ML062480275

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Email: (PA) Pdf Version of Audit Plan
ML062480275
Person / Time
Site: Vermont Yankee Entergy icon.png
Issue date: 04/11/2006
From: Johnny Eads
NRC/NRR/ADRO/DLR/RLRB
To: Faison C, Hamer M, Hoffman J, Gary Young
Entergy Corp
References
%dam200611, DR-03-05-026
Download: ML062480275 (98)
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Audit and Review Plan for Plant Aging Management Programs and Reviews Vermont Yankee Nuclear Power Station Docket No.: 50-271 April 11, 2006 Revision 0 Prepared by Information Systems Laboratories, Inc.

11140 Rockville Pike Rockville, MD 20852 Contract No. DR-03-05-026 Prepared for License Renewal Branch C 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. O bjectives .............................................................. 4
4. Summary of Information Provided in the License Renewal Application ................ 6 4.1 Aging Management Review Results .................................... 6 4.2 Time-Limited Aging Analyses ...................................... 8
5. Overview of Audit, Review, and Documentation Procedure ....................... 11 5.1 Aging Management Programs ....................................... 11 5.2 Aging Management Reviews ...................................... 11 5.3 Time-Limited Aging Analyses ........................................ 12 5.4 NRC-Approved Precedents .......................................... 13 5.5 UFSAR Supplement Review ......................................... 13 5.6 Documents Reviewed by the Project Team ............................. 14 5.7 Public Exit Meeting ............................................ 14 5.8 Documentation Prepared by the Project Team ........................... 14 5.8.1 Audit and Review Plan ...................................... 14 5.8.2 Worksheets ................................ 14 5.8.3 Q uestions ................................................ 14 5.8.4 W ork Packages ........................................... 15 5.8.5 Request for Additional Information ............................. 15 5.8.6 Audit and Review Report .................................... 15 5.8.7 Safety Evaluation Report Input ................................ 15
6. Planning, Audit, Review, and Documentation Procedure .......................... 15 6.1 Planning Activities ................................................ 16 6.1.1 Schedule for Key Milestones and Activities ...................... 16 6.1.2 W ork Assignments ........ ................................ 16 6.1.3 Training and Preparation .................................... 16 6.2 Aging Management Program Audits and Reviews ....................... 17 6.2.1 Types of AMPs ............................................ 17 6.2.2 Scope of AMP Program Elements to be Audited And Reviewed ...... 17 6.2.3 Plant AMPs that are Consistent with the GALL Report .............. 17 6.2.4 Plant-Specific AMPs ........................................ 19 6.3 AMR Audits and Reviews ............................................ 21 6.3.1 Plant AMRs that are Consistent with the GALL Report ............. 21 6.3.2 AMRs Based on NRC-Approved Precedents ..................... 24 6.4 Time-Limited Aging Analyses (TLAA) Audits and Reviews .................. 25 6.4.1 Identify Generic TLAA Issues ................................. 25 6.4.2 Reactor Vessel Neutron Embrittlement Analyses .................. 27 6.4.3 Metal Fatigue Analyses ..................................... 30 6.4.4 Environmental Qualification Analyses for Electrical Components ...... 32 ii

6.4.5 Concrete Containment Tendon Prestress Analysis ................ 34 6.4.6 Containment Liner Plate, Metal Containment, and Penetrations Fatigue Analyses ............................................ 36 6.4.7 Other Plant-Specific TLAAs ................................ 38 6.5 Audit and Safety Review Documentation ............................... 40 6.4.1 Audit and Review Report .................................... 40 6.4.2 Safety Evaluation Report Input ................................ 43 6.5 Documents Reviewed and Document Retention ....................... 48 Appendix A Project Team Members ........................................... A-1 Appendix B RLRC Schedule for 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 Analyses 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-1 Appendix H Aging Management Review Worksheets ............................. H-1 Appendix I Abbreviations and Acronyms ........................................ I-1 Tables Table 1. Aging Management Program Element Descriptions ......................... 49 Table 2. Notes for License Renewal Application Tables 3.X.2-Y ...................... 50 Figures Figure 1. Audit of AMPs That Are Consistent With the GALL Report .................... 51 Figure 2. Audit of Plant-Specific AMPs ............................... .......... 52 Figure 3. Review of AMRs That Are Consistent With the GALL Report ................. 53 Figure 4. Review of AMRs Using NRC-Approved Precedents ........................ 54 Figure 5. Review of TLAAs and Exemptions (from NEI 95-10, Revision 6) .............. 55 iii

Audit and Review Plan for Plant Aging Management Programs and Reviews Vermont Yankee Nuclear Power Stations

1. Introduction By letter dated January 27, 2006 (Agencywide Documents Access and Management System

[ADAMS] Accession Number ML060300082), Entergy Nuclear Vermont Yankee, LLC (Entergy VY), the applicant, submitted to the U.S. Nuclear Regulatory Commission (NRC) its application for renewal of Operating License DPR-28 for Vermont Yankee Nuclear Power Station (VYNPS)

(ML060300085). The applicant requested renewal of its operating license for an additional 20 years beyond the 40-year current license term.

In support of the staffs safety review of the license renewal application (LRA) for VYNPS, the Division of License Renewal (DLR), License Renewal Branch C (RLRC), will lead a project team that will audit and review aging management reviews (AMRs), aging management programs (AMPs), and time-limited aging analyses (TLAAs) developed by the applicant to support its LRA for VYNPS. The project team will include NRC staff and contractor personnel provided by Information Systems Laboratories, Inc. (ISL), RLRC's technical contractor. Appendix A, "Project Team Members," lists the project team members. This document is the RLRC plan for auditing and reviewing of assigned aging management reviews, aging management programs, and time-limited aging analysis for VYNPS.

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

"Requirements for Renewal of Operating Licenses for Nuclear Power Plants;" the guidance provided in Revision 1 of NUREG-1 800, "Standard Review Plan for Review of License Renewal Application for Nuclear Power Plants" (SRP-LR); the guidance provided in Revision I of NUREG-1801, "Generic Aging Lessons Learned (GALL) Report," and this audit and review plan. In the following sections of this document, references to NUREG-1800 and NUREG-1801 will be to the Revision 1 versions of these documents. For the scope of work defined in this audit and review plan, the project team will determine 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 VYNPS current licensing basis (CLB) for the period of extended operation.

The project team will perform its work at NRC Headquarters, Rockville, Maryland; at ISL's offices in Rockville, Maryland; and at the VYNPS site near Brattleboro, Vermont. The project team will perform its work in accordance with the schedule shown in Appendix B, "RLRC Schedule for LRA Safety Review." The project team will conduct a public exit meeting at the applicant's offices in Brattleboro, Vermont, after it completes its on-site work.

This plan includes the following information:

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

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

Summary of Information Provided in License Renewal Application.

Description of the information contained in the license renewal application for VYNPS that is applicable to this plan.

Overview of the Audit, Review, and Documentation Procedure. Summary of the process that the project team will follow to conduct its audit and review of the VYNPS LRA.

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 VYNPS LRA information that is within its scope of review, and to document the results of its work.

Appendices. Supporting information. The project team members are shown in Appendix A and the schedule is shown in Appendix B. The project team's work assignments are shown in Appendices C, D and E. Appendices F, G and H are the worksheets that the individual project team members use to document the results of their audit and review audit work. The application of these worksheets is discussed in Section 6 of this audit and review plan. Appendix I is a list of the abbreviations and acronyms used in this audit and review plan.

2. Background

In 10 CFR 54.4, the scope of license renewal is defined as those systems, structures 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.

License renewal also requires the identification and updating of the TLAAs. During the design phase for a plant, certain assumptions are made about the length of time the plant can operate.

These assumptions are incorporated into design calculations for several of the plant's SSCs. In accordance with 10 CFR 54.21 (c)(1)(i), (ii), and (iii), the applicant must either (i) show that these calculations will remain valid for the period of extended operation, (ii) project the analyses to the end of the period of extended operation, or (iii) demonstrate that the effects of aging on these SSCs can be adequately managed for the period of extended operation.

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In addition, 10 CFR 54.21(d) requires that the applicant submit a supplement (docketed letter submitted under oath and affirmation) 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 and the evaluation of time-limited aging analyses for 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 credited for managing aging of most of the SCs used by 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 period of extended operation.

If an applicant commits to implementing these staff-approved AMPs, the time, effort, and resources used 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) SSCs, (2) component materials, (3) environments to which the components are exposed, (4) the aging effects/aging mechanisms associated with the materials and environments, (5) AMPs that are credited with managing 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 NRC-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 determines that the applicant established that the approvals set forth in the GALL Report apply to its programs.

If an applicant takes credit for a GALL Report program, it is incumbent on the applicant to ensure that its plant program addresses all ten program elements of the referenced GALL Report program. These elements are described in the SRP-LR, Appendix A.1, "Aging Management Review- Generic (Branch Technical Position RLSB-1)." In addition, the conditions at the plant must be bounded by the conditions for which the GALL Report program was evaluated. The applicant must certify in its LRA that it completed the appropriate verifications and that those verifications are documented and retained by the applicant in an auditable form.

The SRP-LR also provides staff guidance for reviewing time-limited aging analyses. 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:

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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 licensee in making a safety determination;
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); and
6. Are contained or incorporated by reference in the CLB.

Finally, the applicant must demonstrated 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 audit and review plan is to determine compliance with 10 CFR 54.21 (a)(3) and 10 CFR 54.21(c)(1). 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 VYNPS is described in Sections 5 and 6 of this audit and review plan. It is intended to accomplish the following objectives:

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

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

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For VYNPS AMPs that the applicant claims will be consistent with GALL Report AMPs after specified enhancements are implemented, determine that the plant AMPs, with the enhancements, will be consistent with the referenced GALL Report AMPs. In addition, determine that the applicant identified the enhancements as commitments in the Updated Final Safety Analysis Report (UFSAR) or other docketed correspondence.

For plant-specific VYNPS AMPs determine that these AMPs are acceptable on the basis of a technical review.

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 an explicitly assumed 40-year plant life (for example, aspects of the reactor vessel design).

Pursuant to 10 CFR 54.21(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 plant's operating license. As indicated in 10 CFR 54.30, the adequacy of the plant's CLB, which includes TLAAs, is not an area within the scope of the license renewal review. Any question regarding the adequacy 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.

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4. Summary of Information Provided in the License Renewal Application 4.1 Aging Management Review Results The VYNPS LRA closely follows the standard LRA format presented in Revision 6 of Nuclear Energy Institute (NEI) 95-10, "Industry Guidelines for Implementing the Requirements of 10 CFR Part 54 - The License Renewal Rule." Section 3 of the VYNPS LRA provides the results of the aging management review for structures and components that the applicant identified as being subject to aging management review. Section 4 VYNPS LRA addressed time-limited aging analyses.

VYNPS LRA Table 3.0-1, Table 3.0-2, and Table 3.0-3 provide descriptions of the subject(s) for these table(s) - 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 I 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 VYNPS LRA Section 3, this is Table 3.1.1, and in the engineered safety features subsection of VYNPS 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.

X Definition 1 Reactor Vessel, Internals and Reactor Coolant System 2 Engineered Safety Features 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, the AMR results for the reactor vessel are presented in VYNPS LRA Table 3.1.2-1, and the results for the reactor vessel internals are presented in VYNPS LRA Table 3.1.2-2. In the engineered safety features, the residual heat removal system results are presented in Table 3.2.2-1 of the VYNPS LRA, and the core spray system is in Table 3.2.2-2 of the VYNPS LRA. For ease of discussion, these table types will hereafter be referred to as "Table 2." These tables present the results of the AMRs.

VYNPS LRA Tables 3.1.1 through 3.6.1 (Table 1 types) provide a summary comparison of how.

the VYNPS AMR results align with Tables 1 through 6 of the GALL Report, Volume 1. These VYNPS LRA tables are bssentially the same as Tables 1 through 6 of the GALL Report, 6

Volume 1, except that the "Type" column has been replaced by an "Item Number" column, the GALL Volume 2 Item Number column has been deleted, and a "Discussion" column has been added. The "Item Number" column provides a means to cross-reference between VYNPS LRA Table 3.X.2-Y (Table 2 type) and VYNPS LRA Table 3.X.1 (Table 1 type). The "Discussion" column includes further information. The following are examples of information that might be contained within the "Discussion" column:

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

& The name of a plant-specific program being used 0 Exceptions to the GALL Report recommendations 0 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 0 A discussion of how the line item differs from the corresponding line item in the GALL Report, when it may appear to be consistent.

VYNPS 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 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 of the VYNPS LRA consists of the following nine columns.

-Component Type. Column 1 identifies the component types that are subject to an AMR. The component types are listed in alphabetical order. In the structural tables, component types are sub-grouped by material.

Intended Function. Column 2 identifies the license renewal intended functions for the listed component types. Definitions and abbreviations of intended functions are listed in Table 2.0-1 in Section 2 of the VYNPS LRA.

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 and external service environments are indicated. A description of these environments is providedin VYNPS LRA Table 3.0-1, Table 3.0-2, and Table 3.0-3 for mechanical, structural, and electrical components, respectively.

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

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

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GALL Report (Vol. 2) Item. Each combination of the following factors listed in LRA Table 2 is compared to the GALL Report to identify consistencies:

component type, material, environment, aging effect requiring management, and aging management program. Column 7 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.

LRA Table I Item. Each combination of the following that has an identified GALL Report item number also has a Table 1 line item reference number:

component type, material, environment, aging effect requiring management, and aging .management program. Column 8 lists the corresponding line item from Table 1. If there is no corresponding item in the GALL Report (Volume 1),

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.

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

  • Technical Specifications
  • docketed licensing correspondence
  • NRC safety evaluation reports
  • BWRVIP documents In Section 4.1, the VYNPS LRA states that as required by 10 CFR 54.21 (c)(1), an evaluation of VYNPS-specific time-limited aging analyses must be performed to demonstrate that:

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

In the VYNPS LRA, the applicant summarized the results of the above evaluations in Table 4.1-1. These evaluations are discussed in subsequent sections of VYNPS LRA Section 4.

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Following the section identifying the TLAAs, the VYNPS LRA next includes a section identifying any exemptions. 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 VYNPS performed this by reviewing VYNPS docketed correspondence which identified VYNPS exemptions. The results of this review determined that no VYNPS exemptions depend on time-limited aging analyses.

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

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

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

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

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

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

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

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

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

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

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

OR Aging effect managed 10 CFR 54.21(c)(1)(iii) 9

TLAA Description Resolution Option Section Environmental Qualification Analyses Aging effect managed 4.4 for Electrical Components 10 CFR 54.21 (c)(1)(iii)

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

Fatigue of safety relief valve (SRV) Analysis remains valid 4.6.2 discharge piping 10 CFR 54.21 (c)(1)(i)

AND Analysis projected 10 CFR 54.21(c)(1)(ii)

Fatigue of other torus-attached piping Analysis projected 4.6.3 10 CFR 54.21 (c)(1)(ii)

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

TLAA in BWRVIPs 4.7.2 BWRVIP-05, RPV circumferential Updated by BWRVIP-74. See 4.7.2.1 welds analysis BWRVIP-74 entry.

BWRVIP-25, core plate rim holddown Analysis projected 4.7.2.2 bolts loss of preload analysis 10 CFR 54.21 (c)(1)(ii)

BWRVIP-38, shroud support fatigue Analysis remains valid 4.7.2.3 analysis 10 CFR 54.21 (c)(1)(i)

BWRVIP-47, lower plenum fatigue Analysis remains valid 4.7.2.4 analysis 10 CFR 54.21 (c)(1)(i)

BWRVIP-48, vessel ID attachment Analysis remains valid 4.7.2.5 welds fatigue analysis 10 CFR 54.21 (c)(1)(i)

BWRVIP-49, instrument penetrations Analysis projected 4.7.2.6 fatigue analysis 10 CFR 54.21 (c)(1)(ii)

BWRVIP-74, reactor vessel 4.7.2.7 P/T curves analysis Addressed in Section 4.2.2 Fatigue analysis Addressed in Section 4.3.1 CVUSE analysis Addressed in Section 4.2.3 Circ/Axial welds analysis Addressed in Sections 4.2.5 and 4.2.6 10

TLAA Description Resolution Option Section BWRVIP-76, core shroud Analysis remains valid 4.7.2.8 10 CFR 54.21 (c)(1)(i)

5. Overview of Audit, Review, and Documentation Procedure The project team will follow the process specified in Section 6 of this audit and review plan to perform its audits and reviews and to document the results of its work. The process is summarized below.

5.1 Aging Management Programs Table 1 of this audit and review plan summarizes the ten program elements that comprise an aging management program. For the VYNPS AMPs for which the applicant claimed consistency with the AMPs included in the GALL Report, the project team will review the VYNPS AMP descriptions and compare program elements for the VYNPS AMPs to the corresponding program elements for the GALL Report AMPs. The review will be documented using the worksheet as discussed in Appendix F. The project team will determine that the VYNPS AMPs contain the program elements of the referenced GALL Report AMP and that the conditions at the plant are bounded by the conditions for which the GALL Report program was evaluated. The-Division of Engineering will review and determine the adequacy of the applicant's 10 CFR 50, Appendix B Program. Other aspect of these program elements will be review by the project team.

For VYNPS AMPs that have one or more exceptions and/or enhancements, the project team will review each exception and/or enhancement to determine whether the exception and/or enhancement is acceptable and whether the VYNPS AMP, as modified by the exception and/or enhancement, would adequately manage the aging effects for which it is credited. The review will be documented using the worksheet as discussed in Appendix F. In some cases, the project team will identify differences that the applicant did not identify between the VYNPS AMPs credited by the applicant and the GALL Report AMPs. The review will be documented using the worksheet as discussed in Appendix F. In these cases, the project team will review the difference to determine whether or not it is acceptable and whether or not the VYNPS AMP, as modified with the difference, would adequately manage the aging effects.

For those VYNPS AMPs that are not included in the GALL Report (i.e., plant-specific AMPs, no precedent), the project team will review the VYNPS AMP against the ten program elements defined in Appendix A of the SRP-LR. The review will be documented using the worksheet shown in Appendix G. The Division of Engineering will review and determine the adequacy of the applicant's 10 CFR 50, Appendix B Program. Other aspect of these program elements will be review 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.

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, 11

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 (includes formerly past precedent material) are technically acceptable and applicable based on a technical review by the project team. 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.

In addition, the project team will also review the AMRs that the applicant claims that are not applicable to its plant.

5.3 Time-Limited Aging Analyses The TLAAs in the VYNPS LRA fall into the broad category of those that are consistent with the NUREG-1 800 TLAA categories. There are no plant-specific exemptions identified in the VYNPS LRA that depend on time-limited aging analyses.

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

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

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

(2) consider the effects of aging.

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

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

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

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

In addition; the project team will also review the TLAAs to determine 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 12

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/Examples for further review by technical specialists could be such as the following:

Reactor Vessel Neutron Embrittlement Analysis EQ for Electrical Equipment (unless audit team is capable)

Intergranular separation in the Heat-Affected Zone (HAZ) of Reactor Vessel Low-Alloy Steel under Austenitic SS Cladding Silting of the Ultimate Heat Sink 5.4 NRC-Approved Precedents To help facilitate the project team staff review of its LRA, an applicant may reference NRC-approved precedents to demonstrate that its non-GALL programs correspond to reviews that the staff had approved for other plants during its review of previous applications for license renewal. When an applicant elects to provide precedent information, the project team will review and determine whether the material presented in the precedent is applicable to the applicant's facility, determine whether the plant program is bounded by the conditions for which the precedent was evaluated and approved, and determine that the plant program contains the program elements of the referenced precedent. In general, if the project team determines that these conditions are satisfied, it will use the information in the precedent to frame and focus its review of the applicant's program.

It is important to note that precedent information is not a part of the LRA; it is supplementary information voluntarily provided by the applicant as a reviewer's aid. The existence of a precedent, in and of itself, is not a sufficient basis to accept the applicant'sProgram. Rather, the precedent facilitates the review of the substance of the matters described in the applicant's program. As such, in its documentation of its reviews of programs 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 program for which it is credited, it may refer the program to the Office of Nuclear Reactor Regulation (NRR) DE for review in the traditional manner, i.e., as described in the SRP-LR, without consideration of the precedent information.

5.5 UFSAR Supplement Review In accordance with the SRP-LR, for the AMRs and associated AMPs and the TLAAs 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 determine that they are acceptable for the stated purpose. In 13

addition, the project team will determine that the applicant identified the enhancements as commitments in the Updated Final Safety Analysis Report (UFSAR) or other docketed correspondence.

5.6 Documents Reviewed by the Project Team In performing its work, the project team will rely heavily on the VYNPS 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 documents, to determine that the applicant's activities and programs will adequately manage the effects of aging on structures and components. To review the TLAAs, the review team will also study the appropriate sections in the VYNPS UFSAR, as well as referring back to appropriate sections in the SRP-LR, GALL Report, and NEI 95-10, Revision 6.

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 these 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 document the results of his or her work on a variety of worksheets. The worksheets are discussed in Appendix F, "Consistent with GALL Report AMP Audit/Review Worksheet;" Appendix G, "Plant-Specific AMP Audit/Review Worksheet;" and Appendix H, "Aging Management Review Worksheets." The use of the worksheets is described in'Section 6 of this audit and review plan.

5.8.3 Questions As specified in Section 6 of this audit and review plan, the project team will ask the applicant questions, while on-site, as appropriate, to facilitate its audit and review activities. The project team will also track and review the applicant's answers to these questions. If an applicant response is necessary to support a finding made by the project team, the applicant may voluntarily submit the response to the NRC under oath and affirmation. As an alternate, the project team may use the RAI process to obtain this response under oath and affirmation.

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5.8.4 Work Packages During the audit and review process, the project team leader, in conjunction with the NRC license renewal project manager, will assemble work packages for any work that the project team will refer to the NRR 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 Request for Additional Information The audit and review process described in this audit and review plan is structured to resolve as many questions as possible during the on-site visits. As examples, the on-site visits are used to obtain clarifications about the VYNPS LRA and explanations as to where certain information may be found in the VYNPS 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 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. RAls will include the technical and regulatory basis for requesting the information.

After the project team 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 will review the response and determine if it resolves the issue that was the reason for the RAI.

The project team 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 and review report was issued before the applicant submitted its response to an RAI, the review of the project team's evaluation of the response will be documented in the SER related to the VYNPS LRA.

5.8.6 Audit and Review Report The project team will document the results of its work in an audit and review report. The project team will prepare its report as described in Section 6.5.1 of this audit and review plan and the latest version of the RLRC GuidelinesForPreparingAudit 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 6.5.2 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, conduct, and document its audit and review work.

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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 renewal decision. Key milestones and activities include, as a minimum:

A. receiving the LRA from the applicant B. receiving work split tables from the NRC license renewal project manager C. making individual work assignments D. training project team members E. holding the project team kickoff meeting F. preparing the audit and review plan G. scheduling on-site visits H. scheduling in-office review periods I. preparing questions J. preparing RAIs K. preparing draft and final audit and review report L. preparing draft and final SER input On-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 NRC technical assistance contractor will provide a proposed project team member work assignments to the NRC project team leader. The NRC project team leader will approve all work assignments. After the audit and review plan is issued, the NRC project team leader may reassign work as necessary.

The NRC technical assistance contractor will develop assignment tables that show which project team member will review each of the VYNPS AMPs and AMRs. Appendix A of this audit and review plan shows the project team members. Appendix C shows the project team member assignments for the AMPs, Appendix D of this audit and review plan shows the project team member assignments for the AMRs, and 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.

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(1) GALL Report (2) SRP-LR (3) Interim Staff Guidance for License Renewal (ISG-LR)

(4) LRA AMPs (5) LRA TLAAs (6) LRA AMRs (7) Basis documents (catalogs of information assembled by the applicant to demonstrate the bases for its programs and activities)

(8) Implementing procedures (9) Operating experience (Licensee Event Reports)

(10) RAIs, audit and review reports, and SERs for other plants (11) Applicant's UFSAR 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, RAls, the audit and review report, and SER input.

F. Process for interfacing with DE and DCI technical reviewers.

6.2 Aging Management Program 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 audit and review plan.

6.2.2 Scope of AMP Program Elements to be Audited And Reviewed Table 1 of this plan shows the ten program elements that are used to evaluate the adequacy of each aging management program. These program elements are also 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 review and determine the adequacy of the applicant's 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 audit and review each plant AMP that the applicant claims is consistent with the GALL Report.

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

B. Review the associated GALL Report 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) ISG-LR (4) RAIs, audit and review reports, and SERs for similar plants (5) LRA (6) basis documents (7) implementation documents (8) operating experience reports (plant-specific and industry)

(9) applicant's UFSAR Audit/Review A. Confirm that VYNPS 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 identify any enhancements to the GALL Report AMP?

(3) Are the program elements consistent with the GALL Report AMP?

B. If the above questions result in the identification of an exception/enhancement or a difference to the GALL Report 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 (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 18

history. A review of the prior five to ten years of operating and maintenance history should be sufficient. The results of the review should confirm consistency with reported industry operating experience.

Differences with previously reported industry experience, such as new aging effects or lack of aging effects, allow for consideration in the plant-specific aging management requirements.

(2) Plant-Specific Operating Experience with Existing Aging Management Programs. The operating experience of aging management programs, 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.

(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 issuance. Operating experience after the issuance 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 an already identified aging effect.

E. If it is necessary to ask the applicant a question to clarify the basis for accepting the justification, an exception, or a difference to the program element of the GALL Report, 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 VYNPS 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 F, "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.

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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, audit and review reports, and SERs for similar plants (5) LRA (6) basis documents (7) implementation documents (8) operating experience reports (plant-specific and industry)

(9) applicant's UFSAR (10) lessons learned developed by RLRC Audit/Review A. Audit/review the VYNPS 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 five to ten years of operating and maintenance history should be sufficient. The results of the review should confirm consistency with reported industry operating experience.

Differences with previously reported industry experience, such as new aging effects or lack of aging effects, allow for consideration in the plant-specific aging management requirements.

(2) Plant-Specific Operating Experience with Existing Aging Management Programs. The operating experience of aging management programs, 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 20

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 issuance. Operating experience after the issuance 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 an already identified aging effect.

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

D. 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 VYNPS 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 G, "Plant-Specific AMP Audit/Review Worksheet."

6.3 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 VYNPS 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 Report AMRs and identify those line items that will be audited/reviewed in conjunction with each of the VYNPS AMRs.

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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, audit and review reports, and SERs for similar plants (5) LRA (6) basis documents (7) implementation documents (8) operating experience reports (plant-specific and industry)

(9) applicant's UFSAR (10) lessons learned developed by RLRC Audit/Review A. 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. 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 determination that 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], 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 extended period of 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 AMP 2 ,

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 1The 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 Ucense 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.

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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.

(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 (docketed letter submitted under oath and affirmation) 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.

(d) If the applicant's response is relied upon as the basis for a finding made by the project team, the applicant's response needs to be docketed under oath and affirmation. This may be reached through the applicant voluntarily submitting the response to the NRC under oath and affirmation, or by the staff using the RAI process.

(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 these AMR line items are acceptable on the basis of a technical review.

AMR Audit/Review Worksheets Document the audits/reviews of VYNPS AMRs using the worksheet provided in Appendix H, "Aging Management Review Worksheets." As an alternate, the project team reviewer may document its review electronically in the AMR spreadsheets.

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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 VYNPS AMRs that the applicant has identified as being consistent with an NRC-approved precedent.

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 documents (8) operating experience reports (plant-specific and industry)

(9) applicant's UFSAR (10) lessons learned developed by RLRC Audit/Review A. The AMR audit/review involves determination 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 VYNPS AMR being reviewed?

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

(3) Is the VYNPS 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 VYNPS AMR, the process shown in Figure 4 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.

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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.

AMR Audit/Review Worksheets Document the audits/reviews using the worksheet provided in Appendix H, "Aging Management Review Worksheets. As an alternate, the project team member may document its review electronically in the AMR spreadsheets.

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 VYNPS TLAAs that the applicant has identified as generic TLAA issues, identify the corresponding TLAAs in NUREG-1800, if appropriate.

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

C. Review the list of the VYNPS 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:

25

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

  • SRP-LR
  • RAIs, audit and review reports, and SERs for similarplants
  • References listed by applicant for each TLAA
  • basis documents
  • implementation documents
  • operating experience reports (plant-specific and industry)
  • lessons learned developed by RLRC
  • applicant's UFSAR E. In addition, the project team will also review the TLAAs to determine if there are emerging issues that should be further evaluated by technical specialists in the NRC Divisions of Component Integrity (DCI) or the Division of Engineering (DE).

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

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

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

0 Reactor Vessel Neutron Embrittlement Analysis

  • EQ for Electrical Equipment (unless audit team is capable) 0 Intergranular separation in the Heat-Affected Zone (HAZ) of Reactor Vessel 0 Low-Alloy Steel under Austenitic SS Cladding

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 VYNPS 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:

26

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

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

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

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

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

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

E. If it is necessary for the applicant to submit additional information to support the basis for the conclusions in their TLAA, the applicant may agree to voluntarily submit the required information as a supplement (docketed letter submitted under oath and affirmation) to the VYNPS 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 team's question(s) related to the particular TLAA, the applicant's response(s) and notation of documents reviewed.

6.4.2 Reactor Vessel Neutron Embrittlement 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.

27

Pre-Review Preparation A. The project team will determine if the TLAAs identified in the VYNPS LRA to be within the NUREG-1 800 TLAA category of "reactor vessel neutron embrittlement" have provided adequate information to ýneet the requirements of 10 CFR 54.21 (c)(1) and 10 CFR 54.21 (c)(2).

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

  • Excel database on TLAAs summarizing how earlier LRAs and SERs presented and reviewed TLAAs
  • SRP-LR
  • ISGs 0 RAIs, audit and review reports, and SERs for similar plants 0 LRA 0 References listed by applicant for each TLAA 0 NEI 95-10, Section 5.1 and Table 6.2-2 0 basis documents
  • implementation documents 0 operating experience reports (plant-specific and industry)
  • lessons learned developed by RLRC

& applicant's UFSAR C. In addition, the project team will also review the VYNPS TLAAs within the NUREG-1 800 TLAA category of "reactor vessel neutron embrittlement" 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 VYNPS 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 VYNPS should state in this section that it does not apply.

28

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

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

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

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

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

D. The project team will ascertain that the VYNPS 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 reactor vessel neutron embrittlement (from NEI 95-10, Table 6.2-2) as follows:

  • Disposition chosen for each of the identified TLAAs. Also, provide a reference to the summary description of TLAA evaluations in the UFSAR 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 VYNPS 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 team's question(s) related to the particular TLAA, the applicant's response(s) and notation of documents reviewed.

29

6.4.3 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 VYNPS 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).

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

0 Excel database on TLAAs summarizing how earlier LRAs and SERs presented and reviewed TLAAs 0 GALL Report, especially Section X.M1

  • SRP-LR
  • RAIs, audit and review reports, and SERs for similar plants
  • References listed by applicant for each TLAA
  • basis documents
  • implementation documents
  • operating experience reports (plant-specific and industry)
  • lessons learned developed by RLRC
  • applicant's UFSAR C. In addition, the project team will also review the VYNPS 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.

30

Audit/Review A. Confirm that each VYNPS 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 VYNPS should state in this section that it does not apply.

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

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

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

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

(6) are contained or incorporated by reference in the CLB D. The project team will ascertain that the VYNPS 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:

  • Disposition chosen for each of the identified TLAAs. Also, provide a reference to the summary description of TLAA evaluations in the UFSAR 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 VYNPS LRA. If not, the NRC may issue an RAI to obtain the information.

31

TLAA Audit Worksheets Document the audits/reviews using a worksheet which contains, as a minimum, the project team's question(s) related to the particular TLAA, the applicant's response(s) and notation of documents reviewed.

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

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

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

  • Excel database on TLAAs summarizing how earlier LRAs and SERs presented and reviewed TLAAs
  • GALL Report, especially Section X.E1
  • SRP-LR
  • RAIs, audit and review reports, and SERs for similar plants
  • References listed by applicant for each TLAA
  • basis documents 0 implementation documents
  • operating experience reports (plant-specific and industry)
  • lessons learned developed by RLRC
  • applicant's UFSAR C. In addition, the project team will also review the VYNPS 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 32

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 VYNPS 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 VYNPS should state in this section that it does not apply.

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

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

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

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

(6) are contained or incorporated by reference in the CLB D. The project team will ascertain that the VYNPS 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:

  • Disposition chosen for each of the identified TLAAs. Also, provide a reference to the summary description of TLAA evaluations in the UFSAR 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.

33

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 VYNPS 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 team's question(s) related to the particular TLAA, the applicant's response(s) and notation of documents reviewed.

6.4.5 Concrete Containment Tendon Prestress Analysis The applicant states in the VYNPS LRA that this TLAA is not applicable for VYNPS. So the material in the following paragraphs is not pertinent to the project team review for this LRA.

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 VYNPS LRA to be within the NUREG-1 800 TLAA category of "concrete containment tendon prestress" have provided adequate information to meet the requirements of 10 CFR 54.21(c)(1) and 10 CFR 54.21 (c)(2).

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

  • Excel database on TLAAs summarizing how earlier LRAs and SERs presented and reviewed TLAAs
  • GALL Report, especially Section X.S1
  • SRP-LR
  • RAIs, audit and review reports, and SERs for similar plants
  • References listed by applicant for each TLAA
  • basis documents
  • implementation documents
  • operating experience reports (plant-specific and industry)
  • lessons learned developed by RLRC
  • applicant's UFSAR C. In addition, the project team will also review the VYNPS TLAAs within the NUREG-1800 TLAA category of "concrete containment tendon prestress" to 34

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 VYNPS 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 VYNPS should state in this section that it does not apply.

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

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

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

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

(6) are contained or incorporated by reference in the CLB D. The project team will ascertain that the VYNPS 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 "concrete containment tendon prestress" (from NEI 95-10, Table 6.2-2) as follows:

  • Disposition chosen for each of the identified TLAAs. Also, provide a reference to the summary description of TLAA evaluations in the UFSAR 35

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 VYNPS 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 team's question(s) related to the particular TLAA, the applicant's response(s) and notation of documents reviewed.

6.4.6 Containment Liner Plate, Metal Containment, and Penetrations 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 VYNPS LRA to be within the NUREG-1800 TLAA category of "containment liner plate, metal containments, and penetrations fatigue analysis" 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:

0 Excel database on TLAAs summarizing how earlier LRAs and SERs presented and reviewed TLAAs 0 GALL Report, especially Section X.E1

  • RAIs, audit and review reports, and SERs for similar plants
  • References listed by applicant for each TLAA 0 NEI 95-10, Section 5.1 and Table 6.2-2
  • basis documents
  • implementation documents 36
  • operating experience reports (plant-specific and industry)
  • lessons learned developed by RLRC
  • applicant's UFSAR C. In addition, the project team will also review the VYNPS TLAAs within the NUREG-1800 TLAA category of "containment liner plate, metal containments, and penetrations fatigue analysis" 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 VYNPS 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 VYNPS should state in this section that it does not apply.

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

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

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

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

(6) are contained or incorporated by reference in the CLB D. The project team will ascertain that the VYNPS 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.

37

E. Review any industry and plant-specific operating experience associated with the TLAA. This is an area "ofreview emphasis. The project team members should consider the following industry guidance on "containment liner plate, metal containments, and penetrations fatigue analysis" (from NEI 95-10, Table 6.2-2) as follows:

Disposition chosen for each of the identified TLAAs. Also, provide a reference to the summary description of TLAA evaluations in the UFSAR 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 VYNPS 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 team's question(s) related to the particular TLAA, the applicant's response(s) and notation of documents reviewed.

6.4.7 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 VYNPS 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:

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

  • RAIs, audit and review reports, and SERs for similar plants
  • References listed by applicant for each TLAA
  • basis documents
  • implementation documents
  • operating experience reports (plant-specific and industry)
  • lessons learned developed by RLRC
  • applicant's UFSAR C. In addition, the project team will also review the VYNPS 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 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 VYNPS 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 VYNPS should state in this section that it does not apply.

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

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

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

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

(6) are contained or incorporated by reference in the CLB 39

D. The project team will ascertain that the VYNPS 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:

0 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 required information as a supplement (docketed letter submitted under oath and affirmation) to the VYNPS 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 team's question(s) related to the particular TLAA, the applicant's response(s) and notation of documents reviewed.

6.5 Audit and Safety Review Documentation As noted in Section 5.7 of this audit and review 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 audit and review plan addresses the preparation of the audit and review report and the SER input.

6.4.1 Audit and Review Report Details on documentation of the audit and review report can be found in the latest version of the RLRC GuidelinesFor PreparingAudit and Review Reports.

In general, the audit and review report should include the following:

A. Cover page B. Table of Contents C. 1. Introduction and General Information 1.1 Introduction 1.2 Background 40

D. 2. Audit and Review Scope E. 3. Aging Management Review Audit and Review Results 3.0 Applicant's Use of Generic Aging Lesson-Leamed Report 3.0.1 Format of the Applicant's License Renewal Application 3.0.1.1 Overview of Table 1 3.0.1.2 Overview of Table 2 3.0.2 Audit and Review Process 3.0.2.1 Review of AMPs 3.0.2.2 Review of AMR Results 3.0.2.3 NRC-Approved Precedents 3.0.2.4 UFSAR Supplement 3.0.2.5 Documentation and Documents Reviewed 3.0.2.6 Commitments to be Included in the Safety Evaluation Report 3.0.2.7 Exit Meeting 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 the GALL Report with Exceptions or Enhancements 3.0.3.3 AMPs That Are Not Consistent with or Not Addressed in the GALL Report 3.1 Applicant's LRA Section 3A1 - Aging Management of Reactor Coolant System 3.1.1 Summary of Technical Information in the Application 3.1.2 Project Team Evaluation 3.1.2.1 AMR Results That Are Consistent with the GALL Report 3.1.2.2 AMR Results for Which Further Evaluation is Recommended 3.1.2.3 AMR Results That Are Not Consistent with or Not Addressed in the GALL Report 3.1.3 Conclusion 3.2 Applicant's LRA Section 3.2 - Aging Management of Engineered Safety Features Systems 3.2.1 Summary of Technical Information in the Application 3.2.2 Project Team Evaluation 3.2.2.1 AMR Results That Are Consistent with the GALL Report 3.2.2.2 AMR Results for Which Further Evaluation is Recommended 3.2.2.3 AMR Results That Are Not Consistent with or Not Addressed in the GALL Report 3.2.3 Conclusion 3.3 Applicant's LRA Section 3.3 - Auxiliary Systems 3.3.1 Summary of Technical Information in the Application 3.3.2 Project Team Evaluation 3.3.2.1 AMR Results That Are Consistent with the GALL Report 41

3.3.2.2 AMR Results for Which Further Evaluation is Recommended 3.3.2.3 AMR Results That Are Not Consistent with or Not Addressed in the GALL Report 3.3.3 Conclusion 3.4 Applicant's LRA Section 3.4 - Aging Management of Steam and Power Conversion System 3.4.1 Summary of Technical Information in the Application 3.4.2 Project Team Evaluation 3.4.2.1 AMR Results That Are Consistent with the GALL Report 3.4.2.2 AMR Results for Which Further Evaluation is Recommended 3.4.2.3 AMR Results That Are Not Consistent with or Not Addressed in the GALL Report 3.4.3 Conclusion 3.5 Applicant's LRA Section 3.5 - Aging Management of Containment, Structures and Component Supports 3.5.1 Summary of Technical Information in the Application 3.5.2 Project Team Evaluation 3.5.2.1 AMR Results That Are Consistent with the GALL Report 3.5.2.2 AMR Results for Which Further Evaluation is Recommended 3.5.2.3 AMR Results That Are Not Consistent with or Not Addressed in the GALL Report 3.5.3 Conclusion 3.6 Applicant's LRA Section 3.6 - Aging Management of Electrical and Instrumentation and Controls 3.6.1 Summary of Technical Information in the Application 3.6.2 Project Team Evaluation 3.6.2.1 AMR Results That Are Consistent with the GALL Report 3.6.2.2 AMR Results for Which Further Evaluation is Recommended 3.6.2.3 AMR Results That Are Not Consistent with or Not Addressed in the GALL Report 3.6.3 Conclusion F. 4. Time-Limited Aging Analysis 4.1 Identification of Time-Limited Aging Analyses and Exemptions 4.1.1 Identification of TLAA 4.1.2 Identification of Exemptions 4.2 Reactor Vessel Neutron Embrittlement Analyses 4.2.1 Reactor Vessel Fluence 4.2.2 Pressure/Temperature Limits 4.2.3 Charpy Upper-Shelf Energy (CVUSE) 4.2.4 Adjusted Reference Temperature 42

4.2.5 Reactor Vessel Circumferential Welds 4.2.6 Reactor Vessel Axial Weld Failure Probability 4.2.7 References 4.3 Metal Fatigue Analyses 4.3.1 Class 1 Fatigue 4.3.2 Non-Class I Fatigue 4.3.3 Effects of Reactor Water Environment on Fatigue Life 4.3.4 References 4.4 Environmental Qualification of Electrical Components 4.5 Concrete Containment Tendon Prestress Analysis 4.6 Containment Liner Plate, Metal Containment, and Penetrations Fatigue Analyses 4.6.1 Fatigue of the Torus 4.6.2 Fatigue of Safety Relief Valve (SRV) Discharge Piping 4.6.3 Fatigue of Other Torus-Attached Piping 4.7 Other Plant-specific Time-limited Aging Analyses 4.7.1 Reflood Thermal Shock of the Reactor Vessel Internals 4.7.2 TLAA in BWRVIP Documents 4.7.3 References G. Attachments Attachment 1 Abbreviations and Acronyms Attachment 2 Project Team and Applicant Personnel Attachment 2A Members of the Public Attachment 3 Elements of an Aging Management Program for License Renewal Attachment 4 Disposition of Requests for Additional Information, LRA Supplements, and Open or Confirmatory Items Attachment 5 List of Documents Reviewed Attachment 6 List of Commitments 6.4.2 Safety Evaluation Report Input

1. General guidance A. The project team will prepare the SER input for the AMP and AMR audits and reviews. The technical assistance contractor shall collect, assemble, and prepare the complete SER input.

B. 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 project team member's worksheets.

43

C. SER inputs are to be prepared for:

(1) each VYNPS AMP that was determined to be consistent with the GALL Report, which has no exceptions or enhancements.

(2) each VYNPS 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.

(3) each plant-specific AMP (4) AMRs that are consistent with the GALL Report (5) project team AMR review results4 D. RLRA/RLRB will prepare an SER shell for the entire SER. The project team is to enter its SER input directly into the RLRA/RLRB shell. The SER input placed into the SER shell should typically contain the following sections. (Note: The following section numbers (3. through 3.X.3 and 4) are based on the numbering system for the SER shell. 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 3.0.1 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 3.0.3.3 AMPs that are Plant-Specific 3.0.4 Quality Assurance Program Attributes Integral to Aging Management Programs 3.X.5 Aging Management of 3.X.1 Summary of Technical Information in the Application 3.X.2 Staff Evaluation 3.X.2.1 Aging Management Review Results that are Consistent with the GALL Report 4 AMRs that are not consistent with the GALL Report.

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.

44

3.X.2.2 Aging Management Review Results For Which Further Evaluation is Recommended by the GALL Report 3.X.2.3 Aging Management Review Results that are Not Consistent with or Not Addressed in the GALL Report 3.X.3 Conclusion

4. Time-Limited Aging Analyses 4.1 Identification of Time-Limited Aging Analyses and Exemptions 4.1.1 Identification of TLAA 4.1.2 Identification of Exemptions 4.2 Reactor Vessel Neutron Embrittlement Analysis 4.2.1 Reactor Vessel Fluence 4.2.2 Pressure/Temperature Limits 4.2.3 Charpy Upper-Shelf Energy (CVUSE) 4.2.4 Adjusted Reference Temperature 4.2.5 Reactor Vessel Circumferential Welds 4.2.6 Reactor Vessel Axial Weld Failure Probability 4.2.7 References 4.3 Metal Fatigue Analysis 4.3.1 Class 1 Fatigue 4.3.2 Non-Class I Fatigue 4.3.3 Effects of Reactor Water Environment on Fatigue Life 4.3.4 References 4.4 Environmental Qualification of Electrical Components 4.5 Concrete Containment Tendon Prestress Analysis 4.6 Containment Liner Plate, Metal Containment, and Penetrations Fatigue Analyses 4.6.1 Fatigue of the Torus 4.6.2 Fatigue of Safety Relief Valve (SRV) Discharge Piping 4.6.3 Fatigue of Other Torus-Attached Piping 4.7 Other Plant-specific Time-limited Aging Analyses 4.7.1 Reflood Thermal Shock of the Reactor Vessel Internals 4.7.2 TLAA in BWRVIP Documents 4.7.3 References 45

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

F. If the applicant submitted a supplement (docketed letter submitted under oath and affirmation) 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.

G. 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.

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

2. SER input A. For VYNPS 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 update (Appendix A of the VYNPS LRA) is acceptable. This SER input documents that the AMP is consistent with the GALL Report.

B. For VYNPS 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 VYNPS 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.

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

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

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

46

(1) Identify the VYNPS LRA section reviewed (2) A summary of the type of information provided in the section of the VYNPS LRA reviewed, including a listing of the VYNPS AMPs reviewed.

(3) Identify the VYNPS LRA Tables 3.X.2-Y reviewed.

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

(5) 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.

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

(7) A finding that determines that:

(a) the applicant identified the applicable aging effects (b) the applicant defined the appropriate combination of materials and environments (c) the applicant specified acceptable AMPs (8) 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.

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

(1) The VYNPS LRA section containing the applicant's further evaluations of AMRs for which further evaluation is required.

(2) A list of the aging effects for which the further evaluation apply.

(3) 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.

(4) 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.

(5) 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.

F. Staff AMR Review Results. 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:

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

47

(1) The VYNPS LRA section reviewed (2) 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.

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

(4) A brief summary of what the staff (project team) reviewed, i.e.,

LRA and applicant basis documents and other implementation documents.

(5) A finding that determines, if true, that:

(a) The applicant identified the applicable aging effects (b) The applicant listed the appropriate combination of materials and environments (c) The applicant specified acceptable AMPs (6) 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.

G. Staff TLAA Review Results. 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:

  • Reactor Vessel Neutron Embrittlement Analysis
  • EQ for Electrical Equipment (unless audit team is capable)
  • Intergranular separation in the Heat-Affected Zone (HAZ) of Reactor Vessel
  • Low-Alloy Steel under Austenitic SS Cladding
  • Silting of the Ultimate Heat Sink 6.5 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 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.

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

4 Detection of aging Detection of aging effects should occur before there is loss effects 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 Monitoring and trending should provide prediction of the trending 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 Administrative controls should provide a formal review and controls 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.

  • The adequacy of the applicant's 10 CFR 50, Appendix B Program associated with this program element is audited by the Division of Engineering.

49

Table 2. 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-1 801 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-1 801 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-1 801 for this component and material.

H Aging effect not in NUREG-1 801 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.

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).

50

Yes lote: Ifan NRC precedent

. Yes xist;. it maybe used as anaid omake the technical eterminal on. Docurnentalon f the axceptance trust be iade onthe technical merits ot a citation to the precedent.

WIs Figure 1. Audit of AMPs That Are Consistent With the GALL Report 51

Figure 2. Audit of Plant-Specific AMPs 52

Figure 3. Review of AMRs That Are Consistent With the GALL Report 53

Figure 4. Review of AMRs Using NRC-Approved Precedents 54

Figure 5. Review of TLAAs and Exemptions (from NEI 95-10, Revision 6) 55

Appendix A Project Team Members

Appendix A Project Team Members Organization Name Function NRC/NRR/DLR/RLRC Mike Morgan Project Team Leader NRC/NRRIDLRIRLRC Kaihwa (Robert) Hsu Backup Team Leader NRC/NRRIDLR/RLRC Mark Lintz Reviewer NRC/NRRJDLR/RLRC Duc Nguyen Reviewer Information Systems Mike Kennedy Contractor Lead, Reviewer Laboratories, Inc.

Information Systems Malcolm Patterson Reviewer Laboratories, Inc.

Information Systems Jon Woodfield Reviewer Laboratories, Inc.

A-1

Appendix B RLRC Schedule for LRA Safety Review

Appendix B RLRC Schedule for LRA Safety Review Plant: Vermont Yankee TAC: MC9668 Team Leader: Michael Morgan Scope of Work:

Backup Team Leader: Kaihwa (Robert) Hsu AMPs/TLAAs - 36 of 37 Project Manager: Johnny Eads AMRs - 2378 of 2378 line items Contractor: Information Systems Laboratories (ISL) RAI Target Date: 11/01/06 Assignments: Mike Kennedy (ISL), Malcolm SE Input to PM: 02/01/07 Patterson (ISL), Jon Woodfield (ISL), Mark Lintz (NRC)

Duc Nguyen (NRC)

ACTIVITY/MILESTONE . 1 PLAN SCHEDULE 1 Receive LRA 1/25/2006 2 Complete Acceptance Review 2/25/2006 3 Make Review Assignments 3/8/2006 4 Conduct Team Planning Meeting 3/21-3/22/2006 5 Issue Audit Plan to PM 3/31/2006 6 Conduct Site Visit 1 4/17-4/21/2006

_ (AMP audit and review) __________________

7 Draft AMP Audit Report Input 5/1-5/5/2006 8 Conduct in-office AMR reviews 5/8-5/12/2006 9 Site Visit 2 5/15-5/19/2006 I__

(AMR audit and review) ____________

10 Draft AMR Audit Report Input 6/5-6/9/2006 11 Optional Site Visit 3 (resolve AMR and AMP questions) 6/26-6/29/2006 12 Public Exit Meeting 6/29/2006 13 Cutoff for providing RAIs to PM 14 Peer Review of Final Draft Audit and Review Report 7/24-7/28/2006 15 Issue Final Audit and Review Report. 8/4/2006 16 Draft SER input (AMPs/AMRs) 8/9-9/11/2006 17 Issue Final Draft SER Input to PM 9115/2006 18 ACRS Subcommittee Meeting 5/1/2007 19 ACRS Full Committee Meeting 9/1/2007 B-1

Appendix C Aging Management Program Assignments

Appendix C Aging Management Program Assignments The following AMPs have been assigned to the project team for review.

Consistent GALL with GALL LRA Report Report AMP AMP Assigned Number Number AMP Title Yes No Reviewer B.1.1 XI.M34 Buried Piping Inspection X Mark Lintz Program B.1.2 XI.M6 BWR CRD Return Line X Malcolm Nozzle Program Patterson B.1.3 XI.M5 BWR Feedwater Nozzle X Malcolm Program Patterson B.1.4 XI.M8 BWR Penetrations Program X Robert Hsu B.1.5 XLM7 BWR Stress Corrosion X Robert Hsu Cracking Program B.1.6 XI.M4 BWR Vessel IDAttachment X Robert Hsu Welds Program B.1.7 XI.M9 BWR Vessel Internals X Robert Hsu Program I B.1.8 XI.S4 Containment Leak Rate X Mark Lintz Program B.1.9 XI.M30 Diesel Fuel Monitoring X Mike Kennedy Program B.1.10 X.E1 Environmental Qualification Yes Duc Nguyen (EQ) of Electric Components Program B.1.11 X.Mi Fatigue Monitoring Program X Malcolm Patterson B.1.12.1 XI.M26 Fire Protection - Fire X Mark Lintz Protection Program B.1.12.2 XI.M27 Fire Protection - Fire Water X Mark Lintz System Program B.1.13 XI.M17 Flow-Accelerated Corrosion Yes Mark Lintz Program B.1.14 NA Heat Exchanger Monitoring PS Mike Kennedy Program C-1

Consistent GALL with GALL LRA Report -Report AMP AMP Assigned Number Number' AMP Title, Yes No Reviewer B.1.15.1 XI.S1 Inservice Inspection - PS Jon Woodfield Containment Inservice Inspection (CII) Program B.1.15.2 XI.M1 Inservice Inspection - PS Malcolm XI.S3 Inservice Inspection (ISI) Patterson Program B.1.16 NA Instrument Air Quality PS Malcolm Program Patterson B.1.17 XI.E3 Non-EQ Inaccessible Yes Duc Nguyen Medium-Voltage Cable Program B.1.18 XI.E2 Non-EQ Instrumentation Yes Duc Nguyen Circuits Test Review Program B.1.19 XI.EI' Non-EQ Insulated Cables Yes Duc Nguyen and Connections Program B.1.20 XI.M39 Oil Analysis Program X Mike Kennedy B.1.21 XI.M32 One-Time Inspection Yes Mike Kennedy XI.M35 Program B.1.22 NA Periodic Surveillance and PS Mike Morgan Preventive Maintenance Program B.1.23 XI.M3 Reactor Head Closure Studs X Mike Morgan Program B.1.24 XI.M31 Reactor Vessel Surveillance Yes DE Program B.1.25 XI.M33 Selective Leaching Program Yes Malcolm Patterson B.1.26 XI.M20 Service Water Integrity X Jon Woodfield Program B.1.27.1 XI.S5 Structures Monitoring - Yes Jon Woodfield Masonry Wall Program B.1.27.2 XI.S6 Structures Monitoring - Yes Jon Woodfield Structures Monitoring Program C-2

Consistent GALL with GALL LRA Report Report AMP AMP Assigned Number Number AMP Title Yes No Reviewer B.1.27.3 NA Structures Monitoring - PS Jon Woodfield Vernon Dam FERC Inspection B.1.28 XI.M36 System Walkdown Program Yes Mark Lintz B.1.29 XI.M13 Thermal Aging and Neutron Yes Robert Hsu Irradiation Embrittlement of Cast Austenitic Stainless Steel (CASS) Program B.1.30.1 NA Water Chemistry Control - PS Mike Morgan Auxiliary Systems Program B.1.30.2 XI.M2 Water Chemistry Control - Yes Mike Morgan BWR Program B.1.30.3 XI.M21 Water Chemistry Control - Yes Mike Morgan Closed Cooling Water Program DE = Division of Engineering PS = plant-specific X = with exceptions C-3

Appendix D Aging Management Review Assignments

Appendix D Aging Management Review Assignments AMR Section Title Reviewer 3.1 Reactor Vessel, Internals, and Reactor Coolant System M. Patterson 3.2 Engineering Safety Features Systems M. Lintz 3.3 Auxiliary Systems M. Kennedy 3.4 Steam and Power Conversion Systems M. Morgan 3.5 Structures and Component Supports J. Woodfield 3.6 Electrical and Instrumentation and Controls D. Nguyen D-1

Appendix E Time-Limited Aging Analyses Review Assignments

Appendix E Time-Limited Aging Analyses Review Assignments LRA GALL TLAA Report TLAA Title Assigned Number TLAA Reviewer NumberN 4.1 Identification of TLAAs and Exemptions Hsu 4.2 --- Reactor Vessel Neutron Embrittlement DE 4.3 X.MI Metal Fatigue Hsu 4.4 X.E1 Environmental Qualification of Electrical Nguyen Components 4.5 X.S1 Concrete Containment Tendon Prestress Not applicable to VYNPS 4.6 --- Containment Liner Plate, Metal Containment, and DE/Hsu Penetrations Fatigue Analyses 4.7.1 Reflood Thermal Shock of the Reactor Vessel DE Internals 4.7.2.1 --- BWRVIP-05, RPV Circumferential Welds DE Analysis 4.7.2.2 --- BWRVIP-25, Core Plate Rim Holddown Bolts DE Loss of Preload Analysis 4.7.2.3 --- BWRVIP-38, Shroud Support Fatigue Analysis Hsu 4.7.2.4 --- BWRVIP-47, Lower Plenum Fatigue Analysis Hsu 4.7.2.5 --- BWRVIP-48, Vessel ID Attachment Welds Hsu Fatigue Analysis 4.7.2.6 --- BWRVIP-49, Instrument Penetrations Fatigue Hsu Analysis 4.7.2.7 --- BWRVIP-74, Reactor Vessel DE P/T Curves Analysis Fatigue Analysis CVUSE Analysis Circ/Axial Welds Analysis 4.7.2.8 --- BWRVIP-76, Core Shroud Hsu E-1

Appendix F Consistent with GALL Report AMP Audit/Review Worksheet

Appendix F Consistent with GALL Report AMP Audit/Review Worksheet The example worksheet provided in this appendix provides, as an aid for the reviewer, a process for documenting the basis for the assessment of the program elements contained in the GALL Report AMPs (Chapter XI of NUREG-1 801, 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.

The entire collection of the GALL Report AMP worksheets can be found at ADAMS Accession No. ML060950189. Table B-2 in the VYNPS LRA identifies the relationship of the VYNPS AMPs to the applicable GALL AMPs so that the appropriate worksheet can be selected by the project team reviewer.

F-1

Audit Worksheet GALL Report AMP Plant:

LRA AMP: Reviewer:

GALL AMP: X.EI, Environmental Qualification (EQ) of Electric Components Date:

Program Auditable GALL Criteria Documentation of Audit Finding Element Program A. The reanalysis of an aging evaluation is normally performed to extend the Consistent with GALL AMP: 0 Yes 0 No Description qualification by reducing excess conservatism incorporated in the prior Document(s) used to confirm Criteria:

evaluation. Reanalysis of an aging evaluation to extend the qualification of a component is performed on a routine basis pursuant to 10 CFR 50.49(e) as part of an EQ program. While a component life limiting condition may be due to thermal, radiation, or cyclical aging, the vast majority of component aging Comment:

limits are based on thermal conditions. Conservatism may exist in aging evaluation parameters, such as the assumed ambient temperature of the component, an unrealistically low activation energy, or in the application of a component (de-energized versus energized). The reanalysis of an aging evaluation is documented according to the station's quality assurance program requirements, which requires the verification of assumptions and conclusions. As already noted, important attributes of a reanalysis include analytical methods, data collection and reduction methods, underlying assumptions, acceptance criteria, and corrective actions (if acceptance criteria are not met).

B. All operating plants must meet the requirements of 10 CFR 50.49 for Consistent with GALL AMP: 0 Yes ONo certain electrical components important to safety. 10 CFR 50.49 defines the Document(s) used to confirm Criteria:

scope of components to be included, requires the preparation and maintenance of a list of in-scope components, and requires the preparation and maintenance of a qualification file that includes component performance specifications, electrical characteristics, and the environmental conditions to Comment:

which the components could be subjected. -

F-2

Program Auditable GALL Criteria Documentation of Audit Finding Element C. 10 CFR 50.49(e)(5) contains provisions for aging that require, in part, Consistent with GALL AMP: 0 Yes ONo consideration of all significant types of aging degradation that can affect Document(s) used to confirm Criteria:

component functional capability. 10 CFR 50.49(e) also requires replacement or refurbishment of components not qualified for the current license term prior to the end of designated life, unless additional life is established through ongoing qualification. Comment D. 10 CFR 50.49(o) establishes four methods of demonstrating qualification Consistent with GALL AMP: 0 Yes ONo for aging and accident conditions. Document(s) used to confirm Criteria:

Comment E. 10 CFR 50.49(k) and (I)permit different qualification criteria to apply Consistent with GALL AMP: 0 Yes ONo based on plant and component vintage. Supplemental EQ regulatory Document(s) used to confirm Criteria:

guidance for compliance with these different qualification criteria is provided in the DOR Guidelines, Guidelines for Evaluating Environmental Qualification of Class 1E Electrical Equipment in Operating Reactors; NUREG-0588, Interim Staff Position on Environmental Qualification of Safety-Related Comment Electrical Equipment; and Regulatory Guide 1.89, Rev. 1, Environmental Qualification of Certain Electric Equipment Important to Safety for Nuclear Power Plants. Compliance with 10 CFR 50.49 provides reasonable assurance that the component can perform its intended functions during accident conditions after experiencing the effects of inservice aging.

F. EQ programs manage component thermal, radiation, and cyclical aging Consistent with GALL AMP: 0 Yes ONo through the use of aging evaluallons based on 10 CFR 50.49(f) qualification Document(s) used to confirm Criteria:

methods. As required by 10 CFR 50.49, EQ components not qualified for the current license term are to be refurbished, replaced, or have their qualification extended prior to reaching the aging limits established in the evaluation. Aging evaluations for EQ components that specify a qualification Comment of at least 40 years are considered time-limited aging analyses (TLAAs) for license renewal.

F-3

Program Auditable GALL Criteria Documentation of Audit Finding Element G. Under 10 CFR 54.21(c)(1)(iii), plant EQ programs, which implement the Consistent with GALL AMP: 0 Yes ONo requirements of 10 CFR 50.49 (as further defined and clarified by the DOR Document(s) used to confirm Criteria:

Guidelines, NUREG-0588, and Regulatory Guide 1.89, Rev. 1), are viewed as aging management programs (AMPs) for license renewal. Reanalysis of an aging evaluation to extend the qualification of components under 10 CFR 50.49(e) is performed on a routine basis as part of an EQ program. Comment Important attributes for the reanalysis of an aging evaluation include analytical methods, data collection and reduction methods, underlying assumptions, acceptance criteria, and corrective actions (if acceptance criteria are not met). These attributes are discussed in the "EQ Component Reanalysis Attributes" section.

H. This reanalysis program can be applied to EQ components now qualified Consistent with GALL AMP: 0 Yes ONo for the current operating term (i.e., those components now qualified for 40 Document(s) used to confirm Criteria:

years or more). As evaluated below, this is an acceptable AMP. Thus, no further evaluation is recommended for license renewal if an applicant elects this option under 10 CFR 54.21 (c)(1)(iii) to evaluate the TLAA of EQ of electric equipment. Comment A. The reanalysis of an aging evaluation is normally performed to extend the Consistent with GALL AMP: 0 Yes ONo qualification by reducing excess conservatism incorporated in the prior Document(s) used to confirm Criteria:.

evaluation. Reanalysis of an aging evaluation to extend the qualification of a component is performed on a routine basis pursuant to 10 CFR 50.49(e) as part of an EQ program. While a component life limiting condition may be due to thermal, radiation, or cyclical aging, the vast majority of component aging Comment EQ Component limits are based on thermal conditions. Conservatism may exist in aging Reanalysis evaluation parameters, such as the assumed ambient temperature of the Attributes component, an unrealistically low activation energy, or in the application of a component (de-energized versus energized). The reanalysis of an aging evaluation is documented according to the station's quality assurance program requirements, which requires the verification of assumptions and conclusions. As already noted, important attributes of a reanalysis include analytical methods, data collection and reduction methods, underlying assumptions, acceptance criteria, and corrective actions (if acceptance criteria are not met).

F-4

Program Auditable GALL Criteria Documentation of Audit Finding Element B. Analytical Methods: The analytical models used in the reanalysis of an Consistent with GALL AMP: 0 Yes ONo aging evaluation are the same as those previously applied during the prior Document(s) used to confirm Criteria:

evaluation. The Arrhenius methodology is an acceptable thermal model for performing a thermal aging evaluation. The analytical method used for a radiation aging evaluation is to demonstrate qualification for the total integrated dose (that is, normal radiation dose for the projected installed life Comment:

plus accident radiation dose). For license renewal, one acceptable method of establishing the 60-year normal radiation dose is to multiply the 40-year normal radiation dose by 1.5 (that is, 60 years/40 years). The result is added to the accident radiation dose to obtain the total integrated dose for the component. For cyclical aging, a similar approach may be used. Other models may be justified on a case-by-case basis.

C. Data Collection and Reduction Methods: Reducing excess conservatism Consistent with GALL AMP: 0 Yes ONo in the component service conditions (for example, temperature, radiation, Document(s) used to confirm Criteria:

cycles) used in the prior aging evaluation is the chief method used for a reanalysis. Temperature data used in an aging evaluation is to be conservative and based on plant design temperatures or on actual plant temperature data. When used, plant temperature data can be obtained in Comment several ways, including monitors used for technical specification compliance, other installed monitors, measurements made by plant operators during rounds, and temperature sensors on large motors (while the motor is not running). A representative number of temperature measurements are conservatively evaluated to establish the temperatures used in an aging evaluation. Plant temperature data may be used in an aging evaluation in different ways, such as (a) directly applying the plant temperature data in the evaluation, or (b) using the plant temperature data to demonstrate conservatism when using plant design temperatures for an evaluation. Any changes to material activation energy values as part of a reanalysis are to be justified on a plant-specific basis. Similar methods of reducing excess conservatism in the component service conditions used in prior aging evaluations can be used for radiation and cyclical aging.

F-5

Program Auditable GALL Criteria Documentation of Audit Finding Element D. Underlying Assumptions: EQ component aging evaluations contain Consistent with GALL AMP: 0 Yes ONo sufficient conservatism to account for most environmental changes occurring Document(s) used to confirm Criteria:

due to plant modifications and events. When unexpected adverse conditions are identified during operational or maintenance activities that affect the normal operating environment of a qualified component, the affected EQ component is evaluated and appropriate corrective actions are taken, which Comment may include changes to the qualification bases and conclusions.

E. Acceptance Criteria and Corrective Actions: The reanalysis of an aging Consistent with GALL AMP: 0 Yes ONo evaluation could extend the qualification of the component. If the Document(s) used to confirm Criteria:

qualification cannot be extended by reanalysis, the component is to be refurbished, replaced, or requalified prior to exceeding the period for which the current qualification remains valid. A reanalysis is to be performed in a timely manner (that is, sufficient time is available to refurbish, replace, or Comment requalify the component if the reanalysis is unsuccessful).

1. Scope of A. EQ programs apply to certain electrical components that are important to Consistent with GALL AMP: 0 Yes ONo Program safety and could be exposed to harsh environment accident conditions, as Document(s) used to confirm Criteria:

defined in 10 CFR 50.49 and Regulatory Guide 1.89, Revision 1.

Comment

2. Preventive A. 10 CFR 50.49 does not require actions that prevent aging effects. EQ Consistent with GALL AMP: 0 Yes ONo Actions program actions that could be viewed as preventive actions include (a) Document(s) used to confirm Criteria:

establishing the component service condition tolerance and aging limits (for example, qualified life or condition limit) and (b) where applicable, requiring specific installation, inspection, monitoring or periodic maintenance actions to maintain component aging effects within the bounds of the qualification Comment:

basis.

3. Parameters A. EQ component qualified life is not based on condition or performance Consistent with GALL AMP: 0 Yes ONo Monitored/ monitoring. However, pursuant to Regulatory Guide 1.89, Rev. 1, such Document(s) used to confirm Criteria:

Inspected monitoring programs are an acceptable basis to modify a qualified life through reanalysis. Monitoring or inspection of certain environmental conditions or component parameters may be used to ensure that the component is within the bounds of its qualification basis, or as a means to Comment:

modify the qualified life.

F-6

Program Auditable GALL Criteria Documentation of Audit Finding Element

4. Detection of A. 10 CFR 50.49 does not require the detection of aging effects for in-service Consistent with GALL AMP: 0 Yes ONo Aging Effects components. Monitoring or inspection of certain environmental conditions or Document(s) used to confirm Criteria:

component parameters may be used to ensure that the component is within the bounds of its qualification basis, or as a means to modify the qualified life.

Comment:

5. Monitoring A. 10 CFR 50.49 does not require monitoring and trending of component Consistent with GALL AMP: 0 Yes ONo and Trending condition or performance parameters of in-service components to manage Document(s) used to confirm Criteria:

the effects of aging. EQ program actions that could be viewed as monitoring include monitoring how long qualified components have been installed.

Monitoring or inspection of certain environmental, condition, or component parameters may be used to ensure that a component is within the bounds of Comment:

its qualification basis, or as a means to modify the qualification.

6. Acceptance A. '10 CFR 50.49 acceptance criteria are that an inservice EQ component is Consistent with GALL AMP: 0 Yes ONo Criteria maintained within the bounds of its qualification basis, including (a) its Document(s) used to confirm Criteria:

established qualified life and (b) continued qualification for the projected accident conditions. 10 CFR 50.49 requires refurbishment, replacement, or requalification prior to exceeding the qualified life of each installed device.

Comment:

B. When monitoring is used to modify a component qualified life, Consistent with GALL AMP: 0 Yes ONo plant-specific acceptance criteria are established based on applicable Document(s) used to confirm Criteria:

10 CFR 50.49(f) qualification methods.

Comment:

F-7

Program Auditable GALL Criteria Documentation of Audit Finding Element

7. Corrective A. If an EQ component is found to be outside the bounds of its qualification Consistent with GALL AMP: 0 Yes ONo Actions basis, corrective actions are implemented in accordance with the station's Document(s) used to confirm Criteria:

corrective action program. When unexpected adverse conditions are identified during operational or maintenance activities that affect the environment of a qualified component, the affected EQ component is evaluated and appropriate corrective actions are taken, which may include Comment:

changes to the qualification bases and conclusions. When an emerging industry aging issue is identified that affects the qualification of an EQ component, the affected component is evaluated and appropriate corrective actions are taken, which may include changes to the qualification bases and conclusions. Confirmatory actions, as needed, are implemented as part of the station's corrective action program, pursuant to 10 CFR 50, Appendix B.

As discussed in the appendix to this report, the staff finds the requirements of 10 CFR Part 50, Appendix B, acceptable to address the corrective actions.

8. Confirmation A. Confirmatory actions, as needed, are implemented as part of the station's Consistent with GALL AMP: 0 Yes ONo Process corrective action program, pursuant to 10 CFR 50, Appendix B. As discussed Document(s) used to confirm Criteria:

in the appendix to this report, the staff finds the requirements of 10 CFR Part 50, Appendix B, acceptable to address the confirmation process.

Comment:

9. A. EQ programs are implemented through the use of station policy, Consistent with GALL AMP: 0 Yes [No Administrative directives, and procedures. EQ programs will continue to comply with Document(s) used to confirm Criteria:

Controls 10 CFR 50.49 throughout the renewal period, including development and maintenance of qualification documentation demonstrating reasonable assurance that a component can perform required functions during harsh accident Conditions. EQ program documents identify the applicable Comment:

environmental conditions for the component locations. EQ program qualification files are maintained at the plant site in an auditable form for the duration of the installed life of the component. EQ program documentation is controlled under the station's quality assurance program. As discussed in the appendix to this report, the staff finds the requirements of 10 CFR Part 50, Appendix B, acceptable to address the administrative controls.

10. Operating A. EQ programs include consideration of operating experience to modify Consistent with GALL AMP: 0 Yes ONo Experience qualification bases and conclusions, including qualified life. Compliance with Document(s) used to confirm Criteria:

10 CFR 50.49 provides reasonable assurance that components can perform their intended functions during accident conditions after experiencing the effects of inservice aging. Comment:

F-8

EXCEPTIONS Item Program LRA Exception Description Basis for Accepting Exception Documents Reviewed Number Elements (Identifier, Para. # andlor Page #)

2.

ENHANCEMENTS Item Program LRA Enhancement Description Basis for Accepting Enhancement Documents Reviewed Number Elements (Identifier, Para.# and/or Page #)

2.

DOCUMENTS REVIEWED DURING AUDIT Document Number Identifier (number) Title Revision and/or Date 2.

3.

,4.

F-9

. Appendix G Plant-Specific AMP Audit/Review Worksheet

Appendix G Plant-Specific AMP Audit/Review Worksheet The example 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 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.

G-1

AUDIT WORKSHEET GALL REPORT AMP Plant:

LRA AMP: Reviewer:

GALL AMP: Plant-sDecific Proaram Date:

Program Auditable GALL Criteria Documentation of Audit Finding Element Program Description

1. Scope of A. The specific program necessary for license renewal should be identified. Consistent with GALL AMP: 0 Yes 0 No Program The scope of the program should include the specific structures and Document(s) used to confirm Criteria:

components of which the program manages the aging.

Comment:

2. Preventive A. The activities for prevention and mitigation programs should be described. Consistent with GALL AMP: 0 Yes 0 No Actions These actions should mitigate or prevent aging degradation. Document(s) used to confirm Criteria:

Comment:

B. For condition or performance monitoring programs, they do not rely on Consistent with GALL AMP: 0 Yes C] No preventive actions and thus, this information need not be provided. More than Document(s) used to confirm Criteria:

one type of aging management program may be implemented to ensure that aging effects are managed.

Comment:

3. Parameters A. The parameters to be monitored or inspected should be identified and Consistent with GALL AMP: 0 Yes 0 No Monitored/ linked to the degradation of the particular structure and component intended Document(s) used to confirm Criteria:

Inspected function(s).

Comment:

G-2

Program Auditable GALL Criteria Documentation of Audit Finding Element B. For a condition monitoring program, the parameter monitored or inspected Consistent with GALL AMP: 0 Yes 0 No should detect the presence and extent of aging effects. Some examples are Document(s) used to confirm Criteria:

measurements of wall thickness and detection and sizing of cracks.

Comment:

C. For a performance monitoring program, a link should be established Consistent with GALL AMP: 0 Yes 0] No between the degradation of the particular structure or component intended Document(s) used to confirm Criteria:

function(s) and the parameter(s) being monitored. A performance monitoring program may not ensure the structure and component intended function(s) without linking the degradation of passive intended functions with the Comment:

performance being monitored.

D. For prevention and mitigation programs, the parameters monitored should Consistent with GALL AMP: 0 Yes 0 No be the specific parameters being controlled to achieve prevention or Document(s) used to confirm Criteria:

mitigation of aging effects.

Comment:

4. Detection of A. The parameters to be monitored or inspected should be appropriate to Consistent with GALL AMP: 0 Yes 0 No Aging Effects ensure that the structure and component intended function(s) will be Document(s) used to confirm Criteria:

adequately maintained for license renewal under all CLB design conditions.

Comment:

B. Provide information that links the parameters to be monitored or inspected Consistent with GALL AMP: 0 Yes 0 No to the aging effects being managed. Document(s) used to confirm Criteria:

Comment:

C. Thus, the effects of aging on a structure or component should be managed Consistent with GALL AMP: 0 Yes 0 No to ensure its availability to perform its intended function(s) as designed when Document(s) used to confirm Criteria:

called upon.

Comment:

D. A program based solely on detecting structure and component failure Consistent with GALL AMP: 0 Yes 0 No should not be considered as an effective aging management program for Document(s) used to confirm Criteria:

license renewal.

Comment:

G-3

Program Auditable GALL Criteria Documentation of Audit Finding Element E. This program element describes "when," "where," and "how" program data Consistent with GALL AMP: 0 Yes 0 No are collected (i.e., all aspects of activities to collect data as part of the Document(s) used to confirm Criteria:

program).

Comment:

F. Provide justification, including codes and standards referenced, that the Consistent with GALL AMP: 0 Yes 0 No technique and frequency are adequate to detect the aging effects before a Document(s) used to confirm Criteria:

loss of SC intended function. A program based solely on detecting SC failures is not considered an effective aging management program.

Comment:

G. When sampling is used to inspect a group of SCs, provide the basis for the Consistent with GALL AMP: 0 Yes 0] No inspection population and sample size. The inspection population should be Document(s) used to confirm Criteria:

based onsuch aspects of the SCs as a similarity of materials of construction, fabrication, procurement, design, installation, operating environment, or aging effects. The sample size should be based on such aspects of the SCs as the Comment:

specific aging effect, location, existing technical information, system and structure design, materials of construction, service environment, or previous failure history.

H. The samples should be biased toward concern in the period of extended Consistent with GALL AMP: 0 Yes 0 No operation. Provisions should also be included on expanding the sample size Document(s) used to confirm Criteria:

when degradation is detected in the initial sample.

Comment:

5. Monitoring A. Monitoring and trending activities should be described, and they should Consistent with GALL AMP: 0 Yes 0 No and Trending provide predictability of the extent of degradation and thus effect timely Document(s) used to confirm Criteria:

corrective or mitigative actions. Plant-specific and/or industry-wide operating experience may be considered in evaluating the appropriateness of the technique and frequency.

Comment:

B. This program element describes"how" the data collected are evaluated Consistent with GALL AMP: 0 Yes 0 No and may also include trending fora forward look. This includes an evaluation Document(s) used to confirm Criteria:

of the results against the acceptance criteria and a prediction regarding the rate of degradation in order to confirm that timing of the next scheduled inspection will occur before a loss of SC. intended function.

Comment:

G-4

Program Auditable GALL Criteria Documentation of Audit Finding Element C. The parameter or indicator trended should be described. Consistent with GALL AMP: 0 Yes 0 No Document(s) used to confirm Criteria:

Comment:

D. The methodology for analyzing the inspection or test results against the Consistent with GALL AMP: 0 Yes 0 No acceptance criteria should be described. Document(s) used to confirm Criteria:

Comment:

E. Trending is a comparison of the current monitoring results with previous Consistent with GALL AMP: 0 Yes 0 No monitoring results in order to make predictions for the future. Document(s) used to confirm Criteria:

Comment:

E. Trending is a comparison of the current monitoring results with previous Consistent with GALL AMP: 0 Yes 0 No monitoring results in order to make predictions for the future. Document(s) used to confirm Criteria:

Comment:

6. Acceptance A. The acceptance criteria of the program and its basis should be described. Consistent with GALL AMP: 0 Yes 0 No Criteria Document(s) used to confirm Criteria:

Comment:

B. The acceptance criteria, against which the need for corrective actions will Consistent with GALL AMP: 0 Yes 0 No be evaluated, should ensure that the structure and component intended Document(s) used to confirm Criteria:

function(s) are maintained under all CLB design conditions during the period of extended operation.

Comment:

C. The program should include a methodology for analyzing the results Consistent with GALL AMP: 0 Yes 0 No against applicable acceptance criteria. Document(s) used to confirm Criteria:

Comment:

G-5

Program Auditable GALL Criteria Documentation of Audit Finding Element D. Corrective action is taken, such as piping replacement, before reaching Consistent with GALL AMP: 0 Yes 0 No this acceptance criterion. Document(s) used to confirm Criteria:

Comment:

E. Acceptance criteria could be specific numerical values, or could consist of Consistent with GALL AMP: 0 Yes 0 No a discussion of the process for calculating specific numerical values of Document(s) used to confirm Criteria:

conditional acceptance criteria to ensure that the structure and component intended function(s) will be maintained under all CLB design conditions.

Information from available references may be cited. Comment:

F. It is not necessary to justify any acceptance criteria taken directly from the Consistent with GALL AMP: 0 Yes 0 No design basis information that is included in the UFSAR because that is a part Document(s) used to confirm Criteria:

of the CLB. Also, it is not necessary to discuss CLB design loads ifthe acceptance criteria do not permit degradation because a structure and component without degradation should continue to function as originally Comment:

designed.

G. Acceptance criteria, which do permit degradation, are based on Consistent with GALL AMP: 0] Yes 0 No maintaining the intended function under all CLB design loads. Document(s) used to confirm Criteria:

Comment:

H. Qualitative inspections should be performed to same predetermined criteria Consistent with GALL AMP: 0 Yes 0 No as quantitative inspections by personnel in accordance with ASME Code and Document(s) used to confirm Criteria:

through approved site specific programs.

Comment:

7. Corrective A. Corrective actions, including root cause determination and Consistent with GALL AMP: 0 Yes 0 No Actions prevention of recurrence, should be timely. Document(s) used to confirm Criteria:

Comment:

G-6

Program Auditable GALL Criteria Documentation of Audit Finding Element

8. Confirmation A. Confirmation process should ensure that preventive actions are Consistent with GALL AMP: 0 Yes 0 No Process adequate and that appropriate corrective actions have been completed and Document(s) used to confirm Criteria:

are effective.

Comment:

9. A. Administrative controls should provide a formal review and Consistent with GALL AMP: 0 Yes 0 No Administrative approval process. Document(s) used to confirm Criteria:

Controls Comment:

10. Operating A. Operating experience with existing programs should be discussed. The Consistent with GALL AMP: 0 Yes 0 No Experience operating experience of aging management programs, including past Document(s) used to confirm Criteria:

corrective actions resulting in program enhancements or additional programs, should be considered. A past failure would not necessarily invalidate an aging management program because the feedback from operating experience should have resulted in appropriate program enhancements or new programs. Comment:

This information can show where an existing program has succeeded and where it has failed (if at all) in intercepting aging degradation in a timely manner. This information should provide objective evidence to support the conclusion that the effects of aging will be managed adequately so that the structure and component intended function(s) will be maintained during the period of extended operation.

G-7

EXCEPTIONS Item Program LRA Exception Description Basis for Accepting Exception Documents Reviewed Number Elements (Identifier, Para.# and/or Page #)

2.

ENHANCEMENTS Item Program LRA Enhancement Description Basis for Accepting Enhancement Documents Reviewed Number Elements (Identifier, Para.# and/or Page #)

2.

Document Reviewed During Audit Document Number Identifier (number) Title Revision and/or Date 2.

3.

oo____________________________________________

4.

G-8

Appendix H Aging Management Review Worksheets

Appendix H Aging Management Review Worksheets The project team reviewer should document its AMR reviews determination in spreadsheets of the Table 1 and Table 2 AMR line items. The documentation should contain the same information as would have been captured in the Table provided in this appendix.

The project team reviewer should use the tables provided in this appendix if the electronic spreadsheet format is not used.

H-1

VYNPS 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 in Table 1 were reviewed and are addressed in the following table.

Further Evaluation Discussion Recommended 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.

4.

H-2

VYNPS 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 Component No. Type Material Environment Aging Effect Note Discussion (draft as Audit Report input)

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

No. Question for applicant (draft per RAI guidance) Response (with date)

References/Documents Used:

5.

6.

7.

H-3"

Appendix I Abbreviations and Acronyms ADAMS Agencywide Documents Access and Management System AMP aging management program AMR aging management review ASME American Society of Mechanical Engineers B&PV boiler and pressure vessel BTP Branch Technical Position BWR boiling water reactor CASS cast austenitic stainless steel CII containment inservice inspection CLB current licensing basis CVUSE charpy upper-shelf energy DCI Divisions of Component Integrity DE Division of Engineering DLR Division of License Renewal EQ environmental qualification FSAR final safety analysis report GALL Generic Aging Lessons Learned GL Generic Letter HAZ heat affected zone ISG interim staff guidance ISG-LR Interim Staff Guidance for License Renewal ISI inservice inspection ISL Information Systems Laboratories, Inc.

LRA license renewal application NEI Nuclear Energy Institute NRC U.S. Nuclear Regulatory Commission NRR Office of Nuclear Reactor Regulation RAI request for additional information RLRC License Renewal Branch C RLSB License Renewal and Standardization Branch SC structures and components I-1

SER safety evaluation report SRP-LR Standard Review Plan-License Renewal SRV safety relief valve SSC systems, structures, and components TLAA time-limited aging analysis UFSAR updated final safety analysis report VY Vermont Yankee VYNPS Vermont Yankee Nuclear Power Station 1-2

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