ML072610107

Rev. 0 to Audit and Review Plan for Plant Aging Management Programs, Reviews and Time-Limited Aging Analyses, Vogtle Electric Generating Plant, Units 1 and 2

ML072610107
Person / Time
Site:	Vogtle
Issue date:	09/17/2007
From:	NRC/NRR/ADRO
To:
Mathew R, K, NRR/DLR/RLRC, 415-2965
Shared Package
ML072610121	List: ML072610107
References
Download: ML072610107 (78)

Text

Audit and Review Plan for Plant Aging Management Programs, Reviews and Time-Limited Aging Analyses Vogtle Electric Generating Plant Units 1 and 2 Docket Nos. 50-424 and 50-425 September 17, 2007 Revision 0

ii TABLE OF CONTENTS

1.

INTRODUCTION............................................................................................................5

2.

BACKGROUND..............................................................................................................6

3.

OBJECTIVES.................................................................................................................8

4.

SUMMARY

OF INFORMATION PROVIDED IN THE LICENSE RENEWAL APPLICATION................................................................................................................9 4.1 Aging Management Review Results................................................................................9 4.1.1 VEGP AMR Comparison with the GALL Report................................................10 4.1.2 Plant-Specific Programs....................................................................................13 4.2 Time-Limited Aging Analyses........................................................................................13

5.

OVERVIEW OF AUDIT, REVIEW, AND DOCUMENTATION PROCEDURE................15 5.1 Aging Management Programs......................................................................................16 5.2 Aging Management Reviews.........................................................................................16 5.3 Time-Limited Aging Analyses........................................................................................16 5.4 FSAR Supplement Review............................................................................................17 5.5 Documents Reviewed by the Project Team..................................................................17 5.6 Status Meeting..............................................................................................................18 5.7 Documentation Prepared by the Project Team.............................................................18 5.7.1 Audit and Review Plan......................................................................................18 5.7.2 Worksheets.......................................................................................................18 5.7.3 Questions..........................................................................................................18 5.7.4 Work Packages.................................................................................................18 5.7.5 Requests for Additional Information...................................................................18 5.7.6 Audit and Review Summary..............................................................................19 5.7.7 Safety Evaluation Report Input..........................................................................19

6.

PLANNING, AUDIT, REVIEW, AND DOCUMENTATION PROCEDURE......................19 6.1 Planning Activities.........................................................................................................19 6.1.1 Schedule for Key Milestones and Activities.......................................................19 6.1.2 Work Assignments............................................................................................20 6.1.3 Training and Preparation...................................................................................20 6.2 Aging Management Program Audits and Reviews........................................................21 6.2.1 Types of AMPs..................................................................................................21 6.2.2 Scope of AMP Program Elements to be Audited and Reviewed........................21 6.2.3 Plant AMPs that are Consistent with the GALL Report......................................21 6.2.4 Plant-Specific AMPs..........................................................................................23 6.3 Aging Management Review Audits and Reviews..........................................................25 6.3.1 Plant AMRs that are Consistent with the GALL Report......................................25 6.3.2 Plant AMRs that Are Not Consistent with the GALL Report...............................28 6.4 Time-Limited Aging Analyses Audits and Reviews........................................................28 6.4.1 Identify Generic TLAA Issues............................................................................28

iii 6.4.2 Metal Fatigue.....................................................................................................31 6.4.3 Environmental Qualification of Equipment.........................................................33 6.4.4 Concrete Containment Tendon Prestress..........................................................35 6.4.5 Penetration Load Cycles...................................................................................37 6.4.6 Other Plant-Specific TLAAs...............................................................................40 6.5 Audit and Safety Review Documentation......................................................................42 6.5.1 Audit and Review Summary..............................................................................42 6.5.2 Safety Evaluation Report Input..........................................................................42 6.6 Documents Reviewed and Document Retention...........................................................47 Appendix A Project Team Members...................................................................................... A-1 Appendix B RLRC Schedule for VEGP LRA Safety Review.................................................. B-1 Appendix C Aging Management Program Assignments........................................................ C-1 Appendix D Aging Management Review Assignments.......................................................... D-1 Appendix E Time-Limited Aging Analysis Review Assignments............................................. E-1 Appendix F Consistent With GALL Report AMP Audit/Review Worksheet.............................F-1 Appendix G Plant-Specific AMP Audit/Review Worksheet.....................................................G-1 Appendix H Aging Management Review Comparison Worksheets........................................ H-1 Appendix I Acronyms, Abbreviations, and Initialisms...............................................................I-1

iv TABLES Table 1. Aging Management Program Element Descriptions..................................................48 Table 2. Notes for License Renewal Application Tables 3.X.2-Y.............................................49 FIGURES Figure 1. Audit of AMPs that are Consistent with the GALL Report.........................................50 Figure 2. Audit of Plant-Specific AMPs....................................................................................51 Figure 3. Review of AMRs that are Consistent with the GALL Report.....................................52 Figure 4. Review of TLAAs and Exemptions (from NEI 95-10, Revision 6)..............................53

5 Audit and Review Plan for Plant Aging Management Programs and Reviews Vogtle Electric Generating Plant Units 1 and 2

1.

INTRODUCTION By letter dated, June 29, 2007, Southern Nuclear Operating Company, Inc. (the applicant),

submitted to the U.S. Nuclear Regulatory Commission (NRC) its application for renewal of Operating License Nos. NPF-68 and NPF-81 for the Vogtle Electric Generating Plant (VEGP)

Units 1 and 2, respectively. The applicant requested renewal of the 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 VEGP, the Division of License Renewal (DLR), Branch C (RLRC), will lead a project team that will audit and review selected aging management reviews (AMRs) and associated aging management programs (AMPs), and time-limited aging analyses (TLAAs) developed by the applicant to support its LRA for VEGP. The project team will include NRC staff and engineers provided by Information Systems Laboratories, Inc. (ISL), RLRCs technical assistance contractor.

Appendix A, Project Team Members, lists the project team members. This document is the RLRC plan for auditing and reviewing plant aging management reviews and aging management programs for VEGP.

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

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

The project team will perform its work at NRC Headquarters, Rockville, Maryland; at ISLs offices in Rockville, Maryland; and at the VEGP site in Waynesboro, Georgia. The project team will perform its work in accordance with the schedule shown in Appendix B, RLRC Schedule for VEGP LRA Safety Review.

This plan includes the following information:

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

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

Vogtle Electric Generating Plant Audit and Review Plan for AMRs, AMPs, and TLAAs 6

Summary of Information Provided in License Renewal Application. Description of the information contained in the license renewal application for VEGP that is applicable to this audit and review 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 VEGP LRA information that is within its scope of review.

Planning, Audit, Review, and Documentation Procedure. The procedure that the project team will use to plan and schedule its work, to audit and review the VEGP 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 teams work assignments are shown in Appendix C, Aging Management Program Assignments, Appendix D, Aging Management Review Assignments, and Appendix E, Time-Limited Aging Analysis Review Assignments. Appendices F, G, and H are the worksheets that the individual project team members use to informally document the results of their audit and review work. The application of these worksheets is discussed in Section 6 of this audit and review plan. Appendix I is a list of the acronyms, abbreviations, and initialisms used in this audit and review plan.

2.

BACKGROUND In 10 CFR 54.4, the scope of license renewal is defined as those structures, systems, and components (SSCs) (1) that are safety-related, (2) whose failure could affect safety-related functions, and (3) that are relied on to demonstrate compliance with the NRCs 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(s) 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 plants SSCs. In accordance with 10 CFR 54.21(c)(1), the applicant must either show that these calculations will remain valid for the period of extended operation, project the analyses to the end of the period of extended operation, or demonstrate that the effects of aging on these SSCs can be adequately managed for the period of extended operation.

In addition, 10 CFR 54.21(d) requires that the applicant submit a supplement to the final safety analysis report (FSAR) that contains a summary description of the programs and activities that it credited to manage the effects of aging and the evaluation of time-limited aging analyses for

Vogtle Electric Generating Plant Audit and Review Plan for AMRs, AMPs, and TLAAs 7

the extended period of operation.

The SRP-LR provides staff guidance for reviewing applications for license renewal. The GALL Report is a technical basis document. It summarizes staff-approved AMPs for the aging management of a large number of SCs that are subject to an AMR. It also summarizes the aging management evaluations, programs, and activities acceptable to the NRC staff for managing aging of most of the SCs used in commercial nuclear power plants, and serves as a reference for both the applicant and staff reviewers to quickly identify those AMPs and activities that the staff has determined will provide adequate aging management during the period of extended operation. If an applicant commits to implementing these staff-approved AMPs, the time, effort, and resources needed to review an applicants LRA will be greatly reduced, thereby improving the efficiency and effectiveness of the license renewal review process. The GALL Report identifies (1) SSCs, (2) component materials, (3) environments to which the components are exposed, (4) 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 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 applicants facility, the staff will accept the applicants reference to the GALL Report. In making this determination, the staff considers whether the applicant has identified specific programs described and evaluated in the GALL Report but does not conduct a review of the substance of the matters described in the GALL Report. Rather, the staff confirms that the applicant verified that the approvals set forth in the GALL Report apply to its programs.

If an applicant takes credit for a GALL 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 TLAAs. Pursuant to 10 CFR 54.21(c)(1), a license renewal application is required to provide a list of TLAAs, as defined in 10 CFR 54.3. In addition, the applicant must provide a list of plant-specific exemptions granted under 10 CFR 50.12 that are based on TLAAs. The number and type of TLAAs vary depending on the plant-specific CLB. All six criteria set forth in 10 CFR 54.3 must be satisfied to conclude that a calculation or analysis is a TLAA.

Pursuant to 10 CFR 54.3, TLAAs are those licensee calculations and analyses that:

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

2. Consider the effects of aging.

Vogtle Electric Generating Plant Audit and Review Plan for AMRs, AMPs, and TLAAs 8

3. Involve time-limited assumptions defined by the current operating term, for example, 40 years.

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

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

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

Finally, the applicant must demonstrate that the TLAAs remain valid for the period of extended operation; the TLAAs have been projected to the end of the period of extended operation; or the 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 verify 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 teams 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 VEGP is described in Sections 5 and 6 of this audit and review plan. It is intended to accomplish the following objectives:

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

For VEGP AMPs that the applicant claims are consistent with GALL Report AMPs with exceptions, verify 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, verify that the applicant has documented an acceptable technical basis for each exception.

For VEGP AMPs that the applicant claims will be consistent with GALL Report AMPs after specified enhancements are implemented, verify that the plant AMPs, with the enhancements, will be consistent with the referenced GALL Report AMPs, or are acceptable on the basis of a technical review. In addition, verify that the applicant identified the enhancements as commitments in the FSAR or other docketed correspondence.

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.

Vogtle Electric Generating Plant Audit and Review Plan for AMRs, AMPs, and TLAAs 9

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 are 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 evaluated the AMRs in accordance with the SRP-LR.

For TLAAs, determine that the applicant has properly identified the TLAAs. TLAAs are certain plant-specific safety analyses that are based on explicitly assumed 40-year plant life (for example, aspects of the reactor vessel design). Pursuant to 10 CFR 54.21(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 plants operating license. As indicated in 10 CFR 54.30, the adequacy of the plants CLB, which includes TLAAs, is not an area within the scope of the license renewal review. Any question regarding the inadequacy of the CLB must be addressed under the backfit rule (10 CFR 50.109) and is separate from the license renewal process.

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

4.

SUMMARY

OF INFORMATION PROVIDED IN THE LICENSE RENEWAL APPLICATION 4.1 Aging Management Review Results The VEGP LRA closely follows the standard LRA format presented in Nuclear Energy Institute (NEI) NEI 95-10, Industry Guideline for Implementing the Requirements of 10 CFR Part 54 -

The License Renewal Rule, Revision 6, June 2005. Section 3 of the VEGP 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 in the VEGP LRA addressed time-limited aging analyses.

VEGP LRA Table 3.0-1 provides descriptions of the service environments used in the AMRs to determine the aging effects requiring management. Results of the AMRs are presented in two different types of tables. The applicant refers to the two types of tables as Table 1 and Table 2.

The first table type is a series of six tables labeled Table 3.X.1, where X is the system/component group number (see table below), and 1 indicates it is a Table 1 type. For example, in the reactor coolant system subsection of VEGP LRA Section 3, this is Table 3.1.1, and in the engineered safety features subsection of VEGP 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

Vogtle Electric Generating Plant Audit and Review Plan for AMRs, AMPs, and TLAAs 10 tables are derived from the corresponding tables in NUREG-1801, Volume 1, and present summary information from the AMRs.

Definition 1

Reactor Vessel, Internals, and Reactor Coolant System 2

Engineered Safety Features Systems 3

Auxiliary Systems 4

Steam and Power Conversion Systems 5

Containments, Structures, and Component Supports 6

Electrical and Instrumentation and Controls Components The second table type is a series of tables labeled Table 3.X.2-Y, where X is the system/component group number, 2 indicates it is a Table 2 type, and Y indicates the subgroup number within group X. For example, within the reactor coolant system subsection, the AMR results for the reactor vessel and internals are presented in VEGP LRA Table 3.1.2-1, and the results for the reactor coolant system and connected lines are presented in VEGP LRA Table 3.1.2-3. In the engineered safety features subsection, the containment spray system results are presented in VEGP LRA Table 3.2.2-1, and the emergency core cooling system is in VEGP LRA Table 3.2.2-2. For ease of discussion, these table types will hereafter be referred to as Table 2. These tables present the results of the AMRs.

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

To take full advantage of the GALL Report, VEGP AMR results have been compared with information set forth in the tables of NUREG-1801. Results of that comparison are provided in the following two table types, Table 1 and Table 2.

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

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

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

The Related Generic Item and Unique Item columns have been replaced by a Discussion column.

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

Vogtle Electric Generating Plant Audit and Review Plan for AMRs, AMPs, and TLAAs 11 Further information is provided in the Discussion column. The following are examples of information that might be contained within this column:

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

The name of a plant-specific program being used.

Exceptions to the NUREG-1801 assumptions.

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

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

4.1.1.2 Purpose of Table 2 Table 2 provides results of the aging management reviews for those structures and components identified in Section 2 of the LRA as being subject to aging management review.

There is a Table 2 for each aging management review within a NUREG-1801 system group.

For example, the engineered safety features system group contains tables specific to the containment spray system, the high head safety injection system, the low head safety injection and residual heat removal system, and the passive safety injection system.

Table 2 consists of the following nine columns:

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

The term piping in component lists may include pipe, pipe fittings (such as elbows and reducers), flow elements, orifices, and thermowells. If such components have unique tag numbers or the specific component has a function other than pressure boundary, then flow elements, orifices and thermowells are identified as a separate component type.

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

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

Vogtle Electric Generating Plant Audit and Review Plan for AMRs, AMPs, and TLAAs 12 Intended Function Column 2 identifies the license renewal intended functions (using abbreviations where necessary) for the listed component types. Definitions and abbreviations of intended functions are listed in Table 2.0-1 in Section 2.

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

Environment Column 4 lists the environment to which the component types are exposed. Internal/external service environments are indicated. A description of these environments is provided in Table 3.0-1.

Aging Effect Requiring Management (AERM)

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

Aging Management Programs (AMP)

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

NUREG-1801, Vol. 2, Item Column 7 documents identified consistencies by noting the appropriate NUREG-1801, Volume 2, item number. If there is no corresponding item number in NUREG-1801, Volume 2, for a particular combination of factors, Column 7 indicates None for this item.

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

Component type Material Environment Aging effect requiring management Aging management program Table 1 Item Column 8 lists the corresponding line item from Table 1. If there is no corresponding item in NUREG-1801, Volume 1, Column 8 is left blank.

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

Component type Material

Vogtle Electric Generating Plant Audit and Review Plan for AMRs, AMPs, and TLAAs 13 Environment Aging effect requiring management Aging management program Notes Column 9 contains notes that are used to describe the degree of consistency with the line items in NUREG-1801, Volume 2. Notes that use letter designations are standard notes based on a letter from A. Nelson, NEI, to P. T. Kuo, NRC, U.S. Nuclear Industrys Proposed Standard License Renewal Application Format Package, Request NRC Concurrence, dated January 24, 2003 (ML030290201). The staff concurred with the NEI standardized format for license renewal applications by letter dated April 7, 2003, from P. T. Kuo, NRC, to A. Nelson, NEI (ML030990052). Notes that use numeric designators are specific to VEGP.

VEGP LRA Table 2 contains the aging management review results and indicates whether the results correspond to line items in Volume 2 of the GALL Report. Correlations between the combination VEGP LRA Table 2 and a combination for a line item in Volume 2 of the GALL Report are identified by the GALL Report item number in Column 7. If None is indicated in Column 7, the applicant did not identify a corresponding combination in the GALL Report. If the applicant identified a GALL Report line item, the next column provides a reference to a Table 1 row number. This reference corresponds to the GALL Report, Volume 2, roll-up to the GALL Report, Volume 1, tables.

4.1.2 Plant-Specific Programs There are eleven plant-specific programs in the VEGP LRA.

4.2 Time-Limited Aging Analyses The VEGP 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 VEGP LRA addresses TLAAs in accordance with 10 CFR 54.3(a) and 54.21(c). In Section 4.1.2, the VEGP 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:

VEGP FSAR Docketed licensing correspondence Design basis documents and databases Applicable Southern Company Services, Inc, Westinghouse Electric Company, and Bechtel Corporation analyses and calculations Also, in Section 4.1.1, the VEGP LRA states that as required by 10 CFR 54.21(c)(1), an evaluation of VEGP-specific TLAAs must be performed to demonstrate that:

Vogtle Electric Generating Plant Audit and Review Plan for AMRs, AMPs, and TLAAs 14 (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 function(s) will be adequately managed for the period of extended operation.

In the VEGP LRA, the applicant summarized the results of the above evaluations in Table 4.1.2-1. These evaluations are discussed in subsequent sections of VEGP LRA Section 4.

Section 4.1.3 of the VEGP LRA identifies plant-specific exemptions. 10 CFR 54.21(c) also requires that the application for a renewed license includes a list of plant-specific exemptions granted pursuant to 10 CFR 50.12 and in effect that are based on TLAAs as defined in 10 CFR 54.3. VEGP performed this by reviewing docketed correspondence which identified VEGP exemptions. As a result of this review, one exemption was identified as meeting the definition of a TLAA. Two other exemptions were identified that are not based on TLAAs, but which permitted changes in the methods for analyses that are TLAAs. The analyses associated with these exemptions have been included in Table 4.1.2-1.

The VEGP LRA next includes a separate section for each of the identified TLAAs within the outline of the corresponding NUREG-1800 TLAA category. The TLAA categories are outlined in the following table.

TLAA Description 10 CFR 54.21(c)(1)

Paragraph Section Reactor Vessel Neutron Embrittlement 4.2 Neutron Fluence 54.21(c)(1)(ii) 4.2.1 Upper Shelf Energy 54.21(c)(1)(ii) 4.2.2 Pressurized Thermal Shock 54.21(c)(1)(ii) 4.2.3 Adjusted Reference Temperature 54.21(c)(1)(ii) 4.2.4 Pressure-Temperature Limits 54.21(c)(1)(ii) and (iii) 4.2.5 Metal Fatigue 4.3 Fatigue of ASME Class 1 Components 4.3.1 Class 1 Piping and Component Design Transient Cycles 54.21(c)(1)(i),

54.21(c)(1)(iii) 4.3.1.1 CUF Monitoring - SG Main and Auxiliary Feedwater Nozzles 54.21(c)(1)(iii) 4.3.1.2 CUF Monitoring - Charging Nozzles 54.21(c)(1)(iii) 4.3.1.3 Thermal Stratification of the Surge Line and Lower Pressurizer Head (IEB 88-11) 54.21(c)(1)(iii) 4.3.1.4 Effects of Reactor Coolant System Environment on Fatigue Life of Piping and Components (GSI-190) 4.3.1.5

Vogtle Electric Generating Plant Audit and Review Plan for AMRs, AMPs, and TLAAs 15 TLAA Description 10 CFR 54.21(c)(1)

Paragraph Section EAF Evaluation - Reactor Vessel Shell and Lower Head 54.21(c)(1)(i) 4.3.1.5.1 EAF Evaluation - Reactor Vessel Inlet and Outlet Nozzles 54.21(c)(1)(i) 4.3.1.5.2 EAF Evaluation - Surge Line Hot Leg Nozzle 54.21(c)(1)(iii) 4.3.1.5.3 EAF Evaluation - Charging Nozzle 54.21(c)(1)(iii) 4.3.1.5.4 EAF Evaluation - Safety Injection Nozzle 54.21(c)(1)(iii) 4.3.1.5.5 EAF Evaluation - RHR System Class 1 Piping 54.21(c)(1)(iii) 4.3.1.5.6 Full Structural Weld Overlays (FSWOL) on Pressurizer Spray Nozzles, Safety and Relief Nozzles, and Surge Line 4.3.1.6 High Energy Line Break Postulated Locations Based on Fatigue Cumulative Usage Factor 4.3.1.7 Fatigue of Non-ASME Class 1 Components 54.21(c)(1)(i) 4.3.2 Fatigue of the Reactor Coolant Pump Flywheel 54.21(c)(1)(i) 4.3.3 Fatigue of Reactor Vessel Supports 54.21(c)(1)(i) 4.3.4 Fatigue of SG Secondary Manway and Handhole Bolts 54.21(c)(1)(iii) 4.3.5 Fatigue of Reactor vessel Internals 54.21(c)(1)(i) 4.3.5.1 Environmental Qualification of Equipment 54.21(c)(1)(iii) 4.4 Concrete Containment Tendon Prestress 54.21(c)(1)(ii) 4.5 Penetration Load Cycles 54.21(c)(1)(i) 4.6 Other Plant-Specific Time-Limited Aging Analyses 4.7 Leak-Before-Break Analysis 54.21(c)(1)(i) 54.21(c)(1)(ii) 4.7.1 Fuel Storage Tank Corrosion Allowance 54.21(c)(1)(iii) 4.7.2 Steam Generator Tube, Loss of Material 54.21(c)(1)(iii) 4.7.3 Cold Overpressure Protection System 54.21(c)(1)(ii) 54.21(c)(1)(iii) 4.7.4

5.

OVERVIEW OF AUDIT, REVIEW, AND DOCUMENTATION PROCEDURE The project team will follow the procedure 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 covered by the procedure is summarized below.

Vogtle Electric Generating Plant Audit and Review Plan for AMRs, AMPs, and TLAAs 16 5.1 Aging Management Programs For the VEGP AMPs for which the applicant claimed consistency with the AMPs included in the GALL Report, the project team will review the VEGP AMP descriptions and compare program elements for the VEGP AMPs to the corresponding program elements for the GALL Report AMPs. The project team will verify that the VEGP AMPs contain the program elements of the referenced GALL Report program and that the conditions at the plant are bounded by the conditions for which the GALL Report program was evaluated. Table 1 of this audit and review plan summarizes the ten program elements that comprise an aging management program. The License Renewal Branch B (RLRB) will review and determine the adequacy of the applicants 10 CFR 50, Appendix B Program. Other aspects of these program elements will be reviewed by the project team.

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

5.2 Aging Management Reviews The AMRs in the VEGP LRA fall into three broad categories: (1) AMR results that are consistent with the GALL Report (i.e., those that the GALL Report concludes are adequate to manage aging of the components referenced in the GALL Report), (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, and (3) AMR results that are not consistent with or not addressed in the GALL Report. For the first category 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 AMRs reported by the applicant to be managed using plant-specific AMPs are technically acceptable. For the second category AMR review, for which the applicant claimed consistency with the GALL Report, and for which the GALL Report recommends further evaluation, the project team will review the applicants evaluation to determine if it adequately addressed the issues for which the GALL Report recommended further evaluation. For the third category AMR review, the project team will review the results of the AMRs for material, environment, AERM, and AMP combinations to determine the technical adequacy.

5.3 Time-Limited Aging Analyses Generally, the TLAAs in the VEGP LRA fall into the broad category of those that are consistent with the NUREG-1800 TLAA categories. However, there are 2 plant-specific exemptions identified in the VEGP LRA that depend on TLAAs.

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).

Vogtle Electric Generating Plant Audit and Review Plan for AMRs, AMPs, and TLAAs 17 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. Determined to be relevant by the applicant in making a safety determination.

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

6. Contained or incorporated by reference in the CLB.

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 Division 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)(1)(i) the analyses remain valid for the period of extended operation or 10 CFR 54.21(c)(1)(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)(1)(ii) - the analyses have been projected to the end of the period of extended operation, the audit team leader will be consulted to determine which TLAAs the audit team will be capable of reviewing.

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

A.

Reactor Vessel Neutron Embrittlement B.

Plant-Specific TLAAs 5.4 FSAR 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 FSAR supplement that summarizes the applicants programs and activities for managing the effects of aging for the extended period of operation.

The project team will also review any commitments associated with its programs and activities made by the applicant and verify that they are acceptable for the stated purpose. In addition, the project team will determine that the applicant identified the enhancements as commitments in the FSAR or other docketed correspondence.

5.5 Documents Reviewed by the Project Team In performing its work, the project team will rely heavily on the VEGP LRA, the audit and review plan, the SRP-LR, and the GALL Report. The project team will also examine the applicants

Vogtle Electric Generating Plant Audit and Review Plan for AMRs, AMPs, and TLAAs 18 precedent review documents, its AMP, AMR, and TLAA basis documents (catalogs of the documentation used by the applicant to develop or justify its AMPs, AMRs, and TLAAs), and other applicant documents, including selected implementing procedures, to verify that the applicants activities and programs will adequately manage the effects of aging on structures and components.

5.6 Status Meeting At the conclusion of its audits and reviews, the project team will debrief the applicants license renewal staff and management regarding the status of the audits and reviews of the LRA AMPs, AMRs and TLAAs assigned to the project team.

5.7 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 summary, and a safety evaluation report (SER) input. The project team will also prepare questions during site visits and will track the applicants responses to these questions.

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

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

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

5.7.4 Work Packages After each site visit, 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 Office of Nuclear Reactor Regulation (NRR) Division of Engineering (DE) or the Division of Component Integrity (DCI) 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.

5.7.5 Requests for Additional Information The review process described in this audit and review plan is structured to resolve as many questions as possible during the site visits. The site visits are used to obtain clarifications about the VEGP LRA and explanations as to where certain information may be found in the VEGP

Vogtle Electric Generating Plant Audit and Review Plan for AMRs, AMPs, and TLAAs 19 LRA or its associated documents. Nevertheless, there may be occasions where an RAI is appropriate to obtain information to support an SER finding. The need for RAIs will be determined by the project team leader during the in-office project staff review or during site visits through discussions with the individual project team members. When the project team leader determines that an RAI is needed, the project team member who is responsible for the area of review will prepare the RAI. RAIs will include the technical and regulatory basis for requesting the information.

After the NRC receives a response to an RAI from the applicant, the project team leader will provide the response to the project team member who prepared the RAI. The project team will review the response and determine if it resolves the issue that was the reason for the RAI. The project team member will document the disposition of the RAI in the SER input.

5.7.6 Audit and Review Summary At the conclusion of the audits and reviews, the project team will prepare a summary of the audits and reviews highlighting the status of its review and any potential RAIs.

5.7.7 Safety Evaluation Report Input The project team will prepare SER input, based on its audit and review, as described in Section 6.5.2 of this audit and review plan.

6.

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

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

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 site visits H.

Scheduling in-office review periods I.

Preparing questions J.

Preparing RAIs K.

Issuing audit and review summary report L.

Preparing draft and final SER input

Vogtle Electric Generating Plant Audit and Review Plan for AMRs, AMPs, and TLAAs 20 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 audit and review plan contains the target schedule for the key milestones and activities.

6.1.2 Work Assignments The NRC technical assistance contractor will propose 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 VEGP 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. Appendix E shows the project team member assignments for TLAAs.

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

A.

A description of the audit and review process.

B.

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

(1)

GALL Report (2)

SRP-LR (3)

Interim Staff Guidance for License Renewal (ISG-LR)

(4)

LRA AMPs (5)

LRA AMRs (6)

LRA TLAAs (7)

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

(8)

Implementing procedures (9)

Operating experience reports (10)

RAIs, audit and review reports, and SERs for similar plants (11)

Applicants FSAR C.

The protocol for interfacing with the applicant.

D.

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

E.

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

F.

Process for interfacing with NRC technical reviewers.

Vogtle Electric Generating Plant Audit and Review Plan for AMRs, AMPs, and TLAAs 21 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 audit and review plan shows the 10 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 RLRB will review and determine the adequacy of the applicants 10 CFR 50, Appendix B Program. Other aspects of these program elements will be reviewed by the project team.

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

Preparation A.

For the VEGP 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 and SERs for similar plants (5)

LRA (6)

Basis documents (7)

Implementation procedures (8)

Operating experience reports (plant-specific and industry)

(9)

Applicants FSAR

Vogtle Electric Generating Plant Audit and Review Plan for AMRs, AMPs, and TLAAs 22 Audit/Review A.

Confirm that the VEGP 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 elements consistent with the GALL Report AMP?

B.

If the above questions results 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 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 Electric Power Research Institute [EPRI] tools) and to confirm the effectiveness of aging management programs. The project team members should consider the industry guidance when assessing operating experience and formulating questions for the applicant. The industry guidance (from NEI 95-10, Revision 6) is as follows:

(1)

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

(2)

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

Vogtle Electric Generating Plant Audit and Review Plan for AMRs, AMPs, and TLAAs 23 (3)

Industry Operating Experience. Industry operating experience and its applicability should be assessed to determine whether it changes plant-specific determinations. NUREG-1801 is based upon industry operating experience prior to its date of issue. Operating experience after the issue date of NUREG-1801 should be evaluated and documented as part of the aging management review. In particular, generic communications such as a bulletin, a generic letter, or an information notice should be evaluated for impact upon the AMP. The evaluation should check for new aging effects or a new component or location experiencing an already identified aging effect.

E.

If it is necessary to ask the applicant a question to clarify the basis for accepting a 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 VEGP 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 There are 11 plant-specific AMPs in the VEGP LRA.

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

Pre-review preparation A.

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

B.

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

1.

GALL Report

2.

SRP-LR

3.

ISG-LR

4.

RAIs and SERs for similar plants

5.

LRA

6.

Basis documents

7.

Implementation procedures

8.

Operating experience reports (plant-specific and industry)

9.

FSAR

Vogtle Electric Generating Plant Audit and Review Plan for AMRs, AMPs, and TLAAs 24

10. Lessons Learned Developed by RLRC Audit/Review A.

Audit/review the VEGP AMP program elements and determine that they are in accordance with the acceptance criteria for the corresponding program elements of Section A.1.2.3 of the SRP-LR.

B.

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

1.

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

2.

Plant-Specific Operating Experience with Aging Management Programs.

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

3.

Industry Operating Experience. Industry operating experience and its applicability should be assessed to determine whether it changes plant-specific determinations. NUREG-1801 is based upon industry operating experience prior to its date of issue. Operating experience after the issue date of NUREG-1801 should be evaluated and documented as part of the aging management review. In particular, generic communications such as a bulletin, a generic letter, or an information notice should be evaluated for impact upon the AMP. The evaluation should check for new aging effects or a new component or location experiencing an already identified aging effect.

C.

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

Vogtle Electric Generating Plant Audit and Review Plan for AMRs, AMPs, and TLAAs 25 D.

If it is necessary for the applicant to submit additional information to resolve a question or an issue or to support the basis or conclusion, the applicant may voluntarily submit the information as a supplement (docketed letter submitted under oath and affirmation) to the LRA. If not, the NRC may issue an RAI to obtain the information.

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

6.3 Aging Management Review Audits and Reviews There are two types of AMRs: those that the applicant claims are consistent with the GALL Report, and those that are not consistent with or not included in the GALL Report. 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 VEGP 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 VEGP AMRs.

C.

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

(1)

GALL Report (2)

SRP-LR (3)

ISG-LR (4)

RAIs and SERs for similar plants (5)

LRA (6)

Basis documents (7)

Implementation procedures (8)

Operating experience reports (plant-specific and industry)

(9)

Applicants FSAR (10)

Lessons learned developed by RLRC

Vogtle Electric Generating Plant Audit and Review Plan for AMRs, AMPs, and TLAAs 26 Audit/Review A.

Each AMR line item is coded with a letter which represents a standard note designation1. The letter notes are described in Table 2 of this audit and review 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 audit and review plan.

B.

The AMR review involves verification that the applicant has satisfied the requirements of 10 CFR 54.21(a)(3). This requirement states: For each structure and component... [within the scope of this part... and... subject to an aging management review] (the applicant) demonstrate(s) that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB for the period of extended operation.

C.

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

(1)

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

(2)

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

(3)

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

1 The AMR line item letter notes are based on a letter from A. Nelson, NEI, to P. T. Kuo, NRC, U.S. Nuclear Industrys Proposed Standard License Renewal Application Format Package, Request NRC Concurrence, dated January 24, 2003 (ML030290201). The staff concurred 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.

Vogtle Electric Generating Plant Audit and Review Plan for AMRs, AMPs, and TLAAs 27 (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 applicants Further Evaluation Recommended response in LRA Section 3.X.2.2.Z is enveloped by Section 3.X.2.2.Z of the SRP-LR. 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 applicants response to the question. If it appears acceptable, document the basis for acceptance and re-start the audit/review for the AMR line item from Step (1) above.

b.

If the applicants response does not resolve the question or issue, prepare an additional question to obtain the information needed to achieve resolution. Review the applicants response to the second question. If it appears acceptable, document the basis for acceptance and re-start the audit/review for the AMR line item from Step (1) above.

c.

If it is necessary for the applicant to submit additional information to resolve a question or an issue or to support a basis or conclusion, the applicant may submit the information as a supplement to the LRA or the NRC may issue an RAI to obtain the information. The project 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 applicants 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 the AMR line items are acceptable on the basis of a technical review.

AMR Audit/Review Worksheets Document the audits/reviews of VEGP AMRs using the worksheet provided in Appendix H, AMR Comparison Worksheets, or on spreadsheets containing similar information.

Vogtle Electric Generating Plant Audit and Review Plan for AMRs, AMPs, and TLAAs 28 6.3.2 Plant AMRs that Are Not Consistent with the GALL Report Review LRA Tables 3.X.2-Y (Table 2s) for LRA Sections 3.1 thru 3.6, where the applicant indicated, via Notes F through J, that the combination of component type, material, environment, and AERM does not correspond to a line item in the GALL Report. Specifically, Note F indicates that the material for the AMR line item component is not evaluated in the GALL Report. Note G indicates that the environment for the AMR line item component and material is not evaluated in the GALL Report. Note H indicates that the aging effect for the AMR line item component, material, and environment combination is not evaluated in the GALL Report. Note I indicates that the aging effect identified in the GALL Report for the line item component, material, and environment combination is not applicable. Note J indicates that neither the component nor the material and environment combination for the line item is evaluated in the GALL Report. For component groups not evaluated in the GALL Report (Notes F-J), the project team reviews the applicants evaluation in accordance with Branch Technical Position RLSB-1 (Appendix A.1 of the SRP-LR) to determine the technical adequacy. If during the review a difference is identified, prepare a question to the applicant, in order to obtain clarification.

Review the applicants response to the question and confirm that it is acceptance in accordance with Appendix A.1 of the SRP-LR.

The AMR review involves verification that the applicant has satisfied the requirements of 10 CFR 54.21(a)(3). This requirement states: For each structure and component... [within the scope of this part... and... subject to an aging management review] (the applicant) demonstrate(s) that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB for the period of extended operation.

6.4 Time-Limited Aging Analyses 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 DCI or the DE. In general, the project team will review TLAAs for which the applicant claims consistency with 10 CFR 54.21(c)(1)(i) the analyses remain valid for the period of extended operation or 10 CFR 54.21(c)(1)(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)(1)(ii) - the analyses have been projected to the end of the period of extended operation, the project team leader will be consulted to determine which TLAAs the project team will be capable of reviewing.

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

6.4.1 Identify Generic TLAA Issues Figure 4, Review 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 VEGP TLAAs that the applicant has identified as generic TLAA issues, identify the corresponding TLAAs in NUREG-1800, if appropriate.

Vogtle Electric Generating Plant Audit and Review Plan for AMRs, AMPs, and TLAAs 29 B.

Review the corresponding TLAAs in NUREG-1800 and identify those that will be audited/reviewed in conjunction with each of the VEGP TLAAs.

C.

Review the list of the VEGP plant-specific exemptions granted pursuant to

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

D.

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

(1)

Excel database on TLAAs summarizing how earlier LRAs and SERs were presented and reviewed (2)

TLAAs (3)

GALL Report (4)

SRP-LR (5)

ISG-LR (6)

RAIs, audit and review reports, and SERs for similar plants (7)

LRA (8)

References listed by applicant for each TLAA (9)

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

Basis documents (11)

Implementation documents (12)

Operating experience reports (plant-specific and industry)

(13)

Lessons-learned developed by RLRC (14)

Applicants FSAR E.

In addition, the project team will also review the SSES 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 Division 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)(1)(i) the analyses remain valid for the period of extended operation or 10 CFR 54.21(c)(1)(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

Vogtle Electric Generating Plant Audit and Review Plan for AMRs, AMPs, and TLAAs 30 54.21(c)(1)(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 and complexity of the provided analysis.

Candidates for further review by technical specialists could be those such as the following:

(1)

Metal Fatigue (VEGP LRA Section 4.3)

(2)

Environmental Qualification of Equipment (VEGP LRA Section 4.4 (3)

Concrete Containment Tendon Prestress (VEGP LRA Section 4.5)

(4)

Penetration Load Cycles (VEGP LRA Section 4.6)

(5)

Plant-Specific Time-Limited Aging Analyses (VEGP LRA Section 4.7)

Audit/Review A.

Confirm that each VEGP 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 VEGP 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 should consider the following industry guidance (from NEI 95-10, Table 6.2-2) as follows:

(1)

The application shall include a list of time-limited aging analyses, as defined by §54.3. The application should include the identification of the affected systems, structures, and components, an explanation of the time dependent aspects of the calculation or analysis, and a discussion of the TLAAs 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.

(2)

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

(3)

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

§54.3. The application shall include an evaluation that justifies the

Vogtle Electric Generating Plant Audit and Review Plan for AMRs, AMPs, and TLAAs 31 continuation of these exemptions for the period of extended operation.

(4)

Summary descriptions of the evaluations of TLAAs for the period of extended operation shall be included in the FSAR supplement (LRA 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 4 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 VEGP LRA. If not, the NRC may issue an RAI to obtain the information.

6.4.2 Metal Fatigue Figure 4, Review 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 VEGP 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:

(1)

Excel database on TLAAs summarizing how earlier LRAs and SERs presented and reviewed TLAAs (2)

GALL Report, especially Section X.M1 (3)

SRP-LR (4)

ISG-LR (5)

RAIs, audit and review reports, and SERs for similar plants (6)

LRA (7)

References listed by applicant for each TLAA (8)

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

Vogtle Electric Generating Plant Audit and Review Plan for AMRs, AMPs, and TLAAs 32 (9)

Basis documents (10)

Implementation documents (11)

Operating experience reports (plant-specific and industry)

(12)

Lessons-learned developed by RLRC (13)

Applicants FSAR C.

In addition, the project team will also review the VEGP 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 DCI or the DE. This is not expected to be an issue for TLAAs for which the applicant claims consistency with 10 CFR 54.21(c)(1)(i) the analyses remain valid for the period of extended operation or 10 CFR 54.21(c)(1)(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)(1)(ii) - the analyses have been projected to the end of the period of extended operation, the project team leader will be consulted to determine which TLAAs the project team will be capable of reviewing.

Consideration should be given to project team expertise and complexity of the provided analysis.

Audit/Review A.

Confirm that each VEGP 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, VEGP should state in this section that it does not apply.

C.

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

(1)

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

(2)

Consider the effects of aging.

(3)

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

(4)

Determined to be relevant by the applicant in making a safety determination.

(5)

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

Vogtle Electric Generating Plant Audit and Review Plan for AMRs, AMPs, and TLAAs 33 (6)

Contained or incorporated by reference in the CLB.

D.

The project team will ascertain that VEGP 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) 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 should consider the guidance presented in Table 6.2-2 of NEI 95-10, Industry Guidelines for Implementing the Requirements of 10 CFR Part 54 - The License Renewal Rule".

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 4 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 VEGP LRA. If not, the NRC may issue an RAI to obtain the information.

6.4.3 Environmental Qualification of Equipment Figure 4, Review 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 VEGP LRA to be within the NUREG-1800 TLAA category of environmental qualification of electric equipment have provided adequate information to meet the requirements of 10 CFR 54.21(c)(1) and 10 CFR 54.21(c)(2).

B.

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

(1)

Excel database on TLAAs summarizing how earlier LRAs and SERs presented and reviewed TLAAs (2)

GALL Report, especially Section X.E1 (3)

SRP-LR (4)

ISG-LR

Vogtle Electric Generating Plant Audit and Review Plan for AMRs, AMPs, and TLAAs 34 (5)

RAIs, audit and review reports, and SERs for similar plants (6)

LRA (7)

References listed by applicant for each TLAA (8)

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

Basis documents (10)

Implementation documents (11)

Operating experience reports (plant-specific and industry)

(12)

Lessons-learned developed by RLRC (13)

Applicants FSAR C.

In addition, the project team will also review the VEGP 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 DCI or the DE. This is not expected to be an issue for TLAAs for which the applicant claims consistency with 10 CFR 54.21(c)(1)(i) the analyses remain valid for the period of extended operation. or 10 CFR 54.21(c)(1)(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)(1)(ii)

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

Audit/Review A.

Confirm that each VEGP 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, VEGP 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.

Vogtle Electric Generating Plant Audit and Review Plan for AMRs, AMPs, and TLAAs 35 (3)

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

(4)

Determined to be relevant by the applicant in making a safety determination.

(5)

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

(6)

Contained or incorporated by reference in the CLB.

D.

The project team will ascertain that VEGP 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) 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 should consider the guidance presented in Table 6.2-2 of NEI 95-10, Industry Guidelines for Implementing the Requirements of 10 CFR Part 54 - The License Renewal Rule".

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 4 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 VEGP LRA. If not, the NRC may issue an RAI to obtain the information.

6.4.4 Concrete Containment Tendon Prestress Figure 4, Review 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 VEGP LRA to be within the NUREG-1800 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:

Vogtle Electric Generating Plant Audit and Review Plan for AMRs, AMPs, and TLAAs 36 (1)

Excel database on TLAAs summarizing how earlier LRAs and SERs presented and reviewed TLAAs (2)

GALL Report (3)

SRP-LR (4)

ISG-LR (5)

RAIs, audit and review reports, and SERs for similar plants (6)

LRA (7)

References listed by applicant for each TLAA (8)

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

Basis documents (10)

Implementation documents (11)

Operating experience reports (plant-specific and industry)

(12)

Lessons-learned developed by RLRC (13)

Applicants FSAR C.

In addition, the project team will also review the VEGP TLAAs within the NUREG-1800 TLAA category of containment liner plate, metal containments, and penetrations fatigue to determine if there are emerging issues that should be further evaluated by technical specialists in the NRC DCI or the DE. This is not expected to be an issue for TLAAs for which the applicant claims consistency with 10 CFR 54.21(c)(1)(i) the analyses remain valid for the period of extended operation. or 10 CFR 54.21(c)(1)(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)(1)(ii)

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

Audit/Review A.

Confirm that each VEGP 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, VEGP should state in this section that it does not apply.

Vogtle Electric Generating Plant Audit and Review Plan for AMRs, AMPs, and TLAAs 37 C.

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

(1)

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

(2)

Consider the effects of aging.

(3)

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

(4)

Determined to be relevant by the applicant in making a safety determination.

(5)

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

(6)

Contained or incorporated by reference in the CLB.

D.

The project team will ascertain that VEGP 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) 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 should consider the guidance presented in Table 6.2-2 of NEI 95-10, Industry Guidelines for Implementing the Requirements of 10 CFR Part 54 - The License Renewal Rule".

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 4 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 VEGP LRA. If not, the NRC may issue an RAI to obtain the information.

6.4.5 Penetration Load Cycles Figure 4, Review 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.

Vogtle Electric Generating Plant Audit and Review Plan for AMRs, AMPs, and TLAAs 38 Pre-Review Preparation A.

The project team will determine if the TLAAs identified in the VEGP LRA to be within the NUREG-1800 TLAA category of Penetration Load Cycles have provided adequate information to meet the requirements of 10 CFR 54.21(c)(1) and 10 CFR 54.21(c)(2).

B.

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

(1)

Excel database on TLAAs summarizing how earlier LRAs and SERs presented and reviewed TLAAs (2)

GALL Report (3)

SRP-LR (4)

ISG-LR (5)

RAIs, audit and review reports, and SERs for similar plants (6)

LRA (7)

References listed by applicant for each TLAA (8)

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

Basis documents (10)

Implementation documents (11)

Operating experience reports (plant-specific and industry)

(12)

Lessons-learned developed by RLRC (13)

Applicants FSAR C.

In addition, the project team will also review the VEGP TLAAs within the NUREG-1800 TLAA category of containment liner plate, metal containments, and penetrations fatigue to determine if there are emerging issues that should be further evaluated by technical specialists in the NRC DCI or the DE. This is not expected to be an issue for TLAAs for which the applicant claims consistency with 10 CFR 54.21(c)(1)(i) the analyses remain valid for the period of extended operation. or 10 CFR 54.21(c)(1)(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)(1)(ii)

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

Vogtle Electric Generating Plant Audit and Review Plan for AMRs, AMPs, and TLAAs 39 Audit/Review A.

Confirm that each VEGP 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, VEGP should state in this section that it does not apply.

C.

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

(1)

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

(2)

Consider the effects of aging.

(3)

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

(4)

Determined to be relevant by the applicant in making a safety determination.

(5)

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

(6)

Contained or incorporated by reference in the CLB.

D.

The project team will ascertain that VEGP 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) 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 should consider the guidance presented in Table 6.2-2 of NEI 95-10, Industry Guidelines for Implementing the Requirements of 10 CFR Part 54 - The License Renewal Rule".

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 4 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 VEGP LRA. If not, the NRC may issue an RAI to obtain the information.

Vogtle Electric Generating Plant Audit and Review Plan for AMRs, AMPs, and TLAAs 40 6.4.6 Other Plant-Specific TLAAs Figure 4, Review 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 VEGP LRA to be within the NUREG-1800 TLAA category of other plant-specific TLAAs have provided adequate information to meet the requirements of 10 CFR 54.21(c)(1) and 10 CFR 54.21(c)(2).

B.

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

(1)

Excel database on TLAAs summarizing how earlier LRAs and SERs presented and reviewed TLAAs (2)

GALL Report (3)

SRP-LR (4)

ISG-LR (5)

RAIs, audit and review reports, and SERs for similar plants (6)

LRA (7)

References listed by applicant for each TLAA (8)

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

Basis documents (10)

Implementation documents (11)

Operating experience reports (plant-specific and industry)

(12)

Lessons-learned developed by RLRC (13)

Applicants FSAR C.

In addition, the project team will also review the VEGP 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 DCI or the DE. This is not expected to be an issue for TLAAs for which the applicant claims consistency with 10 CFR 54.21(c)(1)(i) the analyses remain valid for the period of extended operation. or

Vogtle Electric Generating Plant Audit and Review Plan for AMRs, AMPs, and TLAAs 41 10 CFR 54.21(c)(1)(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)(1)(ii) - the analyses have been projected to the end of the period of extended operation, the project team leader will be consulted to determine which TLAAs the project team will be capable of reviewing. Consideration should be given to project team expertise, past precedent, and complexity of the provided analysis.

Audit/Review A.

Confirm that each VEGP 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, VEGP should state in this section that it does not apply.

C.

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

(1)

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

(2)

Consider the effects of aging.

(3)

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

(4)

Determined to be relevant by the applicant in making a safety determination.

(5)

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

(6)

Contained or incorporated by reference in the CLB.

D.

The project team will ascertain that VEGP 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) 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 should consider the following industry guidance on other plant-specific TLAAs (from NEI 95-10, Table 6.2-2) as follows:

(1)

Identify and evaluate any plant-specific TLAAs.

Vogtle Electric Generating Plant Audit and Review Plan for AMRs, AMPs, and TLAAs 42 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 4 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 VEGP LRA. If not, the NRC may issue an RAI to obtain the information.

6.5 Audit and Safety Review Documentation As noted in Section 5.8 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 summary, and SER input. This section of the audit and review plan addresses the preparation of the audit and review summary and the SER input.

6.5.1 Audit and Review Summary The project team should prepare an audit and review summary upon completion of the on-site audits and reviews of the AMPs, AMRs, and TLAAs assigned to the project team. This summary should provide the following information:

Members who participated in the on-site audits, Dates and location of the audits Guidance documents used for the review Activities performed Documents reviewed Availability of question and answer database Status of the review 6.5.2 Safety Evaluation Report Input A.

General guidance (1)

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

(2)

In general, the data and information needed to prepare the SER input should be available in the project teams audit and review question and answer database and the project team members worksheets.

(3)

SER inputs are to be prepared for:

a.

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

Vogtle Electric Generating Plant Audit and Review Plan for AMRs, AMPs, and TLAAs 43

b.

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

c.

Each plant-specific AMP.

d.

AMRs that are consistent with the GALL Report, for which no further evaluation is recommended.

e.

AMRs that are consistent with the GALL Report, for which further evaluation is recommended.

f.

Project team AMR review results.3 (4)

The SER input should contain the following sections. (Note: The following section numbers (3. through 3.X.3) are based on the numbering system for the SER input. They are not a continuation of the numbering convention used throughout this audit and review plan.)

3.

Aging Management Review Results 3.0 Applicants Use of the Generic Aging Lessons Learned Report 3.01 Format of the LRA 3.02 Staffs Review Process 3.0.2.1 AMRs in the GALL Report 3.0.2.2 FSAR Supplement 3.0.2.3 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.X4 Aging Management of 3.X.1 Summary of Technical Information in the Application 3.X.2 Staff Evaluation 3.X.2.1 Aging Management Evaluations that are Consistent with the GALL Report, for Which Further Evaluation is Not Required 3

AMRs that are not consistent with the GALL Report or not addressed in the GALL Report.

4 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.

Vogtle Electric Generating Plant Audit and Review Plan for AMRs, AMPs, and TLAAs 44 3.X.2.2 Aging Management Evaluations that are Consistent with the GALL Report, for Which Further Evaluation is Recommended 3.X.2.3 AMR Results that are Not Consistent with or Not Addressed in the GALL Report 3.X.3 Conclusion 4.0 Time-Limited Aging Analyses 4.1 Identification of Time-Limited Aging Analyses 4.2 Reactor Vessel Neutron Embrittlement 4.3 Metal Fatigue 4.4 Environmental Qualification of Electrical Equipment 4.5 Concrete Containment Tendon Prestress 4.6 Containment Liner Plate, Metal Containments, and Penetrations Fatigue Analysis 4.7 Other Plant-Specific Time-Limited Aging Analyses 4.7.1 Turbine Rotor Missile Generation Analyses 4.7.2 Crane Cyclic Analyses 4.7.3 Main and Auxiliary Reservoir Sedimentation Analyses 4.7.4 High Energy Line Break Location Postulation Based on Fatigue Cumulative Usage Factor 4.8 Conclusion for Time-Limited Aging Analyses (5)

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

(6)

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

(7)

If an RAI was issued, identify the RAI number and briefly discuss the RAI.

State if the RAI remains open or if the applicants response has been received and accepted. If the response was acceptable, identify the submittal (including the date and the ADAMS accession number) that provided the response and document the basis for its acceptance.

(8)

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

B.

SER input (1)

For VEGP 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 FSAR update (Appendix A of the VEGP LRA) is acceptable. This SER input

Vogtle Electric Generating Plant Audit and Review Plan for AMRs, AMPs, and TLAAs 45 documents that the AMP is consistent with the GALL Report.

(2)

For VEGP AMPs determined to be consistent with the GALL Report, with exceptions or enhancements, the SER input should include a statement that the audit found the VEGP 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 FSAR supplement, and document the basis for concluding that it is acceptable.

(3)

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

(4)

For aging management reviews that are consistent with the GALL Report,5 the SER input should include the following:

a.

Identify the VEGP LRA section reviewed.

b.

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

c.

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

d.

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

e.

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

f.

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

g.

A finding that verifies that:

The applicant identified the applicable aging effects.

The applicant defined the appropriate combination of materials and environments.

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

Vogtle Electric Generating Plant Audit and Review Plan for AMRs, AMPs, and TLAAs 46 The applicant specified acceptable AMPs.

h.

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

(5)

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

a.

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

b.

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

c.

For the applicants further evaluations, provide a summary of the basis for concluding that it satisfied the criteria of Section 3.X.3.2 of the SRP-LR.

d.

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

(6)

Staff AMR Review Results6. 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 SER input should document the following:

a.

The VEGP LRA section reviewed.

b.

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

c.

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

d.

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

LRA and applicant basis documents and other implementation documents).

e.

A finding that verifies, if true, that:

The applicant identified the applicable aging effects.

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

Vogtle Electric Generating Plant Audit and Review Plan for AMRs, AMPs, and TLAAs 47 The applicant listed the appropriate combination of materials and environments.

The applicant specified acceptable AMPs.

f.

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

(7)

TLAA Review Results. This section of the SER input documents the reviews of TLAAs assigned to the project team. The SER input should include the following:

a.

Summary of technical information in the application

b.

Staff evaluation (i)

Regulatory basis (ii)

Scope of review and technical evaluation

c.

FSAR supplement review - stating, if applicable, that the applicant has provided an FSAR supplement summary description of its TLAA evaluation.

d.

Provide a conclusion stating, if applicable, that the applicant has demonstrated that TLAAs for which the applicant claims consistency with 10 CFR 54.21(c)(1)(i) the analyses remain valid for the period of extended operation, or 10 CFR 54.21(c)(1)(ii) the analyses have been projected to the end of the period of extended operation, or 10 CFR 54.21(c)(1)(iii) the effects of aging on the intended function(s) will be adequately managed for the period of extended operation. The staff also concludes that the FSAR supplement contains an appropriate summary description of the activities for managing the effects of aging and the TLAA evaluation, as required by 10 CFR 54.21(d).

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

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

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

Vogtle Electric Generating Plant Audit and Review Plan for AMRs, AMPs, and TLAAs 48 Table 1. Aging Management Program Element Descriptions Element Description 1 Scope of the program The scope of the program should include the specific structures and components subject to an aging management review.

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

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

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

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

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

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

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

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

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

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

Vogtle Electric Generating Plant Audit and Review Plan for AMRs, AMPs, and TLAAs 49 Table 2. Notes for License Renewal Application Tables 3.X.2-Y7 Note Description A

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

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

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

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

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

F Material not in NUREG-1801 for this component.

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

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

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

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

7 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 Industrys 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).

Vogtle Electric Generating Plant Audit and Review Plan for AMRs, AMPs, and TLAAs 50 Figure 1. Audit of AMPs that are Consistent with the GALL Report Start Identify GALL AMP (s) to which LRA AMP is being compared Identify elements of GALL AMP(s) attributes to be audited Identify LRA AMP support documents needed to perform audit Did applicant identify any exceptions to GALL AMP(s)?

Compare each GALL AMP auditable element to the LRA AMP Is the attribute element consistent?

Document the basis for acceptance of the attribute element in worksheet Have all attribute elements been audited?

Have all 7 AMP attributes been audited?

Write SE input per guidance in Section G, H, J Provide audit SE input Conclusion of AMP Audit Is there a technical basis to accept exception or difference?

Ask applicant a clarifying question to continue audit?

Develop and provide question to Team Leader for PMs submittal to applicant Obtain response from applicant Notify NRC Team Leader that Audit of AMR may not proceed Draft RAI Terminate AMP audit Preparation Steps Note:

Preparation steps may be performed as a single combined step for each AMP audited.

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

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

Yes Yes No No Yes Yes No No Yes No No Yes

Vogtle Electric Generating Plant Audit and Review Plan for AMRs, AMPs, and TLAAs 51 Yes No Yes No Yes Yes No No Start Compare each SRP-LR AMP criteria element to the LRA AMP Document the basis for acceptance of the element in worksheet Have all element criteria been audited?

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

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

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

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

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

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

Yes No Is the AMP element consistent?

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

Figure 2. Audit of Plant-Specific AMPs

Vogtle Electric Generating Plant Audit and Review Plan for AMRs, AMPs, and TLAAs 52 Figure 3. Review of AMRs that are Consistent with the GALL Report AMR Item Item is assigned to DE Review corresponding LRA Table 3.X.1 Further Evaluation Recommended and Discussion columns Further Evaluation Review referenced LRA subsection and compare with SRP subsection for any differences Footnote A Footnote B Footnote C Footnote D Footnote E Not consistent with GALL Report.

Evaluate in accordance with Section 6.3.2 of this plan.

Yes No Yes No No No No No No Yes Yes Yes Yes Yes Compare item with GALL Vol. 2 System Table line item for:

component type material environment aging effect AMP AMP is plant-specific Compare item with GALL Vol. 2 System Table line item for:

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

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

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

material environment aging effect Confirm that AMP will address AE for this component and environment Confirm AE still managed despite AMP exception Confirm material, environment, AE, and method per AMP are comparable Confirm material, environment and aging effect are comparable and AE still managed despite AMP exception Confirm AMP can manage this AE Acceptable in all aspects?

Yes No No Yes Mark for Query Mark as Acceptable Mark as Out of Scope Document problem in AMR Comparison Checklist Document basis for acceptance in AMR Comparison Checklist Prepare question Confirm question is captured AMR line item compelte Out of RLEP Scope

Vogtle Electric Generating Plant Audit and Review Plan for AMRs, AMPs, and TLAAs 53 Figure 4. Review of TLAAs and Exemptions (from NEI 95-10, Revision 6)

Identify generic TLAA issues No Identify potential plant unique TLAA issues Identify exemptions in effect Is the exemption based on a TLAA issue?

Does the TLAA meet the criteria of §54.3?

No further evaluation Determine the method of TLAA evaluation Analysis Verify that the TLAA is valid for extended operating period?

Aging review Justify that the TLAA can be projected to the end of the extended period of operation Verify that the TLAA is resolved by managing the aging effects No further evaluation of the exemption is required for license renewal Figure 4.2-1 Document the evaluation Yes Yes No OR OR

Vogtle Electric Generating Plant Audit and Review Plan for AMRs, AMPs, and TLAAs APPENDIX A PROJECT TEAM MEMBERS

Vogtle Electric Generating Plant Audit and Review Plan for AMRs, AMPs, and TLAAs A-1 Appendix A Project Team Members Organization Name Function NRC/NRR/DLR/RLRC Roy Mathew Senior Staff/Reviewer NRC/NRR/DLR/RLRC James Medoff Senior Staff/Reviewer NRC/NRR/DLR/RLRC Farideh Saba Reviewer NRC/NRR/DLR/RLRC Dan Hoang Reviewer NRC/NRR/DLR/RLRC Usman Baig Reviewer NRC/NRR/DLR/RLRC Zuhan Xi Reviewer NRC/NRR/DLR/RLRC Yeon-Ki Chung Reviewer NRC/NRR/DLR/RLRC Qi Gan Reviewer Information Systems Laboratories, Inc.

Mike Kennedy Contractor Lead, Reviewer Information Systems Laboratories, Inc.

Jon Woodfield Reviewer Information Systems Laboratories, Inc.

Cliff Marks Reviewer

Vogtle Electric Generating Plant Audit and Review Plan for AMRs, AMPs, and TLAAs APPENDIX B RLRC SCHEDULE FOR VEGP LRA SAFETY REVIEW

Vogtle Electric Generating Plant Audit and Review Plan for AMRs, AMPs, and TLAAs B-1 Appendix B RLRC Schedule for VEGP LRA Safety Review Plant: Vogtle Electric Generating Plant TAC No.: MD 5903 MD 5904 Senior Staff: Roy Mathew, James Medoff Scope of Work:

Project Manager: D. Ashley AMPs - 36 of 38 Contractor: Information Systems Laboratories, Inc.

AMRs - All line items TLAAs - 6 of 10 RAI Target Date: 1/20/08 Members: Roy Mathew, James Medoff, Dan Hoang, Farideh Saba, Mike Kennedy, Jon Woodfield, Cliff Marks, Yeon-Ki Chung, Zuhan Xi, Qi Gan SE Input to PM:

ACTIVITY/MILESTONE PLAN SCHEDULE ACTUAL SCHEDULE STATUS 1

Receive LRA 6/29/07 6/29/2007 Complete 2

Complete Sufficiency Review 7/27/07 7/27/2007 Complete 3

Make Review Assignments 8/17/07 8/17/07 Complete 4

Conduct Team Meeting 8/29/2007 9/12/07 Complete 5

Issue Audit Plan 9/21/07 9/21/07 6

Develop Draft AMP/TLAA Questions 9/24/07 9/24/07 7

Send Draft AMP Questions to Applicant 9/28/07 9/28/07 8

Conduct Site Visit 1 (AMP Audit and Review) 10/15-19/07 9

Draft AMP SER Input 11/6/07 10 Conduct In-Office AMR Reviews 11/1-12/5/07 11 Develop Draft AMR Questions 11/14/07 12 Send Draft AMP Questions to Applicant 11/23/07 13 Site Visit 2 (AMR/TLAA Audit and Review) 12/10-14/07 14 Optional Site Visit 3 (Resolve AMP, AMR and TLAA Questions) 1/14-16/07 15 Draft AMR/TLAA SER Input 1/8/08 16 Peer Review of SER Input TBD 17 Issue Audit Summary to PM TBD 18 Issue Final RLRC SER Input to PM 5/30/08 19 Issue SER with Open Items By PM 9/12/08 21 ACRS Subcommittee Meeting 10/08 22 ACRS Full Committee Meeting 03/09

Vogtle Electric Generating Plant Audit and Review Plan for AMRs, AMPs, and TLAAs APPENDIX C AGING MANAGEMENT PROGRAM ASSIGNMENT

Vogtle Electric Generating Plant Audit and Review Plan for AMRs, AMPs, and TLAAs C-1 Appendix C Aging Management Program Assignments Consistent With GALL?

No.

LRA AMP Number GALL Report AMP Number LRA Aging Management Program Yes/No Exception Enhancement Plant-Specific Assigned Auditor 1

B.3.1 N/A ACCW System Carbon Steel Components Program (New)

N X

Marks 2

B.3.2 N/A Bolting Integrity Program (New)

N X

Marks 3

B.3.3 XI.M10 Boric Acid Corrosion Control Program (Existing)

Y X

Saba 4

B.3.4 XI.M34 Buried Piping and Tanks Inspection Program (New)

Y X

Woodfield 5

B.3.5 XI.M12 CASS RCS Fitting Evaluation Program (New)

Y X

Saba 6

B.3.6 XI.M21 Closed Cooling Water Program (Existing)

Y X

X Baig 7

B.3.7 N/A Diesel Fuel Oil Program (Existing)

N X

Kennedy 8

B.3.8 XI.M36 External Surfaces Monitoring Program (New)

Y X

Baig 9

B.3.9 XI.M26 XI.M27 Fire Protection Program (Existing)

Y X

X Mathew 10 B.3.10 XI.M17 Flow-Accelerated Corrosion Program (Existing)

Y X

Medoff 11 B.3.11 XI.M37 Flux Thimble Tube Inspection Program (Existing)

Y X

Marks 12 B.3.12 XI.M20 Generic Letter 89-13 Program (Existing)

Y X

X Kennedy 13 B.3.13 N/A Inservice Inspection Program-IWB, IWC, IWD, IWF (Existing)

N X

Medoff 14 B.3.14 N/A Nickel Alloy Management Program for Non-Reactor Vessel Closure Head Penetration Locations (New)

N X

DCI

Vogtle Electric Generating Plant Audit and Review Plan for AMRs, AMPs, and TLAAs C-2 Consistent With GALL?

No.

LRA AMP Number GALL Report AMP Number LRA Aging Management Program Yes/No Exception Enhancement Plant-Specific Assigned Auditor 15 B.3.15 XI.M11A Nickel Alloy Management Program for Reactor Vessel Closure Head Penetrations (Existing)

Y Medoff 16 B.3.16 XI.M39 Oil Analysis Program (Existing)

Y X

X Baig 17 B.3.17 XI.M32 One-Time Inspection Program (New)

Y Kennedy 18 B.3.18 XI.M35 One-Time Inspection Program for ASME Class 1 Small Bore Piping (New)

Y X

Kennedy 19 B.3.19 XI.M33 One-Time Inspection Program for Selective Leaching (New)

Y X

Marks 20 B.3.20 XI.M23 Overhead and Refueling Crane Inspection Program (Existing)

Y Woodfield/

Xi 21 B.3.21 N/A Periodic Surveillance and Preventive Maintenance Activities (Existing)

N X

Marks 22 B.3.22 XI.M38 Piping and Duct Internal Inspection Program (New)

Y X

Baig 23 B.3.23 XI.M3 Reactor Vessel Closure Head Stud Program (Existing)

Y X

Saba 24 B.3.24 N/A Reactor Vessel Internals Program (New)

N X

Medoff 25 B.3.25 N/A Reactor Vessel Surveillance Program (Existing)

Y X

X DCI 26 B.3.26 XI.M19 Steam Generator Tubing Integrity Program (Existing)

Y X

Saba 27 B.3.27 N/A Steam Generator Program for Upper Internals (Existing)

N X

Saba 28 B.3.28 XI.M2 Water Chemistry Control Program (Existing)

Y Medoff 29 B.3.29 XI.S4 10 CFR 50 Appendix J Program (Existing)

Y Hoang/

Xi

Vogtle Electric Generating Plant Audit and Review Plan for AMRs, AMPs, and TLAAs C-3 Consistent With GALL?

No.

LRA AMP Number GALL Report AMP Number LRA Aging Management Program Yes/No Exception Enhancement Plant-Specific Assigned Auditor 30 B.3.30 N/A Inservice Inspection Program - IWE (Existing)

N X

Woodfield/

Xi 31 B.3.31 N/A Inservice Inspection Program - IWL (Existing)

N X

Woodfield/

Xi 32 B.3.32 XI.S6 Structural Monitoring Program (Existing)

Y X

Hoang/

Xi 33 B.3.33 N/A Structural Monitoring Program - Masonry Walls (Existing)

Y X

Hoang/

Xi 34 B.3.34 XI.E1 Non-EQ Cables and Connections Program (New)

Y Mathew 35 B.3.35 XI.E3 Non-EQ Inaccessible Medium-Voltage Cables Program (New)

Y Mathew 36 B.3.36 N/A Non-EQ Cable Connections One-Time Inspection Program (New)

N X

Mathew 37 B.3.37 X.E1 Environmental Qualification Program (Existing)

Y Mathew 38 B.3.38 X.M1 Fatigue Monitoring Program (Existing)

Y X

Chung/

Gan

Vogtle Electric Generating Plant Audit and Review Plan for AMRs, AMPs, and TLAAs APPENDIX D AGING MANAGEMENT REVIEW ASSIGNMENTS

Vogtle Electric Generating Plant Audit and Review Plan for AMRs, AMPs, and TLAAs D-1 Appendix D Aging Management Review Assignments Aging Management Reviews Reviewer 3.1 Aging Management of Reactor Vessel, Internals, and Reactor Coolant System Saba/

Medoff 3.2 Aging Management of Engineered Safety Features Kennedy 3.3 Aging Management of Auxiliary Systems Marks/

Woodfield 3.4 Aging Management of Steam and Power Conversion Systems Baig 3.5 Aging Management of Containment, Structures, and Component Supports Hoang/

Xi 3.6 Aging Management of Electrical and Instrumentation and Controls Mathew

Vogtle Electric Generating Plant Audit and Review Plan for AMRs, AMPs, and TLAAs APPENDIX E TIME-LIMITED AGING ANALYSES REVIEW ASSIGNMENTS

Vogtle Electric Generating Plant Audit and Review Plan for AMRs, AMPs, and TLAAs E-1 Appendix E Time-Limited Aging Analysis Review Assignments 10 CFR 54.21(c)(1)

LRA TLAA Number TLAA Title (i) or (iii)

(ii)

Assigned Reviewer 4.1 Identification of Time-Limited Aging Analyses Medoff 4.2 Reactor Vessel Neutron Embrittlement (ii)

DCI 4.3 Metal Fatigue (i) or (iii)

(ii)

Chung/Gan 4.4 Environmental Qualification of Equipment (iii)

Mathew 4.5 Concrete Containment Tendon Prestress (ii)

DE 4.6 Penetration Load Cycles (i)

Hoang/Xi 4.7 Plant-Specific TLAAs 4.7.1 Leak Before Break (i)

(ii)

Chung/Gan 4.7.2 Diesel Fuel Oil Storage Tank Corrosion Allowance (iii)

Medoff 4.7.3 Steam Generator Tube, Loss of Material (iii)

DCI 4.7.4 Cold Overpressure Protection System (COPS)

(iii)

(ii)

DSS

Vogtle Electric Generating Plant Audit and Review Plan for AMRs, AMPs, and TLAAs APPENDIX F CONSISTENT WITH GALL REPORT AMP AUDIT/REVIEW WORKSHEET

Vogtle Electric Generating Plant Audit and Review Plan for AMRs, AMPs, and TLAAs F-1 Appendix F Consistent With GALL Report AMP Audit/Review Worksheet The worksheet provided in this appendix provides, as an aid for the reviewer, a process for documenting the basis for the assessment of the program elements contained in the GALL Report AMPs (Chapter XI of NUREG-1801, Volume 2). The worksheet provides a systematic method for recording the basis for assessments or to identify when the applicant needs to provide clarification or additional information. Information recorded in the worksheets will also be used to prepare the safety evaluation report input.

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

LRA Appendix Subsection:

LRA AMP

Title:

GALL Report Subsection:

GALL Report

Title:

A.

Element Review and Audit Program

Description:

Consistent with GALL Report Difference Identified Discussion:

1.

Scope of the Program:

Consistent with GALL Report Exception Enhancement Difference Identified Discussion:

2.

Preventive Action:

Consistent with GALL Report Exception Enhancement Difference Identified Discussion:

3.

Parameters Monitored or Inspected:

Consistent with GALL Report Exception Enhancement Difference Identified Discussion:

Vogtle Electric Generating Plant Audit and Review Plan for AMRs, AMPs, and TLAAs F-2

4.

Detection of Aging Effects:

Consistent with GALL Report Exception Enhancement Difference Identified Discussion:

5. Monitoring and Trending:

Consistent with GALL Report Exception Enhancement Difference Identified Discussion:

6. Acceptance Criteria:

Consistent with GALL Report Exception Enhancement Difference Identified Discussion:

7.

Corrective Action:

8.

Confirmation Process:

9.

Administrative Controls:

10.

Operating Experience:

B.

FSAR Supplement Review: (Include any commitments.)

C.

Remarks and Questions:

D.

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

E.

Applicant

Contact:

Project Team Member: Date:

Vogtle Electric Generating Plant Audit and Review Plan for AMRs, AMPs, and TLAAs APPENDIX G PLANT-SPECIFIC AMP AUDIT/REVIEW WORKSHEET

Vogtle Electric Generating Plant Audit and Review Plan for AMRs, AMPs, and TLAAs G-1 Appendix G Plant-Specific AMP Audit/Review Worksheet The worksheet provided in this appendix provides, as an aid for the reviewer, a process for documenting the basis for the assessments concerning individual program elements and sub-elements contained in Branch Technical Position RLSB-1 "Aging Management Review -

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

Plant-Specific AMP Audit/Review Worksheet AMP

Title:

Appendix Subsection:

A.

Element Review and Audit

1.

Scope of the Program:

___ Consistent with SRP-LR

____ Exception

____ Difference Identified Discussion:

SRP Criteria LRA AMP Comment*

2.

Preventive Action:

___ Consistent with SRP-LR

____ Exception

____ Difference Identified Discussion:

SRP Criteria LRA AMP Comment*

3.

Parameters Monitored or Inspected:

___ Consistent with SRP-LR

____ Exception

____ Difference Identified Discussion:

SRP Criteria LRA AMP Comment*

Vogtle Electric Generating Plant Audit and Review Plan for AMRs, AMPs, and TLAAs G-2

4.

Detection of Aging Effects:

___ Consistent with SRP-LR

____ Exception

____ Difference Identified Discussion:

SRP Criteria LRA AMP Comment*

5.

Monitoring and Trending:

___ Consistent with SRP-LR

____ Exception

____ Difference Identified Discussion:

SRP Criteria LRA AMP Comment*

6.

Acceptance Criteria:

___ Consistent with SRP-LR

____ Exception

____ Difference Identified Discussion:

SRP Criteria LRA AMP Comment*

7.

Corrective Action:

To be performed by DIPM

8.

Confirmation Process:

To be performed by DIPM

9.

Administrative Controls:

To be performed by DIPM

10.

Operating Experience:

___ Consistent with SRP-LR

____ Exception

____ Difference Identified Discussion:

SRP Criteria LRA AMP Comment*

Consistent or technical basis for acceptance exception or difference B.

FSAR supplement review: (Include any commitments)

C.

Remarks and questions:

Vogtle Electric Generating Plant Audit and Review Plan for AMRs, AMPs, and TLAAs G-3 D.

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

E.

Applicant

Contact:

Project team member:

Date:

Vogtle Electric Generating Plant Audit and Review Plan for AMRs, AMPs, and TLAAs APPENDIX H AGING MANAGEMENT REVIEW COMPARISON WORKSHEETS

Vogtle Electric Generating Plant Audit and Review Plan for AMRs, AMPs, and TLAAs H-1 Appendix H Aging Management Review Comparison Worksheets The project team reviewer should document its AMRs 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.

Vogtle Electric Generating Plant Audit and Review Plan for AMRs, AMPs, and TLAAs H-2 VEGP 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 Report, Volume 1, Table X. All items applicable in Table 1 were reviewed and are addressed in the following table.

Item No.

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

Number Question for applicant (draft per RAI guidance)

Response (with date)

References/Documents Used:

1.

2.

3.

4.

Vogtle Electric Generating Plant Audit and Review Plan for AMRs, AMPs, and TLAAs H-3 VEGP 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 DCI) were reviewed for: 1) consistency with NUREG-1801, Volume 2 tables, and 2) adequacy of the aging managing programs. All items in 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.)

LRA Page No.

Component Type Material Environment Aging Effect Note Discussion (draft as SER Input Insert)

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

No.

Question for applicant (draft per RAI guidance)

Response (with date)

References/Documents Used:

1.

2.

3.

Note: All Appendix H information can be documented in the AMR Excel spreadsheet; no need to create a separate worksheet.

Vogtle Electric Generating Plant Audit and Review Plan for AMRs, AMPs, and TLAAs APPENDIX I ACRONYMS, ABBREVIATIONS, AND INITIALISMS

Vogtle Electric Generating Plant Audit and Review Plan for AMRs, AMPs, and TLAAs I-1 Appendix I Acronyms, Abbreviations, and Initialisms ADAMS Agencywide Documents Access and Management System AERM Aging effect requiring management AMP aging management program AMR aging management review ASME American Society of Mechanical Engineers BTP Branch Technical Position CASS Cast Austenitic Stainless Steel CFR Code of Federal Regulations CLB current licensing basis DCI Division of Component Integrity DE Division of Engineering DIPM Division of Inspection Program Management DLR Division of License Renewal EPRI Electric Power Research Institute EQ Environmental Qualification FSAR Final Safety Analysis Report GALL Generic Aging Lessons Learned ISG-LR Interim Staff Guidance for License Renewal 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 RLRB License Renewal Branch B RLRC License Renewal Branch C RLSB License Renewal and Standardization Branch SC structures and components SER safety evaluation report SRP-LR Standard Review Plan - License Renewal SSC structure, system, and component

Vogtle Electric Generating Plant Audit and Review Plan for AMRs, AMPs, and TLAAs I-2 TLAA Time Limited Aging Analysis VEGP Vogtle Electric Generating Plant