oversight of the program. . For all other programs, the demonstration should include a complete description of the program and implementation activities.

If aging management programs associated with a particular aging effect are not determined to be adequate, then appropriate enhancements will be needed for that program. Such enhancements may include, but are not limited to, verification of specific design values by one-time inspections, adding steps to a procedure for specific aging effects, changing the frequency of the i

45

. J

Plant Hatch 10 CFR 54 Process required task, adding specific aging management procedures, and/or changing the record keeping requirements.

The following factors should be considered in developing program enhancements:

. Safety significance of the SCC.

l-I

. Nature of the aging effect (i.e., it is readily apparent or easily detected).

. Feasibility of repair / replacement of the affected SCC.

. Compatibility / adaptability of existing programs to detect and manage the aging effects.

. Existence of technology to detect and manage the aging effect.

. Estimated cost, personnel radiation exposure, and impact on normally scheduled outage duration for enhancement options.

If existing programs, with or without enhancements, are not adequate for managing the effects of aging, then new programs or other actions shall be developed as appropriate. Other actions for consideration are refurbishment or replacement. Potential aging effects that could have an

( impact in the current term and may not have an adequate program to manage the aging will be l

identified and addressed under the current license corrective action programs for resolution.

4.2.5 Reference Existing or Previous Reviews Approved by NRC The effects of aging mechanisms on the ongoing performance and reliability of plant systems, structures, and components have been a key focus of the industry for many years. Considerable effort has already been applied to examining the effects of aging for a period of extended operation on passive, long-lived SCCs. In some cases, the work has produced full scope aging l evaluation reports that have been reviewed by the NRC.

- This progress of events is producing a growing library of reports that document the aging management review of a variety of SCCs. This library may provide Plant llatch with the option

! of relying upon the referenced results of a previous aging management review. If such an option l~ is selected, the elements of the aging management review will include: (1) identifying and demonstrating the applicability of a previous review; and, then, (2) demonstrating that the results i

and conclusions are in effect at Plant Hatch.

The elements of the review include the following:

1. The applicability of the selected reference will be demonstrated.

46 o

l

4 Plant Hatch 10 CFR 54 Process' The selected reference will be reviewed to identify the scope, assumptions, and limitations

)

affecting the results and conclusions of the analysis. Other characteristics that should be '

L identified include the configuration, functions, materials, service conditions, and the original design parameters (i.e., corrosion allowance, and loading cycles) and protective measures (i.e., coatings and cathodic protection) affecting the expected service life of the SCC.

The characteristics of the SCC in the selected reference shall be compared to the Plant Hatch SCC. Ifit is demonstrated that the Plant Hatch characteristics are the same or are bounded by .

l l those in the reference, then the selected reference will be applicable and may be used as a basis for the ' aging management review of the Plant Hatch SCC. Any outlier conditions should be reviewed and shown to be non-significant with respect to the results or conclusions of the selected reference. Otherwise, a specific demonstration of the outlier condition using l the method described in Section 4.2.3 shall be performed.

2. The management of aging effects will be demonstrated.

a.To make this demonstration, a review of the plant operating and maintenance history should be performed. Any historical effects that are found to be more aggressive than the conditions described in the selected reference should be investigated and the results factored into the Plant Hatch description of the aging effects.

l b. The selected reference shall be used to identify the programs and features of the programs l that will be used to demonstrate that effects of aging will be managed. The comparable Plant Hatch programs shall be identified, and their features shall be compared to the programs in the selected reference. Ifit determined that the features of the programs in j' the selected reference are in effect, then the aging management conclusions of the selected reference can be directly applied. Any differences shall be identified, and a l

justification provided that demonstrates the conclusions of the selected reference still  ;

apply. The justification should be based upon Plant Hatch features, operating experience  !

and maintenance history, or industry developments since the selected reference was o issued and reviewed by the NRC.

c. Any enhancements to current Plant Ilatch programs cited in the selected reference shall be identified. A description of how and when the enhancement (s) should be implemented will also be provided.

4.2.6 Electrical Compenent Specific Demonstration The aging management review of electrical components will be based upon the " plant spaces" approach as described in SAND 96-0344," Aging Management Guideline for Commercial 47

F 4

Plant Hatch 10 CFR 54 Process

- Nuclear Power Plants - Electrical Cables and Terminations," published by the Department of Energy. The following steps are required to implement this approach.

1,; The environment in each room or plant space identified in Section 4.1 will be determined.

Environmental parameters include normal ambient temperature, normal radiation dose rate and total expected 60-year accumulated dose, normal relative humidity, presence of hot' spots -

or areas where the temperature exceeds the normal temperature in other parts of the room, and areas of significant moisture, wetting, or submergence. Sources ofinformation include  ;

('

~

Environmental Qualification (EQ) environmental data, HVAC design data, FS AR, plant l walkdowns, discussions with plant personnel, health physics surveys, and any available j surveillance reports.

j 2. The 60-year life temperature and radiation environmental criteria for the electrical component i- types will be determined. Most cable types, whether used in EQ applications or not, are included in the EQ program which can provide useful data in determining 60 year criteria.

Also, much research has been conducted in recent years which can provide data to demonstrate that the a large percentage of the existing cables and connectors can be expected l to continue to perfbrm their safety function and meet all regulatory requirements during the period of extended operation. All in-scope plant cables will have a thermal 60-year criterion assigned to them based either on manufacturer's published data or on data contained in EQ test reports. For cable types and components that have not been environmentally qualified, the manufacturer's published temperature data for a 40-year life will be used. The p temperature corresponding to a 40-year life will then be reduced using the Arrhenius process l or other accepted analytical technique to determine a temperature corresponding to a 60-year j life. It may be necessary to determine the materials of construction and search available information sources to identify test data that can be used to determine the 60-year life criteria.

l The 60-year criteria for each discrete component type and cable type will be documented

! based upon temperature and radiation dose.

3. The 60-year life criteria of the various component and cable types will be compared to the ambient environment of each plant space. This will be done on a worst-case basis, where the L

60-year criteria of the cable and/or component type most susceptible to aging will be compared to the environmental parameters in the space. It will be documented whether or not the environment in the space meets the 60-year life criteria of the component. In cases where the 60-year life environmental criteria of the worst-case cable or component are higher than the normal service temperature and 60-year radiation dose of a specific plant area, no further review will be required for that area. In cases where an area temperature or radiation dose exceeds the 60-year criteria of the worst-case component, the next step is to determine whether the worst-case component or cable type is installed in the area being considered. If the component 'or cable type is actually installed in the area, perform the following activities j as applicable:

1 48

e

• 1 1

r Plant Hatch 10 CFR 54 Process I

( l l.

l- .

Search for more detailed material data or more specific environmental data and perform i recalculation of the 60-year life criteria; or  ;

l

. Specify that an aging management program is required which could include component l replacement.

If the worst-case component is not installed in the area, select the worst-case component or cable type installed in the space and perform the evaluation described above. All items that do not meet the criteria for 60 year life in the plant space will be listed and identified as j l requiring an aging management program. The following Figure 4-2 describes the electrical  !

l A M R process.

l l

1 I

i 1

49

1 9

i Plant Hatch 10 CFR 54 Process FIGURE 4-2 ELECTRICAL AGING MANAGE REVIEW FLOW CIIART Electrical AMR Process

" Spaces Approach" l Select Boundary Room l 1r Define Environmental Parameters V

Select plant bounding electncal devce and/or commodity lf Perform an evaluation and/or g, calculation to determine the acceptability of 60 yr. tife for the bounding fievice/ commodity lf YES lb bounding item '

- No further evaluation .+ Document Boundary 4 acceptable for 60 yr Room Evaluation.

to required life?

b YES lf NO ygg Re-perfonn evaluatiort and/or is boundang item -

It/are bounding calculation with more detailed + acceptable for 60 yr.

stern (s)in the room' ma'erial and/or onvironmental life?

data 1!

V "*

Select specifs bounding Aging Management Program is required.

item (s) for the room.

N Evaluate other items in the rtem ard klentify any others that are impacted I

50

e l l

Plant Hatch 10 CFR 54 Process I 4.2.7 Documentation of the Aging Management Review The Rule at 54.21 and 54.37 detail the requirements for documenting the IPA process.

l l'

54.21 Contents of application - technical information.

"Each application must contain the following information:

(a) An integrated plant assessment (IPA) must-(1) For those systems, structures, and components within the scope of the part, as delineated

- 54.4, identify and list those structures and components subject to an aging management review. l (3) For each structure and component identified in paragraph (a)(1) of this section,  !

demonstrate that the effects of aging will be adequately managed so that the intended function (s) will be maintained consistent with the CLB for the period of extended operation."

{54.37 Additional records and recordkeeping requirements

"(a) The licensee shall retain in an auditable and retrievable from for the term of the renewed operating license all information and documentation required by, or otherwise necessary to document compliance with, the provisions of this part.

(b) After the renewed license is issued, the FSAR update required by 10 CFR 50.71(e) must include any systems, structures, and components newly identified that would have been subject to an aging management review or evaluation of time-limited aging analysis in accordance with

{54.21. This FSAR update must describe how the effects of aging will be managed such that the intended function (s) in s54.4(b) will be effectively maintained during the period of extended operation."

I The Rule at 54.21(a)(3) requires utilities to document in the IPA portion of the application a demonstration that the effects of aging will be managed so that the intended function (s) will bc l maintained consistent with the CLB for the period of extended operation. The demonstration should include a description of the aging management activities as well as any changes to the CLB and any plant modifications that are relied on.

i l The Rule at 54.37(a) also requires that all information and documentation necessary to document compliance with the provisions of the Rule be retained in an auditable and retrievable form. The supporting information will be documented either on site or in a Quality Assurance (QA) controlled and approved record storage location. The supporting information should include a general discussion of how the aging management determinations were made, a list of the substantiating references and source documents cross-referenced to the evaluation results, reference to supporting calculations performed, and justification for the assumptions or special conditions used in applying or interpreting the source documents.

51

r e

Plant IIatch 10 CFR 54 Process l

l 5.0 TIME-LIMITED AGING ANALYSES The time-limited aging analysis (TLAA) review identifies and evaluates those time-limited' aging l

analyses within the scope of the Rule, and provides guidance for evaluating these TLAAs to insure that the they remain valid for the period of extended operation. The disposition of exemptions based upon TLAAs is also discussed in this section.

t l The process used to identify and evaluate plant-specific TLAAs is discussed in Section 5.1. The

. process used to identify and evaluate exemptions granted pursuant to 10 CFR 50.12, which are l

based upon TLAAs, is discussed in Section 5.2. Documenting the TLA.A review is discussed in Section 5.3.

5.1 PROCESS FOR IDENTIFYING AND EVALUATING TIME-LIMITED AGING ANALYSES The process contained in this section describes a process that will be used to identify and evaluate time-limited aging analyses as required by 54.21(c)(1) of the Rule. TLAAs are those calculations and analyses that:

. Involve systems and structures within the scope oflicense renewal as delineated in 54,4(a);

. Consider the effects of aging;

. Involve time-limited assumptions defined by the current operating term (40 years);

. Were determined to be relevant in making a safety determination;

. Involve conclusions or provide the basis for conclusions related to the capability of the system and structure to perform its intended functions, as defined in @54.4(b); and

. Are contained or incorporated by reference in the CLB.

The results of the TLAA evaluations will be used in the Plant Hatch license renewal application.

52

, Plant Hatch 10 CFR 54 Process - i

)

.j i

. ]

5.1.1 Process Ovenlew i

Evaluating time-limited aging analysis issues is a two-step process:

.- Identification of TLAA issues related to systems, structures and components determined to

'be within the scope oflicense renewal, and

. Evaluation and resolution of the TLAA issues for the period of extended operation.

I i

l 5.1.2 Identification of the Time-Limited Aging Analyses 1

Plant Hatch calculation logs will be reviewed to identify potential TLAAs. Available lists of TLAAs identified in industry generic evaluations and at other plants will be reviewed to ensure that the Plant Hatch listing is complete. Each step of the process is described more fully in the following paragraphs.

~

L l 1. Identify potential TLAAs.

L Potential TLAAs will be identified through a search of design calculations and evaluations. .

All calculations meeting Criteria 3 (i.e., those which involve time-limited assumptions l L

defined by the current operating term) will be identified and listed. These calculations will l

then be tested against the other five criteria. Those calculations and evaluations meeting all i six criteria will require evaluation for license renewal.

l L 2. Apply the Time-Limited Aging Analysis Scoping Criteria i

i L Not all the potential TLAAs identified and described in steps (1) and (2) need to be evaluated for license renewal. For example, the discussion in the SOC ( III g.[i])(Ref. 2), indicates that calculations or analyses that are based upon an assumed period of plant operation which is less than the current operating term are not a concern for license renewal. The calculations or analyses that shall be evaluated are those that:

a. Involve systems and structures within the scope of the Rule (for TLAA evaluation the

" scope" includes both the passive and active components),

b. Consider one or more aging effects (the effects of aging include, but are not limited to:

loss of material, loss of toughness, loss of pre-stress, settlement, cracking, and loss of dielectric properties), -

53

Plant Hatch 10 CFR 54 Process

c. Involve time-limited assumptions def'med by the current operating term (the defined operating term should be in an analysis that explicitly includes a time limit),

d. Were determined to be relevant in a safety determination (an analysis or~ calculation is considered " relevant" ifit provided the basis for the safety determination and in the absence of the analysis, a different safety conclusion may have been reached),

e. Involve conclusions or provide the basis for conclusions related to the capability of the

, system and structure to perform its intended function, and i.

f. Are contained or incorporated by reference in the CLB (calculations are typically not a i part of the CLB; however, those calculations required to verify assumptions made in the CLB documents should be considered).

Calculations and analyses meeting all of the six criteria above are TLAAs and will require evaluation for license renewal. Typical dispositions for " potential" TLAA issues are shown in Table 5-2.

3. Identify the Time-Limited Aging Analyses that require evaluation for license renewal. The

! listings of TLAA issues identified in industry generic evaluations and at other plants wr11 be reviewed to ensure that the Plant Hatch listing is complete.

5.1.3 Evaluation and Resolution of the Time-Limited Aging Analyses Evaluation and resolution of the time-limited aging analyses shall use one of three different

- approaches as described in {54.21(c)(1) of the Rule. The analyses can be shown to remain valid for the period of ex+ ended operation, the analysis can be extended, or the effects of aging can be shown to be managed over the period of extended operation. The elements of the evaluation for each of these approaches are provided below:

1. Verify the TLAA is valid for the extended operating period.

Typically, the existing TLAAs are based upon the current operating term (e.g.,40 years).

However, there may be cases where the original analysis already encompasses the period of extended operation and only a minor editorial change to the calculation is necessary. On the other hand, in some cases the components associated with a TLAA may have been replaced during the current term, which could mean that the analysis will remain valid for the renewal l term for those components.

It should be demonstrated that the conditions and assumptions used in the TLAA are valid for the extended operating period, acceptance criteria are maintained, and the intended

} function (s) 54 i

e Plant Hatch 10 CFR 54 Process is assured. Any actions, and an associated implementation plan, for revising the affected TLAA source documents (Section 5.1.2) should be identified.

2. Justify the TLAA can be extended.

Even though the current TLAA is not valid for the extended operating period, it may be

possible to revise the analysis by recognizing and re-evaluating any conservative conditions l and assumptions. Relaxing overly conservative assumptions in the original analysis may be l based upon new or refined analytical techniques and/or actual operating conditions as

compared to the anticipated or bounding operating conditions used in the original analysis.

l An acceptable approach for justifying that the TLAA can be extended is described in the l following paragraphs.

The operating and maintenance data and/or available technical references should be reviewed, as appropriate, to characterize the current condition, service duty, rates of degradation, abnormal cecurrences, remaining margins, and circumstances that may affect current trends. This information should be compared to the conditions and assumptions used in the original analysis.

The collected information and/or new or refined analytical techniques should be used to justify that previous conditions and assumptions can be moderated. The current or recast

. condition and/or trends should be extrapolated to demonstrate that the acceptance criteria can

be maintained and/or the intended function (s) is assured throughout the extended operating

period.

Any actions, and an associated implementation plan, for revising the affected TLAA source documents (Section 5.1.2) should be identified. The implementation plan should include all identified TLAAs and the schedule may extend out to the end of the current term. If the schedule extends past the issue of a new license, the TLAAs will be listed with a required revision date in the application.

3. Verify the TLAA is resolved by managing the aging effects.

The two previous approaches may not be preferred for some SCCs or there may be some TLAAs for which the evaluations cannot be shown to be valid for the extended period of operation and for which the period of evaluation cannot be extended to cover the renewal period. Also, certain analyses may be very time consuming and cost prohibitive to disposition using the previously described approaches. In these situations, the process and guidance provided in Section 4.2 shall be used to demonstrate that the aging effects will be managed and intended function is assured.

55

Plant Hatch 10 CFR 54 Process 5.2 PROCESS FOR IDENTIFYING AND EVALUATING EXEMPTIONS CONTAINING TIME-LIMITED AGING ANALYSES  !

Section 54.21(c)(2) of the Rule requires that a list of all exemptions granted pursuant to 10 CFR 50.12 and in effect that are based upon time-limited aging analyses as defined in @54.3 be provided along with the evaluation of time-limited aging analyses. For exemptions that were either granted on the basis of an assumed service life or a period of operation bounded by the original license term (i.e., time-limited aging analyses), justification for continuation of these exemptions shall be provided.

The identification and evaluation of plant-specific exemptions granted pursuant to 10 CFR 50.12 is a two-step process: l

. Identification of exemptions granted in accordance with 10 CFR 50.12 which are still in effect and which are based upon TLAAs.

. Justification the continuance of these exemptions for the extended operating period.

The elements of each step of the process are provided below.

5.2.1 Identification of the Exemptions in Effect Identification of the exemptions will require the review of correspondence between the NRC and SNC to trace the resolution of the exemption. The Plant Hatch dockets will be reviewed to identify the relevant correspondence.

The relevant correspondence will be reviewed to determine that the exemption will be in effect during the extended operating period, involves an SCC within the scope of the Rule, and involves a TLAA issue. If all of these conditions apply, then an evaluation of the exemption shall be performed.

An exemption will be considered no longer in effect when:

1. Docketed correspondence indicates that it has been terminated, l 2. It can be shown that a regulation change has rendered the exemption unnecessary, l

3. It can be shown that a plant modification or operational change has been made which eliminates the necessity of the exemption, or 56 L

O'.

l - Plant Hatch 10 CFR 54 Process

4. Compliance with the regulation can be demonstrated without the exemption.

5.2.2 Evaluation of the Exemptions It is not anticipated that any exemptions with TLAA basis will be identified. Therefore, further work is not anticipated. ,

l i

i 57 l

Plant Hatch 10 CFR 54 Process TABLE 5-1 DISPOSITION OF POTENTIAL TLAAs AND BASIS FOR DISPOSITION Example Disposition NRC correspondence requests a utility to justify Does not qualify as a TLAA because the design that unacceptable cumulative wear did not occur life of control rods is less than 40 years.

during the design life of control rods. Therefore does not meet criterion (3) of the TLAA definition in 54.3.

Maximum wind speed of 100 mph is expected Not a TLAA. Does not involve an aging effect.

to occur once per 50 years Correspondence from the utility to the NRC This example does not meet criterion (4) o.f the states that the membrane on the containment TLAA definition in @ 54.3 and therefore is not basemat is certified by the vendor to last for 40 considered a TLAA. The membrane was not years. credited in any safety evaluation.

Fatigue usage factor for the pressurizer surge This example is a TLAA because it meets all 6 line was determined not to be an issue for the criteria in the definition ofTLAA in 54.3. The l current license period in response to NRC utility's fatigue design basis relies upon l Bulletin 88-11. assumptions related to 40 year operating life for this component. Plant-specific data could be used but is more difficult due to thermal I stratification. l Containment tendon lift off forces are calculated This example is a TLAA because it meets all 6 )

for the 40 year life of the plant. This data is criteria of the TLAA definition in 54.3. The i used during Technical Specification surveillance lift off force curves are limited to 40 year values for comparing measured to predicted lift off currently and are needed to perform a required forces. Technical Specification surveillance.

l 58

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