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Email: (PA) PNPS Audit Plan
	ML062480291
Person / Time
Site:	Pilgrim
Issue date:	03/30/2006
From:	Wen P; NRC/NRR/ADRO/DLR
To:	Michael Orr, Joseph Zabel; ATL International
References
	%dam200612
	Download: ML062480291 (18)
	v • d • e

James Davis - PNPS Audit Plan -Page 1]

From: Peter Wen To: Internet: mporr@atlint.com; Internet:jzabel@atlintl.com Date: Thu, Mar 30, 2006 4:46 PM

Subject:

PNPS Audit Plan Mark and Joe:

As we discussed yesterday (3/29), attached are the WP files to be used in the audit plan.

Peter CC: James Davis

c:\temp\GW)00001.TMP Pageý 1 *1 c:\temp\GWIOOOQ1 .TMP Page 11 Mail Envelope Properties (442C51B5.806 : 20: 35420)

Subject:

PNPS Audit Plan Creation Date Thu, Mar 30, 2006 4:46 PM From: Peter Wen Created By: PXW@nrc.gov Recipients OWGWPO01.HQGWDO01 JAD CC (James Davis) atlint.com mporr (Internet: mporr@atlint.com) atlintl.com jZabel (Intemet:izabel @atlintl.com)

Post Office Route OWGWPO01.HQGWDO01 atlint.com Internet atlinti.com Internet Files Size Date & Time MESSAGE 578 Thursday, March 30, 2006 4:46 PM PNPS Audit Plan TLAA Section 4.wpd 14955 Thursday, March 23, 2006 10:06 AM PNPS Audit Plan TLAA Section 5.wpd 6308 Wednesday, March 29, 2006 2:14 PM PNPS Audit PLan TLAA Section 6.wpd 131322 Tuesday, March 28, 2006 11:16 AM PNPS Audit Plan Figure 5.wpd 88342 Thursday, March 30, 2006 4:41 PM PNPS Audit Plan TLAA Assignments.wpd 9872 Thursday, March 30, 2006 4:39 PM Options Expiration Date: None Priority: Standard ReplyRequested: No Return Notification: None Concealed

Subject:

No Security: Standard

James Davis - PNPS Audit Plan TLAA Section 4.wpd . .Pag..1.. Page I11 4.2 Time-Limited Aging Analyses The PNPS LRA closely follows the standard LRA format presented in Revision 6 of NEI 95-10, "Industry Guidelines for Implementing the Requirements of 10 CFR Part 54 - The License Renewal Rule." Section 4 of the PNPS LRA addresses time-limited aging analyses. In Section 4.1.1, the PNPS LRA states that the calculations and evaluations that could potentially meet the six criteria of 10 CFR 54.3 were identified by searching CLB documents including the following:

Technical Specifications

UFSAR

docketed licensing correspondence

fire protection program documents

NRC safety evaluation reports

BWRVIP documents In Section 4.1, the PNPS LRA states that as required by 10 CFR 54.21 (c)(1), an evaluation of PNPS-specific time-limited aging analyses must be performed to demonstrate that:

(i) The analyses remain valid for the period of extended operation; (ii) The analyses have been projected to the end of the period of extended operation; or (iii) The effects of aging on the intended functions(s) will be adequately managed for the period of extended operation.

In the PNPS LRA, the applicant summarized the results of the above evaluations in Table 4.1-1.

These evaluations are discussed in subsequent sections of PNPS LRA Section 4.

Following the section identifying the TLAAs, the PNPS LRA next includes a section identifying any exemptions. Section 10 CFR 54.21(c) also requires that the application for a renewed license includes a list of plant-specific exemptions granted pursuant to 10 CFR 50.12 and in effect that are based on time-limited aging analyses as defined in 10 CFR 54.3. The PNPS performed this by reviewing PNPS docketed correspondence which identified PNPS exemptions. The results of this review determined that no PNPS exemptions depend on TLAAs.

The PNPS LRA next includes a separate section for each of the identified TLAAs within the outline of the corresponding NUREG-1 800 TLAA category. The TLAA categories are outlined in the next table.

TLAA Description Resolution Option Section Reactor Vessel Neutron Embrittlement Analyses 4.2 Pressure-temperature limits Analyses remain valid 4.2.2 10 CFR 54.21 (c)(1 )(i)

Charpy upper-shelf energy Analyses projected 4.2.3 10 CFR 54.21 (c)(1)(ii)

Adjusted reference temperature Analyses projected 4.2.4 1 10 CFR 54.21 (c)(1)(ii)

James Davis-- PNPS Audit Plan TLAA Section 4.wpd .Page_ I:

Reactor vessel circumferential welds Analysis projected 4.2.5 inspection relief 10 CFR 54.21 (c)(1)(ii)

Reactor vessel axial welds failure Analysis projected 4.2.6 probability 10 CFR 54.21 (c)(1)(ii)

Metal Fatigue Analyses 4.3 Class 1 fatigue Analyses remain valid 4.3.1 10 CFR 54.21 (c)(1)(i)

OR Aging effect managed 10 CFR 54.21 (c)(1)(iii)

Non-Class 1 fatigue Analyses remain valid 4.3.2 10 CFR 54.21 (c)(1)(i)

Effects of reactor water environment Analyses remain valid 4.3.3 on fatigue life 10 CFR 54.21 (c)(1)(i)

OR Analyses projected 10 CFR 54.21 (c)(1)(ii)

OR Aging effect managed 10 CFR 54.21 (c)(1)(iii)

Environmental Qualification Analyses Aging effect managed 4.4 for Electrical Equipment 10 CFR 54.21 (c)(1)(iii)

Containment Liner Plate, Metal Containment, and Penetrations 4.6 Fatigue Analyses Fatigue of primary containment I Analysis projected 4.6.1 1 10 CFR 54.21 (c)(1)(ii)

Other TLAA 4.7 Reflood thermal shock of the reactor Analysis remains valid 4.7.1 vessel internals 10 CFR 54.21 (c) (1) (i)

TLAA in BWRVIPs 4.7.2 BWRVIP-05, RPV circumferential Addressed in Sections 4.2.5 4.7.2.1 welds analysis BWRVIP-48, vessel ID attachment Analysis remains valid 4.7.2.2 welds fatigue analysis 10 CFR 54.21 (c)(1)(ii)

BWRVIP-49, instrument penetrations Analysis projected 4.7.2.3 fatigue analysis 10 CFR 54.21 (c)(1)(ii)

BWRVIP-74, reactor vessel 4.7.2.4 P/T curves analysis Addressed in Section 4.2.2 Fatigue analysis Addressed in Section 4.3.1 CvUSE analysis Addressed in Section 4.2.3 Circ/Axial welds analysis Addressed in Sections 4.2.5 and 4.2.6 BWRVIP-76, core shroud fatigue Analysis remains valid 4.7.2.5 analysis 10 CFR 54.21 (c)(1)(ii)

James Davis - PNPS Audit Plan TLAA Section 5.wpd Page 11, James Davis PNPS Audit Plan TLAA Section 5.wpd

- Page 1]

5.3 Time-Limited Aging Analyses The TLAAs in the PNPS LRA fall into the broad category of those that are consistent with the NUREG-1800 TLAA categories. There are no plant-specific exemptions identified in the VYNPS LRA that depend on time-limited aging analyses.

For its TLAA reviews, the project team will determine if the applicant had provided adequate information to meet the requirements of 10 CFR 54.21 (c)(1) and 10 CFR 54.21 (c)(2).

Further, the project team will conduct both regulatory evaluations and technical evaluations to determine, as defined in 10 CFR 54.3, that each TLAA meets the following six criteria:

(1) involve systems, structures, and components that are within the scope of license renewal, as delineated in 10 CFR 54.4(a).

(2) consider the effects of aging.

(3) involve time-limited assumptions defined by the current operating term (40 years).

(4) are determined to be relevant by the applicant in making a safety determination.

(5) involve conclusions, or provide the basis for conclusions, related to the capability of the system, structure, and component to perform its intended functions, as delineated in 10 CFR 54.4(b).

(6) are contained or incorporated by reference in the CLB.

In addition, the project team will also review the TLAAs to determine ifthere are emerging issues that should be further evaluated by technical specialists in the NRC Divisions of Component Integrity (DCI) or the Division of Engineering (DE). This is not expected to be an issue for TLAAs for which the applicant claims consistency with 10 CFR 54.21 (c)(i) "the analyses remain valid for the period of extended operation." or 10 CFR 54.21 (c)(iii) "the effects of aging on the intended function(s) will be adequately managed for the period of extended operation."

For TLAAs for which the applicant claims consistency with 10 CFR 54.21 (c)(ii) - "the analyses have been projected to the end of the period of extended operation," the audit team leader will be consulted to determine which TLAAs the audit team will be capable of reviewing.

Consideration should be given to project team expertise, past precedent, and complexity of the provided analysis. Candidates for further review by technical specialists could be such as the following:

Reactor Vessel Neutron Embrittlement Analysis Intergranular separation in the Heat-Affected Zone (HAZ) of Reactor Vessel Containment Liner Plate, Metal Containment, and Penetrations Fatigue Analyses Low-Alloy Steel under Austenitic SS Cladding

James Davis - PNPS Audit PLan TLAA Section_6ý.wpd, James Davis~ - PNPS Audit P~an TLAA Section .wp-.. Page 1i]

6.4 Time-Limited Aging Analyses (TLAA) Audits and Reviews Audit and review of TLAAs are discussed below. The project team will also review the TLAAs to determine if there are emerging issues that should be further evaluated by technical specialists in the NRC Divisions of Component Integrity (DCI) or the Division of Engineering (DE). In general, the project team will review TLAAs that are for which the applicant claims consistency with 10 CFR 54.21 (c)(i) "the analyses remain valid for the period of extended operation." or 10 CFR 54.21 (c)(iii) "the effects of aging on the intended function(s) will be adequately managed for the period of extended operation." For TLAAs for which the applicant claims consistency with 10 CFR 54.21 (c)(ii) - "the analyses have been projected to the end of the period of extended operation," the audit team leader will be consulted to determine which TLAAs the audit team will be capable of reviewing. Consideration should be given to team expertise, past precedent, and complexity of the provided analysis.

6.4.1 Identify Generic TLAA Issues Figure 5, "Evaluation of TLAAs and Exemptions," taken from NEI 95-10, Revision 6, shows the process of evaluating and reviewing TLAAs and also identifying the exemptions in effect. This process flowchart shows the activities and decisions used to audit/review each TLAA that the applicant identifies.

Pre-Review Preparation A. For the PNPS TLAAs that the applicant has identified as generic TLAA issues, identify the corresponding TLAAs in NUREG-1800, if appropriate.

B. Review the corresponding TLAAs in NUREG-1 800 and identify those that will be audited/reviewed in conjunction with each of the PNPS TLAAs.

C. Review the list of the PNPS plant-specific exemptions granted pursuant to

§50.12 and in effect that are based on TLAAs as defined in §54.3. The application shall include an evaluation that justifies the continuation of these exemptions for the period of extended operation.

D. Identify and locate the documents needed to perform the review. These may include, but are not limited to, the following:

0 Excel database on TLAAs summarizing how earlier LRAs and SERs presented and reviewed 0 TLAAs 0 GALL Report 0 SRP-LR

ISG-LR

RAIs, audit and review reports, and SERs for similar plants

LRA

References listed by applicant for each TLAA

NEI 95-10, Section 5.1 and Table 6.2-2

basis documents

- implementation documents

operating experience reports (plant-specific and industry)

James Davis - PNPS Audit PLan TLAA Section6.wpd. Page2l I

lessons learned developed by RLRC

applicant's UFSAR E. In addition, the project team will also review the TLAAs to determine if there are emerging issues that should be further evaluated by technical specialists in the NRC Divisions of Component Integrity (DCI) or the Division of Engineering (DE).

This is not expected to be an issue for TLAAs for which the applicant claims consistency with 10 CFR 54.21 (c)(i) "the analyses remain valid for the period of extended operation." or 10 CFR 54.21 (c)(iii) "the effects of aging on the intended function(s) will be adequately managed for the period of extended operation."

For TLAAs for which the applicant claims consistency with 10 CFR 54.21 (c)(ii) -

"the analyses have been projected to the end of the period of extended operation," the audit team leader will be consulted to determine which TLAAs the audit team will be capable of reviewing. Consideration should be given to team expertise, past precedent, and complexity of the provided analysis. Candidates for further review by technical specialists could be such as the following:

0 Reactor Vessel Neutron Embrittlement Analysis (PNPS LRA Section 4.2)

Containment Liner Plate, Metal Containment, and Penetrations Fatigue Analyses (PNPS LRA Section 4.6)

Reflood Thermal Shock Analyses of the Reactor Vessel Internals (PNPS LRA Section 4.7.1)

Audit/Review A. Confirm that each PNPS TLAA listed in this section is appropriate. Refer to any analyses and evaluations created during the acceptance review process.

B. If a TLAA is listed in the SRP-LR or NEI 95-10 and not in its LRA, the PNPS should state in this section that it does not apply.

C. Review any industry and plant-specific operating experience associated with the TLAA. This is an area of review emphasis. The project team members should consider the following industry guidance (from NEI 95-10, Table 6.2-2) as follows:

The application shall include a list of time-limited aging analyses, as defined by §54.3. The application should include the identification of the affected systems, structures, and components, an explanation of the time dependent aspects of the calculation or analysis, and a discussion of the TLAA's impact on the associated aging effect. The identification of the results of the time-limited aging analysis review, which may be provided in tabular form, may reference the section in the Integrated Plant Assessment-Aging Management Review chapter where more details of the actual review and disposition (as required by §54.21 (c)(1)(i)-(iii)) are located.

The application shall include a demonstration that (1) the analyses remain valid for the period of extended operation, (2) the analyses have been (or have been identified and will be [§54.29(a)]) projected to the end of the period of extended operation or (3) the effects of aging on the

James Davis - PNPS Audit PLan TLAA Section 6.wpd p~age 3.11 Pag....

intended function(s) will be adequately managed for the period of extended operation.

The application shall include a list of plant-specific exemptions granted pursuant to §50.12 and in effect that are based on TLAAs as defined in

§54.3. The application shall include an evaluation that justifies the continuation of these exemptions for the period of extended operation.

Summary descriptions of the evaluations of TLAAs for the period of extended operation shall be included in the UFSAR supplement (Appendix A).

D. If it is necessary to ask the applicant a question to clarify the basis for their analyses, follow the logic process shown in Figure 5 of this audit and review plan.

E. If it is necessary for the applicant to submit additional information to support the basis for the conclusions in their TLAA, the applicant may agree to voluntarily submit the required information as a supplement (docketed letter submitted under oath and affirmation) to the PNPS LRA. If not, the NRC may issue an RAI to obtain the information.

TLAA Audit Worksheets Document the audits/reviews using the worksheet provided in Appendix I, "TLAA Audit/Review Worksheet."

6.4.2 Metal Fatigue Analyses Figure 5, "Evaluation of TLAAs and Exemptions," taken from NEI 95-10, Revision 6, shows the process of evaluating and reviewing TLAAs and also identifying the exemptions in effect. This process flowchart shows the activities and decisions used to audit/review each TLAA that the applicant identifies.

Pre-Review Preparation A. The project team will determine ifthe TLAAs identified in the PNPS LRA to be within the NUREG-1 800 TLAA category of "metal fatigue" have provided adequate information to meet the requirements of 10 CFR 54.21 (c)(1) and 10 CFR 54.21 (c)(2).

B. Identify and locate the documents needed to perform the review. These may include, but are not limited to, the following:

Excel database on TLAAs summarizing how earlier LRAs and SERs presented and reviewed TLAAs

GALL Report, especially Section X.M1

SRP-LR

ISG-LR

RAIs, audit and review reports, and SERs for similar plants

LRA

References listed by applicant for each TLAA

NEI 95-10, Section 5.1 and Table 6.2-2

James Davis - PNPS Audit PLan TLAA Section 6.wr)d -Pae4I Pa~ie41 James Davis- PNPS Audit PLan TLAA Section 6.wDd

basis documents

implementation documents

operating experience reports (plant-specific and industry)

lessons learned developed by RLRC

applicant's UFSAR C. In addition, the project team will also review the PNPS TLAAs within the NUREG-1800 TLAA category of "metal fatigue" to determine if there are emerging issues that should be further evaluated by technical specialists in the NRC Divisions of Component Integrity (DCI) or the Division of Engineering (DE). This is not expected to be an issue for TLAAs for which the applicant claims consistency with 10 CFR 54.21 (c)(i) "the analyses remain valid for the period of extended operation." or 10 CFR 54.21 (c)(iii) "the effects of aging on the intended function(s) will be adequately managed for the period of extended operation."

For TLAAs for which the applicant claims consistency with 10 CFR 54.21 (c)(ii) -

"the analyses have been projected to the end of the period of extended operation," the audit team leader will be consulted to determine which TLAAs the audit team will be capable of reviewing. Consideration should be given to team expertise, past precedent, and complexity of the provided analysis.

Audit/Review A. Confirm that each PNPS TLAA listed in this section is appropriate. Refer to any analyses and evaluations created during the acceptance review process.

B. If a TLAA is listed in the SRP-LR or NEI 95-10 and not in its LRA, the PNPS should state in this section that it does not apply.

C. The project team will conduct both regulatory evaluations and technical evaluations to determine, as defined in 10 CFR 54.3, that each TLAA meets the following six criteria:

(1) involve systems, structures, and components that are within the scope of license renewal, as delineated in 10 CFR 54.4(a)

(2) consider the effects of aging (3) involve time-limited assumptions defined by the current operating term (40 years)

(4) are determined to be relevant by the applicant in making a safety determination (5) involve conclusions, or provide the basis for conclusions, related to the capability of the system, structure, and component to perform its intended functions, as delineated in 10 CFR 54.4(b)

(6) are contained or incorporated by reference in the CLB D. The project team will ascertain that the PNPS satisfactorily demonstrates that (1) the analyses remain valid for the period of extended operation, (2) the analyses have been (or have been identified and will be [§54.29(a)]) projected to the end of the period of extended operation or (3) the effects of aging on the intended function(s) will be adequately managed for the period of extended operation.

E. Review any industry and plant-specific operating experience associated with the

James Davis - PN PS Audit PLan TLAA Section_ 6.wpd Pageý5.1 James Davis PNPS Audit PLan TLAA Section 6.wpd

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Page5~

TLAA. This is an area of review emphasis. The project team members should consider the following industry guidance on metal fatigue (from NEI 95-10, Table 6.2-2) as follows:

Disposition chosen for each of the identified TLAAs. Also, provide a reference to the summary description of TLAA evaluations in the FSAR supplement (Appendix A). Use hypertext to link to the appropriate location in the appendix for electronic submittals [§54.21 (c)(1) and

§54.21(d)1.

F. If it is necessary to ask the applicant a question to clarify the basis for their analyses, follow the logic process shown in Figure 5 of this audit and review plan.

G. If it is necessary for the applicant to submit additional information to support the basis for the conclusions in their TLAA, the applicant may agree to voluntarily submit the required information as a supplement (docketed letter submitted under oath and affirmation) to the PNPS LRA. If not, the NRC may issue an RAI to obtain the information.

TLAA Audit Worksheets Document the audits/reviews using the worksheet provided in Appendix I, "TLAA Audit/Review Worksheet."

6.4.3 Environmental Qualification Analyses for Electrical Components Figure 5, "Evaluation of TLAAs and Exemptions," taken from NEI 95-10, Revision 6, shows the process of evaluating and reviewing TLAAs and also identifying the exemptions in effect. This process flowchart shows the activities and decisions used to audit/review each TLAA that the applicant identifies.

Pre-Review Preparation A. The project team will determine ifthe TLAAs identified in the PNPS LRA to be within the NUREG-1800 TLAA category of "environmental qualification of electric equipment" have provided adequate information to meet the requirements of 10 CFR 54.21 (c)(1) and 10 CFR 54.21 (c)(2).

B. Identify and locate the documents needed to perform the review. These may include, but are not limited to, the following:

Excel database on TLAAs summarizing how earlier LRAs and SERs presented and reviewed TLAAs

GALL Report, especially Section X.E1 0 SRP-LR

ISG-LR 0 RAIs, audit and review reports, and SERs for similar. plants 0 LRA

References listed by applicant for each TLAA

NEI 95-10, Section 5.1 and Table 6.2-2

basis documents

James Davis - PNPS Audit PLan TLAA Sýeqtiqn 6.wpd James Davis PNPS Audit P~an TLAA ection 6.wpd.. Page 6

implementation documents

operating experience reports (plant-specific and industry)

lessons learned developed by RLRC

applicant's UFSAR C. In addition, the project team will also review the PNPS TLAAs within the NUREG-1800 TLAA category of "environmental qualification of electric equipment" to determine if there are emerging issues that should be further evaluated by technical specialists in the NRC Divisions of Component Integrity (DCI) or the Division of Engineering (DE). This is not expected to be an issue for TLAAs for which the applicant claims consistency with 10 CFR 54.21 (c)(i) "the analyses remain valid for the period of extended operation." or 10 CFR 54.21 (c)(iii) "the effects of aging on the intended function(s) will be adequately managed for the period of extended operation." For TLAAs for which the applicant claims consistency with 10 CFR 54.21 (c)(ii) - "the analyses have been projected to the end of the period of extended operation," the audit team leader will be consulted to determine which TLAAs the audit team will be capable of reviewing.

Consideration should be given to team expertise, past precedent, and complexity of the provided analysis.