ML051600008

Audit & Review Plan for Plant Aging Management Reviews & Programs for Monticello Nuclear Generating Plant

ML051600008
Person / Time
Site:	Monticello
Issue date:	06/02/2005
From:	Advanced Technologies & Labs International
To:	Dudley N NRC/NRR/DRIP/RLEP
Dudley N, NRR/DRIP/RLEP, 415-1154
Shared Package
ML051580004	List: ML051580005 ML051600008 ML051600081
References
TAC MC6440
Download: ML051600008 (34)

Text

Audit and Review Plan for Plant Aging Management Reviews and Programs Monticello Nuclear Generating Plant Docket No.: 50-263 June 2, 2005 Prepared by Advanced Technologies and Laboratories International, Inc.

20010 Century Blvd., Suite 500 Germantown, MD 20874 Contract No. DR-03-05-027 Prepared for License Renewal and Environmental Impacts Program Division of Regulatory Improvement Programs Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001

1 Table of Contents

1. Introduction..1

2. Background.2

3. Objectives4

4. Summary of Information Provided in the License Renewal Application5

5. Overview of Audit, Review, and Documentation Procedure7

6. Planning, Audit, Review and Documentation Procedure...10 Appendix A - Project Team Members...A-1 Appendix B - ScheduleB-1 Appendix C - Aging Management Program Assignments.C-1 Appendix D - Aging Management Review Assignments...D-1 Appendix E - Abbreviations and Acronyms E-1 Tables Table 1 Aging Management Program Element Description19 Table 2 Notes for License Renewal Application Tables 3.x.2-y.....20 Figures Figure 1 Audit of AMPs That Are Consistent With the GALL Report....21 Figure 2 Audit of Plant-Specific AMPs.......22 Figure 3 Review of AMRs That Are Consistent With the GALL Report....23

2 Audit and Review Plan for Plant Aging Management Reviews and Programs

1.

INTRODUCTION By letter dated March 24, 2005, the Nuclear Management Company, LLC submitted to the U.S.

Nuclear Regulatory Commission (NRC) its application for renewal of Operating License DPR-22 for Monticello Nuclear Generating Plant (MNGP). The applicant requested renewal of the operating license for an additional 20 years beyond the 40-year current license term.

In support of the NRC staff's safety review of the license renewal application (LRA) for the Monticello Nuclear Generating Plant, the License Renewal and Environmental Impacts Program, License Renewal Section B (RLEP-B), will lead a project team, which will audit and review selected aging management reviews (AMRs) and associated aging management programs (AMPs). This document is the RLEP-B plan for auditing and reviewing the AMPs and AMRs. The project team includes the NRC staff and Advanced Technologies and Laboratories International, Inc. (ATL) engineers, who are listed in Appendix A, Project Team Members, of this audit plan.

The project team will audit and review its assigned AMPs and AMRs against the requirements and guidance contained in the following documents:

Title 10 of the Code of Federal Regulations, Part 54, Requirements for Renewal of Operating Licenses for Nuclear Power Plants NUREG-1800, Standard Review Plan for Review of License Renewal Application for Nuclear Power Plants (SRP-LR), issued July 2001 NUREG-1801, Generic Aging Lessons Learned (GALL) Report, issued July 2001 For the scope of work defined in this audit plan, the project team will evaluate whether the applicants 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 MNGP current licensing basis (CLB) for the extended period of operation.

The project team plans to perform its work at NRC Headquarters, Rockville, Maryland; at ATLs Germantown, MD office, and at the applicants offices at Monticello, Minnesota. The project team plans to perform its work in accordance with the schedule shown in Appendix B, Schedule. The project team will conduct a public exit meeting at the applicants offices in Monticello, Minnesota, after it completes its on-site work.

3

2.

BACKGROUND 10 CFR 54.4(a) states that plant systems, structures, and components (SSCs) within the scope of license renewal are:

(1)

Safety-related SSCs which are relied upon to remain functional during and following design-basis events (2)

All non-safety related SSCs whose failure could prevent satisfactory accomplishment of any of the functions identified for safety-related SSCs (3)

All SSCs relied on in safety analyses or plant evaluations to perform a function that demonstrates compliance with the Commissions 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 extended period of operation. 10 CFR 54.21(d) requires that the applicant submit a supplement to the updated final safety analysis report (UFSAR) 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 license renewal applications. In particular, the SRP-LR provides guidance for further evaluation of aging management programs as recommended by the GALL report and identifies associated technical positions that are acceptable to the staff.

The GALL Report contains the staffs generic evaluation of the existing plant programs and documents the technical basis for determining where existing programs are adequate without modification and where existing programs should be augmented for the extended period of operation. The evaluation results documented in the GALL Report indicate that many of the existing programs are adequate to manage the aging effects for particular structures or components for license renewal without change. If an applicant commits to implementing these staff-approved aging management programs (AMPs), the time, effort, and resources needed to review an applicants LRA will be greatly reduced, thereby improving the efficiency and effectiveness of the license renewal review process.

The GALL Report identifies the structures and components that are with in the scope of license renewal and subject to an AMP. For each structure or component in a system, the GALL Report identifies the associated materials, environments, and aging effects to which the components are exposed, and the AMPs that are acceptable to the staff for managing the aging effects. The GALL Report also identifies those AMPs that require further evaluation.

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

4 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 applicants facility, the staff will accept the applicants 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 determines 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 on-site in an auditable form.

3.

OBJECTIVES The overall objective of the audit and review described in this plan is to evaluate compliance with 10 CFR 54.21(a)(3) such that for each identified SSC the applicant demonstrates that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB for the extended period of operation. The audit and review process ensures that for each structure and component that is within the scope of the project teams review the effects of aging will be adequately managed.

The audit and review procedure is described in Sections 5 and 6 of this plan. The plan objectives are:

For plant AMPs that the applicant claims are consistent with GALL AMPs, evaluate whether the plant AMPs contain the program elements of the referenced GALL AMP (for the seven program elements that are within the scope of review of the project team) and that the conditions at the plant are bounded by the conditions for which the GALL AMPs were evaluated.

For plant AMPs that the applicant claims are consistent with GALL AMPs with exceptions, evaluate whether 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, evaluate whether the applicant has documented an acceptable technical basis for each exception.

For plant AMPs that the applicant claims will be consistent with GALL AMPs after specified enhancements are implemented, evaluate whether 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, evaluate whether the applicant identified the enhancements as commitments in the UFSAR supplement or other docketed correspondence.

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

5 For AMRs that the applicant claims are consistent with the GALL Report, evaluate whether the plant AMRs are consistent with the criteria of the GALL.

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

4.

SUMMARY

OF INFORMATION PROVIDED IN THE LICENSE RENEWAL APPLICATION The MNGP 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 3, April 2001. Section 3 of the LRA provides the aging management review results for the structures and components identified by the applicant.

LRA Table 3.0-1 and Table 3.0-2 provide descriptions of the mechanical, civil, and electrical service environments, used in the AMRs to determine the 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 a Table 1 type. For example, in the reactor vessel, internals, and 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.

X Definition 1

Reactor Vessel, Internals, and Reactor Coolant System 2

Engineered Safety Features 3

Auxiliary Systems 4

Steam and Power Conversion Systems 5

Containments, 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 vessel, internals, and reactor coolant system (group 1), the AMR results for the reactor head vent system (subgroup

1) are presented in LRA Table 3.1.2-1, and the results for the reactor pressure vessel (subgroup

2) are presented in LRA Table 3.1.2-2. Under the engineered safety features (group 2), the automatic pressure relief system (subgroup 1) results are presented in Table 3.2.2-1 of the LRA, and the combustible gas control system (subgroup 2) is in Table 3.2.2-2 of the LRA.

6 In LRA Tables 3.1.1 through 3.6.1 (Table 1 types), the applicant provides a summary of the comparison of its AMR results to the GALL Report. These LRA tables are similar to Tables 1 through 6 of the GALL Report, Volume 1. The applicant added a "Discussion" column, which includes additional information that may be useful to the projects team. Also, the applicant added an "Item Number" column, which provides a means to cross-reference between an LRA Table 3.X.2-Y (Table 2 type) and an LRA Table 3.X.1 (Table 1 type).

The following are examples of information that might be contained within the Discussion 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 GALL Report assumptions; A discussion of how the line item is consistent with the corresponding line item in the GALL Report, when it may not be intuitively obvious; A discussion of how the line item differs from the corresponding line item in the GALL Report, when it may appear to be consistent.

LRA Table 2 types provide the detailed results of the AMRs for those SCs that are subject to an aging management review. There is a Table 2 for each subgroup within the six system/component groups. For example, the engineered safety features group contains tables specific to automatic pressure relief, combustible gas control, core spray, high pressure coolant injection, primary containment mechanical, reactor core isolation cooling, residual heat removal, and secondary containment systems All LRA Table 2s consist of the following nine columns.

Component Commodity. Column 1 identifies the component or commodity types that are subject to an AMR. The component or commodity types are listed in alphabetical order.

Intended Function. Column 2 identifies the license renewal intended functions for the listed component and commodities. Definitions and abbreviations of intended functions are listed in Table 2.1-1 in Section 2 of the LRA.

Material. Column 3 lists the materials of the component or commodity type being evaluated.

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

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

7 Aging Management Program. Column 6 lists the program(s) used to manage the aging effect.

NUREG-1801 Volume 2 Item. The applicant compared each combination of component type, material, environment, aging effect requiring management, and aging management program factors listed in LRA Table 2 to the GALL Report to identify consistencies. In Column 7, the applicant documents identified consistencies by noting the appropriate GALL Report item number. If there is no corresponding item number in the GALL Report for a particular combination of factors, column 7 is left blank.

Table 1 Item. The applicant compared each combination of component type, material, environment, aging effect requiring management, and aging management program that has an identified GALL Report item number and a Table 1 line item reference number.

Column 8 lists the corresponding line item from Table 1. If there is no corresponding item in the GALL Report, column 8 is left blank.

Notes. Column 9 contains notes that are used to describe the degree of consistency with the line items in the GALL Report. 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). The standard notes are shown in Table 2 of this plan. Notes that use numeric designators are specific to MNGP.

LRA Table 2 contains the aging management review results and indicates whether the results correspond to line items in the GALL Report. Correlations between a combination in LRA Table 2 and a combination in Volume 2 of the GALL Report are identified in column 7 of Table 2. 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, column 8 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. Many of the GALL Report evaluations recommend a plant-specific program. In these cases, the applicant considers its AMR evaluation to be consistent with the GALL Report, if an appropriate plant-specific AMP has been credited to manage aging.

5.

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

5.1 Aging Management Programs Table 1 of this plan summarizes the 10 program elements that comprise an aging management program. Of these 10 program elements, program elements 1 through 6, and program element 10 are within the project teams scope of review. The NRC Division of Inspection Program Management (DIPM) is responsible for reviewing program elements 7, 8, and 9, which will be addressed as part of the applicants quality assurance program. The results of the DIPM staffs

8 reviews will be documented in Section 3 of the safety evaluation report associated with the LRA safety review.

The project team will review the AMPs that the applicant claims are consistent with GALL AMPs, and compare the MNGP AMP program elements 1 through 6 and program element 10 to the corresponding AMP program elements in the GALL Report. The project team will evaluate whether each MNGP AMP contains the program elements of the referenced GALL AMP, and that the conditions at the plant are bounded by the conditions identified in the GALL AMP.

The project team will evaluate each of the MNGP AMPs that have an exception or an enhancement to an associated AMP in the GALL Report. The project team will identify the difference(s) between the MNGP AMP and the associated AMP in the GALL Report, and determine whether the MNGP AMP, as modified by the difference(s), will adequately manage the aging effects for which it is credited.

The project team will review one (1) MNGP AMP that is not included in the GALL Report (i.e.,

plant-specific AMP). In this case, the project team will review the AMP against the seven program elements that are within its scope of review. The project team will determine whether this AMP is adequate to manage the aging effects for which it is credited.

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 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 applicants evaluation to determine if it adequately addressed the issues for which the GALL Report recommends further evaluation.

5.3 UFSAR Supplement Review In accordance with the SRP-LR, the project team will review the applicants UFSAR supplement, to ensure (1) that the applicants programs and activities credited for aging management are summarized, and (2) that any commitments to enhance the applicants AMPs, in order to be consistent with the AMPs evaluated in the GALL Report, are documented.

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 applicants 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 evaluate whether they are acceptable for the stated purpose.

5.4 Documents Reviewed by the Project Team In performing its work, the project team will rely heavily on the LRA, the audit plan, the SRP-LR,

9 and the GALL Report. The project team will also examine the applicants precedent review documents, its AMP and AMR basis documents (catalogs of the documentation used by the applicant to develop or justify its AMPs and AMRs), and other applicant documents, including selected implementing procedures, to evaluate whether the applicants activities and programs will adequately manage the effects of aging on structures and components.

5.5 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.

5.6 Documentation Prepared by the Project Team The project team will prepare an audit plan, worksheets, work packages, requests for additional information (RAIs), an audit report, and safety evaluation report (SER) inputs. The project team will also prepare questions during site visits and will track the applicants responses to the questions.

5.6.1 Worksheets Each project team member will informally document the results of his or her work on a variety of worksheets. The use of the worksheets is described in Section 6 of this plan.

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

5.6.3 Work Packages After each on-site audit, the project team leader, in conjunction with the project manager, will assemble work packages for any work that the project 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 gathered by the project team.

5.6.4 Requests for Additional Information 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 project team leader will provide the response to the project team member who prepared the RAI. The project team member will review the response and determine if it resolves the issue addressed in the RAI.

10 The project team member will document the disposition of the RAI in the audit 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.

5.6.5 Audit Report The project team will document the results of its work in an audit report. The project team will prepare its report as described in Section 6.4.1 of this plan and the latest version of the RLEP-B Guidelines for Preparing Audit Reports.

5.6.6 Safety Evaluation Report Input The project team will prepare SER inputs that are based on the audit report, as described in Section 6.4.2 of this plan.

6.

PLANNING, AUDIT, AND DOCUMENTATION PROCEDURE This section of the audit 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 manager, the project team leader, and the applicant will establish the schedule for on-site visits. The project team leader prepares the schedule for the key milestones and activities, consistent with the overall schedule developed by the project manager. The key milestones and activities schedule for the AMP and AMR audit of the Monticello Nuclear Generating Plant license renewal application is provide in Appendix B of this audit plan.

6.1.2 Work assignments The project team leader should use the contracting process to identify the contractor personnel who will be members of the project team. The project team leader will approve all work assignments and may re-assign work as necessary.

The contractor will develop the assignment tables that identify which project team member will review each assigned AMP and AMR. Appendix A of this plan contains the project team membership. Appendix C contains the project team member assignments for the AMPs.

Appendix D of this plan contains the project team member assignments for the AMRs.

6.1.3 Training and Preparation.

The project team leader should hold a project team meeting to review the following information.

Each project team member should review the relevant sections of the following documents prior to the first on-site audit.

NUREG-1800, Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants, issued July 2001

11 NUREG-1801, Generic Aging Lessons Learned (GALL) Report, issued July 2001 Staff position letters concerning interim staff guidance for license renewal issues Monticello Nuclear Generating Plant License Renewal Application.

In preparation for the on-site audits, the project team members will review their assigned AMPs or AMRs and examine relevant safety evaluation reports, audit reports, and/or requests for additional information from prior staff LRA reviews. In addition, if feasible, the project team members should identify the applicants basis documents and implementing procedures that they plan to audit on-site. Any questions identified by the project team members during the pre-audit reviews may be transmitted to the applicant prior to the on-site audits.

The project team leader is the point of contact with the licensee. Project team members may work directly with the licensees staff to gather information and understand the information contained in the license renewal application. However, the project team leader is the only project team member who can make formal requests or agreements with the licensee.

The project team leader is the point of contact with the NRC technical staff. Project team members may work directly with the NRC technical staff to exchange technical information concerning the audit of the license renewal application. However, the project team leader is the only project team member who can make formal requests or agreements with the NRC technical staff.

The NRC Management Directives and the contract requirements will govern the project teams travel requirements, work hours, issuance of request for additional information, and control of licensee documents.

6.2 Aging Management Program Audits 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.

6.2.1 Scope of AMP Elements to be Audited 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 project teams scope of review includes elements 1 through 6 and element 10. The Division of Inspection Program Management is responsible for reviewing elements 7, 8, and 9, as part of its assessment of the applicants quality assurance program. The program elements audited or reviewed is the same for both AMPs that are consistent with the GALL Report and for plant-specific AMPs.

6.2.2 Plant AMPs That Are Consistent With the GALL Report The flowchart for the audit of AMPs that are consistent with the GALL report is presented in Figure 1 of this audit plan. The flowchart 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. In preparation for the audit, the project team members will review each of the AMPs

12 they have been assigned, identify the corresponding GALL AMPs, and determine the elements that will be audited. Then the project team members should identify the documents needed to perform the audit.

Once on site, the project team members should use the plant-specific basis document and implementing procedures to confirm that the AMP elements are consistent with the corresponding AMP elements in the GALL Report. In addition, the project team members should identify any exceptions to the AMP elements in the GALL Report. If an AMP element is inconsistent with the corresponding AMP element in the GALL Report, the project team members should determine whether the inconsistency is acceptable, develop a technical basis, and document their assessments.

The project team members should confirm the effectiveness of each AMP by reviewing industry and plant-specific operating experience. The project team members should consider the following industry guidance from NEI 95-10, Revision 3, when assessing operating experience.

Operating Experience - Aging Effects Requiring Management. A plant-specific operating experience review should assess the operating and maintenance history. A review of the prior five 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.

Operating Experience with Aging Management Programs. Plant-specific operating experience with existing programs should be considered. 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.

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 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 a previously identified aging effect.

Any questions resulting from the audit will be discussed with the applicant, and either resolved by the project team or turned over to the NRC technical staff for resolution. If it is necessary for the applicant to submit additional information to support the basis for accepting a program element, an exception, or a difference, the applicant may agree to voluntarily submit the required information as a supplement to the LRA.

6.2.4 Plant-specific AMPs The project team will review both of the plant-specific AMPs identified in Appendix B of the

13 MNGP LRA.

The flowchart for the review of plant-specific AMPs is presented in Figure 2 of this audit plan.

The flowchart shows the activities and decisions used by the project team to review a plant-specific AMP. In preparation for the on-site audit, the assigned project team member will review the plant-specific AMP, and identify documents needed to perform the review.

Once on site, the project team member should use the plant-specific basis document and implementing procedures to confirm that the seven program elements of the plant-specific AMP are consistent with the corresponding program elements in Section A.1.2.3 of the SRP-LR. The project team member should identify any exceptions to the program elements in Section A.1.2.3 of the SRP-LR. If a program element of the plant-specific AMP is inconsistent with the corresponding program element in Section A.1.2.3 of the SRP-LR, the project team member should determine whether the inconsistency is acceptable, develop a technical basis, and document the assessment.

The project team member should evaluate the effectiveness of the plant-specific AMP by reviewing industry and plant-specific operating. The project team member should consider the following industry guidance from NEI 95-10, Revision 3, when assessing operating experience.

Operating Experience - Aging Effects Requiring Management. A plant-specific operating experience review should assess the operating and maintenance history. A review of the prior five 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.

Operating Experience with Aging Management Programs. Plant-specific operating experience with existing programs should be considered. 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.

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 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 a previously identified aging effect.

Any questions resulting from the audit will be discussed with the applicant, and either resolved by the project team or turned over to the NRC technical staff for resolution. If it is necessary for the applicant to submit additional information to support the basis for accepting a program element, an exception, or a difference, the applicant may agree to voluntarily submit the required information as a supplement to the LRA.

14 6.3 Audit of Aging Management Review (AMR) Results There are two types of AMRs: those that the applicant claims are consistent with the GALL Report, and those that are plant-specific. The project team will review AMRs that are consistent with the AMRs in the GALL Report.

6.3.1 Scope of AMR to be Audited The NRC staff has split the responsibility for assessing the aging management review results in the license renewal application between the project team and the NRC technical staff. The project team will assess the AMRs that are consistent with the GALL report. Each AMR line item is coded with a letter which represents a standard note designation. The letter notes are described in Table 2 of this plan. The notes coded with A though E are classified as consistent with the GALL Report, and will be addressed by the project team in accordance with the guidance contained in this plan. Notes that use numeric designators are plant-specific and provide additional information to be considered during the staff assessment.

6.3.2 AMR Results That Are Consistent With the GALL Report The flowchart for the audit of AMRs that are consistent with the GALL report is presented in Figures 3-1 and 3-2 of this audit plan. The flowchart shows the activities and decisions used by the project team to review and audit each plant AMR that the applicant claims is consistent with the GALL Report. In preparation for the audit, the project team members will review each of the AMRs they have been assigned and identify the corresponding AMRs in the GALL Report.

The AMR review involves evaluating whether the applicant has satisfied the requirements of 10 CFR 54.21(a)(3). This requirement states that for each structure and component, within the scope of license renewal, the applicant demonstrates that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the current licensing basis of the plant for the extended period of operation. The project team should evaluate compliance by following the process shown in Figures 3-1 and 3-2. The process is summarized below:

Project team members should review each assigned AMR line and determine if the AMR is consistent with the GALL Report.

Note A indicates: The applicant identifies a plant-specific AMP. 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 extended period of operation, 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, prepare a question to the applicant, in order to obtain clarification.

Note B indicates that the identified AMP takes some exceptions to the GALL Report. The project team should evaluate the AMP exceptions and document its assessment.

Notes C and D identify components that are not consistent with the GALL report. The

15 project team should evaluate the acceptability of the component type for the material, environment, and aging effect. If Note D applies the project team should also evaluate the acceptability of the AMP exceptions and document the results of its assessment.

Note E identifies an AMP that is inconsistent with the AMP identified in the GALL report.

The project team should evaluate the AMP to determine if the scope of the alternate AMP envelopes the AMR line item and satisfies 10 CFR 54.21(a)(3). The project team should document the results of its assessment.

The project team should evaluate the corresponding LRA Table 3.X.1entry that is referenced in LRA Table 3.X.2.Y. If applicable, the project team will determine whether the applicants 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, and document its assessment.

The project team members will prepare questions for the applicant whenever additional information or clarifications are needed. The project team will evaluate the applicants responses. When a response does not resolve the issue, the project team should prepare additional questions. If it is necessary for the applicant to submit additional information to resolve an issue, the applicant may submit the information as a supplement to the LRA or the NRC may issue an RAI to obtain the information. The project team leader should be consulted if docketed information is needed.

6.4 Audit Documentation As noted in Section 5.6 of this plan, the project team will prepare an audit plan, worksheets, work packages, requests for additional information, an audit report, and a SER input. This section of the plan addresses the preparation of the audit report and the SER input.

6.4.1 Audit 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:

Cover page Table of Contents Section 1 Introduction and General Information o Section 1.1 Introduction o Section 1.2

Background

o Section 1.3 Summary of Information in the License Renewal Application o Section 1.4 Audit Scope o Section 1.5 Audit Process o Section 1.6 Exit Meeting Section 2 Aging Management Programs (AMP)

Section 3 Aging Management Review (AMR) Results Abbreviations and Acronyms Project Team and Applicant Personnel Elements of an Aging Management Program for License Renewal

16 Disposition of Requests for Additional Information, LRA Supplements, and Open Items List of Documents Reviewed List of Commitments 6.4.2 Safety Evaluation Report Input 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 will collect, assemble, and prepare the complete SER input.

In general, the data and information needed to prepare the SER input should be available in the project teams audit report and the project team members worksheets. The project team should prepare the following:

Assessments for each AMP that was determined to be consistent with the GALL Report Assessments for each AMP that was determined to be consistent with the GALL Report, which has exceptions or enhancements.

Assessment of the operating experience associated with each AMP Assessment of the FSAR supplement associated with each AMP Assessment of AMR results that are consistent with the GALL Report Conclusions of the acceptability of AMPs and AMR results The project teams SER input will provide information for the following SER sections. The project team will format its SER inputs to correspond to the following SER section numbers (3. through 3.X.3). The SER section numbers are not a continuation of the numbering convention used throughout this audit plan.

3. Aging Management Review Results 3.0.

Applicants Use of the Generic Aging Lessons Learned Report 3.0.1. Format of the LRA 3.0.2. Staffs 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 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 3.0.4. Quality Assurance Program Attributes Integral to Aging Management Programs 3.X.1 Aging Management of ______

1 The LRA AMR results are broken down into six sections and address the following system/structure

17 3.X.1. Summary of Technical Information in the Application 3.X.2. Staff Evaluation 3.X.2.1.

AMR Results that are Consistent with the GALL Report 3.X.2.2.

AMR Results 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 The project team will provide a discussion of its assessment of operating experience for each AMP that it evaluated. The project team will provide a discussion of its assessment of the FSAR supplement for each AMP that it evaluated.

The project team will document the applicants amendments and supplements to the LRA by summarizing the issue that the amendment or supplement resolved and the project teams assessment and basis for resolving the issue. The project team will document the date and ADAMS accession number for each amendment or supplement.

The project team will document any requests for additional information (RAI) issued by the team, summarize the RAI, and identify the RAI number. The project team will document the applicants response to the RAI by summarizing the response and the project teams assessment and basis for resolving the RAI. The project team will document the date and ADAMS accession number for each RAI response. The project team will identify unresolved RAIs as open items.

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 the basis for concluding that the UFSAR supplement (Appendix A of the LRA) is acceptable. This SER input documents that the AMP is consistent with the GALL Report.

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 extended period of 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.

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

For AMR evaluations that are consistent with the GALL Report, and for which no further evaluation is recommended, the SER input should include the following:

Identify the LRA section reviewed 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.

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

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

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

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.

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

A finding that the applicant identified the applicable aging effects A finding that the applicant defined the appropriate combination of materials and environments A finding that the applicant specified acceptable AMPs 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 extended period of operation, and that 10 CFR 54.21(a)(3) has been satisfied.

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

The LRA section containing the applicants further evaluations of AMRs for which further evaluation is required.

A list of the aging effects for which the further evaluations apply.

For the applicants further evaluations, provide a summary of the basis for concluding that it satisfied the criteria of Section 3.X.3.2 of the SRP-LR (X=1, 2, 3, 4, 5, or 6 as applicable).

A statement that the staff audited the applicants further evaluations against the criteria contained in Section 3.X.3.2 of the SRP-LR.

A statement that the audit report contains additional information. Also identify the issue date and the ADAMS accession number for the audit report.

6.5 Documents Reviewed and Document Retention The project team should document in Attachment 5 to the audit report any procedures, design basis documents, or engineering reports used to formulate the basis for its assessment of AMPs or AMRs. After the audit report is issued, the project team members should submit all worksheets generated during the audit to the project team leader.

After the renewed license is issued, the project team members should discard the documents collected or generated during the creation of the audit report and SER inputs. Examples of these documents are audit worksheets, questions, answers, issue tracking lists, and personal notes. Documents that are on the docket or are publicly available may be retained.

19 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 mitigating ive 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 extended period of 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 extended period of operation.

20 TABLE 2 STANDARD NOTES FOR LICENSE RENEWAL APPLICATION TABLES 3.X.2-Y 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.

21

22

23

24

25 APPENDIX A PROJECT TEAM MEMBERS Organization Name Function NRC/NRR/DRIP/RLEP-B N. Dudley Team leader NRC/NRR/DRIP/RLEP-B P. Wen Backup team leader NRC/NRC/DRIP/RLEP-B M. Lintz Reviewer - Systems NRC/NRC/DE/EEIB-B J. Knox Electrical ATL International B. Messitt Contractor lead, Reviewer -

Systems ATL International S. Traiforos Reviewer - Structures ATL International C. Lapp Reviewer - Mechanical ATL International W. Jackson Reviewer - Materials

26 APPENDIX B RLEP-B SCHEDULE FOR LRA SAFETY REVIEW Plant: Monticello Nuclear Generating Plant Project Team Leader: Noel Dudley Backup Project Team Leader: Peter Wen Project Manager: Daniel Merzke Contractor: ATL Activity/Milestone Scheduled Completion 2005 1

Receive license renewal application 03/31 2

Make review assignments (project manager) 05/15 3

Train project team 05/18 4

Hold project team planning (kick-off) meeting 05/19 5

Issue audit plan to project manager 05/18 6

Conduct first site visit (AMP reviews) 06/13-6/17 7

Draft AMP audit report input (team members) 06/24 8

Draft SER input for AMP reviews (team members) 08/22 9

Conduct in-office AMR reviews 06/27-07/08 10 Conduct second site visit (resolve AMP and AMR questions) 07/11-07/15 11 Draft AMR audit report input (team members )

08/05 12 Draft SER input for AMR reviews (team members )

08/22 13 Conduct third site visit (resolve outstanding issues and questions) 07/25-07/29 14 Conduct public exit meeting 08/05 15 Conduct writing session for audit report and SER input N/A 16 Cutoff for providing RAIs to project manger 08/12 17 Final audit report (AMP and AMR sections) 09/21 18 Final input for draft SER with open items 09/21

C-1 APPENDIX C AGING MANAGEMENT PROGRAM ASSIGNMENTS MNGP LRA AMP Number GALL Report AMP Number Aging Management Program Consistent W/ GALL?

Assigned Auditor B2.1.1 XI.S4 10 CFR Part 50, Appendix J Yes Exception P. Wen B2.1.2 XI.M01 ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD Program Yes Exception W. Jackson B2.1.3 XI.S3 ASME Section XI, Subsection IWF Yes Enhanced W. Jackson B2.1.4 XI.M18 Bolting Integrity Yes Enhanced NRC/NRR/DE B2.1.5 XI.M34 Buried Piping & Tanks Inspection Yes Enhanced C. Lapp B2.1.6 Plant-Spec.

Bus Duct Inspection Program No J. Knox B2.1.7 XI.M06 BWR Control Rod Drive Return Line Nozzle Yes Exception P. Wen B2.1.8 XI.M05 BWR Feedwater Nozzle Yes Enhanced P. Wen B2.1.9 XI.M08 BWR Penetrations Yes Exception W. Jackson B2.1.10 XI.M07 BWR Stress Corrosion Cracking Yes Exception W. Jackson B2.1.11 XI.M04 BWR Vessel ID Attachment Weld Yes Exception W. Jackson B2.1.12 XI.M09 BWR Vessel Internals Yes Exception Enhanced W. Jackson B2.1.13 XI.M21 Closed-Cycle Cooling Water Yes Exception Enhanced M. Lintz B2.1.14 XI.M24 Compressed Air Monitoring Yes Exception Enhanced M. Lintz

C-2 MNGP LRA AMP Number GALL Report AMP Number Aging Management Program Consistent W/ GALL?

Assigned Auditor B2.1.15 XI.E01 Electrical Cables & Connectors Not Subject to 10 CFR 50.49 Environmental Qualification (EQ)

Requirements Yes Consistent J. Knox B2.1.16 XI.E02 Electrical Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Used In Instrumentation Circuits Yes Exception J. Knox B2.1.17 XI.M26 Fire Protection Program Yes Exception Enhanced C. Lapp B2.1.18 XI.M27 Fire Water System Program Yes Enhanced C. Lapp B2.1.19 XI.M17 Flow-Accelerated Corrosion Yes Consistent P. Wen B2.1.20 XI.M30 Fuel Oil Chemistry Yes Exception Enhanced B. Messitt B2.1.21 XI.E03 Inaccessible Medium Voltage (2kV to 34.5kV)

Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Yes Consistent J. Knox B2.1.22 XI.M23 Inspection of Overhead Heavy Load and Light Load (Related to Refueling) Handling Systems Yes Exception Enhanced B. Messitt B2.1.23 XI.M32 One-Time Inspection Program Yes Consistent B. Messitt B2.1.24 XI.M20 Open-Cycle Cooling Water System Program Yes Consistent M. Lintz B2.1.25 XI.M02 Plant Chemistry Program Yes Exception C. Lapp B2.1.26 XI.S01 Primary Containment In-Service Inspection Program Yes Consistent S. Traiforos B2.1.27 XI.S8 Protective Coating Monitoring and Maintenance Program Yes Enhanced B. Messitt B2.1.28 XI.M03 Reactor Head Closure Studs Yes Consistent M. Lintz

C-3 MNGP LRA AMP Number GALL Report AMP Number Aging Management Program Consistent W/ GALL?

Assigned Auditor B2.1.29 XI.M31 Reactor Vessel Surveillance Yes Enhanced NRD/NRR/DE B2.1.30 XI.M33 Selective Leaching Yes Exception S. Traiforos B2.1.31 XI.S05 XI.S06 XI.S07 Structures Monitoring Program Yes Enhanced S. Traiforos B2.1.32 Plant-Spec.

Systems Condition Monitoring Program No Enhanced NRC/NRR/DE B2.1.33 XI.M13 Thermal Aging and Neutron Irradiation Embrittlement of CASS Program Yes Consistent P. Wen B3.2 X.M01 Metal Fatigue of Reactor Coolant Pressure Boundary TLAA Yes Enhanced W. Jackson B3.1 X.E01 Environmental Qualification (EQ) Program -

TLAA Yes Consistent J. Knox TIME-LIMITED AGING ANALYSES 4.4 TLAA Irradiation Assisted Stress Corrosion Cracking (IASCC)

M. Lintz 4.7 TLAA Environmental Qualification of Electrical Equipment (EQ)

J. Knox

D-1 APPENDIX D AGING MANAGEMENT REVIEW ASSIGNMENTS Aging Management Reviews Reviewer 3.1 Aging Management of Reactor Vessel, Internals, and Reactor Coolant System W. Jackson 3.2 Aging Management of Engineered Safety Features P. Wen/C.

Lapp 3.3 Aging Management of Auxiliary Systems B. Messitt 3.4 Aging Management of Steam and Power Conversion Systems M. Lintz 3.5 Aging Management of Containment, Structures, and Component Supports S. Traiforos 3.6 Aging Management of Electrical and Instrumentation and Controls J. Knox

E-1 APPENDIX E ACRONYMS AND ABBREVIATIONS AC Alternating Current ACI American Concrete Institute ADAMS Agency wide documents access and management system ADS Automatic Depressurization System AERM Aging Effects Requiring Management AISC American Institute of Steel Construction AMP Aging Management Program AMR Aging Management Review ANSI American National Standards Institute API American Petroleum Institute APRM Average Power Range Monitor ARM Area Radiation Monitor ASCE American Society of Civil Engineers ASME American Society of Mechanical Engineers ASTM American Society for Testing and Materials ATL Advanced Technologies and Laboratories International, Inc.

ATWS Anticipated Transient Without Scram ATWS-RPT Anticipated Transient Without Scram-Recirculation Pump Trip BTP Branch Technical Position BWR Boiling Water Reactor BWROG Boiling Water Reactor Owners Group BWRVIP Boiling Water Reactor Vessel and Internals Program CAP Corrective Action Program CCW Component Cooling Water/Closed Cooling Water CDD Condensate Deep Bed Demineralizer DE NRC/NRR/Division of Engineering CFD Condensate Filter Demineralizer CHRS Containment Heat Removal System DIPM NRC/NRR/Division of Inspection Program Management CLB Current Licensing Basis CRD Control Rod Drive CRDH Control Rod Drive Housing CRDM Control Rod Drive Mechanism CS Core Spray/Carbon Steel CSCS Core Standby Cooling System CST Condensate Storage Tank CW Circulating Water CUF Cumulative Usage Factor DBA Design Basis Accident DBE Design Basis Earthquake DC Direct Current DG Diesel Generator DGB Diesel Generator Building D/P Differential Pressure

E-2 DSCSS Drywell and Suppression Chamber Spray System DWT Demineralized Water Tank EAF Environmentally Assisted Fatigue E&RC Environmental and Radiation Control ECC Emergency Core Cooling ECCS Emergency Core Cooling System EFPY Effective Full Power Years EHC Electro-Hydraulic Control EPRI Electric Power Research Institute EPU Extended Power Uprate EQ Environmental Qualification ESF Engineered Safety Features FAC Flow Accelerated Corrosion FHA Fire Hazards Analysis FO Fuel Oil FOST Fuel Oil Storage Tank FP Fire Protection FPP Fire Protection Program FSAR Final Safety Analysis Report FW Feedwater GALL Generic Aging Lessons Learned (the GALL Report is NUREG-1801)

GDC General Design Criteria GE General Electric GL Generic Letter GSI Generic Safety Issue HELB High Energy Line Break HEPA High Efficiency Particulate Air HPCI High Pressure Coolant Injection HPCS High Pressure Core Spray (not an applicable system for MGNP)

HVAC Heating, Ventilating, and Air Conditioning IA Instrument Air IASCC Irradiation Assisted Stress Corrosion Cracking I&C Instrumentation and Control ID Inside Diameter IE Inspection and Enforcement (former NRC Office of Inspection and Enforcement)

IEEE Institute Of Electrical And Electronic Engineers IGSCC Intergranular Stress Corrosion Cracking ILRT Integrated Leak Rate Test (Containment Type A Test)

IN Information Notice INPO Institute Of Nuclear Power Operations IPA Integrated Plant Assessment (10 CFR 54.21(a))

ISG Interim (NRC) Staff Guidance ISI In-Service Inspection KV Kilovolt

E-3 LBB Leak-Before-Break LER Licensee Event Report LOCA Loss of Coolant Accident LPCI Low Pressure Coolant Injection LPCS Low Pressure Core Spray LR License Renewal LRA License Renewal Application MIC Microbiologically Induced Corrosion MNGP Monticello Nuclear Generating Plant MS Main Steam MSLB Main Steam Line Break MSR Moisture Separator Reheater MWTS Makeup Water Treatment System NDE Nondestructive Examination NDTT Nil-Ductility Transition Temperature NEI Nuclear Energy Institute NFPA National Fire Protection Association NMC Nuclear Management Company NPS Nominal Pipe Size NRC Nuclear Regulatory Commission NRR NRC/Office of Nuclear Reactor Regulation NSSS Nuclear Steam Supply System NUREG Designation of publications prepared by the NRC staff PASS Post-Accident Sampling System PCS Primary Containment Structure PFM Probabilistic Fracture Mechanics pH Concentration of Hydrogen Ions PM Preventive Maintenance PNS Pneumatic Nitrogen System PORV Power-Operated Relief Valve P-T Pressure-Temperature PTS Pressurized Thermal Shock PVC Polyvinyl Chloride PWS Potable Water System QA Quality Assurance RAI Request for Additional Information RBCCW Reactor Building Closed Cooling Water RCIC Reactor Core Isolation Cooling RCPB Reactor Coolant Pressure Boundary RFP Reactor Feedwater Pump RG Regulatory Guide RHR Residual Heat Removal RLEP-B NRC/NRR/License Renewal and Environmental Impacts Program/Section B RMS Radiation Monitoring System RPV Reactor Pressure Vessel

E-4 RTNDT Reference Temperature, Nil-Ductility Transition RTNDT(U)

Reference Temperature, Nil-Ductility Transition (Unirradiated)

RVI Reactor Vessel Internals RWCU Reactor Water Cleanup System RXS Reactor Building Sampling System SA Service Air SAT Startup Auxiliary Transformer SBO Station Blackout SC Structure/Component (10 CFR 54.21(a)(1)), also Suppression Chamber SCC Stress Corrosion Cracking SCW Screen Wash Water SDV Scram Discharge Volume SER Safety Evaluation Report SFP Spent Fuel Pool SGTS Standby Gas Treatment System SI Safety Injection SLC Standby Liquid Control SR Safety Related SRP Standard Review Plan SRP-LR Standard Review Plan for License Renewal SRV Safety Relief Valve SS Stainless Steel SSC Systems, Structures, and Components (10CFR 54.4(a))

SW Service Water TAC Technical Assignment Control (internal NRC work management tool)

TB Turbine Building TBCCW Turbine Building Closed Cooling Water TGSCC Trans-Granular Stress Corrosion Cracking TLAA Time-Limited Aging Analysis UAT Unit Auxiliary Transformer UFSAR Updated Final Safety Analysis Report USE Upper Shelf Energy UUSE Unirradiated Upper Shelf Energy UT Ultrasonic Test VAC Volts alternating current VDC Volts direct current