ML062580162

Audit Trip Report Regarding Entergy Nuclear Operations Inc. License Renewal Application for Pilgrim Nuclear Power Station, Dated January 25, 2006

ML062580162
Person / Time
Site:	Pilgrim
Issue date:	09/15/2006
From:	Hamzehee H NRC/NRR/ADES/DE/EQVB
To:	Kuo P NRC/NRR/ADRO/DLR
Greg Galletti, NRR/DE/EQVB (301) 415-294
References
TAC MC9669
Download: ML062580162 (8)

Text

September 15, 2006MEMORANDUM TO: P.T. Kuo, Deputy Director Division of License Renewal Office of Nuclear Reactor RegulationFROM: Hossein Hamzehee, Chief /RA/ Bill Rogers for Quality & Vendor Branch B Division of Engineering Office of Nuclear Reactor Regulation

SUBJECT:

AUDIT TRIP REPORT REGARDING THE ENTERGY NUCLEAR OPERATIONS, INC., LICENSE RENEWAL APPLICATION FOR THE PILGRIM NUCLEAR POWER STATION, DATED JANUARY 25, 2006Plant Name: Pilgrim Nuclear Power StationUtility Name: Entergy Nuclear Operations, Inc.

Docket No: 50-00293 (DPR-35)

TAC No: MC9669 Review Branch: Quality & Vendor Branch BDuring the week of June 6 - 9, 2006, the Quality and Vendor Branch B(EQVB)performed an audit of the Entergy Nuclear Operations, Inc.(the applicant) license renewal scoping and screening methodology developed to support the Pilgrim Nuclear Power Station license renewal application (LRA), dated January 25, 2006. The focus of the staff's audit was on the applicant's administrative controls governing implementation of the LRA scoping andscreening methodology, and review of the technical basis for selected scoping and screening results for various plant systems, structures, and components. The audit team also reviewedquality attributes for aging management programs and training for personnel that developed the LRA. A trip report containing a summary of the audit results is attached.

Enclosure:

As statedCONTACT:Bill Rogers, NRR/DE/EQVB(301) 415-2945 September 15, 2006MEMORANDUM TO: P.T. Kuo, Deputy Director Division of License Renewal Office of Nuclear Reactor RegulationFROM: Hossein Hamzehee, Chief /RA/ Bill Rogers for Quality & Vendor Branch B Division of Engineering Office of Nuclear Reactor Regulation

SUBJECT:

AUDIT TRIP REPORT REGARDING THE ENTERGY NUCLEAR OPERATIONS, INC., LICENSE RENEWAL APPLICATION FOR THE PILGRIM NUCLEAR POWER STATION, DATED JANUARY 25, 2006Plant Name: Pilgrim Nuclear Power StationUtility Name: Entergy Nuclear Operations, Inc.

Docket No: 50-00293 (DPR-35)

TAC No: MC9669 Review Branch: Quality & Vendor Branch BDuring the week of June 6 - 9, 2006, the Quality and Vendor Branch B(EQVB)performed an audit of the Entergy Nuclear Operations, Inc.(the applicant) license renewal scoping and screening methodology developed to support the Pilgrim Nuclear Power Station license renewal application (LRA), dated January 25, 2006. The focus of the staff's audit was on the applicant's administrative controls governing implementation of the LRA scoping andscreening methodology, and review of the technical basis for selected scoping and screening results for various plant systems, structures, and components. The audit team also reviewedquality attributes for aging management programs and training for personnel that developed the LRA. A trip report containing a summary of the audit results is attached.

Enclosure:

As statedCONTACT:Bill Rogers, NRR/DE/EQVB(301) 415-2945DISTRIBUTION:EQVB R/F RidsNrrOd PBuckberg, PM, JZimmerman, LLund, GGalletti ADAMS ACCESSION NO.: ML062580162OFFICEEQV/DEBC/EQV/DENAMEGGallettiHHamzeheeDATE 09/ 15 /06 09/ 15 /06 OFFICIAL RECORD COPY

EnclosureAUDIT TRIP REPORT ENTERGY NUCLEAR OPERATIONS, INC., LICENSE RENEWALAPPLICATION FOR THE PILGRIM NUCLEAR POWER STATION, DATED JANUARY 25, 2006I. IntroductionDuring the week of June 6-9, 2006, B ill Rogers, Greg Galletti, and Steve Tingen of the Qualityand Vendor Branches A & B, audited the Entergy Nuclear Operations, Inc. (the applicant) license renewal scoping and screening methodology developed to support the Pilgrim Nuclear Power Station (PNPS) license renewal application (LRA). The audit was performed at the applicant's facility outside of Plymouth, Massachusetts. The focus of the staff's audit was onthe applicant's administrative controls governing implementation of the LRA scoping andscreening methodology and review of the technical basis for selected scoping and screening results for various plant systems, structures, and components. The audit team also reviewedquality attributes for aging management programs, training for personnel that developed the LRA, and quality practices used by the applicant to develop the LRA. II. Backgr oundTitle 10 of the Code of Federal Regulations, Part 54 (10 CFR Part 54), "Requirements forRenewal of Operating Licenses for Nuclear Power Plants," Section 54.21, "Contents ofApplication - Technical Information," requires that each application for license renewal containan integrated plant assessment (IPA). Furthermore, the IPA must list and identify those structures and components (SCs) that are subject to an aging management review (AMR) from the systems, structures, and components (SSCs) that are within the scope of license renewal. 10 CFR 54.4(a) identifies the plant SSCs within the scope of license renewal. SCs within the scope of license renewal are screened to determine if they are long-lived, passive equipment that is subject to an aging management review in accordance with 10 CFR 54.21(a)(1). III. Scoping MethodologyThe scoping evaluations for the PNPS LRA were performed by the applicant's license renewalproject personnel and contractor personnel. The audit team conducted detailed discussions with the applicant's license renewal project management personnel and reviewed documentation pertinent to the scoping process. The audit team assessed if the scoping methodology outlined in the LRA and implementation procedures was appropriately implemented and if the scoping results were consistent with current licensing basis requirements. The audit team also reviewed a sample of system scoping results for thefollowing systems and structures: Reactor Core Isolation Cooling and Yard Structures(structural review). In general, the team determined that the applicant's overall approach to license renewal SSCscoping appeared to be adequate. However, the audit team identified several issues where additional information will be required to complete the LRA review. These issues aredocumented in a request for additional information and are briefly described below. *During the scoping and screening methodology audit, the NRC audit team questionedhow non-accident design basis events, particularly design basis events that may not be described in the Updated Final Safety Analysis Report (UFSAR), were considered during scoping. The NRC audit team noted that limiting the review of design basesevents to those described in the UFSAR accident analysis could result in omission of safety-related functions described in the current licensing basis. The audit team, therefore, requested the applicant to provide a list of the design basis events evaluatedas part of the license renewal scoping process, and describe the methodology used to ensure that all design bases events (including conditions of normal operation, anticipated operational occurrences, design basis accidents, external events, and natural phenomena) were addressed during license renewal scoping. *Based on a review of the LRA, the applicant's scoping and screening implementationprocedures, and discussions with the applicant, the audit team determined that additional information is required with respect to certain aspects of the applicant's evaluation of the 10 CFR 54.4(a)(2) criteria. The audit team requested that theapplicant provide supplemental information regarding how the structural boundary, which includes the portion of the non-safety piping system outside the safety-relatedpressure boundary and relied upon to provide structural support for the pressure boundary, was developed. Additionally, the team requested the applicant to defineequivalent anchors and indicate whether equivalent anchors were used to determine any plant system structural boundary.IV.Screening MethodologyThe audit team reviewed the methodology used by the applicant to determine ifmechanical, structural, and electrical components within the scope of license renewal would be subject to further aging management review. The applicant provided the audit team with a detailed discussion of the processes used for each discipline and provided administrative documentation that described the screening methodology. The auditteam also reviewed the screening results reports for the Reactor Core Isolation Cooling system and Yard Structures. The team noted that the applicant's screening processwas performed in accordance with its written requirements and was consistent with the guidance provided in NUREG-1800, "Standard Review Plan for Review of LicenseRenewal Applications for Nuclear Power Plants," Revision 1, (LR-SRP), and the Nuclear Energy Institute (NEI) 95-10, "Industry Guidelines for Implementing the Requirements of 10 CFR Part 54 - The License Renewal Rule," Revision 6, (NEI 95-10). The audit team determined that the screening methodology was consistent with the requirements of theRule for the identification of SSCs that meet the screening criteria of10 CFR 54.21(a)(1).V.Aging Management Program Quality Assurance AttributesThe NRC staff reviewed the applicant's Aging Management Programs (AMPs) describedin Appendix A, "Updated Safety Analysis Report Supplement," and Appendix B, "Aging Management Programs and Activities," of the LRA, and License Renewal Project Document (LRPD)-02, "Aging Management Program Evaluation Report," Revision 1.

The purpose of this review was to ensure that the quality assurance attributes (corrective action, confirmation process, and administrative controls) were consistentwith the staff's guidance described in NUREG-1800, Section A.2, "Quality Assurance forAging Management Programs (Branch Technical Position IQMB-1)."Based on the NRC staff's evaluation, the descriptions of the AMPs and their associatedquality attributes provided in Appendix A, Section A.2.1, and Appendix B, Section B.0.3,of the LRA are consistent with the staff's position regarding quality assurance for aging management. However, the description of the corrective action attribute in Section 2.0 of LRPD-02 did not credit the 10 CFR Part 50, Appendix B, quality assurance program.

Therefore, the NRC staff requested that the applicant clarify that the same correctiveaction program will be applied to all AMPs and that this program meets the requirementsof 10 CFR Part 50, Appendix B.VI. Quality Assurance Controls Applied to LRA DevelopmentThe NRC audit team reviewed the quality controls used by the applicant to ensure thatscoping and screening methodologies utilized in the LRA were adequately implemented. Although the applicant did not develop the LRA under a 10 CFR 50, Appendix B, QAprogram, the applicant utilized the following quality assurance (QA) processes duringthe LRA development:*Implementation of the scoping and screening methodology was governed by writtenprocedures.*The applicant reviewed previous LRA NRC requests for additional information to ensurethat applicable issues were addressed in the LRA.*The LRA was reviewed by the Off-Site and On-Site Safety Review Committees prior tosubmittal to the NRC.*The applicant performed an industry peer review of the LRA.

• The applicant's QA organization performed an independent review of the LRA. Thepurpose of this review was to ensure that the technical information used to develop the LRA was updated and approved in accordance with the station's QA program, and that industry peer and Off-Site and On-Site Safety Review Committee issues were resolved and associated corrective actions implemented. The audit team concluded that these quality assurance activities, which exceededcurrent regulatory requirements, provided additional assurance that LRA development activities were performed consistently with the LRA descriptions.VII.Training for License Renewal Project PersonnelThe audit team reviewed the applicant's training process to ensure the guidelines andmethodology for the scoping and screening activities would be performed in a consistent and appropriate manner. The NRC audit team reviewed the applicant's training process to ensure the guidelines and methodology for the scoping and screening activities wereperformed in a consistent and appropriate manner. The License Renewal Project Guidelines (LRPGs) provided the guidance andrequirements for the training of the license renewal (LR) project and site personnel. The training consisted of a combination of reading and attending training sessions. The attachment specified the level of training which was required for the various groups participating in the development of the LRA and began with initial training, documentedon a qualification card. The training was required for both the LR project personnel who prepared the application and for the site personnel who reviewed the application. Inaddition, LR refresher training was provided for the LR project and site personnel participating in the review. Refresher training included information on the LR process and information specific to the site. LR project and site personnel were required to review applicable LR regulations, NEI 95-10 and associated procedures. The applicant developed periodic production meetings in which the LR project personnel shared their knowledge and experience of a given subject with each other. The NRC audit team reviewed completed qualification and training records of several ofthe applicant's LR project personnel and also reviewed completed check lists. The audit team found these records adequately documented the required training for the LRproject personnel. Additionally, based on discussions with the applicant's LR project personnel during the audit, the audit team verified that the applicant's LR projectpersonnel were knowledgeable on the LR process requirements and the specific technical issues within their areas of responsibility. On the basis of discussions with the applicant's license renewal project personnelresponsible for the scoping and screening process, and a review of selected design documentation in support of the process, the audit team concluded that the applicant'sLR project personnel understood the requirements of and adequately implemented the scoping and screening methodology established in the applicant's renewal application. The audit team did not identify any concerns regarding the training of the applicant's LRproject or site personnel.VIII. Exit MeetingA public exit meeting was held with the applicant on July 26, 2006, to discuss the resultsof the scoping and screening methodology audit. The audit team identified preliminary areas where additional information would be required to support completion of the staff's LRA review. Requests for additional information related to the applicant's scoping and screening methodology were forwarded to the applicant on July 25, 2006 (ADAMS Accession No.ML062070240).IX.Documents Reviewed 1.AMRC-05, "Aging Management Review of Yard Structures," Revision 1.2.AMRC-06, "Aging Management Review of Bulk Commodities," Revision 1. 3.AMRE-01, "Electrical Screening and Aging Management Reviews," Revision 2.4.AMRM-06, "Aging Management Review of the Reactor Core Isolation Cooling System,"Revision 0. 5.AMRM-26, "Aging Management Review of the Main Condenser and MSIV leakagePathway," Revision 0.6.AMRM-30, "Aging Management Review of Nonsafety-related Systems and ComponentsAffecting Safety-related Systems," Revision 1.7.ENN-MS-S-009-PNPS, "Pilgrim Site Specific Guidance and System Safety FunctionSheets," Revision 0.8.License Renewal Project Document (LRPD)-01, "System and Structure ScopingResults," Revision 0.9.LRPD-02, "Aging Management Program Evaluation Reports," Revision 1 10.License Renewal Project Guideline (LRPG)-01, "License Renewal Project Plan,"Revision 2. 11.LRPG-03, "System and Structure Scoping Methodology," Revision 2.

12.LRPG-04, "Mechanical System Screening and Aging Management Reviews," Rev. 2.

13.LRPG-05, "Electrical System Scoping, Screening and Aging Management Reviews,"Rev. 2.14.LRPG-06, "Structural Screening and Aging Management Reviews," Revision 2.

15.Letter from the NRC to ENTERGY, "REQUEST FOR ADDITIONAL INFORMATIONFOR THE REVIEW OF THE PILGRIM NUCLEAR POWER STATION LICENSE RENEWAL APPLICATION (TAC MC9669)," dated July 25, 2006 (ADAMS Accession No. ML062070240)16.NUREG-1800, "Standard Review Plan for Review of License Renewal Applications forNuclear Power Plants," Revision 1, dated September 2005.17.NEI 95-10, "Industry Guideline for Implementing the Requirements of 10 CFR Part 54 -The License Renewal Rule," Revision 6, dated September 2005.18.PNPS License Renewal Application, dated January 25, 2006

19. PNPS Maintenance Rule SSC Basis Documents 20.TDBD-105, Fire Protection and Appendix R Program, Rev. EA 21.TDBD-103, Environmental Qualification, Rev. E0 22.TDBD-122, Anticipated Transients Without Scram (ATWS) , Rev. E023.TDBD-115, Station Blackout, Rev. E0X.Personnel Contacted During Methodology Audit Fred MogoleskoENTERGY License Renewal Project ManagerDoug EllisENTERGY License Renewal Licensing EngineerDavid LachENTERGY License Renewal Team Ted IveyENTERGY License Renewal Team Alan CoxENTERGY License Renewal Team Brian Ford ENTERGY Licensing Manager Stan BatchENTERGY License Renewal Team Jill BrochuPNPS License Renewal TeamDavid WellsPNPS Licensing Engineer Brian SullivanPNPS P&C Engineering ManagerBill RiggsPNPS Projects M anagerRam SubbaratnamNRC License Renewal Project Manager, NRRDevender Reddy NRC/NRR/DLRLinh TranNRC/NRR/DLR Kent HowardNRC/NRR/DLR Jacob Zimmerman NRC/NRR/DLR, Branch Chief Kim GreenISL, Inc. (NRC Contractor)

Clifford MarksISL, Inc. (NRC Contractor)