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NEI 17-01, Industry Guideline for Implementing the Requirements of 10 CFR Part 54 for Subsequent License Renewal.
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NEI 17-01 Industry Guideline for Implementing the Requirements of 10 CFR Part 54 for Subsequent License Renewal March 2017

NEI 17-01 March 2017 NEI 17-01 Nuclear Energy Institute Industry Guideline for Implementing the Requirements of 10 CFR Part 54 for Subsequent License Renewal March 2017 iii

NEI 17-01 March 2017 ACKNOWLEDGEMENTS This guidance document, Industry Guideline for Implementing the Requirements of 10 CFR Part 54 for Subsequent License Renewal, NEI 17-01, was developed by the Nuclear Energy Institute (NEI) License Renewal Task Force. We appreciate the direct participation of the many utilities that contributed to the development of the guideline and the participation of the balance of the industry that reviewed and submitted comments to improve the document clarity and consistency. The dedicated and timely effort of the many task force participants, including their managements support of the effort, is greatly appreciated.

NEI also wishes to express its appreciation to the Electric Power Research Institute that did considerable technical work to assist with the development of this industry guideline.

NOTICE Neither NEI, nor any of its employees, members, supporting organizations, contractors, or consultants make any warranty, expressed or implied, or assume any legal responsibility for the accuracy or completeness of, or assume any liability for damages resulting from any use of, any information apparatus, methods, or process disclosed in this report or that such may not infringe privately owned rights.

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NEI 17-01 March 2017 TABLE OF CONTENTS 1 INTRODUCTION ............................................................................................................ 9

1.1 BACKGROUND

.................................................................................................................9 1.2 PURPOSE AND SCOPE ....................................................................................................10 1.3 APPLICABILITY .............................................................................................................11 1.4 UTILIZATION OF NUREG-2191, NUREG-2192, REGULATORY GUIDE, AND NRC ISGS ........................................................................................................................11 1.5 RESOLUTION OF CURRENT SAFETY ISSUES (E.G., GSIS AND USIS)............................12 1.6 ORGANIZATION OF THE GUIDELINE ............................................................................13 2 OVERVIEW OF PART 54 ............................................................................................ 14 3 IDENTIFY THE SSCS WSLR AND THEIR INTENDED FUNCTIONS ............................. 17 3.1 SSCS WSLR .................................................................................................................18 3.1.1 Safety-Related SSCs .....................................................................................20 3.1.2 NSR SSCs Whose Failure Prevents SR SSCs from Fulfilling Their SR Function .........................................................................................................20 3.1.3 SSCs Relied on to Demonstrate Compliance with Certain Specific Commission Regulations ..............................................................................21 3.2 INTENDED FUNCTIONS OF SSCS WSLR ......................................................................23 3.3 DOCUMENTING THE SCOPING PROCESS ......................................................................24 4 INTEGRATED PLANT ASSESSMENT (IPA) ................................................................. 25 4.1 IDENTIFICATION OF SCS SUBJECT TO AMR AND INTENDED FUNCTIONS ..................26 4.2 IDENTIFICATION OF AERMS .......................................................................................31 TECHNIQUES TO IDENTIFY AGING EFFECTS ........................................................................33 4.2.1 Consistency with NUREG-2191, Volume 2 Line Items .............................35 4.3 DEMONSTRATE THAT THE EFFECTS OF AGING ARE MANAGED ................................36 4.3.1 AMP Review Using NUREG-2191 ..............................................................40 4.3.2 Plant-Specific AMP Review .........................................................................41 4.3.3 Use of AMP Previously Approved by NRC ................................................42 4.4 OE REVIEW ..................................................................................................................42 4.5 DOCUMENTING THE IPA ..............................................................................................43 4.5.1 Documenting the Identification of SCs Subject to an AMR .....................43 4.5.2 Documenting the AMR.................................................................................44 5 TLAAS INCLUDING EXEMPTIONS ............................................................................. 45 5.1 TLAAS 45 v

NEI 17-01 March 2017 5.1.1 Verify that the TLAA Is Valid for the SPEO .............................................48 5.1.2 Justifying the TLAA Can Be Projected to the End of the SPEO .............49 5.1.3 Verify that the TLAA is Resolved by Managing the Aging Effects .........49 5.1.4 Timing for Evaluation of TLAA..................................................................49 5.2 EXEMPTIONS .................................................................................................................52 5.3 DOCUMENTING THE EVALUATION OF THE TLAAS AND EXEMPTIONS ......................52 6 SLRA FORMAT AND CONTENT .................................................................................. 55 6.1 GENERAL INFORMATION ..............................................................................................55 6.2 SLRA FORMAT AND CONTENT GUIDANCE .................................................................55 7 POST-SLRA SUBMITTAL ACTIVITIES ......................................................................... 69 7.1 UPDATE OF THE SLRA FOR CLB CHANGES ...............................................................69 7.2 SLRA APPEALS ............................................................................................................69 7.3 POST-SLR NEWLY IDENTIFIED SSCS..........................................................................72 APPENDIX A REFERENCES ............................................................................................... A APPENDIX B STANDARD SLRA FORMAT AND CONTENT .................................................. B vi

NEI 17-01 March 2017 List of Tables Table 3.1-1: Sample Listing of Potential Information Sources................................... 22 Table 4.1-1: Treatment of Consumables ........................................................................ 30 Table 4.2-1: NUREG-2191 Consistency Notes for AMR Results .................................. 35 Table 4.3-1: Aging Management Activity 10 Program Elements ................................. 38 Table 5.1-1: Disposition Of Potential TLAAs And Basis For Disposition .................... 50 Table 5.1-2: Potential TLAAs ........................................................................................... 51 Table 6.2-1: Standard SLRA Format ............................................................................... 56 Table 6.2-2: Guidance for Preparing the Standard SLRA Format ............................... 58 List of Figures Figure 2.0-1: SLR Implementation Process................................................................... 16 Figure 3.0-1: A Method to Identify SSCs and Intended Functions WSLR [§ 54.4(a)

&(b)] ................................................................................................................................... 19 Figure 4.1-1: Identification of SCs Subject to AMR [§ 54.21(a)(1)] ............................. 27 Figure 4.2-1: Identification of AERMs............................................................................ 32 Figure 4.3-2: AMP Review ............................................................................................... 39 Figure 5.0-1: Evaluation of TLAAs and Exemptions [§ 54.21(c)].................................. 46 Figure 7.2-1: License Renewal Appeals Process ......................................................... 71 vii

NEI 17-01 March 2017 ACRONYMS ADAMS Agencywide Documents Access and Management System AERM Aging Effect Requiring Management AMP Aging Management Program AMR Aging Management Review BTP Branch Technical Position CLB Current Licensing Basis EOP Emergency Operating Procedure EQ Environmental Qualification ER Environmental Report FAC Flow-Accelerated Corrosion FP Fire Protection FSAR Final Safety Analysis Report GALL-SLR Generic Aging Lessons Learned- Subsequent License Renewal GSI Generic Safety Issue HELB High Energy Line Break I&C Instrumentation and Controls IEEE Institute of Electronic and Electrical Engineers IPA Integrated Plant Assessment IPEEE Individual Plant Examination of External Events ISG Interim Staff Guidance LRA License Renewal Application NEI Nuclear Energy Institute NRC Nuclear Regulatory Commission NSR Non-Safety-Related OE Operating Experience OMB Office of Management and Budget PEO Period of Extended Operation PRA Probabilistic Risk Assessment RAI Request for Additional Information SAMG Severe Accident Management Guidelines SC Structure or Component SER Safety Evaluation Report SLR Subsequent License Renewal SLRA Subsequent License Renewal Application SOC Statements of Consideration SPEO Subsequent Period of Extended Operation SQUG Seismic Qualification Utility Group SR Safety-Related SRP-SLR Standard Review Plan - Subsequent License Renewal SSC Systems, Structures, and Components TLAA Time-Limited Aging Analysis UFSAR Updated Safety Analysis Report USI Unresolved Safety Issue WSLR Within Scope of License Renewal viii

NEI 17-01 March 2017 INDUSTRY GUIDELINE FOR IMPLEMENTING THE REQUIREMENTS OF 10 CFR PART 54 FOR SUBSEQUENT LICENSE RENEWAL 1 INTRODUCTION This guideline provides an acceptable approach for implementing the requirements of 10 CFR Part 54, the License Renewal Rule, hereinafter referred to as the Rule, for Subsequent License Renewal (SLR). The process outlined in this guideline is founded on industry experience in implementing the Rule for initial license renewal and on the lessons learned from that industry experience that can be applied to SLR. It is expected that following this guideline will offer a stable and efficient process, resulting in the issuance of a renewed license. However, applicants may elect to use other suitable methods or approaches for satisfying the Rules requirements and completing a Subsequent License Renewal Application (SLRA).

This guideline uses terminology specific to the Rule. A copy of 10 CFR Part 54 is accessible from the NRCs LR webpage and should be reviewed.

1.1 BACKGROUND

In December 1991, the Nuclear Regulatory Commission (NRC) published 10 CFR Part 54 to establish the procedures, criteria and standards governing nuclear plant license renewal. Since publishing the original Rule, the NRC and the industry conducted various activities related to its implementation. In September 1994, the NRC proposed an amendment to the Rule. The final amendment was published in May 1995. It focuses on the effects of aging on long-lived, passive structures and components and time-limited aging analyses (TLAAs) as defined in 10 CFR 54.21(a)(1) and 54.3, respectively. In addition, the amendment allows greater reliance on the current licensing basis (CLB), the Maintenance Rule (10 CFR 65), and existing plant programs.

As of the date of this publication, there are only 4 operating units that have not applied for their initial renewed operating licenses. Additionally, 46 units have entered their initial periods of extended operation (PEOs). In 2009, the very first plants that entered their initial PEOs became eligible, per 10 CFR 54, to apply for their second renewed licenses. Not long before this, in 2008, NEI, NRC, DOE, and EPRI hosted the very first workshop for the nuclear industry to begin to examine operation beyond the initial PEOs, or beyond 60 years of operation.

Since that time, all stakeholders within the industry have worked together to determine what was needed to prepare for the first SLRA submittal and its NRC review. This included significant efforts by NEI, NRC, DOE, EPRI, and nuclear utilities to determine what materials and technical issue research was needed to support operation beyond initial PEOs. Additionally, over that time frame, the NRCs Division of License Renewal began the effort to initiate research and acquire data for the publication of SLR guidance that would replace the NRC guidance documents that had been published for initial LR (NUREG-1800, Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants; NUREG-1801, Generic Aging Lessons Learned (GALL) Report; NUREG-1850, Frequently Asked Questions on License Renewal of Nuclear Power Reactors; NUREG-1950, Disposition of Public Comments and Technical Bases 9

NEI 17-01 March 2017 for Changes in the License Renewal Guidance Documents NUREG-1800 and NUREG-1801; and Regulatory Guide 1.188, Standard Format and Content for Applications to Renew Nuclear Power Plant Operating Licenses. As part of that effort, they also examined ways in which the agency infrastructure might need to be changed to support the reviews of SLRAs. As a result of those activities, on January 31st, 2014, SECY-14-0016, Ongoing Staff Activities to Assess Regulatory Considerations for Power Reactor Subsequent License Renewal, was submitted to the Commission. It contained recommendations and options for making changes to the NRCs LRA review process that would be used specifically for SLRAs. One of those recommendations included rulemaking for 10 CFR 54 specific to SLR.

The Commission responded on August 29th, 2014 with memorandum Staff Requirements -

SECY-14-0016 - Ongoing Staff Activities to Assess Regulatory Considerations for Power Reactor Subsequent License Renewal. In that memorandum, the Commission disapproved the staffs recommendation for rulemaking for power reactor SLR and identified specific requirements for the NRC staff to facilitate SLRA reviews. Since then, the industry stakeholders have worked to incorporate the Commissions requirements and develop the infrastructure and processes necessary for the generation of SLRAs and their NRC reviews as they are submitted.

To support this effort, prior to this document being published, nuclear utilities, through NEI, working with the other SLR stakeholders, including INPO, also published NEI 14-12, Aging Management Program Effectiveness, NEI 14-13, Use of Industry Operating Experience for Age-Related Degradation and Aging Management Programs, and the Second License Renewal Roadmap. This document is an update to NEI 95-10, Rev. 6, Industry Guidelines for Implementing the Requirements of 10 CFR 54. It provides the appropriate NEI 95-10 equivalent guidelines for the generation of nuclear plant SLRAs having the content needed by the NRC, including the Advisory Committee on Reactor Safeguards (ACRS), on which to base the recommendation to the Commission for the issuance of subsequent renewed licenses.

1.2 PURPOSE AND SCOPE The major elements of the guideline (with their respective guideline sections) include:

Identifying the systems, structures and components within the scope of license renewal (WSLR) (Section 3.1);

Identifying the intended functions of systems, structures and components (SSCs) WSLR (Section 3.2);

Identifying the structures and components (SCs) subject to aging management review (AMR) and intended functions (Section 4.1);

Assuring that effects of aging are managed (Section 4.2);

Application of new programs and inspections for SLR (Section 4.3);

Identifying and resolving TLAAs (Section 5.1);

Identifying and evaluating exemptions based on TLAAs (Section 5.2); and Identifying a standard format and content for a SLRA (Section 6.0).

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NEI 17-01 March 2017 Applicants interested in SLR are responsible for preparing a plant-specific SLRA which includes general information and technical information. The general information is much the same as that provided with the initial LRA. The technical information includes an Integrated Plant Assessment (IPA), the CLB changes during the NRC review of the application, TLAAs, a supplement to the Updated Final Safety Analysis Report (UFSAR), any technical specification changes or additions necessary to manage the effects of aging during the subsequent period of extended operation (SPEO), and a supplement to the plants environmental report (ER) that complies with the requirements of Subpart A of 10 CFR Part 51, accessible from the NRCs LR webpage.

1.3 APPLICABILITY This document is applicable to any operating license for nuclear power plants licensed pursuant to Sections 103 or 104b of the Atomic Energy Act of 1954, as amended (68 Stat. 919), and Title II of the Energy Reorganization Act of 1974 (88 Stat. 1242).

1.4 UTILIZATION OF NUREG-2191, NUREG-2192, REGULATORY GUIDE AND NRC ISGS Applicants should consider three regulatory guidance documents: NUREG-2191, Generic Aging Lessons Learned for Subsequent License Renewal (GALL-SLR) Report, NUREG-2192, Standard Review Plan for Review of Subsequent License Renewal Applications for Nuclear Power Plants, and NRC Regulatory Guide (RG) titled, Standard Format and Content for Subsequent License Renewal Applications for Nuclear Power Plants. These documents have replaced, and are equivalent to, initial LRA guidance documents NUREG-1801, NUREG-1800, and Regulatory Guide 1.188, respectively. NUREG-2191 documents the NRC staff evaluation of generic aging management programs (AMPs) to document the basis for determining when such programs are adequate without change and when they should be augmented for SLR. NUREG-2192 is a basis document to NUREG-2191 that provides NRC staff guidance in reviewing a SLRA. NRCs RG provides guidance on the format for the information that is to be submitted in a SLRA.

NUREG-2191 contains tables with various nuclear power plant components, materials, environments, aging effects/mechanisms, aging management programs (AMPs), and a column noting whether evaluation beyond that contained in NUREG-2191 is required. It also contains the NRC evaluation of common AMPs. Many of these programs have been determined adequate, without change, to manage aging effects for particular SCs. These include programs commonly credited for managing aging effects associated with TLAAs. There are evaluations of mechanical programs, structural programs and electrical programs. NUREG-2191 programs are one acceptable way to manage aging effects. An applicant may credit other programs for aging management. NUREG-2191 has appendices that discuss quality assurance and operating experience for AMPs.

NUREG-2192 contains guidance for NRC reviewers of SLRAs. Its principal purpose is to ensure the quality and uniformity of staff reviews of applications. It contains a chapter corresponding to each of the sections of an application: administrative information, scoping and screening 11

NEI 17-01 March 2017 methodology for identifying SCs subject to AMR and implementation results, AMR results, and TLAAs. An appendix contains three branch technical positions (BTPs) and a guideline for addressing operating experience (OE) in AMPs. BTP RLSB-1 addresses the aging management demonstration required by 10 CFR 54.21(a)(3). BTP IQMB-1 describes an acceptable process for implementing the corrective actions, the confirmation process and the administrative controls elements of AMPs for SLR. BTP RLSB-2 addresses aging effects or TLAAs related to unresolved safety issues (USIs) or generic safety issues (GSIs). Appendix A.4, Operating Experience for Aging Management Programs, provides guidance on the incorporation of OE in AMPs and maintaining AMP effectiveness through the use of OE.

NRCs RG for SLR provides a summary of application contents and formatting specifications.

Changes and clarifications to the above guidance documents suggested by license renewal stakeholders and approved by the staff can be communicated via interim staff guidance (ISG) documents. The process is described in NRC document License Renewal Interim Staff Guidance Process, Revision 2. Details about each of the ISGs are available on the NRC License Renewal Guidance Documents web page.

Generally, ISGs will discuss technical issues rather than process issues.

It is important for applicants to note that the ISG positions for SLR may require considerations that differ from the applicant plants CLB. Applicants may want to ensure their SLRAs are clear with respect to the CLB and note that some SLRA content is based on an ISG rather than the CLB.

1.5 RESOLUTION OF CURRENT SAFETY ISSUES (E.G., GSIS AND USIS)

Generic resolution of a GSI or USI is not necessary for the issuance of a renewed license. GSIs and USIs that do not contain issues related to SLR AMR or TLAA evaluation need not be reviewed. However, designation of an issue as a GSI or USI does not exclude the issue from the scope of the AMR or TLAA evaluation.

USIs, HIGH and MEDIUM priority issues described in Appendix B in NUREG-0933, that involve aging effects for SCs subject to AMR or TLAAs, should be specifically addressed. The version of NUREG-0933 that is current on the date six months before the date of the SLRA should be used to identify such issues. Prior to SLRA Safety Evaluation Report (SER) completion, any new issues contained in later versions of NUREG-0933 must be reviewed and addressed if determined to be applicable to the applicants plant and they involve aging effects for SCs subject to AMR or they are associated with a TLAA. The results may be submitted to the NRC in the annual update.

For a GSI or USI affecting the AMR or TLAA evaluation, there are several approaches that can be used to satisfy the finding required by §54.29:

If resolution has been achieved before issuance of a renewed license, implementation of that resolution could be incorporated within the SLRA. The plant-specific implementation information should be provided.

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NEI 17-01 March 2017 An applicant may choose to submit a technical rationale that demonstrates that the CLB will be maintained until some later time in the SPEO, at which time one or more reasonable options (e.g., replacement, analytical evaluation, or a surveillance/maintenance program) would be available to adequately manage the effects of aging. The SLRA would have to describe the basis for concluding that the CLB is maintained in the SPEO and briefly describe options that are technically feasible during the SPEO to manage the effects of aging; but, it would not have to pre-select which option would be used.

Another approach could be for an applicant to develop an AMP that, for that plant, incorporates a resolution to the aging effects issue.

Another option could be to propose to amend the CLB (as a separate action outside the SLRA), which, if approved, would remove the intended function(s) from the CLB.

During the preparation and review of a SLRA, an applicant, or the NRC, may become aware of an aging management or TLAA issue that may be generically applicable (but is not yet part of the formal GSI resolution process). An applicant must still address the issue in its SLRA to demonstrate that the effects of aging are or will be adequately managed or that TLAAs have been evaluated for the SPEO.

See NUREG-2192, Appendix A.3, BTP RLSB-2 for more information on this matter.

1.6 ORGANIZATION OF THE GUIDELINE Obtaining a renewed operating license requires a three-phase approach. The first phase is the technical work that must be performed to generate the information that is included in the SLRA.

The second phase is the preparation of the SLRA. Phase three is submitting the SLRA and the post-submittal activities required up until issuance of the renewed operating license by the Commission.

The technical work includes determining the SSCs WSLR, identifying the SCs subject to AMR, identifying aging effects requiring management (AERMs), evaluating plant programs, and reviewing TLAAs and exemptions and justifying their applicability for license renewal. The technical phase produces results or information that is ultimately incorporated into the SLRA, so it is important to maintain accurate and detailed supporting documentation. This supporting documentation is not required to be submitted as part of the application; however, it must be auditable and retrievable for NRC review. Sections 3, 4 and 5 of this document provide guidance on how to proceed through the technical phase. These sections explain what work needs to be done, how to do it, and the expected results.

Section 6 discusses the standard SLRA format. The standard format is discussed in Appendix B.

Section 7 discusses the activities after submittal of the SLRA including annual updates, the review, and post-renewal process requirements.

Applicants are encouraged to review applications that have been submitted and the resulting SERs that are issued in the form of NUREGs.

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NEI 17-01 March 2017 2 OVERVIEW OF PART 54 The Rule contains the regulatory requirements that must be satisfied to obtain a renewed operating license, which allows continued operation of a nuclear power plant beyond its previous license term. (Figure 2.0-1 reflects the license renewal implementation process.)

The Rule is founded on two principles. The first principle of license renewal is that with the possible exception of the detrimental effects of aging on the functionality of certain plant SSCs in the SPEO and possibly a few other issues related to safety only during the SPEO, the regulatory process is adequate to ensure that the licensing bases of all currently operating plants provide and maintain an acceptable level of safety so that operation will not be inimical to public health and safety or common defense and security. The second and equally important principle of license renewal holds that the plant-specific licensing basis must be maintained during the renewal term in the same manner and to the same extent as during the original licensing term.

In addition to the identification and evaluation of TLAAs, the focus of the Rule is on providing reasonable assurance that the effects of aging on the functionality of long-lived, passive SCs are adequately managed in accordance with the plant-specific CLB design basis conditions such that the intended functions are maintained in the SPEO. This demonstration is documented in the SLRA.

The SLRA contains general information, technical information, information regarding technical specifications and environmental information.

The general information concerns the plant site and the plant owner(s). The required information is specified in 10 CFR 50.33(a) through (e), (h) and (i). Additionally, the application must include conforming changes to the standard indemnity agreement, 10 CFR 140.92, Appendix B, to account for the expiration term of the proposed renewed license.

The technical information includes: (1) the integrated plant assessment (IPA), which is the demonstration that the effects of aging on long-lived, passive SCs are being adequately managed such that the intended functions are maintained, consistent with the CLB, in the renewal period; (2) the listing and evaluation of TLAAs and any exemptions in effect that are based on TLAAs; and (3) a supplement to the plants UFSAR that contains a summary description of the programs and activities that are cited as managing the effects of aging and the evaluation of TLAAs.

The application also must include any changes or additions to the plants technical specifications that are necessary to manage the effects of aging during the SPEO. Last, the application must contain a supplement to the plants ER that complies with the requirements of 10 CFR Part 51.

Once the SLRA is submitted to the NRC, it must be amended each year to identify any changes to the CLB that materially affect the contents of the application, including the UFSAR supplement.

Information and documentation required by, or otherwise necessary to document compliance with, the Rule must be maintained by the applicant in an auditable and retrievable form for the term of the renewed operating license. Additionally, after the renewed license is issued, the 14

NEI 17-01 March 2017 UFSAR update required by 10 CFR 50.71(e) must include any SSCs newly identified that would have been subject to AMR or evaluated as a TLAA in accordance with §54.21.

The Rule, at 10 CFR 54.30, specifies matters that are not subject to NRC review and that may not be contested in a hearing for license renewal. The intent of the provision in 10 CFR 54.30 is to clarify that safety matters of noncompliance for the current operating term should not be the subject of the SLRA or the subject of a hearing in a renewal proceeding, absent specific NRC direction. Issues concerning operation during the currently authorized term of operation should be addressed as part of the current license in accordance with the Commissions current regulatory process rather than deferred until a renewal review (which will not occur if the licensee chooses not to renew its operating license). Furthermore, 10 CFR 54.30 is intended to make clear that aging issues discovered during the renewal review for the SCs that are reviewed in 10 CFR 54.21(a)(3) or §54.21 (c)(1) and that raise questions about the capability of these SCs to perform their intended function during the current term of operation must be addressed under the current license. However, an applicant for renewal is not relieved from addressing the issue relevant to the SPEO as part of its SLRA.

Section 54.30 does not require a general demonstration of compliance with the CLB as a prerequisite for issuing a renewed license. Section 54.30 discusses the applicants responsibilities for addressing safety matters under its current license, which are not within the scope of the renewal review.

Since this is a guidance document for SLR, its users will have already implemented Part 54 for the applicable plants initial LRA submittal and PEO entry. Because of the requirement under

§54.37(a) for the maintenance of auditable and retrievable documentation from that project, all of that documentation is available in the plants record storage system. Even for the plants that submitted LRAs prior to the issuance of NUREGs 1800, 1801, and Regulatory Guide 1.188, much of what was done for initial LR scoping, the IPA, and the determination of the TLAAs is still applicable for SLR. Complying with the requirements of §54.37(b) have served to keep that initial LR scope up to date due to the efforts required to analyze plant changes and report newly identified components to the NRC essentially for each refueling cycle. Some licensees, as part of that effort, will have also identified and documented the plant components that were found to have been added to the plant since initial LRA submittal. The coupling of both of those sets of information and the re-use of the IPA and TLAA documentation that provided the basis for the initial LRA submittal provide a significant starting point for SLR.

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NEI 17-01 March 2017 Figure 2.0-1: SLR Implementation Process Identify SSCs & intended functions Identify TLAAs &

WSLR [ § 54.4] Exemptions [§ 54.3 ]

(Section 3. 0) (Section 5. 0)

Methods to identify SCs subject to AMR

[§ 54.21(a)(1)(i) & (ii )] [§54.21 (a)(2)]

(Section 4. 1)

Methods for demonstrating that the Methods for evaluating TLAAs &

effects of aging are adequately exemptions managed [§ 54.21 (a)(3)] [§ 54.21(c)(1), (2)]

(Section 4. 2) (Section 5. 0)

Content of Application -

Technical Information:

- Identify long- lived, passive SCs [§ 54.21(a)(1)]

- Describe & justify methods [ § 54 .21(a)( 2)]

- Demonstrate AERMs [§ 54.21(a)(3)]

- Evaluation of TLAAs [ § 54.21( c)]

( Section 6. 0)

CLB Changes affecting SLRA Technical Specification Changes

[§ 54.21( b)] [§ 54. 22]

UFSAR Supplement

[§ 54.21(d)]

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NEI 17-01 March 2017 3 IDENTIFY THE SSCS WSLR AND THEIR INTENDED FUNCTIONS This section provides a process for determining which of the many SSCs that make up a commercial nuclear power plant are included WSLR. The scoping process described in this guideline is at the system and structure level for the majority of the SSCs. This is not intended to imply that scoping at a component level is not allowed by the Rule. In fact, for some plants it may be easier to scope at the component level. In addition, it may be convenient for a plant to scope using more than one method. For instance, a system-based scoping approach may be used for mechanical systems and a component or commodity-based scoping approach used for electrical systems (Figure 3.0-1 is a process diagram for this section).

To assist the applicant in determining the SSCs WSLR, a list of potential information sources is provided as Table 3.1.1. The table is not intended to be all encompassing nor is it intended to be a list of must review sources. During the development of this guidance document, there was significant interaction with the NRC staff regarding the inclusion of probabilistic risk assessment (PRA) summary report and individual plant examination of external events (IPEEEs) in the table.

Clearly, these two sources contain information that is beyond the plants licensing basis and, if the applicant chooses to use them as information sources, ultimately, the provisions of §54.4 prevail. This means that while the PRA summary report and the facilitys IPEEE may mention SSCs, only those that meet the criteria delineated in §54.4 are considered to be WSLR.

The Commission was clear on this point in the Statements of Consideration for the 1995 license renewal rulemaking. In response to a comment from the state of Illinois, the Commission acknowledges the existence of the PRA and IPEEEs; however, the Commission also stated The CLB for currently operating plants is largely based on deterministic engineering criteria.

Consequently, there is considerable logic in establishing license renewal scoping criteria that recognize the deterministic nature of a plants licensing basis. Without the necessary requirements and appropriate controls for plant-specific PRAs, the Commission concludes that it is inappropriate to establish a license renewal scoping criterion, as suggested by Illinois, that relies on plant-specific probabilistic analyses.

The table also identifies the emergency operating procedures (EOPs) and Severe Accident Management Guidelines (SAMGs) as potential information sources. Like the PRA summary report and the IPEEE studies, the EOPs and SAMGs are beyond design basis. While the Commission did not speak to the use of these documents in the Statements of Consideration, it is reasonable to extend the Commissions view on the use of PRA and IPEEEs as scoping criteria to the EOPs and SAMGs as well.

NUREG-2192, Section 2.1.3 and Table 2.1-1 list the documents an NRC reviewer is expected to consider. NUREG-2192, Section 2.1.3.1 describes some general expectations of scoping.

NUREG-2192, Sections 2.2.1, 2.2.3.1, and Table 2.2-1 provide examples an NRC reviewer may consider in reviewing scoping results.

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NEI 17-01 March 2017 3.1 SSCS WSLR Part 54 Reference

§54.4 (a) Plant systems, structures, and components within the scope of this part are -

(1) Safety-related systems, structures, and components which are those relied upon to remain functional during and following design-basis events (as defined as in 10 CFR 50.49 (b)(1)) to ensure the following functions:

(i) The integrity of the reactor coolant pressure boundary; (ii) The capability to shut down the reactor and maintain it in a safe shutdown condition; or (iii)The capability to prevent or mitigate the consequences of accidents that could result in potential offsite exposure comparable to the guidelines in § 50.34(a)(1),

50.67(b)(2), or § 100.11 of this chapter, as applicable.

(2) All non-safety-related systems, structures, and components whose failure could prevent satisfactory accomplishment of any of the functions identified in paragraphs (a)(1)(i),

(ii), or (iii) of this section.

(3) All systems, structures, and components relied on in safety analyses or plant evaluations to perform a function that demonstrates compliance with the Commission's regulations for fire protection (10 CFR 50.48), environmental qualification (10 CFR 50.49),

pressurized thermal shock (10CFR 50.61), anticipated transients without scram (10 CFR 50.62), and station blackout (10 CFR 50.63).

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NEI 17-01 March 2017 Figure 3.0-1: A Method to Identify SSCs and Intended Functions WSLR [§ 54.4(a) &(b)]

For each SSC in the plant, identify applicable information sources (process the SSC through each path)

Is the SSC relied on to Is the SSC SR? demonstrate compliance with

[§ 54.4(a)(1)] certain NRC regulations?

[§ 54.4(a)(3)]

No 1

Yes Is the SSC NSR whose failure could prevent a SR function? No 1 Yes

[§ 54.4(a)(2)]

No Yes Identify the function(s) that Identify the function(s) that meets demonstrates compliance with the the requirements of [§ 54.4(a)(1) or Commission's regulations [§ (2)]

54.4(a)(3)]

SSCs WSLR and the associated intended functions are identified SSC is not WSLR Figure 4.1-1 19

NEI 17-01 March 2017 3.1.1 Safety-Related SSCs There are a number of viable alternatives for identifying safety-related (SR) SSCs. Table 3.1-1 is a listing of information sources for consideration in this process. There may be information sources available to applicants that are not identified in Table 3.1-1. These sources may be considered as well.

Regardless of the approach used, a SR SSC is WSLR if it is relied upon to remain functional during and following design basis events as defined in §50.49(b)(1) to ensure the following functions:

The integrity of the reactor coolant pressure boundary; The capability to shut down the reactor and maintain it in a safe shutdown condition; or The capability to prevent or mitigate the consequences of accidents that could result in potential off-site exposure comparable to the guidelines in §50.34(a)(1), §50.67(b)(2), or

§100.11 of this chapter, as applicable.

It is conceivable that, because of plant unique considerations and preferences, applicants may have previously elected to designate some SSCs as SR that do not perform any of the requirements of §54.4(a)(1). Therefore, a SSC may not meet the requirements of §54.4(a)(1) although it is designated as SR for plant- specific reasons. However, the SSCs would still need to be evaluated for inclusion WSLR using the criteria in §54.4(a)(2) and §54.4(a)(3). For example, an applicant may have designated refueling equipment as SR even though it does not meet the criteria delineated above. In such cases, the applicant shall include a discussion of the process (in accordance with §54.21(a)(2)) for making these determinations.

Similarly, an applicants current licensing basis (CLB) definition of SR may not match the

§54.4(a)(1) definition. In these cases, the applicant should apply the §54.4(a)(1) definition for purposes of identifying the SSCs that are WSLR. This is consistent with NUREG-2192, Section 2.1.3.1.1.

Relative to the industrys post-Fukushima efforts, the modifications that have been made within the plant to facilitate new connections of the now required standby emergency portable power and emergency portable cooling water equipment may bring additional components installed associated with the new connections in the applicable interfacing systems into scope for license renewal. These added components are subject to AMRs but may screen out; however, the portable emergency equipment that is normally stored outside of the plant is not WSLR.

3.1.2 NSR SSCs Whose Failure Prevents SR SSCs from Fulfilling Their SR Function An applicant should rely on the plants CLB, actual plant-specific experience, industry wide OE, as appropriate, and existing plant-specific engineering evaluations to determine the appropriate SSCs in this category. Consideration of hypothetical failures that could result from system interdependencies that are not part of the CLB and that have not been previously experienced is not required. Hypothetical failures that are part of the CLB may require consideration of second-,

third-, or fourth-level support systems. NUREG-2192, Section 2.1.3.1.2 and Table 2.1-2 contain 20

NEI 17-01 March 2017 NRC expectations on non-safety-related (NSR) scoping. See Appendix F of NEI 95-10, Rev. 6, for the industry guidance for §54.4(a)(2) scoping criterion. Also see NUREG-2192, Table 2.1-2 regarding hypothetical failures.

For the plants that had initial LRA submittals prior to the 2004/2005 time frame, this effort may not have been the same methodology and/or standards as that performed for later LRA submittals. For that reason, those plants may need to expend more effort for their §54.4(a)(2) scoping effort for SLR.

3.1.3 SSCs Relied on to Demonstrate Compliance with Certain Specific Commission Regulations Systems, structures and components relied on to perform a function that demonstrates compliance with the following regulations are also in the scope of the Rule:

Fire Protection (10 CFR 50.48)

Environmental Qualification (10 CFR 50.49)1 Pressurized Thermal Shock (10 CFR 50.61) - only applicable to PWRs Anticipated Transient Without Scram (10 CFR 50.62)

Station Blackout (10 CFR 50.63)

The information sources in Table 3.1-1 could be considered for identifying the SSCs whose functions are relied on to demonstrate compliance with the regulatory requirements (i.e., whose functions were credited in the analysis or evaluation). Mere mention of a SSC in the analysis or evaluation does not constitute support of a specified regulatory function. An applicant should rely on the plants CLB, plant-specific experience, industry-wide OE, as appropriate, and existing plant-specific engineering evaluations to determine the appropriate SSCs in this category. Consideration of hypothetical failures that could result from system interdependencies that are not part of the plants CLB and that have not been previously experienced is not required. Hypothetical failures that are part of the CLB may require consideration of second-,

third-, or fourth-level support systems. See NUREG-2192, Section 2.1.3.1.3 for NRC expectations on regulated events scoping. Also see NUREG-2192, Table 2.1-2 regarding cascading.

Relative to Fire Protection under 10 CFR 50.48, many plants have adopted NFPA-805, replacing Appendix R, since receipt of their initial renewed operating licenses. This very likely affects the plant equipment that is WSLR for SLR as compared to what was WSLR for initial LR. Some plant equipment may have been added to scope and some equipment may have been deleted.

1 The Statements of Consideration (SOC) for the amendments to 10 CFR Part 54 [60FR22466] state that ...the Commission agrees that for purposes of §54.4, the scope of §50.49 equipment to be included within §54.4 is that equipment already identified by licensees under 10 CFR 50.49(b). Licensees may rely upon their listing of 10 CFR 50.49 equipment, as required by 10 CFR Part 50.49(d), for purposes of satisfying §54.4 with respect to equipment within the scope of §50.49.

21

NEI 17-01 March 2017 After the NRCs approval for NFPA-805 implementation, these differences should have been identified by the plants activities relative to its ongoing compliance with the requirements of

§54.37(b).

Table 3.1-1: Sample Listing of Potential Information Sources

Verified Databases (database that is subject to administrative controls to assure and maintain the integrity of the stored data or information)

Master Equipment Lists (including NSSS Vendor Listings)

Q-Lists

UFSARs

Piping and Instrument Diagrams

Electrical One-Line or Schematic Drawings

Operations and Training Handbooks

Design Basis Documents

General Arrangement or Structural Outline Drawings

Quality Assurance Plan or Program

Maintenance Rule Compliance Documentation

Design Basis Event Evaluations

Docketed Correspondence

System Interaction Commitments

Technical Specifications

EQ Program Documents

Regulatory Compliance Reports (Including SERs)

PRA Summary Report EOPs SAMGs IPEEEs

Initial LR project database(s)

Initial LR project scoping/screening reports

Initial LR project AMR reports

Initial LR project TLAA evaluation report

Initial LRA and applicable RAI responses and SER

Vendor Topical Reports 22

NEI 17-01 March 2017 3.2 INTENDED FUNCTIONS OF SSCS WSLR Part 54 Reference

§54.4

(b) The intended functions that these systems, structures, and components must be shown to fulfill in §54.21 are those functions that are the bases for including them within the scope of license renewal as specified in paragraphs (a)(1)-(3) of this section.

The intended functions define the plant process, condition, or action that must be accomplished to perform or support2 a safety function for responding to a design basis event or to perform or support a specific requirement of one of the five regulated events in §54.4(a)(3). At a system level, the intended functions may be thought of as the functions of the system that are the bases for including this system WSLR per §54.4(a)(1) - §54.4(a)(3). Where the plant's licensing basis includes requirements for redundancy, diversity, and defense- in-depth, the system intended functions include providing for the same redundancy, diversity, and defense-in-depth during the SPEO. For example, a system with two independent trains, according to the plant's CLB, has to perform the intended functions by each independent train.

As noted in the above reference, §54.4(b) provides criteria that should be used to identify the intended functions of SSCs within the scope of the Rule. Therefore, as part of the SLR process, an applicant should establish a method that identifies SSCs within the scope of the Rule and the intended functions that are the basis for their inclusion.

In identifying intended functions, it is important to understand that the terms systems, structures, and components (SSCs) and structures and components (SCs) are used differently throughout the Rule and statements of consideration (SOC). The SOC, in a footnote (60FR22462), clarifies why "SSCs" is used in some sections of the SOC and Rule versus "SCs ".

The SOC clarifies that the scoping section (§54.4) includes SSCs rather than just SCs to allow an applicant flexibility in how it develops and implements a methodology to identify those SCs that are subject to an AMR for SLR. Also, §54.4 and the associated SOC sections include SSCs to allow the applicant flexibility on how exemptions containing TLAAs can be evaluated for the SPEO (§54.21 (c)(2)) because exemptions might have been granted for a particular system.

The IPA required by §54.21(a) is performed at the structure/component level. Guidance on the IPA process is provided in Section 4 of this guideline. The Rule contains flexibility to permit an applicant to start the IPA process at either the system/structure or structure/component level as long as the passive, long-lived SCs are identified. The intended functions of the SCs are the same regardless of the starting point. If the starting point is the system level, the system intended functions are identified as previously discussed. However, the intended functions of the SCs still have to be determined as discussed in Section 4.1. These functions are the specific functions of the SCs that support the system/structure intended function(s). Similarly, if the starting point is the structure/component level, the intended functions are those that included these SCs WSLR. A 2

The term support here includes SSCs whose failure could prevent other SSCs from performing their intended function 23

NEI 17-01 March 2017 SC may have multiple functions; but, only the function(s) meeting the criteria of §54.4 are to be identified for SLR. See NUREG-2192, Table 2.1-4(a) and (b) for examples. Intended functions need not be defined for component piece parts.

The process leading to the Maintenance Rule scoping determinations may also have produced a listing of the system and structure functions. Although it is not a requirement of the Maintenance Rule, such a listing may be based on a documented procedure that ensures a comprehensive and consistent approach to defining the functions for all the systems within the scope of the Maintenance Rule. If this is the case, then the Maintenance Rule documentation can be used to help identify the functions of SR systems and NSR (affecting SR) systems WSLR. The information sources used to identify the systems required for compliance with the regulations in

§54.4(a)(3) should be used to identify their associated functions. If the Maintenance Rule documentation does not define the system functions, does not rely on a procedure that uses a structured approach, or the applicant elects not to use this source, then alternative documentation such as a verified database or a safety analysis report, operations training manuals, etc., can be used to identify the functions of SR systems and NSR (affecting SR) systems. A sample listing of information sources that can be used to identify the functions of all systems (and SCs) WSLR is provided in Table 3.1-1.

3.3 DOCUMENTING THE SCOPING PROCESS Section 54.37(a) of the Rule requires applicants to retain in an auditable and retrievable form all information and documentation required by, or otherwise necessary to document compliance with, the provisions of the Rule.

The results of the scoping determination should be documented in a format consistent with other plant documentation practices. The information may be maintained in hard-copy or electronic format. If available and appropriate, the information may be incorporated into an existing plant database. The applicant should use the quality assurance program in effect at the plant when documenting the results of the scoping process. The information to be documented by the applicant should include:

A designation of the plant SSCs that are SR (§54.4 (a)(1)), meet the requirements of §54.4(a)(2),

or meet the requirements of §54.4(a)(3);

Identification of the SSCs functions that meet the requirements of §54.4(b) and, therefore, are intended functions; and The information sources, used to accomplish the above, and any discussion needed to clarify their use.

NRC inspection for compliance with this requirement is performed in accordance with Inspection Procedure 71002, License Renewal Inspection.

Applicants have typically provided mechanical system drawings to NRC concurrent with the application. The drawings are generally not a part of the application and are submitted only to facilitate NRC staff review. The NRC staff reviews the scoping and screening in accordance with 24

NEI 17-01 March 2017 Section 2.3 of NUREG-2192. To facilitate NRC staff review, the applicants should submit drawings showing the mechanical components that are WSLR in accordance with 10 CFR 54.4(a), and in addition, system functions that meet 10 CFR 54.4(a) should also be identified.

4 INTEGRATED PLANT ASSESSMENT (IPA)

The IPA is the core of the SLRA. It is the transition from the scoping process to the screening process where the focus is on SCs and their intended functions. Once the SSCs WSLR are identified, the next step is to determine which SCs are subject to AMR. Specifically,

§54.21(a)(1) states that the AMR is required for the SCs that perform an intended function without moving parts or without a change in configuration or properties (i.e., it is passive) and that are not subject to replacement based on a qualified life or specified time period (i.e., it is long-lived). The IPA also includes a description and justification of the methods used to determine the passive, long-lived SCs and a demonstration that the effects of aging on those SCs will be adequately managed so that the intended function(s) will be maintained consistent with the plant-specific CLB for the SPEO.

Section 4.1 presents one method to identify SCs subject to AMR. There are two steps required to perform an AMR. First, aging effects that require management (AERMs) are identified and evaluated. Then AMPs are identified to manage the effects of aging such that the intended SC function can be maintained consistent with the CLB for the SPEO. Section 4.2 describes methods to identify AERMs. Evaluation of AMPs is presented in Section 4.3.

25

NEI 17-01 March 2017 4.1 IDENTIFICATION OF SCS SUBJECT TO AMR AND INTENDED FUNCTIONS Part 54 Reference

§54.21(a)(1)(i) and (ii)

(1) For those systems, structures, and components within the scope of this part, as delineated in §54.4, identify and list those structures and components subject to an aging management review. Structures and components subject to an aging management review shall encompass those structures and components -

(i) That perform an intended function, as described in §54.4, without moving parts or without a change in configuration or properties. These structures and components include, but are not limited to, the reactor vessel, the reactor coolant system pressure boundary, steam generators, the pressurizer, piping, pump casings, valve bodies, the core shroud, component supports, pressure retaining boundaries, heat exchangers, ventilation ducts, the containment, the containment liner, electrical and mechanical penetrations, equipment hatches, seismic Category I structures, electrical cables and connections, cable trays, and electrical cabinets, excluding, but not limited to, pumps (except casing), valves (except body), motors, diesel generators, air compressors, snubbers, the control rod drive, ventilation dampers, pressure transmitters, pressure indicators, water level indicators, switchgears, cooling fans, transistors, batteries, breakers, relays, switches, power inverters, circuit boards, battery chargers, and power supplies; and (ii) That are not subject to replacement based on a qualified life or specified time period.

§54.21(a)(2)

(2) Describe and justify the methods used in paragraph (a)(1) of this section.

The method that will accomplish the objective of identifying SCs subject to AMR must identify the SCs meeting the criteria of §54.21(a)(1)(i) and (ii). Figure 4.1-1 reflects the method described in this section 26

NEI 17-01 March 2017 Figure 4.1-1: Identification of SCs Subject to AMR [§ 54.21(a)(1)]

From Figure 3.0-1 Identify the components No Is the SSC a structure? Yes and their functions Is the component Is the component subject to replacement considered passive in the IPA Yes based on qualified life or specified No process?

time period?

[§ 54.21(a)(1)(i)]

[§ 54.21(a)(1)(ii)]

Determine if structure or component commodity groupings apply No Yes AMR is not required List the SCs that require AMR Figure 4.2-1 27

NEI 17-01 March 2017 Selection of an appropriate method is dependent on the applicants information management system(s). For example, the availability of computer databases of plant equipment may result in a more efficient component-by-component review. Absent such databases, an applicant may use a manual review based on system piping and instrumentation drawings and electrical one-line diagrams supplemented by other plant documentation as required.

If an applicant chooses, the applicant can use a bounding approach and the list could be larger (e.g.,

all passive SCs). Such a bounding approach may be more efficient, especially when a program will cover all SCs in an area whether or not all the SCs in the area are subject to AMR.

All long-lived, passive SCs that perform or support an intended function without moving parts or a change in configuration or properties are subject to AMR. For all such SCs, the SC intended function is documented for use during the AMR of the IPA. The SC intended function is the specific function of the SC that supports the system intended function. Plant-specific CLBs require intended functions to be performed under a variety of design conditions. NUREG-2192 (SRP), Table 2.1-4(a) & (b) is a listing of typical passive SC intended functions.

In making the determination that a SC's intended function is performed without moving parts or a change in configuration or properties, it is not necessary to consider the piece parts of the SC.

However, in the case of valves and pumps, the valve bodies and pump casings may perform an intended function by maintaining the pressure-retaining boundary and, therefore, would be subject to AMR.

If the SC is not subject to replacement based on a qualified life or specified time period, then it is considered long-lived pursuant to §54.21(a)(1)(ii). Replacement programs may be based on vendor recommendations, plant experience, or any means that establishes a specific service life, qualified life, or replacement frequency under a controlled program. SCs that are not long-lived are not subject to AMR.

Use of Commodity Groups It may be beneficial to create commodity groups of like SCs, possibly including those that are active and passive, to disposition the entire group with a single AMR. The basis for group SCs can be such characteristics as similar design, similar materials of construction, similar aging management practices, and/or similar environments. If the environment in which the SC operates suggests potential different environmental stressors, then the commodity group determination also could consider service time, operational transients, previous failures, and any other conditions that would suggest different results. Table 2.1-5 of NUREG-2192 provides a listing, although not all-inclusive, of typical plant components, structures, and commodity groups, along with a determination of whether the group is active or passive. Applicants are encouraged to use this table in determining SCs subject to an AMR.

Structures Requiring AMR Structures WSLR are long-lived and passive and require AMR. It may be useful, however, to categorize structures by type (e.g., poured concrete, block concrete, structural steel, shield walls, metal siding, foundation on piles, etc.) in preparation for the AMR. Subdividing complex structures into discrete elements (e.g., walls, floors, slabs, doors, penetrations, foundations, etc.) may be useful 28

NEI 17-01 March 2017 because some elements may not have intended functions as defined in the Rule and, therefore, are not subject to AMR. It may also be useful to individually identify spill containment, flood control, and fire barrier structural components where applicable and appropriate. A building, for example, with several rooms may be WSLR because one of its rooms performs an intended function. Only that one room needs to be identified as requiring AMR.

Structural Support Components Structural supports either support or restrain mechanical and electrical equipment (e.g., hangers, pipe whip restraints, cable trays and supports). Structural supports can be considered part of or separate from the applicable structure. This guideline assumes that structural support commodity groups will be addressed separately from the applicable structure.

Also, there may be piping segments that provide structural support. For example, the SR/NSR boundary along a pipe run may occur at a valve location. The piping segment between this valve and the next seismic anchor provides structural support in a seismic event. This piping segment is WSLR.

Complex Assemblies Some SCs, when combined, are considered a complex assembly (e.g., diesel generator starting air skids or heating, ventilating, and air conditioning refrigerant units). An applicant should establish the boundaries for such assemblies by identifying each SC that makes up the complex assembly and determining whether each one is subject to AMR. NUREG-2192, Table 2.1-2 provides an example for a control room chiller assembly of how the components that require AMR might be determined.

Consumables Consumables also need to be considered in the process for determining the SCs subject to an AMR.

Consumables, as used in this guideline, comprise the following four categories: (a) packing, gaskets, component seals, O-rings; (b) structural sealants; (c) oil, grease and component filters; and (d) system filters, fire extinguishers, fire hoses and air packs. Table 4.1-2 and NUREG-2192, Table 2.1-3 provide methods to disposition these consumables. Disposition of consumables should be described in the methodology as noted in NUREG 2192, Table 2.1-3.

29

NEI 17-01 March 2017 Table 4.1-1: Treatment of Consumables Consumable Disposition These would not necessarily be called out explicitly in Packing, Gaskets, Component the scoping and screening. Instead they would be Seals and O-rings implicitly addressed at the component level. The applicant will be able to exclude these utilizing a clear basis such as the example of ASME Section III not being relied upon for pressure boundary.

Structural sealants would not necessarily be called out Structural Sealants explicitly in the scoping and screening. Instead they would be implicitly addressed at the component level.

Structural sealants may perform functions without moving parts or change in configuration and they are not typically replaced. It is expected that the applicants structural AMP will address aging management of these items on a plant specific basis.

For these commodities, the screening process would Oil, Grease and Component be expected to exclude these materials because they Filters are short-lived.

These may be excluded, on a plant-specific basis, from System Filters, Fire Extinguishers, an AMR under 10 CFR 54.21(a)(1)(ii) in that they are Fire Hoses and Air Packs periodically replaced. The SLRA should identify the standards that are relied on for replacement as part of the method description; for example, NFPA standards for fire protection equipment.

30

NEI 17-01 March 2017 4.2 IDENTIFICATION OF AERMS Part 54 Reference

§54.21(a)(3)

(3) For each structure and component identified in paragraph (a)(1) of this section, demonstrate that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB for the period of extended operation.

This section presents various techniques used to identify AERMs. However, other techniques may be acceptable provided that the demonstration method required by §54.21(a)(3) is accomplished. Figure 4.2-1 depicts the process to identify AERMs.

The demonstration required by §54.21(a)(3) is developed by first determining how the SC or commodity group performs its intended function(s). Next, the AERMs are identified. Finally, the applicable prospective plant AMPs are identified, and the ability to manage the aging effects is reviewed. The assembled information is then used to demonstrate either that the effects of aging will be managed by existing AMPs so that the SC intended function(s) will be maintained for the SPEO or that an additional, new AMP is necessary.

31

NEI 17-01 March 2017 Figure 4.2-1: Identification of AERMs Figure 4.1-1 SC, or Commodity Group Specific Review Figure 5.0-1 Identify Material and Review OE Environment Identify Aging Effects Identify and Aging Effects Evaluation Aging Effects Evaluation Describe as a Consistent with NUREG- No Consistent with Exception to No Plant Specific 2191? NUREG-2191? Aging Effect Yes Yes Identify and Describe Exception Further Evaluation Required?

No Yes Document Further Evaluation Document Aging Effects Evaluation 32

NEI 17-01 March 2017 TECHNIQUES TO IDENTIFY AGING EFFECTS There are various techniques used to identify and assess aging effects. For some SCs, design margins and/or material properties are known and can be reviewed. In such cases, an analysis may be sufficient to demonstrate that the effects of aging are managed. For other SCs, performance or maintenance history is available and can be reviewed to assist in demonstrating that the effects of aging are managed. These and other considerations point to the need to determine the appropriate level of review for the type of SC or commodity group and plant-unique conditions.

Assessing the appropriate level of review involves examining information from various investigations and developing a scope statement to describe the depth of review that is needed for the SC or commodity group. As appropriate, the assessment should include the following activities:

Assemble information relative to the SC material properties and design margins. If the components are made from different materials or are subject to distinctly different aging effects, a separate review of each may be needed. Because minor differences in chemical content between different alloys may not significantly affect the way in which the materials age, in most cases detailed material specification may not be necessary to identify aging effects.

Internal and external environments to which components subject to an AMR are exposed should be defined to identify environmental parameters or conditions that are applicable to the environment. A specific environment may be used to bound several environments based on consistency with the specific environmental parameters or conditions.

Based on material and environment combinations, identify the aging effects potentially affecting the SCs abilities to perform their intended functions. Various industry documents are available to provide guidance on identification of those aging effects.

Review the design or material properties to determine if certain aging effects can be shown by analysis not to affect the capability of the SC to perform its intended function during the SPEO. Of particular interest are parameters such as corrosion allowance, fatigue cycles, loading conditions, fracture toughness, tensile strength, dielectric strength, radiation exposure, and environmental exposure.

OE review is described in Section 4.4.

Material-Environment-Stressor Approach To determine AERMs, the applicant should consider and address the materials, environment, and stressors that are associated with each SC or commodity group under review. In many instances, the proper selection of materials for the operating environment results in few, if any, AERMs. For example, erosion/corrosion has very little or no aging effect on stainless steel piping. Conversely, carbon steel is subject to erosion/corrosion in a raw water environment. Several industry references identify aging effects based upon specific material-environment combinations. After identification of plant-specific environments and materials, the following industry references could be used as the primary means to identify and evaluate aging effects:

33

NEI 17-01 March 2017 Non-Class 1 Mechanical Implementation Guideline and Mechanical Tools, EPRI 1010639 Aging Effects for Structures and Structural Components (Structural Tools), EPRI 1002950 License Renewal Electrical Handbook, EPRI 1003057.

In addition to the consideration of materials, environment, and stressors, the applicant should consider and address the plant-specific CLB, plant and industry OE and existing engineering evaluations to identify the AERMs for the SC subject to an AMR. The AERMs are those that have been identified using the considerations described above, and that adversely affect the SC such that the intended function(s) may not be maintained consistent with the CLB for the SPEO.

Spaces Approach The AMR can also be performed using a spaces approach. In the spaces approach, the plant is segregated into areas where common, bounding environmental parameters can be assigned. These areas can be of any size such as a specific area in a room, an entire room, a floor of a building or even all inside areas of an entire building. A bounding environmental parameter, such as temperature, would be the highest average temperature present around the subject components in the defined area.

When used to perform an AMR of a component or commodity group for a specific environmental stressor, the process would be as follows:

Identify all component or commodity group materials of construction that have potential aging effects when exposed to the environmental stressor.

Determine the value of the bounding environmental parameter to which the components in the area to be reviewed are exposed.

Compare the aging characteristics of the identified materials to the bounding environment and determine if the components will be able to maintain their intended function through the SPEO.

Plant-Specific Aging Analysis Based on Loss of Intended Function By analysis, an applicant may be able to demonstrate that it is not possible for an aging effect to result in a loss of the SCs intended function(s) under design basis conditions. The demonstration ultimately should conclude that there is reasonable assurance that the CLB will be maintained for the SPEO and, therefore, that the effects of aging need not be managed. A commitment to an inspection for SLR, as discussed in Section 4.3, may be needed to verify specific design values, demonstrate that an aging effect is occurring as anticipated, or that an aging effect is not significant. Monitoring industry OE, such as the results of inspections for LR or SLR at other plants, may also contribute to the demonstration in these cases.

Use of References Reviewed by the NRC Plant and generic industry references that provide an AMR of the same type of SC should be reviewed. A search of the public document room indices may identify such reports. References that have been reviewed and approved by the NRC provide an acceptable approach.

In the selected reference, identify the scope, assumptions and limitations affecting the results and conclusions of the analysis. Other characteristics that may need to be identified include the 34

NEI 17-01 March 2017 configuration, functions, materials, service conditions, and original design parameters (corrosion allowance, loading cycles, etc.) and protective measures (coatings, cathodic protection, etc.) affecting the expected service life of the SC.

The identified characteristics of the SC in the selected reference should be compared to the plant-specific SC. The objective is to demonstrate that the plant characteristics are the same as, or are bounded by, the reference, and, therefore, it may be concluded that the selected report is applicable and may be used as a basis for the AMR of the plant SC. Any outlier conditions should be identified and reviewed to show that they are not significant with respect to the results or conclusions of the selected reference. Otherwise, a SC-specific AMR (guideline Section 4.2.1) of the outlier condition should be performed.

4.2.1 Consistency with NUREG-2191, Volume 2 Line Items Each combination of component type, material, environment, and AERM should be compared with NUREG-2191 line items to identify consistencies. If there is no corresponding line item in NUREG-2191, the combination is a plant-specific aging evaluation result.

Each applicant should identify how the aging evaluation results align with information in NUREG-2191. This is accomplished through a series of notes identified in Table 4.2-2. All note references with letters are standard notes that will be the same from application to application throughout the industry. Any notes the plant requires that are in addition to the standard notes will be identified by a number and deemed plant-specific.

Table 4.2-1: NUREG-2191 Consistency Notes for AMR Results Standard Notes A. Consistent with NUREG-2191 item for component, material, environment, and aging effect.

AMP is consistent with NUREG-2191 AMP.

B. Consistent with NUREG-2191 item for component, material, environment, and aging effect.

AMP takes some exceptions to NUREG-2191 AMP.

C. Component is different, but consistent with NUREG-2191 item for material, environment, and aging effect. AMP is consistent with NUREG-2191 AMP.

D. Component is different, but consistent with NUREG-2191 item for material, environment, and aging effect. AMP takes some exceptions to the NUREG-2191 AMP.

E. Consistent with NUREG-2191 item for material, environment, and aging effect, but a different AMP is credited or NUREG-2191 identifies a plant-specific AMP.

F. Material not in NUREG-2191 for this component.

G. Environment not in NUREG-2191 for this component and material.

35

NEI 17-01 March 2017 H. Aging effect not in NUREG-2191 for this component, material, and environment combination.

I. Aging effect in NUREG-2191 for this component, material, and environment combination is not applicable.

J. Neither the component nor the material and environment combination are evaluated in NUREG-2191.

Plant-Specific Notes

1. Determined on a plant-specific basis.

4.3 DEMONSTRATE THAT THE EFFECTS OF AGING ARE MANAGED The Rule requires an applicant to demonstrate that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB for the SPEO.

In performing the demonstration, an applicant should consider all programs and activities associated with the SC. Plant programs and activities that apply to the SCs or commodity groups should be reviewed to determine if they include actions to manage the effects of aging.

AMPs are generally of four types: prevention, mitigation, condition monitoring, and performance monitoring. Prevention programs preclude the aging effect from occurring; for example, coating programs to prevent external corrosion of a tank. Mitigation programs attempt to slow the effects of aging; for example, chemistry programs to mitigate internal corrosion of piping. Condition monitoring programs inspect and examine for the presence of and extent of aging effects; for example, visual inspection of concrete structures for cracking and ultrasonic measurement of pipe wall for erosion-corrosion induced wall thinning. Performance monitoring tests the ability of a SC to perform its intended function(s); for example, heat balances on heat exchangers for the heat transfer intended function of the tubes (see NEI 95-10, Rev. 6, Appendix C, Reference 1).

In some instances, more than one type of AMP may be implemented to ensure that the aging effects are adequately managed to ensure the intended function is maintained in the SPEO. For example, managing the internal corrosion of piping may rely on a mitigation program (water chemistry) to minimize susceptibility to corrosion and a condition monitoring program (ultrasonic inspection) to verify that the corrosion is insignificant.

The demonstration is not intended to be a reverification of the SC design basis. However, in some cases, verification of a specific design basis parameter may be necessary if that parameter or condition is affected by an aging effect and potentially results in a loss of SC intended function. This verification may consist of a physical measurement at susceptible locations or on a sampling basis, as justified, or an evaluation that demonstrates that the aging effect will be at a sufficiently slow rate such that the design basis parameter will not be reduced below a value necessary to assure that the intended function(s) will be maintained during the SPEO. For example, a SR piping component is designed to have structural integrity under design loads, such as normal, upset, emergency, and faulted conditions, in accordance with the plants CLB. An aging effect that should be evaluated for piping is loss of material due to erosion/corrosion. A loss of material could result in pipe wall 36

NEI 17-01 March 2017 thinning below design values rendering the pipe unable to sustain its design loads. However, erosion/corrosion affects piping differently depending on the material of construction. Carbon steel piping may be susceptible to loss of material due to erosion/corrosion, and it would be appropriate to evaluate the pipe wall thickness to verify that this design value remains acceptable. Conversely, stainless steel piping is resistant to loss of material from erosion/corrosion and this aging effect normally would not be significant and, thus, it would not be necessary to evaluate the pipe wall thickness to verify this design value.

To make the required demonstration, an applicant may elect to rely on a single program/activity or a combination of AMPs/activities. Once the applicant has determined the approach for making the demonstration (i.e., single program/activity, multiple programs/activities), the potential aging management program/activity will be evaluated for the 10 elements noted in Table 4.3-1. Hereafter, AMP(s), aging management activities, or collections of aging management programs and activities used to manage an aging effect will be referred to as an AMP.

Figure 4.3-2 identifies three methods that can be used to review the acceptability of an AMP to manage aging in the SPEO. The following sections describe the three methods:

Section 4.3.1 provides a method to review an AMP to demonstrate that the AMP corresponds to the AMP reviewed and approved in NUREG-2191,Section X or Section XI.

Section 4.3.2 provides a method to perform a plant-specific evaluation of an AMP that is not described in NUREG-2191.

Section 4.3.3 provides a method to reference the results of a previous review of an AMP that has been found acceptable by the NRC.

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NEI 17-01 March 2017 Table 4.3-1: Aging Management Activity 10 Program Elements Element Description

1. Scope of the Activity Scope of the program/activity should include the specific SCs subject to AMR for SLR.

2. Preventive Actions Preventive actions should mitigate or prevent aging degradation.

3. Parameters Monitored or Parameters monitored or inspected should be linked to the Inspected degradation of the particular SC intended function(s).

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

5. Monitoring and Monitoring and trending should provide predictability of the Trending extent of degradation and provide timely corrective or mitigating actions.

6. Acceptance Criteria Acceptance criteria, against which the need for corrective action will be evaluated, should ensure that the SC intended function(s) are maintained under all CLB design conditions during the SPEO.

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

8. Confirmation Processes Confirmation processes should ensure that preventive actions are adequate and that 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 OE of the aging management activity, including past corrective actions resulting in program enhancements or additional programs or activities, should provide objective evidence to ensure that the effects of aging will be adequately managed so that the intended functions of the SC will be maintained during the SPEO.

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NEI 17-01 March 2017 Figure 4.3-1: AMP Review Identify Potential Aging Management Activity(s) From Figure 4.2-1 Evaluate AMP Can a previously using NUREG- approved NRC No 2191 section X AMP be or XI criteria? credited?

Yes Yes If required by NUREG-2191, If required, perform plant perform further evaluation specific evaluations No Is plant AMP consistent with No previously approved NRC AMP?

Is AMP Will consistent with enhancements Evaluate AMP using NUREG-2191? be required? NUREG-2191 Appendix A1 AMP No elements Yes Yes Describe Yes enhancement to Describe and If required, describe AMP justify exception enhancement to AMP Document 10 element AMP review & further evaluation (As required) 39

NEI 17-01 March 2017 4.3.1 AMP Review Using NUREG-2191 The AMP should be reviewed to confirm that it is consistent with each of the 10 elements of the generic program described in NUREG-2191 Section X or Section XI. NUREG-2191 documents the NRC staffs basis for determining whether certain programs are adequate to manage aging effects without change or should be augmented to manage aging effects. NUREG-2191 may be referenced in a SLRA and should be treated in the same manner as an NRC approved topical report. If each of the 10 elements in NUREG-2191 is applicable and consistent with the proposed AMP, the NRC should find that the reference to the NUREG-2191 AMP is acceptable and no further review is required.

Note that NUREG-2191 identifies one acceptable way to manage aging effects. Alternative methods to manage aging may be proposed in the SLRA. Although the use of NUREG-2191 is not required, its use should facilitate timely, uniform review by the NRC.

If a NUREG-2191 AMP is selected to manage aging, the AMP review should demonstrate consistency of the plant-specific AMP elements with the NUREG-2191 AMP elements. Some engineering judgment may be used in determining that an AMP is consistent with NUREG-2191.

When there is some expectation that the NRC staff may not come to the same determination with respect to the same program element, the differences should be identified and documented. Any exceptions of the plant AMP to the NUREG-2191 AMP elements should be described and justified.

The justification may use an analysis, propose an alternate technique, or provide other considerations to confirm that the exception, when considered in conjunction with the remainder of the 10 elements, would demonstrate that the effects of aging will be adequately managed. The justification may entail identification that the exception was approved for a previous renewed license for the plant under review. Additionally, the applicant may use past precedents for the exception from its approval at another plant to justify the exception. In these two instances, the exception and associated justification must be consistent with the review in the applicable plants LR SER.

Certain line items in NUREG-2191 mechanical, electrical, and structural sections identify AMPs that require further evaluation to augment the specified NUREG-2191 AMP. When required, NUREG-2191 further evaluations must be documented and their conclusions presented in conjunction with the results of the NUREG-2191 AMP evaluation for NRC review.

Enhancements There may be an AMP where all the NUREG-2191 AMP recommendations cannot be satisfied without appropriate enhancements to the AMP or preparation of a new AMP may be needed.

Enhancements are revisions or additions to existing AMP(s) that will be committed for implementation prior to the SPEO. Enhancements may expand, but not reduce the scope of the AMP.

Enhancements may include, but are not limited to, verification of specific design values by inspection(s), adding steps to an AMP for specific aging effects, changing the frequency of the required task, adding specific aging effects mitigation procedures, or changing the record-keeping requirements. The factors that should be considered when selecting an appropriate enhancement include:

The risk significance of the SC; The nature of the aging effect (i.e., is it readily apparent/easily detected?);

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NEI 17-01 March 2017 The feasibility of repair/replacement of the affected SC; The compatibility/adaptability of existing programs to detect and manage the aging effect(s);

The existence of technology to detect and manage the aging effect(s); and The estimated cost, personnel radiation exposure, and impact on normally scheduled outage duration for determining the enhancement.

If existing AMPs, with or without enhancements, are not adequate for managing the effects of aging, new programs or other actions shall be developed as appropriate. One action an applicant could use is a One-Time Inspection Program as discussed in NUREG-2191,Section XI.M32. It is possible that an applicant is already performing a relevant inspection or has previously performed an inspection that produced appropriate data for SLR. Other actions for consideration are refurbishment3 or replacement.

Quality Assurance and Administrative Controls Existing 10 CFR 50, Appendix B, Quality Assurance Programs may be used to generically address the AMP elements of corrective actions, confirmation process, and administrative controls for SR SSCs WSLR. For NSR SCs subject to an AMR, the existing 10 CFR 50, Appendix B, Quality Assurance Program may be used to address the AMP elements of corrective actions, confirmation process, and administrative controls. Alternative means to address the elements of corrective actions, confirmation process, and administrative controls for managing aging of NSR SCs that are subject to AMR may be used but should be consistent with the guidance in NUREG-2192, Appendix A.1 for the applicable elements.

4.3.2 Plant-Specific AMP Review NUREG-2191 identifies acceptable AMPs to manage aging effects. Alternative (plant-specific) methods to manage aging may be proposed in the SLRA. Plant-specific AMPs should be described in terms of the 10 program elements noted in Figure 4.3-1 and the guidance in NUREG-2192, Appendix A.1, Aging Management Review - Generic (Branch Technical Position RLSB-1).

The following should be considered when performing a plant-specific AMP review:

Parameters monitored/inspected: This attribute should include observable parameters or indicators to be monitored or inspected for each aging effect managed. The observable parameters should be linked to the degradation of the SC intended functions in the SPEO.

The plant-specific AMR should either (1) identify an AMP that detects the effects of aging before the SC would lose the ability to perform its intended function, or (2) demonstrate that the SC intended function will be maintained during the SPEO without the need for an AMP.

When an inspection is necessary, sampling may be used to evaluate a group of SCs. If sampling is used, the program description should describe and justify the methods used for selecting the population and the sample size. A sample consists of one or more SCs drawn from the scope. The applicant must determine a sample size that is adequate to provide reasonable assurance that the effects of aging on the SC population will not prevent the performance of intended functions during the SPEO. The size of the sample should include 41

NEI 17-01 March 2017 consideration of the specific aging effect, location, existing technical information, materials of construction, service environment, previous failure history, etc. The sample should be biased toward locations most susceptible to the specific aging effect of concern. The results of the inspection also should be evaluated to assess whether the sample size is adequate or if it needs to be expanded.

An inspection for SLR may be performed prior to submittal of the SLRA. The SLRA may include a commitment to perform an inspection prior to the commencement of the SPEO.

There also may be justification for performing the inspection during the SPEO.

AMP elements of corrective actions, confirmation process, and administrative controls were previously addressed in the Quality Assurance and Administrative Controls portion of Section 4.3.1.

4.3.3 Use of AMP Previously Approved by NRC Industry references (e.g. Owners Group Topical Reports, BWRVIP, etc.) that have been approved and reviewed by the NRC can be used to demonstrate that the effects of aging will be managed. The selected reference should also be used to identify the AERMs and confirm that the assumptions and basis used for determining the aging effects are applicable to the plant. To do this, a review of the plant operating and maintenance history should be performed to confirm that all aging effects apply.

Adjustments to the referenced aging effects due to plant-specific conditions may be required. The results may be factored into the description of the aging effects.

The selected reference should be used to identify the programs and features of the programs credited in the review. The comparable plant programs should be identified, and their features should be compared to the programs in the selected reference. Any differences should be identified, and it should be justified that conclusions of the selected reference still apply. The justification may be based on plant-unique features, plant operating and maintenance history, and/or industry developments since the selected reference was issued and reviewed by the NRC. Any plant-specific evaluations required by the reference should be performed.

Any enhancements to current programs or new programs that are cited in the selected reference should be identified. The enhancement(s) that will be implemented for the plant SC should be described.

4.4 OE REVIEW Industry and plant-specific OE requires review to identify AERMs that are not identified by the industry guidance documents (such as EPRI tools) and to confirm the effectiveness of AMPs.

OE - AERMs A plant-specific OE review should assess the operating and maintenance history. A review of the prior five to ten years or back to the first LRA OE cut-off date of operating and maintenance history should be sufficient. The results of the review should confirm consistency with documented industry OE. Differences with previously documented industry experience such as new aging effects or lack of aging effects allow consideration of plant-specific aging management requirements.

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NEI 17-01 March 2017 OE with AMPs Plant-specific OE with existing programs must be considered. The OE of AMPs during the first PEO, including past corrective actions resulting in program enhancements or additional programs, must 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 SPEO.

Guidance for reviewing industry OE is presented in BTP RLSB-1 in Appendix A.1 of the Branch Technical Positions in NUREG-2192. Appendix A.4 also addresses AMP OE and AMP effectiveness considerations from the previous PEO. Also NEI 14-12 (Reference 27) as described in section 1.1 should be considered.

Industry OE Industry OE and its applicability should be assessed to determine whether it changes plant-specific determinations. NUREG-2191 is based upon industry OE prior to its date of issue. OE after the issue date of NUREG-2191 should be evaluated and documented as part of the AMR. In particular, generic communications such as a bulletin or an information notice should be evaluated for impact upon the AMP. The evaluation should check for new aging effects or a new component or location experiencing an already identified aging effect. Also NEI 14-13 (Reference 28) as described in section 1.1 should be considered.

4.5 DOCUMENTING THE IPA Section 54.37(a) of the Rule requires applicants to retain in an auditable and retrievable form all information and documentation required by, or otherwise necessary to document compliance with, the provisions of the Rule.

The results of the IPA should be documented in a format consistent with other plant documentation practices. The information may be maintained in hard-copy or electronic format. It may be appropriate to incorporate the information into an existing plant database if available. The applicant should use the quality assurance program in effect at the plant when documenting the results of the IPA.

4.5.1 Documenting the Identification of SCs Subject to an AMR The information to be documented and retained by the applicant should include:

An identification and listing of SCs subject to an AMR and the intended functions; A description and justification of the methods used to determine the SCs that are subject to AMR; and The information sources used to accomplish the above, and any discussion needed to clarify their use.

The information documented and retained by the applicant will form the bases of the information contained in the application as further discussed in Section 6.

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NEI 17-01 March 2017 4.5.2 Documenting the AMR The information to be documented by the applicant should include:

An identification of the AERMs; An identification of the specific programs or activities that will manage the effects of aging for each SC or commodity group listed; A description of how the programs and activities will manage the effects of aging; A discussion of how the determinations were made; A list of substantiating references and source documents; A discussion of any assumptions or special conditions used in applying or interpreting the source documents; and A description of AMPs credited for SLR.

The information documented and retained by the applicant will form the bases of the information contained in the SLRA as further discussed in Section 6.

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NEI 17-01 March 2017 5 TLAAS INCLUDING EXEMPTIONS The Rule requires that TLAAs be evaluated. It is intended that TLAAs will capture certain plant-specific aging analyses that are explicitly based on the current operating term of the plant. In addition, the Rule requires exemptions, based on TLAAs, to be identified and analyzed to justify continuation into the SPEO. Figure 5.0-1 outlines the process for evaluating TLAAs and exemptions.

5.1 TLAAS Part 54 Reference

§54.3

Time-limited aging analyses, for the purposes of this part, are those licensee calculations and analyses that:

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

(2) Consider the effects of aging; (3) Involve time-limited assumptions defined by the current operating term, for example, 40 years; (4) Were determined to be relevant by the licensee in making a safety determination; (5) Involve conclusions or provide the basis for conclusions related to the capability of the system, structure, and component to perform its intended functions, as delineated in §54.4(b); and (6) Are contained or incorporated by reference in the CLB.

§54.21(c)(1)

(1) A list of time-limited aging analyses, as defined in §54.3, must be provided.

The applicant shall demonstrate that -

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

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NEI 17-01 March 2017 Figure 5.0-1: Evaluation of TLAAs and Exemptions [§ 54.21(c)]

Identify generic TLAA issues Identify the exemptions in effect Identify potential plant unique TLASS issues Is the exemption Yes based on a TLAA issue?

No further Does the evaluation TLAA meet No the criteria of § 54.3?

Yes No Determine the method of TLAA evaluation Analysis AMP Verify that Justify that Verify that the TLAA is the TLAA the TLAA is No further valid for can be resolved by evaluation of the SPEO? OR projected managing the exemption to the end the aging is required for of the SPEO effects SLR Figure 4.2-1 Document the evaluation 46

NEI 17-01 March 2017 The applicant must identify the plant-specific TLAA by applying the six criteria delineated in §54.3.

The criteria may be applied in any order depending on plant- specific document search capabilities.

Guidance for applying the six criteria is provided below.

Involve SSCs WSLR as delineated in §54.4(a). The SSC scoping step of the IPA (Section 3.0) should be performed prior to or concurrent with the TLAA identification. (TLAAs may involve active and/or passive components)

Consider the effects of aging. The effects of aging include, but are not limited to, loss of material, loss of toughness, loss of pre-stress, settlement, cracking, and loss of dielectric properties.

Involve time-limited assumptions defined by the current operating term; e.g., 60 years. The defined operating term should be explicit in the analysis. Simply asserting that a component is designed for a service life or plant life is not sufficient. The assertion should be supported by calculations or other analyses that explicitly include a time limit.

Were determined to be relevant by the licensee in making a safety determination. Relevancy is a determination that the licensee must make based on a review of the information available.

A calculation or analysis is relevant if it can be shown to have direct bearing on the action taken as a result of the analysis performed. Analyses are also relevant if they provide the basis for the licensees safety determination and, in the absence of the analyses, the licensee may have reached a different safety conclusion.

Involve conclusions or provide the basis for conclusions related to the capability of the SSC to perform its intended functions as delineated in §54.4(b). As stated in the first criterion, the intended functions must be identified prior to or concurrent with the TLAA identification.

Analyses that do not affect the intended functions of the SSCs are not TLAAs.

Are contained or incorporated by reference in the CLB. Plant-specific documents contained or incorporated by reference in the CLB include the UFSAR, SERs, Technical Specifications, the fire protection plan/hazards analyses, correspondence to and from the NRC, QA plan, topical reports included as references within the UFSAR or correspondence to the NRC.

Calculations and analyses that are not in the CLB or not incorporated by reference are not TLAAs. When the code of record is mentioned in the UFSAR, for particular groups of SCs, referenced material includes all calculations required by that code of record for those SCs.

All six criteria must be satisfied to conclude that a calculation or analysis is a TLAA. As an aid to applicants, Table 5.1-1 provides examples of how the six criteria may be applied and Table 5.1-2 lists potential TLAAs that have been identified from the industrys review of plant-specific CLB documents, various codes, standards, and regulatory documents. The table also identifies TLAA considerations that are specifically identified in NUREG-2192, Section 4.

TLAAs that need to be addressed are not necessarily those analyses that have been previously reviewed or approved by the NRC. The following examples illustrate TLAAs that need to be addressed and were not previously reviewed and approved by the NRC:

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NEI 17-01 March 2017 The UFSAR states that the design complies with a certain national code and standard. A review of the code and standard reveals that an analysis or calculation is required. Some of these calculations or analyses will be TLAAs. The actual calculation was performed by the licensee to meet code and standard requirements. The specific calculation was not referenced in the UFSAR. The NRC has not reviewed the calculation.

In response to a generic letter, a licensee submitted a letter to the NRC committing to perform a TLAA that would address the concern in the generic letter. The NRC had not documented a review of the licensees response and had not reviewed the actual analysis.

The following examples illustrate analyses that are not TLAAs and need not be addressed under 10 CFR 54.21(c):

Population projections; Cost-benefit analysis for plant modifications; or Analysis with time-limited assumptions defined short of the current operating term of the plant; for example, an analysis for a component based on a service life that would not reach the end of the current operating term.

Identified plant-specific TLAAs must be demonstrated acceptable in accordance with §54.21(c)(1) of the Rule. One approach is to verify that the analysis remains valid for the SPEO. Guidance for this approach is provided under Section 5.1.1. Another approach is to verify that the analysis can be projected to the end of the SPEO. Guidance for this approach is provided in Section 5.1.2. A third approach is to show that the effects of aging on the intended function(s) will be adequately managed for the SPEO. Guidance for this approach is provided in Section 5.1.3.

5.1.1 Verify that the TLAA Is Valid for the SPEO The TLAAs are based on the current operating term (e.g., 60 years). Therefore, the approach outlined in this section may not be applied for the extended operating term, and one of the other approaches (see Sections 5.1.2 and 5.1.3) should be utilized. However, there may be cases where the original analysis or efforts to address new issues during plant operation have resulted in an analysis that can be demonstrated to remain valid for the SPEO. A SC may have been qualified for at least 60 years. A detailed review of the analysis may demonstrate that the qualification is valid for the SPEO and no reanalysis is required. An acceptable approach for verifying that the TLAA remains valid is described in the following paragraphs.

The TLAA issue should be described with respect to the objective(s) of the analysis, conditions and assumptions used in the analysis, acceptance criteria, AERMs, and intended function(s). It should be demonstrated that (1) the conditions and assumptions used in the analysis already address the AERM(s) for the SPEO, and (2) acceptance criteria are maintained to provide reasonable assurance that the intended function(s) is maintained.

Any actions and an associated implementation plan for reconciling the affected TLAA source documents should be identified.

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NEI 17-01 March 2017 5.1.2 Justifying the TLAA Can Be Projected to the End of the SPEO The current TLAA may not be valid for the SPEO; however, it may be possible to revise the TLAA by recognizing and reevaluating any conservative conditions and assumptions. Examples include relaxing overly conservative assumptions in the original analysis, using new or refined analytical techniques and/or performing the analysis using an 80-year life. The TLAA may then be shown to be valid for SPEO.

5.1.3 Verify that the TLAA is Resolved by Managing the Aging Effects The SC(s) associated with the TLAA should be identified. The TLAA should be described with respect to the objectives of the analysis, conditions and assumptions used in the analysis, acceptance criteria, AERM(s) and intended function(s). The guidance provided in Section 4.2 may be used to demonstrate that the effects of aging on the intended function are adequately managed for the SPEO.

Also, the monitoring of the aging effect analyzed in the TLAA may include future inspection/examination to detect the aging effect. See NUREG-2191,Section X for TLAA-specific programs the NRC has evaluated.

5.1.4 Timing for Evaluation of TLAA The evaluation of TLAAs could be completed and submitted at the time of the SLRA. However, an applicant may defer the completion of the evaluation of TLAAs to a time after the issuance of the renewed license.

When an applicant elects to defer completing the evaluation of a TLAA at the time of the SLRA, the applicant should submit the following details in the SLRA to support a conclusion that the effects of aging addressed by that TLAA will be managed for a specific SC:

Details concerning the method that will be used for TLAA evaluation; Acceptance criteria that will be used to judge the adequacy of the SC, consistent with the CLB, when the TLAA evaluation or analysis is performed; Corrective actions that the applicant could perform to provide reasonable assurance that the component in question will perform its intended function when called upon or will not be outside its design basis established by the plants CLB; and Identification of when the TLAA evaluation will be completed to ensure that the necessary evaluation will be performed before the SC in question would not be able to perform its intended functions established by the CLB.

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NEI 17-01 March 2017 Table 5.1-1: Disposition Of Potential TLAAs And Basis For Disposition Example Disposition NRC correspondence requests a utility to justify This example does not qualify as a TLAA that unacceptable cumulative wear did not occur because the design life of control rods is less during the design life of control rods. than 40 years. Therefore, does not meet criterion (3) of the TLAA definition in § 54.3.

Maximum wind speed of 100 mph is This is not a TLAA. Does not involve an expected to occur once per 50 years. aging effect.

Correspondence from the utility to the NRC This example does not meet criterion (4) of the states that the membrane on the containment TLAA definition in § 54.3 and, therefore, is not basemat is certified by the vendor to last for considered a TLAA. The membrane was not 40 years. credited in any safety evaluation.

Fatigue usage factor for the pressurizer surge This example is a TLAA because it meets all six line was determined not to be an issue for the criteria in the definition of TLAA in current license period in response to NRC § 54.3. The utilitys fatigue design basis reliesBulletin 88-11. on assumptions related to 40 year operating life for this component. Plant specific data could be used but is more difficult due to thermal stratification.

Containment tendon liftoff forces are calculated This example is a TLAA because it meets all six for the initial 40-year life of the plant. This data criteria of the TLAA definition in is used during Technical Specification § 54.3. The liftoff force curves are limited to 40 surveillance for comparing measured to year values currently and are needed to perform predicted liftoff forces. a required Technical Specification surveillance.

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NEI 17-01 March 2017 Table 5.1-2: Potential TLAAs TLAA NUREG-2192 TLAA Considerations

- Upper-Shelf Energy

- Pressurized Thermal Shock (PWRs)

Reactor Vessel Neutron - Pressure-Temperature (P-T) Limits Embrittlement - Elimination of Circumferential Weld Inspection (for BWRs)

- Axial Welds (for BWRs)

- ASME Section III, Class 1

- ANSI B31.1 Metal Fatigue Analysis

- Other Evaluations Based on CUF

- ASME Section III, Class 2 and 3 Environmental Qualification of - DOR Guidelines Electrical Equipment - NUREG-0588, Category II (IEEE Std 323-1971)

- NUREG-0588, Category I (IEEE Std 323-1974)

- GSI 168 Concrete Containment Tendon - Concrete Containment Tendon Prestress Analysis Prestress Containment Liner Plate, Metal - ASME Section III, MC or Class 1 Containments and Penetrations - Other Evaluations Based on CUF Fatigue Analysis Other Plant-Specific TLAAs - See Note Note: NUREG-2192 provides general guidance for plant-specific TLAAs. Some examples of plant-specific TLAAs identified in previous LRAs include:

In-service flaw growth analyses that demonstrate structure stability for 40 years Containment penetration pressurization cycles Fatigue analysis of polar crane (Crane cycle load limits)

Reactor Coolant Pump Fly Wheel Leak-Before-Break Analysis Service Water Intake Structure Settlement CE-half-nozzle design and mechanical nozzle seal assemblies 51

NEI 17-01 March 2017 5.2 EXEMPTIONS Part 54 Reference

§54.21(c)(2)

(3) A list must be provided of all plant-specific exemptions granted pursuant to 10 CFR 50.12 and in effect that are based on time-limited aging analyses as defined in §54.3. The applicant shall provide an evaluation that justifies the continuation of these exemptions for the period of extended operation Section 54.21(c)(2) of the Rule requires that a list of all exemptions granted under 10 CFR 50.12 that are in effect and based on a TLAA be provided along with the evaluation of TLAAs.

Identification of an exemption may require the review of correspondence between the NRC and the plant. Many plants have licensing commitment tracking systems or databases of information on licensing documents. As an alternate method or as verification to the search, the NRCs ADAMS may be utilized to search for licensing correspondence and, thus, exemptions granted.

It should be determined that the exemption granted pursuant to 10 CFR 50.12 will be in effect during the SPEO, involves a SSC WSLR and involves a time-limited aging issue. If all of these conditions apply, then an evaluation of the exemption must be performed. The TLAA within the exemption is evaluated using the guidance in Section 5.1.

The scope of the exemption, the analysis that forms the basis for the exemption, and the affected SC(s) and/or the TLAA should be identified. The analysis that forms the basis for the exemption may have been identified during the evaluation of the TLAAs.

The exemption should be evaluated to determine its effect on the capability of the associated plant programs to detect or mitigate the effects of aging or on the conditions and assumptions used in the TLAA for the SPEO. The evaluation of the associated TLAA may provide sufficient justification to continue the exemption.

5.3 DOCUMENTING THE EVALUATION OF THE TLAAS AND EXEMPTIONS Section 54.37(a) of the Rule requires applicants to retain in an auditable and retrievable form all information and documentation required by, or otherwise necessary to document compliance with, the provisions of the Rule.

The results of the TLAAs and exemptions evaluation should be documented in a format consistent with other plant documentation practices. The information may be maintained in hard-copy or electronic format. If available and appropriate, the information may be incorporated into an existing plant database. The applicant should use the quality assurance program in effect at the plant when documenting the results of the TLAAs and exemptions evaluation.

The information to be documented by the applicant should include:

A list of the TLAAs and exemptions applicable to the plant; 52

NEI 17-01 March 2017 A description of the evaluation performed or to be performed on each plant- specific TLAA and exemption; A general discussion of how the determinations were made; A list of substantiating references and source documents; and A discussion of any assumptions or special conditions used in applying or interpreting the source documents.

The information documented and retained by the applicant will form the bases of the information contained in the application as further discussed in Chapter 6.

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NEI 17-01 March 2017 6 SLRA FORMAT AND CONTENT The standard SLRA format is presented in Table 6.2-1. Table 6.2-2 provides guidance for preparing the standard SLRA. Contents of the SLRA are general information required by §54.17 and §54.19 and technical information required by §54.21, §54.22 and §54.23.

6.1 GENERAL INFORMATION The SLRA contains the technical information that the NRC staff will review to determine if the effects of aging on long-lived, passive SCs are being managed such that the associated intended functions are maintained consistent with the CLB in the SPEO. The technical information must be of sufficient detail to allow the NRC to make the finding that there is reasonable assurance that the activities authorized by the renewed license will continue to be in accordance with the CLB

(§54.29(b)).

The application should contain clear and concise presentations of the required information.

Confusing or ambiguous statements and unnecessarily verbose descriptions do not contribute to expeditious technical review. Claims of adequacy in the AMR should be supported by technical bases. The level of detail contained in the application should be commensurate with the requirements of the Rule.

The NRC staff reviewers will use NUREG-2191 and NUREG-2192 during their evaluation of the SLRA. An applicant should consider addressing differences from NUREG-2192 in the SLRA.

Generally, applicants will find it beneficial to credit many of the NUREG-2191 evaluations of AMPs.

NUREG-2191 provides one way to manage the aging effects. Other programs may be demonstrated to be adequate. Section 4.3 of this guideline identifies three methods that can be used to demonstrate that the effects of aging are managed. The SLRA is based on the information contained in plant-specific documentation as described in Sections 3.3, 4.3, and 5.3 of this guideline. However, detailed procedures/calculations need not be included in the SLRA. Once the license is issued the application is a historical licensing document and is not required to be updated.

6.2 SLRA FORMAT AND CONTENT GUIDANCE This section provides the standard SLRA format. Table 6.2-1 is the SLRA Table of Contents.

Guidance for preparing the information for each section of the SLRA is provided in Table 6.2-2.

Additional guidelines are provided in Appendix B. This format was developed by applicants who planned submittals to NRC in 2003 and has since been standardized.

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NEI 17-01 March 2017 Table 6.2-1: Standard SLRA Format 1 ADMINISTRATIVE INFORMATION 2 SCOPING AND SCREENING METHODOLOGY FOR IDENTIFYING SCs SUBJECT TO AMR AND IMPLEMENTATION RESULTS 2.1 Scoping and Screening Methodology 2.2 Plant Level Scoping Results 2.3 Scoping and Screening Results: Mechanical Systems 2.3.1 Reactor Coolant System 2.3.2 Engineered Safety Features 2.3.3 Auxiliary Systems 2.3.4 Steam and Power Conversion System 2.4 Scoping and Screening Results: Structures 2.5 Scoping and Screening Results: Electrical and Instrumentation and Controls Systems 3 AMR RESULTS 3.1 Aging Management of Reactor Vessel, Internals and Reactor Coolant System 3.2 Aging Management of Engineered Safety Features 3.3 Aging Management of Auxiliary Systems 3.4 Aging Management of Steam and Power Conversion System 3.5 Aging Management of Containments, Structures and Component Supports 3.6 Aging Management of Electrical and Instrumentation and Controls 4 TLAAs 4.1 Identification of TLAAs 4.2 Reactor Vessel Neutron Embrittlement Analysis 4.3 Metal Fatigue Analysis 4.4 EQ of Electrical Equipment 4.5 Concrete Containment Tendon Prestress Analysis 4.6 Containment Liner Plate, Metal Containments and Penetrations Fatigue Analysis 4.7 Other Plant-Specific TLAAs 56

NEI 17-01 March 2017 APPENDICES A: UFSAR SUPPLEMENT B: AMPs AND ACTIVITIES C: (OPTIONAL)

D: TECHNICAL SPECIFICATION CHANGES E: ENVIRONMENTAL INFORMATION 57

NEI 17-01 March 2017 Table 6.2-2: Guidance for Preparing the Standard SLRA Format 1 ADMINISTRATIVE INFORMATION The following information, required by §54.17 and §54.19, is consistent with the information contained in the facilitys original operating license application as delineated in 10 CFR 50.33(a) through (e), (h) and (i):

(1) Name of applicant.

(2) Address of applicant.

(3) Description of business or occupation of applicant.

(4) Organization and management of applicant.

Note that the Rule prohibits any person who is a citizen, national, or agent of a foreign country, or any corporation, or other entity which the Commission knows or has reason to know is owned, controlled, or dominated by an alien, a foreign corporation, or a foreign government, from applying for and obtaining a renewed license.

(5) Class of License, the use of the facility, and the period of time for which the license is sought.

(6) Earliest and latest dates for alterations, if proposed.

(7) Listing of regulatory agencies having jurisdiction and appropriate news publications (if applicable).

(8) Conforming changes to the standard indemnity agreement (9) Restricted data agreement Pursuant to §54.17 (f) and (g): If the application contains Restricted Data or other defense information, it must be prepared in such a manner that all Restricted Data and other defense information are separated from unclassified information in accordance with 10 CFR 50.33(j).

As part of its application and in any event prior to the receipt of Restricted Data or the issuance of a renewed license, the applicant shall agree in writing that it will not permit any individual to have access to Restricted Data until an investigation is made and reported to the Commission on the character, association, and loyalty of the individual and the Commission shall have determined that permitting such persons to have access to Restricted Data will not endanger the common defense and security. The agreement of the applicant in this regard is part of the renewed license, whether so stated or not.

The contents specified for the application are the minimum set required by the regulations. Upon issuance of the renewed operating license, this part of the application becomes a historical document with no further revisions.

2 SCOPING AND SCREENING METHODOLOGY FOR IDENTIFYING SCs SUBJECT TO AMR AND IMPLEMENTATION RESULTS Guidance:

This subsection provides a brief introduction to Section 2. In addition, it contains Table 2-1, Intended Functions Abbreviations & Definitions, which contains the meanings for the abbreviations used in the screening and AMR results tables to represent the intended functions for SCs.

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NEI 17-01 March 2017 2.1. Scoping and Screening Methodology Guidance:

Describe and justify the methodology used to determine the SSCs WSLR and the SCs subject to an AMR [.§54.21(a)(2)].

The scoping and screening method for mechanical, electrical, and civil/structural disciplines may vary. In such cases each method should be described and justified.

Identify the set of plant-specific design basis events, and corresponding set of plant-specific nomenclature, that the applicant relied on, or that form the basis, to determine the scope of SSCs required in §54.4, consistent with the plants CLB. Presenting this information in a table or matrix may make the NRCs review more efficient.

To the extent the Maintenance Rule scoping criteria are the same for the Rule, licensees may use the same methodology.

An applicant may attempt to make the NRC review of the SLRA more efficient by indicating its position regarding the subject of any LR ISGs under development at the time of SLRA submittal.

2.2 Plant Level Scoping Results Guidance:

Provide a list of all the plant systems and structures identifying those that are WSLR. For example, a list may contain 135 plant systems and structures, identifying only 37 that are WSLR. If the list exists elsewhere, such as in the UFSAR, it is acceptable to merely identify that linkage.

The Rule does not require the identification of all plant systems and structures. However, providing such a list may make the NRCs review more efficient.

2.3 System Scoping and Screening Results: Mechanical Systems Guidance:

Empty heading 2.3.1 Reactor Coolant System Guidance:

For each system, provide the following information: system description to the level of detail that it can be used in the SER, system intended functions, UFSAR references, reference to drawings submitted with or as part of the SLRA, a table of component types requiring AMR with their intended functions and a reference to the Section 3 tables with the AMR results for the component types [Ref. §54.21(a)(1)].