ML061220630

License Renewal Audit and Review Plan for Plant Aging Management Review and Programs for the Pilgrim Nuclear Power Plant, Docket Number 50-293

ML061220630
Person / Time
Site:	Pilgrim
Issue date:	04/26/2006
From:	Advanced Technologies & Labs International
To:	NRC/NRR/ADRO/DLR
Davis J
References
Download: ML061220630 (67)

Text

Audit and Review Plan for Plant Aging Management Reviews and Programs Pilgrim Nuclear Power Station Docket No.: 50-293 April 26, 2006 Prepared by Advanced Technologies and Laboratories International, Inc.

20010 Century Blvd., Suite 500 Germantown, MD 20874 Contract No. DR-03-06-030 Prepared for Division of License Renewal Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001

TABLE OF CONTENTS

1. INTRODUCTION......................................................... 1

2. BACKGROUND

......................................................... 2

3. OBJECTIVES........................................................... 4

4.

SUMMARY

OF INFORMATION PROVIDED IN THE LICENSE RENEWAL APPLICATION 5 4.1 Aging Management Review Results.................................... 5 4.1.1 PNPS AMR Comparison with GALL............................... 6 4.1.2 Plant-Specific Programs....................................... 10 4.2 Time-Limited Aging Analyses

........................................ 10 5.

OVERVIEW OF AUDIT, REVIEW, AND DOCUMENTATION PROCEDURE....... 12 5.1 Aging Management Programs........................................ 12 5.2 Aging Management Reviews......................................... 13 5.3 Time-Limited Aging Analyses

........................................ 13 5.4 NRC-Approved Precedents.......................................... 14 5.5 UFSAR Supplement Review......................................... 15 5.6 Documents Reviewed by the Project Team.............................. 15 5.7 Public Exit Meeting................................................ 15 5.8 Documentation Prepared by the Project Team........................... 15 5.8.1 Audit and Review Plan........................................ 15 5.8.2 Worksheets................................................ 15 5.8.3 Questions.................................................. 16 5.8.4 Work Packages............................................. 16 5.8.5 Requests for Additional Information.............................. 16 5.8.6 Audit and Review Report...................................... 16 5.8.7 Safety Evaluation Report input.................................. 16

6. PLANNING, AUDIT, REVIEW, AND DOCUMENTATION PROCEDURE............. 17 6.1 Planning Activities................................................. 17 6.1.1 Schedule for Key Milestones and Activities........................ 17 6.1.2 Work Assignments........................................... 17 6.1.3 Training and Preparation...................................... 18 6.2 Aging Management Program (AMP) Audits and Reviews................... 18 6.2.1 Types of AMPs.............................................. 18 6.2.2 Scope of AMP elements to be audited and reviewed................. 18 6.2.3 Plant AMPs that Are Consistent with the GALL Report

............... 19 6.2.4 Plant-Specific AMPs.......................................... 21 6.3 Aging Management Review (AMR) Audits and Reviews.................... 22 6.3.1 Plant AMRs that Are Consistent with the GALL Report............... 22 6.3.2 AMRs Based on NRC-Approved Precedents....................... 25 6.4 Time-Limited Aging Analyses (TLAA) Audits and Reviews.................. 26 6.4.1 Identify Generic TLAA Issues

................................... 27 6.4.2 Metal Fatigue Analyses........................................ 29 6.4.3 Environmental Qualification Analyses for Electrical Components......... 31 6.4.4 Other Plant-Specific TLAAs..................................... 33 6.5 Audit and Safety Review Documentation................................ 35

6.5.1 Audit and Review Report...................................... 36 6.5.2 Safety Evaluation Report Input.................................. 36 6.6 Documents Reviewed and Document Retention.......................... 41 Appendix A - Project Team Membership........................................ A-1 Appendix B - RLRC Schedule for Pilgrim LRA Safety Review........................ B-1 Appendix C - Aging Management Program Assignments.......................... C-1 Appendix D - Aging Management Review Assignments............................ D-1 Appendix E - Time-Limited Aging Analysis Review Assignments..................... E-1 Appendix F - Consistent with Gall Report AMP Audit/Review Worksheet............... F-1 Appendix G - Plant-specific AMP Audit/Review Worksheet.......................... G-2 Appendix H - AMR Comparison Worksheets

.................................... H-1 Appendix I - Acronyms, Abbreviations, and Initialisms.............................

I-1 TABLES Table 1. Aging Management Program Element Descriptions......................... 42 Table 2. Notes for License Renewal Application Tables 3.X.2-Y...................... 43 FIGURES Figure 1. Audit of AMPs that are Consistent with the GALL Report.................... 44 Figure 2. Audit of Plant-Specific AMPs......................................... 45 Figure 3. Review of AMRs that are Consistent with the GALL Report.................. 46 Figure 4. Review of AMRs Using NRC-Approved Precedents........................ 47 Figure 5. Review of TLAAs and Exemptions (from NEI 95-10, Revision 6).............. 48

1 Audit and Review Plan for Plant Aging Management Reviews and Programs 1.

INTRODUCTION By letter dated January 25, 2006 (ADAMS Accession Number ML060300028), Entergy Nuclear Operations, Inc., submitted to the U.S. Nuclear Regulatory Commission (NRC) its application for renewal of Operating License DPR-35 for Pilgrim Nuclear Power Station (PNPS.) The applicant requested renewal of the operating license for an additional 20 years beyond the 40-year current license term.

In support of the staff's safety review of the license renewal application (LRA) for PNPS, the Division of License Renewal (DLR), Branch C (RLRC), will lead a project team that will audit and review selected aging management reviews (AMRs) and associated aging management programs (AMPs), and time-limited aging analyses (TLAAs) developed by the applicant to support its LRA for PNPS. The project team will include both NRC staff and engineers provided by Advanced Technologies and Laboratories International, Inc. (ATL), RLRC's technical assistance contractor. Appendix A, "Project Team Membership," lists the project team members. This document is the RLRC plan for auditing and reviewing plant aging management reviews and aging management programs for PNPS.

The project team will audit and review its assigned AMPs, AMRs, and TLAAs against the requirements of Title 10 of the Code of Federal Regulations, Part 54 (10 CFR Part 54),

"Requirements for Renewal of Operating Licenses for Nuclear Power Plants;" the guidance provided in NUREG-1800, Revision 1, "Standard Review Plan for Review of License Renewal Application for Nuclear Power Plants" (SRP-LR), dated September 2005; the guidance provided in NUREG-1801, Revision 1, "Generic Aging Lessons Learned (GALL) Report," dated September 2005; and this plan. For the scope of work defined in this audit plan, the project team will verify that the applicant's aging management activities and programs will adequately manage the effects of aging on structures and components, so that their intended functions will be maintained consistent with the PNPS current licensing basis (CLB) for the period of extended operation.

The team will perform its work at NRC Headquarters, Rockville, Maryland; at ATL's offices in Germantown, Maryland; and at the PNPS site near Plymouth, Massachusetts. The project team will perform its work in accordance with the schedule shown in Appendix B, "Schedule."

The team will conduct a public exit meeting at or near the applicant's offices in Plymouth, Massachusetts, after it completes its onsite work.

This plan includes the following information:

Introduction and background. Summary of the license renewal requirements, as stated in the Code of Federal Regulations, and a summary of the documents that the project team will use to conduct the audit and review process described in this plan.

Objectives. The objectives of the audits and reviews addressed by this plan.

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Summary of Information Provided in License Renewal Application. Description of the information contained in the license renewal application for PNPS that is applicable to this plan.

Overview of the Audit, Review, and Documentation Procedure. Summary of the process the project team will follow to audit and review the LRA information that is within its scope of review.

Planning, Audit, Review, and Documentation Procedure. The procedure that the project team will use to plan and schedule its work, to audit and review the LRA information that is within its scope of review, and to document the results of its work.

Appendices. Supporting information. The project team membership is shown in Appendix A and the schedule is shown in Appendix B. The team's work assignments are shown in Appendix C, "Aging Management Program Assignments," Appendix D, "Aging Management Review Assignments," Appendix E Time-Limited Aging Analysis Review Assignments. Appendices F, G, and H are the worksheets that the individual team members use to informally document the results of their review and audit work.

The application of these worksheets is discussed in Section 6 or this plan. Appendix I is a list of the acronyms, abbreviations, and initialisms used in this plan.

2.

BACKGROUND In 10 CFR 54.4, the scope of license renewal is defined as those structures, systems, and components (SSCs) (1) that are safety-related, (2) whose failure could affect safety-related functions, and (3) that are relied on to demonstrate compliance with the NRC's regulations for fire protection, environmental qualification, pressurized thermal shock, anticipated transients without scram, and station blackout.

An applicant for a renewed license must review all SSCs within the scope of license renewal to identify those structures and components (SCs) subject to an AMR. SCs subject to an AMR are those that perform an intended function without moving parts or without a change in configuration or properties (passive), and that are not subject to replacement based on qualified life or specified time period (long-lived). Pursuant to 10 CFR 54.21(a)(3), an applicant for a renewed license must demonstrate that the effects of aging will be managed in such a way that the intended function or functions of those SCs will be maintained, consistent with the CLB, for the period of extended operation. 10 CFR 54.21(d) requires that the applicant submit a supplement to the final safety analysis report (FSAR) that contains a summary description of the programs and activities that it credited to manage the effects of aging during the extended period of operation.

The SRP-LR provides staff guidance for reviewing applications for license renewal. The GALL Report is a technical basis document. It summarizes staff-approved AMPs for the aging management of a large number of SCs that are subject to an AMR. It also summarizes the aging management evaluations, programs, and activities acceptable to the NRC staff for

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managing aging of most of the SCs used in commercial nuclear power plants, and serves as a reference for both the applicant and staff reviewers to quickly identify those AMPs and activities that the staff has determined will provide adequate aging management during the extended period of operation. If an applicant commits to implementing these staff-approved AMPs, the time, effort, and resources needed to review an applicant's LRA will be greatly reduced, thereby improving the efficiency and effectiveness of the license renewal review process. The GALL Report identifies (1) systems, structures, and components, (2) component materials, (3) the environments to which the components are exposed, (4) the aging effects associated with the materials & environments, (5) the AMPs that are credited to manage the aging effects, and (6) recommendations for further applicant evaluations of aging effects and their management for certain component types.

The GALL Report is treated in the same manner as an approved topical report that is generically applicable. An applicant may reference the GALL Report in its LRA to demonstrate that its programs correspond to those that the staff reviewed and approved in the GALL Report.

If the material presented in the LRA is consistent with the GALL Report and is applicable to the applicant's facility, the staff will accept the applicant's reference to the GALL Report. In making this determination, the staff considers whether the applicant has identified specific programs described and evaluated in the GALL Report but does not conduct a re-review of the substance of the matters described in the GALL Report. Rather, the staff confirms that the applicant verified that the approvals set forth in the GALL Report apply to its programs.

If an applicant takes credit for a GALL AMP, it is incumbent on the applicant to ensure that the plant AMP contains all the program elements of the referenced GALL AMP. In addition, the conditions at the plant must be bounded by the conditions for which the GALL AMP was evaluated. The applicant must certify in its LRA that it completed the verifications and that they are documented onsite in an auditable form.

The SRP-LR also provides staff guidance for reviewing TLAAs. Pursuant to 10 CFR 54.21(c)(1) a license renewal application is required to provide a list of TLAAs, as defined in 10 CFR 54.3. In addition, the applicant must provide a list of plant-specific exemptions granted under 10 CFR 50.12 that are based on TLAAs. The number and type of TLAAs vary depending on the plant-specific CLB.

All six criteria set forth in 10 CFR 54.3 must be satisfied to conclude that a calculation or analysis is a TLAA. Pursuant to 10 CFR 54.3, TLAAs are those licensee calculations and analyses that:

1. Involve systems, structures, and components 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, for example, 40 years.

4. Were determined to be relevant by the licenses in making a safety determination.

Pilgrim Nuclear Power Station AMP and AMR Audit and Review Plan 4

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

6. Are contained or incorporated by reference in the CLB.

Finally, the applicant must demonstrate that the TLAAs remain valid for the period of extended operation; the TLAAs have been projected to the end of the period of extended operation; or the aging effects of aging on the intended function(s) will be adequately managed for the period of extended operation. The staff performs a technical review as well as reviews the area relating to the identification of TLAAs. The staff also confirms that the applicant did not omit any TLAAs, as defined in 10 CFR 54.3.

3.

OBJECTIVES The overall objective of the audit and review described in this plan is to verify compliance with 10 CFR 54.21(a)(3). Therefore, the audit and review process helps ensure that for each structure and component within the scope of the project team's review, 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.

The audit and review procedure for PNPS is described in Sections 5 and 6 of this plan. It is intended to accomplish the following objectives:

For PNPS AMPs that the applicant claims are consistent with GALL AMPs, verifying that the plant AMPs contain the program elements of the referenced GALL AMP and that the conditions at the plant are bounded by the conditions for which the GALL AMPs were evaluated.

For PNPS AMPs that the applicant claims are consistent with GALL AMPs with exceptions, verifying that the plant AMPs contain the program elements of the referenced GALL AMPs and that the conditions at the plant are bounded by the conditions for which the GALL AMPs were evaluated. In addition, verifying that the applicant has documented an acceptable technical basis for each exception.

For PNPS AMPs that the applicant claims will be consistent with GALL AMPs after specified enhancements are implemented, verifying that the plant AMPs, with the enhancements, will be consistent with the referenced GALL AMPs, or are acceptable on the basis of a technical review. In addition, verifying that the applicant identified the enhancements as commitments in the Updated Final Safety Analysis Report (UFSAR) or other docketed correspondence.

For plant-specific PNPS AMPs that the applicant claims are consistent with AMPs that the staff has previously approved for another plant, verifying the AMPs are acceptable on the basis of a technical review.

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For AMR line items that the applicant claims are consistent with the GALL Report, determine that these AMR line items are consistent with the recommendation of the GALL Report.

For AMR line items (Table 1s) that the applicant claims are not applicable with the GALL Report, determine that these AMR line items are acceptable on the basis of a technical review.

For AMR line items that the applicant claims consistent with AMR line items that the staff has previously approved for another plant, determine that these AMR line items are acceptable on the basis of a technical review.

For AMR line items for which the GALL Report recommends further evaluation, determine that the applicant has addressed the further evaluation, and evaluating the AMRs in accordance with the SRP-LR.

For TLAAs, determine that the applicant has properly identified the TLAAs. TLAAs are certain plant-specific safety analyses that are based on explicitly assumed 40-year plant life (for example, aspects of the reactor vessel design). Pursuant to 10 CFR 54.219(c)(1), a license renewal applicant is required to provide a list of TLAAs, as defined in 10 CFR 54.3. The area relating to the identification of TLAAs is reviewed.

TLAAs may have developed since issuance of a plants operating license. As indicated in 10 CFR 54.30, the adequacy of the plants CLB, which includes TLAAs, is not an area within the scope of the license renewal review. Any question regarding the inadequacy of the CLB must be addressed under the backfit rule (10 CFR 50.109) and is separate from the license renewal process.

Determine that the applicant has demonstrated that (1) the TLAAs remain valid for the period of extended operation; (2) the TLAAs have been projected to the end of the period of extended operation; or (3) the aging effects of aging on the intended function(s) will be adequately managed for the period of extended operation.

4.

SUMMARY

OF INFORMATION PROVIDED IN THE LICENSE RENEWAL APPLICATION 4.1 Aging Management Review Results The PNPS LRA closely follows the standard LRA format presented in NEI 95-10, "Industry Guideline for Implementing the Requirements of 10 CFR Part 54 - The License Renewal Rule,"

Revision 6, June 2005. Section 3 of the LRA provides the results of the aging management review for structures and components that the applicant identified as being subject to aging management review.

LRA Table 3.0-1, Table 3.0-2, and Table 3.0-3 provide descriptions of the mechanical, structural, and electrical service environments, respectively, used in the AMRs to determine the

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aging effects requiring management. Results of the AMRs are presented in two different types of tables. The applicant refers to the two types of tables as Table 1 and Table 2.

The first table type is a series of six tables labeled Table 3.X.1, where "X" is the system/

component group number (see table below), and "1" indicates it is a Table 1 type. For example, in the reactor coolant system subsection of the LRA Section 3, this is Table 3.1.1, and in the engineered safety features subsection of LRA Section 3, this is Table 3.2.1. For ease of discussion, these table types will hereafter be referred to as "Table 1." These tables are derived from the corresponding tables in NUREG-1801, Volume 1, and present summary information from the AMRs.

Definition 1

Reactor Vessel, Internals, and Reactor Coolant System 2

Engineered Safety Features Systems 3

Auxiliary Systems 4

Steam and Power Conversion Systems 5

Structures and Component Supports 6

Electrical and Instrumentation and Controls The second table type is a series of tables labeled Table 3.X.2-Y, where "X" is the system/

component group number, "2" indicates it is a Table 2 type, and "Y" indicates the subgroup number within group "X". For example, within the reactor coolant system subsection, the AMR results for the reactor vessel are presented in Table 3.1.2-1, and the results for the reactor vessel internals are in Table 3.1.2-2. In the engineered safety features subsection, the residual heat removal system results are presented in Table 3.2.2-1, and the core spray system is in Table 3.2.2-2. For ease of discussion, these table types will hereafter be referred to as "Table 2." These tables present the results of the AMRs.

4.1.1 PNPS AMR Comparison with GALL The applicant compared the PNPS AMR results with information set forth in the tables of the GALL Report and provided the results of its comparisons in two table types that correlate with the two table types described above.

To take full advantage of the GALL Report, PNPS AMR results have been compared w/

information set forth in the tables of NUREG-1801. Results of that comparison are provided in the following two table types, Table 1 and Table 2.

4.1.1.1 Purpose of Table 1 The purpose of Table 1 is to provide a summary comparison of how the PNPS AMR results align with the corresponding table of NUREG-1801, Volume 1. These tables are essentially the same as Tables 1 through 6 provided in NUREG-1801, Volume 1, with the following exceptions:

Pilgrim Nuclear Power Station AMP and AMR Audit and Review Plan 7

The ID column is labeled "Item Number" and the spacing has been expanded to include the table number.

The "Type" column has been deleted. Items applicable to PWRs only are noted as such.

The "Related Item" column has been replaced by a "Discussion" column.

The "Item Number" column provides a means to cross-reference to Table 1 from the Table 2s.

Further information is provided in the "Discussion" column. The following are examples of information that might be contained within this column:

Any "Further Evaluation Recommended" information or reference to the location of that information.

The name of a plant-specific program being used.

Exceptions to the NUREG-1801 assumptions.

A discussion of how the line item is consistent with the corresponding line item in NUREG-1801, Volume 1, when it may not be intuitively obvious.

A discussion of how the line item is different than the corresponding line item in NUREG-1801, Volume 1, when it may appear to be consistent.

4.1.1.2 Purpose of Table 2 Table 2 provides results of the aging management reviews for those structures and components identified in Section 2 as being subject to aging management review. There is a Table 2 for each aging management review within a NUREG-1801 system group. For example, the engineered safety features system group contains tables specific to residual heat removal, core spray, automatic depressurization, high pressure coolant injection, reactor core isolation cooling, standby gas treatment, and primary containment penetrations.

Table 2 consists of the following nine columns:

Component Type Column 1 identifies the component types from Section 2 of this application that are subject to aging management review. Similar to Section 2, component types are listed in alphabetical order. In the Class 1 tables in Section 3.1 and the structural tables in Section 3.5, component types are alphabetical by sub-groups.

The term "piping" in component lists may include pipe, pipe fittings (such as elbows &

reducers), flow elements, orifices, and thermowells. If such components have unique tag

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numbers or the specific component has a function other than pressure boundary, then flow elements, orifices and thermowells are identified as a separate component type.

The term "heat exchanger (shell)" may include the bonnet/channel head and tubesheet. In cases where the bonnet/channel head and tubesheet provide a unique material and environment combination, they will be uniquely identified as a separate component type.

The general component type of "tank" includes components identified as tanks or accumulators on LRA drawings.

Intended Function Column 2 identifies the license renewal intended functions (using abbreviations where necessary) for the listed component types. Definitions and abbreviations of intended functions are listed in Table 2.0-1 in Section 2.

Material Column 3 lists the particular materials of construction for the component type being evaluated.

Environment Column 4 lists the environment to which the component types are exposed. Internal/external service environments are indicated. A description of these environments is provided in Tables 3.0-1, 3.0-2, and 3.0-3 for mechanical, structural, and electrical components, respectively.

Aging Effect Requiring Management Column 5 lists the aging effects requiring management for material and environment combinations for each component type.

Aging Management Programs (AMP)

Column 6 lists the programs used to manage the aging effects requiring management.

NUREG-1801, Vol. 2, Item Column 7 documents identified consistencies by noting the appropriate NUREG-1801, Volume 2, item number. If there is no corresponding item number in NUREG-1801, Volume 2, for a particular combination of factors, column 7 is left blank.

Each combination of the following factors listed in Table 2 is compared to NUREG-1801, Volume 2, to identify consistencies:

Component type.

Material.

Environment.

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Aging effect requiring management.

Aging management program.

Table 1 Item Column 8 lists the corresponding line item from Table 1. If there is no corresponding item in NUREG-1801, Volume 1, column 8 is left blank.

Each combination of the following that has an identified NUREG-1801, Volume 2 item number also has a Table 1 line item reference number:

Component type.

Material.

Environment.

Aging effect requiring management.

Aging management program.

Notes Column 9 contains notes that are used to describe the degree of consistency with the line items in NUREG-1801, Volume 2. Notes that use letter designations are standard notes based on a letter from A. Nelson, NEI, to P. T. Kuo, NRC, U.S. Nuclear Industrys Proposed Standard License Renewal Application Format Package, Request NRC Concurrence, dated January 24, 2003 (ML030290201). The staff concurred with the NEI standardized format for license renewal applications by letter dated April 7, 2003, from P. T. Kuo, NRC, to A. Nelson, NEI (ML030990052). Notes that use numeric designators are specific to PNPS.

PNPS LRA Table 2 contains the aging management review results and indicates whether the results correspond to line items in Volume 2 of the GALL Report. Correlations between the combination PNPS LRA Table 2 and a combination for a line item in Volume 2 of the GALL Report are identified by the GALL Report item number in Column 7. If Column 7 is blank, the applicant did not identify a corresponding combination in the GALL Report. If the applicant identified a GALL Report line item, the next column provides a reference to a Table 1 row number. This reference corresponds to the GALL Report, Volume 2, roll-up to the GALL Report, Volume 1, tables.

4.1.2 Plant-Specific Programs Many of the GALL Report evaluations refer to plant-specific programs. In these cases, the applicant considers the PNPS evaluation to be consistent with the GALL Report if the other elements are consistent. Any appropriate AMP is considered to be a match to the GALL program for line items referring to a plant-specific program.

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

Pilgrim Nuclear Power Station AMP and AMR Audit and Review Plan 10 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:

A. Technical Specifications B. UFSAR C. docketed licensing correspondence D. fire protection program documents E. NRC safety evaluation reports F. 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:

A. The analyses remain valid for the period of extended operation; B. The analyses have been projected to the end of the period of extended operation; or C. 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-1800 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 10 CFR 54.21(c)(1)(i) 4.2.2 Charpy upper-shelf energy Analyses projected 10 CFR 54.21(c)(1)(ii) 4.2.3 Adjusted reference temperature Analyses projected 10 CFR 54.21(c)(1)(ii) 4.2.4

Pilgrim Nuclear Power Station AMP and AMR Audit and Review Plan TLAA Description Resolution Option Section 11 Reactor vessel circumferential welds inspection relief Analysis projected 10 CFR 54.21(c)(1)(ii) 4.2.5 Reactor vessel axial welds failure probability Analysis projected 10 CFR 54.21(c)(1)(ii) 4.2.6 Metal Fatigue Analyses 4.3 Class 1 fatigue Analyses remain valid 10 CFR 54.21(c)(1)(i)

OR Aging effect managed 10 CFR 54.21(c)(1)(iii) 4.3.1 Non-Class 1 fatigue Analyses remain valid 10 CFR 54.21(c)(1)(i) 4.3.2 Effects of reactor water environment on fatigue life Analyses remain valid 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) 4.3.3 Environmental Qualification Analyses for Electrical Equipment Aging effect managed 10 CFR 54.21(c)(1)(iii) 4.4 Containment Liner Plate, Metal Containment, and Penetrations Fatigue Analyses 4.6 Fatigue of primary containment Analysis projected 10 CFR 54.21(c)(1)(ii) 4.6.1 Other TLAA 4.7 Reflood thermal shock of the reactor vessel internals Analysis remains valid 10 CFR 54.21(c)(1)(i) 4.7.1 TLAA in BWRVIPs 4.7.2 BWRVIP-05, RPV circumferential welds analysis Addressed in Sections 4.2.5 4.7.2.1 BWRVIP-48, vessel ID attachment welds fatigue analysis Analysis remains valid 10 CFR 54.21(c)(1)(ii) 4.7.2.2 BWRVIP-49, instrument penetrations fatigue analysis Analysis projected 10 CFR 54.21(c)(1)(ii) 4.7.2.3

Pilgrim Nuclear Power Station AMP and AMR Audit and Review Plan TLAA Description Resolution Option Section 12 BWRVIP-74, reactor vessel P/T curves analysis Fatigue analysis CVUSE analysis Circ/Axial welds analysis Addressed in Section 4.2.2 Addressed in Section 4.3.1 Addressed in Section 4.2.3 Addressed in Sections 4.2.5 and 4.2.6 4.7.2.4 BWRVIP-76, core shroud fatigue analysis Analysis remains valid 10 CFR 54.21(c)(1)(ii) 4.7.2.5 5.

OVERVIEW OF AUDIT, REVIEW, AND DOCUMENTATION PROCEDURE The project team will follow the procedure specified in Section 6 of this plan to perform its audits and reviews and to document the results of its work. The process covered by the procedure is summarized below.

5.1 Aging Management Programs Table 1 of this audit and review plan summarizes the program elements that comprise an aging management program. For the PNPS AMPs for which the applicant claimed consistency with the AMPs included in the GALL Report, the project team will review the PNPS AMP descriptions and compare program elements for the PNPS AMPs to the corresponding program elements for the GALL AMPs. The project team will verify that the PNPS AMPs contain the program elements of the referenced GALL program and that the conditions at the plant are bounded by the conditions for which the GALL program was evaluated. The Division of Engineering will review and determine the adequacy of the applicants 10 CFR 50, Appendix B Program. Other aspects of these program elements will be reviewed by the project team.

For PNPS AMPs that have one or more exception and/or enhancement, the project team will review each exception and/or enhancement to determine whether the exception and/or enhancement is acceptable, and whether the AMP, as modified by the exception and/or the enhancement, would adequately manage the aging effects for which it is credited. In some cases, the project team will identify differences that the applicant did not identiry between the PNPS AMPs credited by the applicant and the GALL Report AMPs. In these cases, the project team will review the difference to determine whether the PNPS AMP, as modified by the difference, would adequately manage the aging effects for which it is credited.

For those PNPS AMPs that are not included in the GALL Report (i.e., plant-specific AMPs), the project team will review the AMP against the ten program elements defined in Appendix A of the SRP-LR. The Division of Engineering will review and determine the adequacy of the applicants 10 CFR 50, Appendix B Program. Other aspect of these program elements will be reviewed by the project team. On the basis of its reviews, the project team will determine whether these AMPs will manage the aging effects for which they are credited.

Pilgrim Nuclear Power Station AMP and AMR Audit and Review Plan 13 5.2 Aging Management Reviews The AMRs in the GALL Report fall into two broad categories: (1) those that the GALL Report concludes are adequate to manage aging of the components referenced in the GALL Report, and (2) those for which the GALL Report concludes that aging management is adequate, but further evaluation is recommended for certain aspects of the aging management process. For its AMR reviews, the project team will determine (1) whether the AMRs reported by the applicant to be consistent with the GALL Report are indeed consistent with the GALL Report, and (2) whether the plant-specific AMRs reported by the applicant to be based on a previously-approved precedent are technically acceptable and applicable. For component groups evaluated in the GALL Report for which the applicant claimed consistency with the GALL Report, and for which the GALL Report recommends further evaluation, the project team will review the applicant's evaluation to determine if it adequately addressed the issues for which the GALL Report recommended further evaluation.

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 PNPS 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(e).

2. Consider the effects of aging.

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

4. 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 fucntions, as delineated in 10 CFR 54.4(b).

6. Contained or incorporated by reference in the CLB.

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

Pilgrim Nuclear Power Station AMP and AMR Audit and Review Plan 14 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:

A. Reactor Vessel Neutron Embrittlement Analysis B. Reflood Thermal Shock Analyses of the Reactor Vessel Internals 5.4 NRC-Approved Precedents To help facilitate the staff review of its LRA, the applicant referenced NRC-approved precedents to demonstrate that certain non-GALL AMPs correspond to programs that the staff had approved for other plants during its review of previous applications for license renewal.

Using the precedent information, the project team will (1) determine whether the material presented in the precedent is applicable to the applicant's facility, (2) determine whether the applicant's AMP is bounded by the conditions for which the precedent was evaluated and approved, and (3) verify that the applicant's AMP contains the program elements of the referenced precedent. In general, if the project team determines that these conditions are satisfied, it will use the precedent to frame and focus its review of the applicant's AMP.

It is important to note that precedent information is not a part of the license renewal application; it is supplementary information voluntarily provided by the applicant as a reviewers' aid. The existence of a precedent, in and of itself, is not a sufficient basis to accept the applicant's AMP.

Rather, the precedent facilitates the review of the substance of the matters described in the applicant's AMP. As such, in the project team's documentation of its reviews of AMPs that are based on precedents, the precedent information is typically implicit in the evaluation, rather than explicit. If the project team determines that a precedent identified by the applicant is not applicable to the particular plant AMP for which it is credited, then the project team reviews the AMP as a plant-specific AMP without consideration of the precedent information.

5.5 UFSAR Supplement Review Consistent with the SRP-LR, for the AMRs and associated AMPs that it will review, the project team will review the UFSAR supplement that summarizes the applicant's programs and activities for managing the effects of aging for the extended period of operation. The project team will also review any commitments associated with its programs and activities made by the applicant and verify that they are acceptable for the stated purpose.

5.6 Documents Reviewed by the Project Team

Pilgrim Nuclear Power Station AMP and AMR Audit and Review Plan 15 In performing its work, the project team will rely heavily on the LRA, the audit and review plan, the SRP-LR, and the GALL Report. The project team will also examine the applicant's precedent review documents, its AMP, AMR, and TLAA basis documents (catalogs of the documentation used by the applicant to develop or justify its AMPs, AMRs, and TLAAs), and other applicant documents, including selected implementing procedures, to verify that the applicant's activities and programs will adequately manage the effects of aging on structures and components.

5.7 Public Exit Meeting After it completes its audits and reviews, the project team will hold a public exit meeting to discuss the scope and results of its audits and reviews.

5.8 Documentation Prepared by the Project Team The project team will prepare an audit and review plan, worksheets, work packages, requests for additional information (RAIs), an audit and review report, and a safety evaluation report (SER) input. The project team will also prepare questions during site visits and will track the applicant's responses to the questions.

5.8.1 Audit and Review Plan The project team leader will prepare a plant-specific audit and review plan as described herein.

5.8.2 Worksheets Each project team member will informally document the results of his or her work on a variety of worksheets. The worksheets are shown in Appendix E, "Consistent with GALL Report AMP Audit/Review Worksheet"; Appendix F, "Plant-Specific AMP Audit/Review Worksheet"; and Appendix G, "Aging Management Review Worksheets", and Appendix H, TLAA-Audit/Review Worksheet. The use of the worksheets is described in Section 6 of this plan.

5.8.3 Questions As specified in Section 6 of this plan, the project team members will ask the applicant questions during the on-site audits, as appropriate, to facilitate its audit and review activities. The team will also track the applicant's answers to the questions.

5.8.4 Work Packages After each site visit, the project team leader, in conjunction with the project manager, will assemble work packages for any work that the team will refer to the NRR Division of Engineering (DE) for review. Each work package will include a work request and any applicable background information on the review item that was gathered by the project team.

5.8.5 Requests for Additional Information

Pilgrim Nuclear Power Station AMP and AMR Audit and Review Plan 16 The review process described in this plan is structured to resolve as many questions as possible during the site visits. As examples, the site visits are used to obtain clarifications about the LRA and explanations as to where certain information may be found in the LRA or its associated documents. Nevertheless, there may be occasions where an RAI is appropriate to obtain information to support an SER finding. The need for RAIs will be determined by the project team leader during the site visits through discussions with the individual project team members. When the project team leader determines that an RAI is needed, the project team member who is responsible for the area of review will prepare the RAI. RAIs will include the technical and regulatory basis for requesting the information.

After the NRC receives a response to an RAI from the applicant, the team leader will provide the response to the team member who prepared the RAI. The team member will review the response and determine if it resolves the issue that was the reason for the RAI. The team member will document the disposition of the RAI in the audit and review report (unless the report was issued before the RAI response was received) and in the SER input. If the audit report was issued before the applicant submitted its response to an RAI, the review of the response will be documented in the SER.

5.8.6 Audit and Review Report The project team will document the results of its work in an audit and review report. The team will prepare its report as described in Section 6.4.1 of this plan and the latest version of the RLRC Guidelines For Preparing Audit and Review Reports.

5.8.7 Safety Evaluation Report input The project team will prepare SER input, based on the audit and review report, as described in Section 6.4.2 of this plan.

6.

PLANNING, AUDIT, REVIEW, AND DOCUMENTATION PROCEDURE This section of the audit and review plan contains the detailed procedures that the project team will follow to plan, perform, and document its work.

6.1 Planning Activities 6.1.1 Schedule for Key Milestones and Activities The project team leader will establish the schedule for the key milestones and activities, consistent with the overall schedule for making the licensing decision. Key milestones and activities include, as a minimum:

Receiving the LRA from the applicant.

Receiving work split tables from the project manager.

Making individual work assignments.

Training project team members.

Pilgrim Nuclear Power Station AMP and AMR Audit and Review Plan 17 Holding the project team kickoff meeting.

Preparing the audit and review plan.

Scheduling site visits.

Scheduling in-office review periods.

Preparing questions.

Preparing RAIs.

Preparing draft and final audit and review report.

Preparing draft and final SER input.

Site visits will be scheduled on the basis of discussions between the project team leader, the NRC license renewal project manager, and the applicant.

Appendix B of this plan contains the target schedule for the key milestones and activities.

6.1.2 Work Assignments The technical assistance contractor will propose team member work assignments to the NRC project team leader. The NRC project team leader will approve all work assignments. After the audit plan is issued, the team leader may reassign work as necessary.

The contractor will develop assignment tables that show which project team member will review each AMP and AMR. Appendix A of this plan shows the project team membership. Appendix C shows the team member assignments for the AMPs. Appendix D of this plan shows the team member assignments for the AMRs. Appendix E shows the project team member assignments for TLAAs.

6.1.3 Training and Preparation The training and preparation will include the following:

A. A description of the audit and review process.

B. An overview of audit/review-related documentation and the documentation that the project team will audit and review.

1. GALL Report

2. SRP-LR

3. Interim Staff Guidance for License Renewal (ISG-LR)

4. LRA AMPs

5. LRA AMRs

6. Basis documents (catalogues of information assembled by the applicant to demonstrate the bases for its programs and activities)

7. Implementing procedures

8. Operating experience reports

9. RAIs, audit reports, and SERs for other plants

10. Applicant's UFSAR

11. LRA TLAAs

Pilgrim Nuclear Power Station AMP and AMR Audit and Review Plan 18 C. The protocol for interfacing with the applicant.

D. Administrative issues such as travel, control of documentation, work hours, etc.

E. Process for preparing questions, RAIs, the audit and review report, and SER input.

F. Process for interfacing with DE technical reviewers.

6.2 Aging Management Program (AMP) Audits and Reviews 6.2.1 Types of AMPs There are two types of AMPs: those that the applicant claims are consistent with AMPs contained in the GALL Report, and those that are plant-specific. The process for auditing and reviewing both types of AMPs is presented in the following sections of this plan.

6.2.2 Scope of AMP elements to be audited and reviewed Table 1 of this plan shows the 10 program elements that are used to evaluate the adequacy of each aging management program. These program elements are presented in Branch Technical Position (BTP) RLSB-1, "Aging Management Review - Generic," in Appendix A of the SRP-LR, and are summarized in the GALL Report.

The program elements audited or reviewed is the same for both AMPs that are consistent with the GALL Report and for plant-specific AMPs. The Division of Engineering will reveiw and determine the adequacy of the applicants 10 CFR 50, Appendix B Program. Other aspects of these program elements will be reviewed by the project team.

6.2.3 Plant AMPs that Are Consistent with the GALL Report Figure 1, "Audit of AMPs that Are Consistent with the GALL Report," is the process flowchart that shows the activities and decisions used by the project team to review and audit each plant AMP that the applicant claims is consistent with the GALL Report.

Preparation A. For the plant AMP being reviewed, identify the corresponding GALL AMP.

B. Review the associated GALL AMP and identify those elements that will be audited.

C. Identify the documents needed to perform the audit. These may include, but are not limited to, the following:

1. GALL Report

2. SRP-LR

3. ISGs

Pilgrim Nuclear Power Station AMP and AMR Audit and Review Plan 19

4. RAIs and SERs for similar plants

5. LRA

6. Basis documents

7. Implementation procedures

8. Operating experience reports (plant-specific and industry)

9. UFSAR Audit/Review A. Confirm that PNPS AMP program elements are consistent with the corresponding elements of the GALL Report AMP by answering the following questions and then following the process shown in Figure 1.

1. Did the applicant identify any exceptions to the GALL Report AMP?

2. Did the applicant identity any enhancements to the GALL Report AMP?

3. Are the elements consistent with the GALL Report AMP?

B. If either of the above questions results in the identification of an exception/enhancement or a difference to the GALL AMP, determine whether it is acceptable on the basis of an "adequate technical justification."

C. If an acceptable basis exists for an exception/enhancement or difference, document the basis in the worksheet and later in the audit and review report and the SER input.

D. Review the industry and plant-specific operating experience associated with the AMP.

The review is to identify aging effects requiring management that are not identified by the industry guidance documents (such as EPRI tools) and to confirm the effectiveness of aging management programs. The project team members should consider the industry guidance when assessing operating experience and formulating questions for the applicant. The industry guidance (from NEI 95-10, Revision 6) is as follows:

1. Plant-Specific Operating Experience with Aging Effects Requiring Management. A plant-specific operating experience review should assess the operating and maintenance history. A review of the prior 5 to 10 years of operating and maintenance history should be sufficient. The results of the review should confirm consistency with documented industry operating experience. Differences with previously documented industry experience such as new aging effects or lack of aging effects allow consideration of plant-specific aging management requirements.

2. Plant-Specific Operating Experience with existing Aging Management Programs.

The operating experience of AMPs, including corrective actions resulting in program enhancements or additional programs, should be considered. The review should provide objective evidence to support the conclusion that the effects of aging will be managed so that the intended function(s) will be maintained during the extended period of operation. Guidance for reviewing industry operating experience is presented in BTP RLSB-1 in Appendix A.1 of the Branch Technical Positions in NUREG-1800.

Pilgrim Nuclear Power Station AMP and AMR Audit and Review Plan 20

3. Industry Operating Experience. Industry operating experience and its applicability should be assessed to determine whether it changes plant-specific determinations.

NUREG-1801 is based upon industry operating experience prior to its date of issue.

Operating experience after the issue date of NUREG-1801 should be evaluated and documented as part of the aging management review. In particular, generic communications such as a bulletin, a generic letter, or an information notice should be evaluated for impact upon the AMP. The evaluation should check for new aging effects or a new component or location experiencing an already identified aging effect.

E. If it is necessary to ask the applicant a question to clarify the basis for accepting a program element, or an exception or a difference to the GALL Report AMP, follow the logic process shown in Figure 1.

F. If it is necessary for the applicant to submit additional information to support the basis for accepting the justification, an exception, or a difference to a program element, the applicant may agree to voluntarily submit the required information as a supplement (docketed letter submitted under oath and affirmation) to the LRA. If not, the NRC may issue an RAI to obtain the information.

AMP audit worksheets Document the audits/reviews using the worksheet provided in Appendix E, "Consistent with GALL Report AMP Audit/Review Worksheet."

6.2.4 Plant-Specific AMPs Figure 2, "Audit of Plant-Specific AMPs," is the process flowchart that shows the activities and decisions used to audit/review each plant-specific AMP.

Pre-review preparation A. Review Section A.1.2.3 of the SRP-LR and identify those element criteria that will be reviewed.

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

1. GALL Report

2. SRP-LR

3. ISG-LR

4. RAIs and SERs for similar plants

5. LRA

6. Basis documents

7. Implementation procedures

8. Operating experience reports (plant-specific and industry)

Pilgrim Nuclear Power Station AMP and AMR Audit and Review Plan 21

9. UFSAR

10. Lessons Learned Developed by RLRC Audit/Review A. Audit/review the PNPS AMP program elements and determine that they are in accordance with the acceptance criteria for the corresponding program elements of Section A.1.2.3 of the SRP-LR.

B. Review the industry and plant-specific operating experience associated with the AMP.

This is an area of review emphasis. They require review to identify aging effects requiring management that are not identified by the industry guidance documents (such as EPRI tools) and to confirm the effectiveness of aging management programs. The project team members should consider the industry guidance when assessing operating experience and formulating questions for the applicant. The industry guidance (from NEI 95-10, Revision 6) is as follows:

1. Plant-Specific Operating Experience with Aging Effects Requiring Management.

The review should assess the operating and maintenance history. A review of the prior 5 to 10 years of operating and maintenance history should be sufficient. The results of the review should confirm consistency with documented industry operating experience. Differences with previously documented industry experience such as new aging effects or lack of aging effects allow consideration of plant-specific aging management requirements.

2. Plant-Specific Operating Experience with Aging Management Programs. The operating experience of aging management programs, including past corrective actions resulting in program enhancements or additional programs, should be considered. The review should provide objective evidence to support the conclusion that the effects of aging will be managed so that the intended function(s) will be maintained during the extended period of operation. Guidance for reviewing industry operating experience is presented in BTP RLSB-1 in Appendix A.1 of the Branch Technical Positions in NUREG-1800.

3. Industry Operating Experience. Industry operating experience and its applicability should be assessed to determine whether it changes plant-specific determinations.

NUREG-1801 is based upon industry operating experience prior to its date of issue.

Operating experience after the issue date of NUREG-1801 should be evaluated and documented as part of the aging management review. In particular, generic communications such as a bulletin, a generic letter, or an information notice should be evaluated for impact upon the AMP. The evaluation should check for new aging effects or a new component or location experiencing an already identified aging effect.

C. If it is necessary to ask the applicant a question, follow the process shown in Figure 2.

E. If it is necessary for the applicant to submit additional information to resolve a question

Pilgrim Nuclear Power Station AMP and AMR Audit and Review Plan 22 or an issue or to support the basis or conclusion, the applicant may voluntarily submit the information as a supplement (docketed letter submitted under oath and affirmation) to the LRA. If not, the NRC may issue an RAI to obtain the information.

AMP review worksheets Document the audit/review using the worksheet provided in Appendix F, "Plant-Specific AMP Audit/Review Worksheet."

6.3 Aging Management Review (AMR) Audits and Reviews There are two types of AMRs: those that the applicant claims are consistent with the GALL Report, and those that are plant-specific. Audit and review of both types of AMRs are discussed below.

6.3.1 Plant AMRs that Are Consistent with the GALL Report Figure 3, "Review of AMRs that Are Consistent with the GALL Report," is the process flowchart that shows the activities and decisions used to audit/review each AMR that the applicant claims is consistent with the GALL Report.

Preparation A. For the PNPS AMRs that the applicant claims are consistent with the GALL Report, identify the corresponding AMRs in Volume 2 of the GALL Report.

B. Review the associated GALL AMRs and identify those line items that will be audited/reviewed in conjunction with each of the PNPS AMRs.

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

1. GALL Report

2. SRP-LR

3. ISG-LR

4. RAIs and SERs for similar plants

5. LRA

6. Basis documents

7. Implementation procedures

8. Operating experience reports (plant-specific and industry)

9. UFSAR

10. Lessons Learned Developed by RLRC

Pilgrim Nuclear Power Station AMP and AMR Audit and Review Plan 1

The AMR line item letter notes are based on a letter from A. Nelson, NEI, to P. T. Kuo, NRC, "U.S. Nuclear Industry's Proposed Standard License Renewal Application Format Package, Request NRC Concurrence," dated January 24, 2003 (ML030290201). The staff concurred in the format of the standardized format for LRAs by letter dated April 7, 2003, from P.T. Kuo, NRC, to A. Nelson, NEI (ML030990052).

2 Some GALL AMRs reference the use of a plant-specific AMP. In such cases the AMR audit requires the project team member to confirm that the plant-specific AMP is appropriate to manage the aging effects during the period of extended operation.

23 Audit/Review A. Each AMR line item is coded with a letter which represents a standard note designation.1 The letter notes are described in Table 2 of this plan. Notes that use numeric designators are plant-specific. The note codes A though E are classified as "consistent with the GALL Report," and will be reviewed in accordance with the guidance contained in this plan.

B. The AMR review involves verification that the applicant has satisfied the requirements of 10 CFR 54.21(a)(3). This requirement states: For each structure and component...

[within the scope of this part... and... subject to an aging management review] (the applicant) demonstrate(s) 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.

C. Determine compliance by following the process shown in Figure 3. The process is summarized below:

1. For each AMR line item, perform the review associated with the letter note (A through E) assigned to the AMR line item. Specifically, determine if the AMR is consistent with the GALL Report for the elements associated with its note.

2. If Note A applies, and the applicant uses a plant-specific AMP2 determine if the component is within the scope of the cited plant AMP. If the component is within the scope of the plant AMP, the AMR line item is acceptable. If not acceptable, go to Step (7) below.

3. If Note B applies, review the LRA exceptions and document the basis for acceptance in the worksheet, and later in the audit and review report. If not acceptable, go to Step (7) below.

4. If Note C or D applies, determine if the component type is acceptable for the material, environment, and aging effect. If Note D applies, also review the LRA exceptions and document the basis for acceptance in the worksheet, and later in the audit and review report. If not acceptable, go to Step (7) below.

Pilgrim Nuclear Power Station AMP and AMR Audit and Review Plan 3

Applicant-identified NRC-approved precedents are only to be used as an aid for performing AMR audits. The audit conclusions will be based on the technical basis of the AMR and its applicability to the plant being reviewed. It is not acceptable to simply cite the NRC-approved precedent as its basis.

24

5. If Note E applies, review the AMP audit report findings to determine if the scope of the alternate AMP envelopes the AMR line item being reviewed and satisfies 10 CFR 54.21(a)(3). If it does not, go to Step (7) below.

6. Review the corresponding LRA Table 3.X.1 entry that is referenced in LRA Table 3.X.2.Y. If applicable, determine whether the applicant's "Further Evaluation Recommended" response in LRA Section 3.X.2.2.Z is enveloped by Section 3.X.2.2.Z of the SRP-LR. If not, go to Step (7) below. If the LRA section does not meet the acceptance criteria of Appendix A of the SRP-LR, go to Step (7) below.

7. If during the review a difference is identified, prepare a question to the applicant, in order to obtain clarification.

a. Review the applicant's response to the question. If it appears acceptable, re-start the audit/review for the AMR line item from Step (1) above.

b. If the applicant's response does not resolve the question or issue, prepare an additional question to obtain the information needed to achieve resolution.

Review the applicant's response to the second question. If it appears acceptable, re-start the audit/review for the AMR line item from Step (1) above.

c.

If it is necessary for the applicant to submit additional information to resolve a question or an issue or to support a basis or conclusion, the applicant may submit the information as a supplement to the LRA or the NRC may issue an RAI to obtain the information. The team leader should be consulted if docketed information may be needed.

8. Review LRA Table 3.X.1. for AMR line items (Table 1s) that the applicant claims are not applicable with the GALL Report, determine that the AMR line items are acceptable on the basis of a technical review.

AMR audit/review worksheets Document the audits/reviews of plant AMRs using the worksheet provided in Appendix G, "Aging Management Review Worksheets."

6.3.2 AMRs Based on NRC-Approved Precedents Figure 4, "AMR Review Using NRC-Approved Precedent," is the process flowchart that shows the activities and decisions used to review plant AMRs that the applicant has identified as being consistent with an NRC-approved precedent.3

Pilgrim Nuclear Power Station AMP and AMR Audit and Review Plan 25 Preparation Identify the documents needed to perform the audit/review. These may include, but are not limited to, the following:

1. GALL Report

2. SRP-LR

3. ISG-LR

4. RAIs and SERs for similar plants

5. LRA

6. Basis documents

7. Implementation procedures

8. Operating experience reports (plant-specific and industry)

9. UFSAR

10. Lessons Learned Developed by RLRC Audit/Review A. The AMR audit/review involves verification that the requirements of 10 CFR 54.21(a)(3) are satisfied. This criterion states that, "For each structure and component [within the scope of license renewal], 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."

B. For AMRs with an NRC-approved precedent, this may be achieved by answering the following questions while following the assessment process shown in Figure 4.

1. Is the precedent appropriate for the LRA AMR being reviewed?

2. Is the NRC-approved precedent sufficiently documented or understood to technically support the adequacy of the LRA AMR being reviewed?

3. Is the LRA AMR within the bounds of the chosen NRC-approved precedent?

4. If any of these questions results in a "No" answer, then additional information is required to make a determination that the AMR is acceptable.

5. If it is necessary to ask the applicant a question to obtain clarification on the basis for accepting the AMR, the process shown in Figure 4 should be used.

6. If it is necessary for the applicant's response to be docketed as a basis for accepting the exception or difference, the applicant may voluntarily docket the response or the NRC may issue an RAI.

Pilgrim Nuclear Power Station AMP and AMR Audit and Review Plan 26 AMR audit/review worksheets Document the audits/reviews using the worksheet provided in Appendix G, "Aging Management Review Worksheets."

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-1800 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:

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

2. TLAAs

3. GALL Report

4. SRP-LR

Pilgrim Nuclear Power Station AMP and AMR Audit and Review Plan 27

5. ISG-LR

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

7. LRA

8. References listed by applicant for each TLAA

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

10. Basis documents

11. Implementation documents

12. Operating experience reports (plant-specific and industry)

13. Lessons learned developed by RLRC

14. Applicants 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:

1. Reactor Vessel Neutron Embrittlement Analysis (PNPS LRA Section 4.2)

2. 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:

1. 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

Pilgrim Nuclear Power Station AMP and AMR Audit and Review Plan 28 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.

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

3. 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.

4. 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 a worksheet which contains, as a minimum, the project teams question(s) related to the particular TLAA, the applicants response(s) and notation of documents reviewed.

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 if the TLAAs identified in the PNPS LRA to be within the NUREG-1800 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).

Pilgrim Nuclear Power Station AMP and AMR Audit and Review Plan 29 B. Identify and locate the documents needed to perform the review. These may include, but are not limited to, the following:

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

2. GALL Report, especially Section X.M1

3. SRP-LR

4. ISG-LR

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

6. LRA

7. References listed by applicant for each TLAA

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

9. Basis documents

10. Implementation documents

11. Operating experience reports (plant-specific and industry)

12. Lessons learned developed by RLRC

13. Applicants 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.

Pilgrim Nuclear Power Station AMP and AMR Audit and Review Plan 30

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

4. 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. 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 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:

1. 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 a worksheet which contains, as a minimum, the project teams question(s) related to the particular TLAA, the applicants response(s) and notation of documents reviewed.

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.

Pilgrim Nuclear Power Station AMP and AMR Audit and Review Plan 31 Pre-Review Preparation A. The project team will determine if the 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:

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

2. GALL Report, especially Section X.E1

3. SRP-LR

4. ISG-LR

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

6. LRA

7. References listed by applicant for each TLAA

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

9. Basis documents

10. Implementation documents

11. Operating experience reports (plant-specific and industry)

12. Lessons learned developed by RLRC

13. Applicants 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.

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.

Pilgrim Nuclear Power Station AMP and AMR Audit and Review Plan 32 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. 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. 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 TLAA.

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

1. 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 submi ttals [§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.

Pilgrim Nuclear Power Station AMP and AMR Audit and Review Plan 33 TLAA Audit Worksheets Document the audits/reviews using a worksheet which contains, as a minimum, the project teams question(s) related to the particular TLAA, the applicants response(s) and notation of documents reviewed.

6.4.4 Other Plant-Specific TLAAs 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 if the TLAAs identified in the PNPS LRA to be within the NUREG-1800 TLAA category of other plant-specific TLAAs 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:

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

2. GALL Report

3. SRP-LR

4. ISG-LR

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

6. LRA

7. References listed by applicant for each TLAA

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

9. Basis documents

10. Implementation documents

11. Operating experience reports (plant-specific and industry)

12. Lessons learned developed by RLRC

13. Applicants UFSAR C. In addition, the project team will also review the PNPS TLAAs within the NUREG-1800 TLAA category of other plant-specific 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

Pilgrim Nuclear Power Station AMP and AMR Audit and Review Plan 34 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. 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. 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 TLAA.

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

1. Identify and evaluate any plant-specific TLAAs.

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

Pilgrim Nuclear Power Station AMP and AMR Audit and Review Plan 35 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 a worksheet which contains, as a minimum, the project teams question(s) related to the particular TLAA, the applicants response(s) and notation of documents reviewed.

6.5 Audit and Safety Review Documentation As noted in Section 5.7 of this plan, the project team will prepare an audit and review plan, worksheets, work packages, requests for additional information, an audit and review report, and a SER input. This section of the plan addresses the preparation of the audit and review report and the SER input.

6.5.1 Audit and Review Report The project team should prepare input to the audit report in accordance with the guidance provided in the Writing Guide and Template for Preparing License Renewal Application Audit Report. The audit report should follow the following format:

A. Cover page B. Table of Contents C. Section 1 Introduction and General Information

1. Section 1.1 Introduction

2. Section 1.2

Background

3. Section 1.3 Summary of Information in the License Renewal Application

4. Section 1.4 Audit Scope

5. Section 1.5 Audit Process

6. Section 1.6 Exit Meeting D. Section 2 Aging Management Programs (AMP)

E. Section 3 Aging Management Review (AMR) Results F. Attachment 1 Abbreviations and Acronyms G. Attachment 2 Project Team and Applicant Personnel H. Attachment 3 Elements of an Aging Management Program for License Renewal I. Disposition of Requests for Additional Information, LRA Supplements, and Open Items

Pilgrim Nuclear Power Station AMP and AMR Audit and Review Plan 4

AMRs that are not consistent with the GALL Report.

36 J. List of Documents Reviewed K. Attachment 6 List of Commitments 6.5.2 Safety Evaluation Report Input A. General guidance

1. Each project team member should prepare the SER input for the AMP and AMR audits and reviews that he or she performed. The technical assistance contractor shall collect, assemble, and prepare the complete SER input.

2. In general, the data and information needed to prepare the SER input should be available in the project team's audit and review report and the team member's worksheets.

3. SER inputs are to be prepared for:

a. Each AMP that was determined to be consistent with the GALL Report, which has no exceptions or enhancements.

b. Each AMP that was determined to be consistent with the GALL Report, which has exceptions (identified by either the applicant or the project team) or enhancements.

c.

Each plant-specific AMP.

d. AMRs that are consistent with the GALL Report.

e. Project team AMR review results.4

4. The SER input should contain the following sections. (Note: The following section numbers (3. through 3.X.3) are based on the numbering system for the SER input.

They are not a continuation of the numbering convention used throughout this plan.)

3.

Aging Management Review Results 3.0 Applicant's Use of the Generic Aging Lessons Learned Report 3.01 Format of the LRA 3.02 Staff's Review Process 3.0.2.1 AMRs in the GALL Report 3.0.2.2 NRC-Approved Precedents 3.0.2.3 UFSAR Supplement 3.0.2.4 Documentation and Documents Reviewed 3.0.3 Aging Management Programs

Pilgrim Nuclear Power Station AMP and AMR Audit and Review Plan 5

The LRA AMR results are broken down into six sections and address the following system/structure groups: (1) Section 3.1, reactor vessel, internals and reactor coolant system, (2) Section 3.2, engineering safety features systems, (3) Section 3.3, auxiliary systems, (4)

Section 3.4, steam power and conversion systems, (5) Section 3.5, structures and component supports, (6) Section 3.6, electrical and instrumentation and controls.

37 3.0.3.1 AMPs that are Consistent With the GALL Report 3.0.3.2 AMPs that are Consistent With GALL Report With Exceptions or Enhancements 3.0.3.3 AMPs that are Plant-Specific 3.0.4 Quality Assurance Program Attributes Integral to Aging Management Programs 3.X5 Aging Management of ______

3.X.1 Summary of Technical Information in the Application 3.X.2 Staff Evaluation 3.X.2.1 Aging Management Evaluations that are Consistent with the GALL Report, for Which Further Evaluation is Not Required 3.X.2.2 Aging Management Evaluations that are Consistent with the GALL Report, for Which Further Evaluation is Recommended 3.X.2.3 AMR Results that are Not Consistent with or Not Addressed in the GALL Report 3.X.3 Conclusion

5. For each AMP audited/reviewed by the project team, the SER shall include a discussion of the team's review of the operating experience program element.

6. If the applicant submitted an amendment or a supplement to its LRA that is associated with the project team's audit or review activities, document the submittal (include the date and ADAMS accession number) and explain the issue that the submittal resolved and discuss the basis for the resolution.

7. If an RAI was issued, identify the RAI number and briefly discuss the RAI. State if the RAI remains open or if the applicant response has been received and accepted.

If the response was acceptable, identify the submittal (including the date and the ADAMS accession number) that provided the response and document the basis for its acceptance.

8. Issues (e.g., RAIs) that have not been resolved by the applicant at the time the SER input is prepared should be identified as open items.

B. SER input

1. For AMPs determined to be consistent with the GALL Report, without exceptions, include the AMP title, the plant AMP paragraph number, and a discussion of thebasis for concluding that the UFSAR update (Appendix A of the LRA) is

Pilgrim Nuclear Power Station AMP and AMR Audit and Review Plan 6

The audit results documented in this section address the AMRs consistent with the GALL Report for which no further evaluation is recommended.

38 acceptable. This SER input documents that the AMP is consistent with the GALL Report.

2. For AMPs determined to be consistent with the GALL Report, with exceptions or enhancement, the SER input should include a statement that the audit found the AMP consistent with the GALL Report and that any applicant-identified exceptions to the GALL Report were found technically acceptable to manage the aging effect during the period of extended operation. The SER input should identify the exceptions and provide the basis for acceptance. The SER input will also address the UFSAR supplement, and document the basis for concluding that it is acceptable.

3. For plant-specific AMPs, the SER input should document the basis for accepting each of the seven elements reviewed by the project team. The SER input should also include a discussion concerning the adequacy of the UFSAR supplement.

4. For aging management evaluations that are consistent with the GALL Report,6 the SER input should include the following:

a. Identify the LRA section reviewed.

b. A summary of the type of information provided in the section of the LRA reviewed, including a listing of the AMPs reviewed.

c.

Identify the LRA Tables 3.X.2-Y reviewed.

d. A summary review of the AMR Notes A through E used to classify the AMR line items used in these tables.

e. A brief summary of what the staff (project team) reviewed to perform the audit (i.e., LRA and applicant basis documents and other implementation documents).

Reference the appendix that lists the details of the documents reviewed.

f.

The bases for accepting any exceptions to GALL AMRs that were identified by the applicant or the project team member.

g. A finding that verifies that:

The applicant identified the applicable aging effects.

The applicant defined the appropriate combination of materials and environments.

The applicant specified acceptable AMPs.

Pilgrim Nuclear Power Station AMP and AMR Audit and Review Plan 7

This section documents reviews of AMRs assigned to the project team that are not consistent with the GALL Report.

39

h. A conclusion stating, if applicable, that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended functions will be maintained consistent with the CLB for the period of extended operation, and that 10 CFR 54.21(a)(3) has been satisfied.

5. For aging management evaluations that are consistent with the GALL Report, for which further evaluation is recommended, the SER input should include the following:

a. The LRA section containing the applicant's further evaluations of AMRs for which further evaluation is required.

b. A list of the aging effects for which the further evaluation apply.

c.

For the applicant's further evaluations, provide a summary of the basis for concluding that it satisfied the criteria of Section 3.1.3.2 of the SRP-LR.

d. A statement that the staff audited the applicant's further evaluations against the criteria contained in Section 3.1.3.2 of the SRP-LR.

e. A statement that the audit and review report contains additional information.

Also identify the issue date and the ADAMS accession number for the audit and review report.

6. Staff AMR Review Results.7 This section of the SER input documents the reviews of AMRs assigned to the project team that are not consistent with the GALL Report.

The audit report should document the following, based on a precedent identified by the applicant:

a. The LRA section reviewed.

b. A summary of the type of information provided in the section of the LRA, reviewed, including a listing of the AMPs reviewed for this LRA section.

c.

Identify the LRA Tables 3.X.2-Y documented by this audit writeup.

d. A brief summary of what the staff (project team) reviewed (i.e., LRA and applicant basis documents and other implementation documents).

e. A finding that verifies, if true, that:

The applicant identified the applicable aging effects.

Pilgrim Nuclear Power Station AMP and AMR Audit and Review Plan 40 The applicant listed the appropriate combination of materials and environments.

The applicant specified acceptable AMPs.

f.

Provide a conclusion stating, if applicable, that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended functions will be maintained consistent with the CLB for the period of extended operation, and that 10 CFR 54.21(a)(3) has been satisfied.

6.6 Documents Reviewed and Document Retention Any documents reviewed that were used to formulate the basis for resolution of an issue, such as the basis for a technical resolution, the basis for the acceptance of an exception or an enhancement, etc., should be documented as a reference in the audit and review report.

Upon issuance of the audit and review report, all worksheets that were completed by contractor and NRC personnel shall be given to the NRC project team leader.

After the NRC has made its licensing decision, all copies of documents collected and all documents generated to complete the audit and review report, such as audit worksheets, question and answer tracking documentation, etc., are to be discarded.

Pilgrim Nuclear Power Station AMP and AMR Audit and Review Plan 41 Table 1. Aging Management Program Element Descriptions Element Description 1 Scope of the program The scope of the program should include the specific structures and components subject to an aging management review.

2 Preventive actions Preventive actions should mitigate or prevent the applicable aging effects.

3 Parameters monitored or inspected Parameters monitored or inspected should be linked to the effects of aging on the intended functions of the particular structure and component.

4 Detection of aging effects Detection of aging effects should occur before there is loss of any structure and component intended function. This includes aspects such as method or technique (i.e., visual, volumetric, surface inspection), frequency, sample size, data collection and timing of new/one-time inspections to ensure timely detection of aging effects.

5 Monitoring and trending Monitoring and trending should provide prediction of the extent of the effects of aging and timely corrective or mitigative actions.

6 Acceptance criteria Acceptance criteria, against which the need for corrective action will be evaluated, should ensure that the particular structure and component intended functions are maintained under all current licensing basis design conditions during the period of extended operation.

7 Corrective actions Corrective actions, including root cause determination and prevention of recurrence, should be timely.

8 Confirmation process The confirmation process should ensure that preventive actions are adequate and appropriate corrective actions have been completed and are effective.

9 Administrative controls Administrative controls should provide a formal review and approval process.

10 Operating experience Operating experience involving the aging management program, including past corrective actions resulting in program enhancements or additional programs, should provide objective evidence to support a determination that the effects of aging will be adequately managed so that the structure and component intended functions will be maintained during the period of extended operation.

Pilgrim Nuclear Power Station AMP and AMR Audit and Review Plan 8

Each AMR line item is coded with a letter which represents a standard note designation based on a letter from A. Nelson, NEI, to P.T. Kuo, NRC, "U.S. Nuclear Industry's Proposed Standard License Renewal Application Format Package, Request NRC Concurrence," dated January 24, 2003 (ML030290201). The staff concurred in the format of the standardized format for license renewal applications by letter dated April 7, 2003, from P.T. Kuo, NRC, to A.

Nelson, NEI (ML030990052).

42 Table 2. Notes for License Renewal Application Tables 3.X.2-Y8 Note Description A

Consistent with NUREG-1801 [GALL Report] item for component, material, environment, and aging effect. AMP is consistent with NUREG-1801 AMP.

B Consistent with NUREG-1801 item for component, material, environment, and aging effect. AMP takes some exceptions to NUREG-1801 AMP.

C Component is different, but consistent with NUREG-1801 item for material, environment, and aging effect. AMP is consistent with NUREG-1801 AMP.

D Component is different, but consistent with NUREG-1801 item for material, environment, and aging effect. AMP takes some exceptions to NUREG-1801 AMP.

E Consistent with NUREG-1801 for material, environment, and aging effect, but a different aging management program is credited.

F Material not in NUREG-1801 for this component.

G Environment not in NUREG-1801 for this component and material.

H Aging effect not in NUREG-1801 for this component, material and environment combination.

I Aging effect in NUREG-1801 for this component, material and environment combination is not applicable.

J Neither the component nor the material and environment combination is evaluated in NUREG-1801.

Pilgrim Nuclear Power Station AMP and AMR Audit and Review Plan 43 Figure 1. Audit of AMPs that are Consistent with the GALL Report Yes No Yes Yes No Yes No Start Did applicant identify any exceptions to GALL AMP(s)?

Compare each GALL AMP auditable element to the LRA AMP Document the basis for acceptance of the attribute element in worksheet Have all attribute elements been audited?

Yes Preparation Steps Identify GALL AMP(s) to which LRA AMP is being compared Identify elements of GALL AMP(s) attributes to be audited Identify LRA AMP support documents needed to perform audit Is there a technical basis to accept exception or difference?

Note: If a prior NRC precedent exists, it may be used as an aid to make the technical determination.

Documentation of the acceptance must be made on the technical merits not a citation to the precedent.

Ask applicant a clarifying question to continue audit?

No Notify NRC Team Leader that Audit of AMR may not proceed.

Terminate AMP audit Develop and provide question to Team Leader for PMs submittal to applicant Obtain response from applicant Draft RAI No Note; Preparation steps may be performed as a single combined step for each AMP audited.

Yes No Is the attribute element consistent?

Write audit report input per guidance in Section D.E.F Conclusion of AMP audit Provide audit report input Write SE input per guidance in Section G.H.J Provide audit SE input Have all 7 AMP attributes been audited?

No

Pilgrim Nuclear Power Station AMP and AMR Audit and Review Plan 44 Yes No Yes No Yes Yes No No Start Compare each SRP-LR AMP criteria element to the LRA AMP Document the basis for acceptance of the element in worksheet Have all element criteria been audited?

Preparation Steps Identify criteria of SRP-LR, Appendix A elemets which are auditable Identify LRA AMP support documents needed to perform audit Is there a technical basis to accept exception or difference?

Note: If a prior NRC precedent exist, it may be used as an aid to make the technical determination.

Documentation of the acceptance must be made on the technical merits not a citation to the precedent.

Is it appropriate to ask applicant a clarifying question to continue audit?

Develop question No Notify NRC Team Leader that review of AMP may not proceed.

Terminate AMP audit Provide question to Team leader for PMs submittal to applicant Obtain response from applicant Draft RAI Note; Preparation steps may be performed as a single combined step for each AMP audited.

Yes No Is the AMP element consistent?

Write audit and review report input Conclusion of AMP review Provide NRC team leader and contractor audit report input Write SER input Provide NRC team leader and contractor audit SER input Have all 7 AMP elements been audited?

Figure 2. Audit of Plant-Specific AMPs

Pilgrim Nuclear Power Station AMP and AMR Audit and Review Plan 45 Footnote A Confirm that AMP will address AE for this component and environment Compare line item with GALL Vol. 2 System Table line item for:

component type material environment aging effect Confirm AE still managed despite AMP exception Confirm material, environment, AE, and method per AMP are comparable Confirm material, environment and aging effect are comparable and AE still managed despite AMP exception Confirm AMP can manage this AE Footnote B Footnote C Footnote D Footnote E Compare line item with GALL Vol. 2 System Table line item for:

material environment aging effect AMP Compare line item with GALL Vol. 2 System Table line item for:

material environment aging effect Compare line item with GALL Vol. 2 System Table line item for:

material environment aging effect Compare item with GALL Vol. 2 System Table item for:

component type material environment aging effect AMP Item is assigned to DE No Document basis for acceptance in AMR Comparison Checklist Prepare question Review corresponding LRA Table 3.X.1"Further Evaluation Recommended" and "Discussion" columns Review referenced LRA subsection and compare with SRP subsection for any differences Acceptable in all aspects No Mark as Out of Scope Out of RLEP Scope Mark as Acceptable Mark for query Document problem in AMR Comparison Checklist Confirm question is captured AMR line item complete AMR item AMP is Plant-Specific No Yes Yes Yes No No No No No Yes Yes Yes Yes Yes Yes No Further Evaluation Figure 3. Review of AMRs that are Consistent with the GALL Report

Pilgrim Nuclear Power Station AMP and AMR Audit and Review Plan 46 Review cited SER Valid precedent Applicant proposes precedent Review cited LRA (may not be required in all cases)

RAIs exist Review all relevant RAIs Document basis for acceptance in AMR Comparison Checklist Mark as Acceptable AMR complete Alternative precedent identified Prepare question Mark for query Document problem in AMR Comparison Checklist Confirm question is captured Out of RLEP Scope Mark as Open Item Propose assignment to DE Additional information needed Identify or request alternative precedent Document absence of precedent in AMR Comparison Checklist Yes Yes Yes Yes Yes No No No No No Figure 4. Review of AMRs Using NRC-Approved Precedents

Pilgrim Nuclear Power Station AMP and AMR Audit and Review Plan 47 Figure 5. Review of TLAAs and Exemptions (from NEI 95-10, Revision 6)

Pilgrim Nuclear Power Station AMP and AMR Audit and Review Plan A-1 APPENDIX A PROJECT TEAM MEMBERSHIP Organization Name Function NRC/NRR/DLR/RLRC James Davis Team leader NRC/NRR/DLR/RLRC Peter Wen Back-up Team Leader NRC/NRR/DLR/RLRC Dan Hoang Reviewer - Structures NRC/NRR/DLR/RLRC Duc Nguyen Reviewer - Electrical ATL International Erach Patel Contractor lead, Reviewer - Mechanical ATL International Bob Jackson Reviewer - Systems ATL International Wayne Pavinich Reviewer - Materials

Pilgrim Nuclear Power Station AMP and AMR Audit and Review Plan B-1 APPENDIX B RLRC SCHEDULE FOR PILGRIM LRA SAFETY REVIEW Plant:

Pilgrim Nuclear Power Station TAC No. MC9669 Team Leader:

James Davis Scope of Work:

Backup Team Leader: Peter Wen AMPs - 37 of 38 Project Manager:

Kathy Weaver TLAAs - 6 of 9 Contractor:

ATL International, Inc AMRs - 3,375 Total line items Assignments:

Erach Patel (ATL)

RAI Target Date: 08/04/06 Peter Wen (NRC), Dan Haung (NRC),

SE Input to PM:

10/16/06 Duc Nguyen (NRC), Robert Jackson (ATL), Wayne Pavinich (ATL)

Activity/Milestone Scheduled Date 1

Received license renewal application (LRA) 01/27/06 2

Make review assignments (Project Manager) 03/28/06 3

Train project team (Team Introduction Meeting) 03/20/06 4

Hold team planning and kick-off meeting 03/20/06 5

Issue audit plan to Project Manager 05/01/06 6

Conduct first site visit (AMP audit and review) 05/22 - 05/26/06 7

Draft AMP audit report input 06/09/06 8

Conduct in-office AMR reviews 06/12 - 06/16/06 9

Conduct second site visit (AMR audit and review) 06/19 - 06/23/06 10 Draft AMR audit report input 07/14/06 11 Third site visit to resolve issues and questions (if needed) 07/24 - 07/27/06 12 Conduct public exit meeting 07/27/06 13 Cutoff for providing RAIs to Project Manager 08/04/06 14 Peer review of final draft audit and review report 08/07 - 08/18/06 15 Issue final audit and review report 09/08/06 16 Issue final draft SER input to Project Manager 10/16/06 17 ACRS subcommittee meeting April 2007 18 ACRS full committee meeting Sept. 2007

Pilgrim Nuclear Power Station AMP and AMR Audit and Review Plan C-1 APPENDIX C AGING MANAGEMENT PROGRAM ASSIGNMENTS PNPS LRA AMP Number GALL Report AMP Number Aging Management Program Consistent With GALL?

Assigned Auditor B.1.1 XI.M.22 Boraflex Monitoring Yes Peter Wen B.1.2 XI.M.34 Buried Piping and Tanks Inspection Yes Exception Jim Davis B.1.3 XI.M.6 BWR Control Rod Drive Return Line Nozzle Yes Exception Jim Davis B.1.4 XI.M.5 BWR Feedwater Nozzle Yes Exception Jim Davis B.1.5 XI.M.8 BWR Penetrations Yes Exception Bob Jackson B.1.6 XI.M.7 BWR Stress Corrosion Cracking Yes Exception - Enhanced Bob Jackson B.1.7 XI.M.4 BWR Vessel ID Attachment Welds Yes Exception Bob Jackson B.1.8 XI.M.9 BWR Vessel Internals Yes Exception - Enhanced Bob Jackson B.1.9 XI.S.4 Containment Leak Rate Yes Dan Hoang B.1.10 XI.M.30 Diesel Fuel Monitoring Yes Exception - Enhanced Wayne Pavinich B.1.11 X.E.1 Environmental Qualification of Electric Components Yes Duc Nguyen B.1.12 X.M.1 Fatigue Monitoring Yes Exception Erach Patel B.1.13.1 XI.M.26 Fire Protection Yes Exception - Enhanced Erach Patel B.1.13.2 XI.M.27 Fire Water System Yes Exception - Enhanced Erach Patel B.1.14 XI.M.17 Flow-Accelerated Corrosion Yes Peter Wen B.1.15 N/A Heat Exchanger Monitoring Wayne Pavinich B.1.16.1 N/A Containment Inservice Inspection Dan Hoang

Pilgrim Nuclear Power Station AMP and AMR Audit and Review Plan PNPS LRA AMP Number GALL Report AMP Number Aging Management Program Consistent With GALL?

Assigned Auditor C-2 B.1.16.2 N/A Inservice Inspection Bob Jackson B.1.17 N/A Instrument Air Quality Wayne Pavinich B.1.18 XI.E.4 Metal-Enclosed Bus Inspection Yes Exception Duc Nguyen B.1.19 XI.E.3 Non-EQ Inaccessible Medium-Voltage Cable Program Yes Duc Nguyen B.1.20 XI.E.2 Non-EQ Instrumentation Circuits Test Review Yes Duc Nguyen B.1.21 XI.E.1 Non-EQ Insulated Cables and Connections Yes Duc Nguyen B.1.22 XI.M.39 Oil Analysis Yes Exception - Enhanced Wayne Pavinich B.1.23 XI.M.32 One-Time Inspection Yes Erach Patel B.1.24 N/A Periodic Surveillance and Preventive Maintenance Wayne Pavinich B.1.25 XI.M.3 Reactor Head Closure Studs Yes Exception Bob Jackson B.1.26 XI.M.31 Reactor Vessel Surveillance Yes Enhanced DE Staff B.1.27 XI.M.33 Selective Leaching Yes Peter Wen B.1.28 XI.M.20 Service Water Integrity Yes Exception Wayne Pavinich B.1.29.1 XI.S.5 Masonry Wall Yes Dan Hoang B.1.29.2 XI.S.6 Structures Monitoring Yes Enhanced Dan Hoang B.1.29.3 XI.S.7 Water Control Structures Monitoring Yes Enhanced Dan Hoang B.1.30 XI.M.36 System Walkdown Yes Peter Wen B.1.31 XI.M.13 Thermal Aging and Neutron Irradiation Embrittlement of Cast Austenitic Stainless Steel (CASS)

Yes Peter Wen B.1.32.1 N/A Water Chemistry Control - Auxiliary Systems Erach Patel

Pilgrim Nuclear Power Station AMP and AMR Audit and Review Plan PNPS LRA AMP Number GALL Report AMP Number Aging Management Program Consistent With GALL?

Assigned Auditor C-3 B.1.32.2 XI.M.2 Water Chemistry Control - BWR Yes Erach Patel B.1.32.3 XI.M.21 Water Chemistry Control - Closed Cooling Water Yes Exception Erach Patel

Pilgrim Nuclear Power Station AMP and AMR Audit and Review Plan D-1 APPENDIX D AGING MANAGEMENT REVIEW ASSIGNMENTS Aging Management Reviews Reviewer 3.1 Aging Management of Reactor Vessel, Internals, and Reactor Coolant System Bob Jackson 3.2 Aging Management of Engineered Safety Features Wayne Pavinich 3.3 Aging Management of Auxiliary Systems Erach Patel 3.4 Aging Management of Steam and Power Conversion Systems Peter Wen 3.5 Aging Management of Containment, Structures, and Component Supports Dan Hoang 3.6 Aging Management of Electrical and Instrumentation and Controls Duc Nguyen

Pilgrim Nuclear Power Station AMP and AMR Audit and Review Plan E-1 APPENDIX E TIME-LIMITED AGING ANALYSIS REVIEW ASSIGNMENTS LRA TLAA Number GALL Report TLAA Number TLAA Title 10 CFR 54.21(c)(1)

Assigned Reviewer (i) or (iii)

(ii) 4.1 Identification of TLAAs and Exemptions J. Davis 4.2 Reactor Vessel Neutron Embrittlement (i)

(ii)

DCI 4.3 X.M.1 Metal Fatigue (i) or (iii)

(ii)

E. Patel 4.4 X.E.1 Environmental Qualification or Electrical Components (iii)

D. Nguyen 4.5 X.S.1 Concrete Containment Tendon Prestress Not Applicable to PNPS N/A 4.6 Containment Liner Plate, Metal Containment, and Penetrations Fatigue Analysis (ii)

D. Hoang 4.7.1 Reflood Thermal Shock Analysis of the Reactor Vessel Internals (i)

DCI 4.7.2.1 TLAA in BWRVIP-05 DCI 4.7.2.2 TLAA in BWRVIP-48 (ii)

B. Jackson 4.7.2.3 TLAA in BWRVIP-49 (ii)

B. Jackson 4.7.2.4 TLAA in BWRVIP-74 DCI 4.7.2.5 TLAA in BWRVIP-76 (ii)

B. Jackson

Pilgrim Nuclear Power Station AMP and AMR Audit and Review Plan F-1 APPENDIX F CONSISTENT WITH GALL REPORT AMP AUDIT/REVIEW WORKSHEET The worksheet provided in this appendix provides, as an aid for the reviewer, a process for documenting the basis for the assessment of the elements and sub-elements contained in the GALL Report AMPs (Chapter XI of NUREG-1801, Volume 2). The worksheet provides a systematic method for recording the basis for assessments or to identify when the applicant needs to provide clarification or additional information. Information recorded in the worksheets will also be used to prepare the audit and review report and the safety evaluation report input.

A complete set of GALL Report AMP worksheets can be found at ADAMS Accession Number ML060950189.

Pilgrim Nuclear Power Station AMP and AMR Audit and Review Plan F-2 LRA Appendix Subsection:

LRA AMP

Title:

GALL Report Subsection:

Gall Report

Title:

A. Element Review and Audit Program

Description:

G Consistent with GALL Report G Difference Identified Discussion:

1. Scope of Program:

G Consistent with GALL Report G Exception G Enhancement G Difference Identified Discussion:

2. Preventive Action:

G Consistent with GALL Report G Exception G Enhancement G Difference Identified Discussion:

3. Parameters Monitored/Inspected:

G Consistent with GALL Report G Exception G Enhancement G Difference Identified Discussion:

4. Detection of Aging Effects:

G Consistent with GALL Report G Exception G Enhancement G Difference Identified Discussion:

5. Monitoring and Trending:

G Consistent with GALL Report G Exception G Enhancement G Difference Identified Discussion:

6. Acceptance Criteria:

G Consistent with GALL Report G Exception G Enhancement G Difference Identified Discussion:

7. Corrective Action:

Pilgrim Nuclear Power Station AMP and AMR Audit and Review Plan F-3

8. Confirmation Process:

9. Administrative Controls:

10. Operating Experience:

B. FSAR supplement review: (Include any commitments.)

C. Remarks and questions:

D. References/documents used: (Include number designation, full title, revision number, date, and page numbers, and ADAMS accession number.)

E. Applicant contact:

Project team member: __________________________________ Date: ______________

Pilgrim Nuclear Power Station AMP and AMR Audit and Review Plan G-1 APPENDIX G PLANT-SPECIFIC AMP AUDIT/REVIEW WORKSHEET The worksheet provided in this appendix provides, as an aid for the reviewer, a process for documenting the basis for the assessments concerning individual program elements and sub-elements contained in Branch Technical Position RLSB-1 "Aging Management Review -

Generic," in Appendix A to the SRP-LR. The worksheet provides a systematic method to record the basis for assessments or identifying when the applicant needs to provide additional information. Information recorded in these worksheets will be used when preparing the audit and review report and the safety evaluation report input.

Pilgrim Nuclear Power Station AMP and AMR Audit and Review Plan G-2 Plant-Specific AMP Audit/Review Worksheet AMP

Title:

Appendix Subsection: ____________________________________________________

A. Element Review and Audit

1. Scope of Program:

___ Consistent with SRP-LR

____ Exception

____ Difference Identified Discussion:

SRP Criteria LRA AMP Comment*

2. Preventive Action:

___ Consistent with SRP-LR

____ Exception

____ Difference Identified Discussion:

SRP Criteria LRA AMP Comment*

3. Parameters Monitored/Inspected:

___ Consistent with SRP-LR

____ Exception

____ Difference Identified Discussion:

SRP Criteria LRA AMP Comment*

4. Detection of Aging Effects

___ Consistent with SRP-LR

____ Exception

____ Difference Identified Discussion:

SRP Criteria LRA AMP Comment*

Pilgrim Nuclear Power Station AMP and AMR Audit and Review Plan G-3

5. Monitoring and Trending

___ Consistent with SRP-LR

____ Exception

____ Difference Identified Discussion:

SRP Criteria LRA AMP Comment*

6. Acceptance Criteria

___ Consistent with SRP-LR

____ Exception

____ Difference Identified Discussion:

SRP Criteria LRA AMP Comment*

7.

Corrective Action:

To be performed by DIPM 8.

Confirmation Process:

To be performed by DIPM 9.

Administrative Controls:

To be performend by DIPM 10.

Operating Experience:

___ Consistent with SRP-LR

____ Exception

____ Difference Identified Discussion:

SRP Criteria LRA AMP Comment*

Consistent or technical basis for acceptance exception or difference B. FSAR supplement review: (Include any committments.)

C. Remarks and questions:

D. References/Documents used: (Include number designation, full title, revision number, date, page numbers, and ADAMS accession number.)

E. Applicant

Contact:

Project team member:_________________________________

Date: ______________

Pilgrim Nuclear Power Station AMP and AMR Audit and Review Plan H-1 Appendix H AMR Comparison Worksheets

Pilgrim Nuclear Power Station AMP and AMR Audit and Review Plan H-2 PNPS AMR Component (Table 1) Worksheet:

Audit Date:

Unit:

Table No.:

Chapter:

Auditor Name(s):

The audit team verified that items in Table 3.X.1 (Table 1) correspond to items in the GALL Volume 1, Table X. All items applicable to BWRs in Table 1 were reviewed and are addressed in the following table.

Item No.

Further Evaluation Recommended Discussion Audit Remarks (Document all questions for applicant here):

Number Question for applicant (draft per RAI guidance)

Response (with date)

References/Documents Used:

1.

2.

3.

4.

Pilgrim Nuclear Power Station AMP and AMR Audit and Review Plan H-3 PNPS AMR MEAP Comparison (Table 2) Worksheet Audit Date:

Unit:

Table No.:

Chapter:

Auditor Name(s):

Line items to which Notes A, B, C, D, and E are applied or for which a precedent was cited (except for those assigned to DE) were reviewed for: 1) consistency with NUREG-1801, Volume 2 tables, and 2) adequacy of the aging managing programs. All items in the Table 2 of the system named above are acceptable with the exception of items in boldface type.

(Reviewers need not duplicate information in the 2nd-5th columns that are reflected in the discussion/draft audit report.)

LRA Page No.

Component Type Material Environment Aging Effect Note:

Discussion (draft as Audit Report Insert)

Audit Remarks (Document all questions for the applicant here):

No.

Question for applicant (draft per RAI guidance)

Response (with date)

References/Documents Used:

1.

2.

3.

Pilgrim Nuclear Power Station AMP and AMR Audit and Review Plan J-1 APPENDIX I ACRONYMS, ABBREVIATIONS, AND INITIALISMS ADAMS Agencywide Documents Access and Management System AMP aging management program AMR aging management review ASME American Society of Mechanical Engineers CLB current licensing basis DE Division of Engineering DIPM Division of Inspection Program Management FSAR final safety analysis report GALL Generic Aging Lessons Learned ISG interim staff guidance LRA license renewal application NEI Nuclear Energy Institute NRC U.S. Nuclear Regulatory Commission NRR Office of Nuclear Reactor Regulation PNPS Pilgrim Nuclear Power Station RAI request for additional information RLEP-B License Renewal and Environmental Impacts Program, Section B RLSB License Renewal and Standardization Branch SC structures and components

Pilgrim Nuclear Power Station AMP and AMR Audit and Review Plan J-2 SER safety evaluation report SRP-LR Standard Review Plan - License Renewal SSC structure, system, and component TLAA Time Limited Aging Analysis UFSAR updated final safety analysis report