ML12339A668

Official Exhibit - NRC000123-00-BD01 - Audit and Review Plan for Plant Aging Management Reviews and Programs

ML12339A668
Person / Time
Site:	Indian Point
Issue date:	03/31/2012
From:	Office of Nuclear Reactor Regulation
To:
SECY RAS
References
RAS 22174, 50-247-LR, 50-286-LR, ASLBP 07-858-03-LR-BD01
Download: ML12339A668 (73)

Text

United States Nuclear Regulatory Commission Official Hearing Exhibit NRC000123 In the Matter of:

Entergy Nuclear Operations, Inc. Submitted: March 31, 2012 (Indian Point Nuclear Generating Units 2 and 3)

ASLBP #: 07-858-03-LR-BD01 Docket #: 05000247 l 05000286 Exhibit #: NRC000123-00-BD01 Identified: 10/15/2012 Admitted: 10/15/2012 Withdrawn:

Rejected: Stricken:

Other:

Audit and Review Plan for Plant Aging Management Reviews and Programs Indian Point Nuclear Generating Unit Nos. 2 and 3 Docket No.: 50-247 50-286

TABLE OF CONTENTS

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

2. BACKGROUND . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2

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

4.

SUMMARY

OF INFORMATION PROVIDED IN THE LICENSE RENEWAL APPLICATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 4.1 Aging Management Review Results . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 4.1.1 IP2 and IP3 AMR Comparison with the GALL Report . . . . . . . . . . . . . . . . 7 4.1.2 Plant-Specific Programs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 4.2 Time-Limited Aging Analyses . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10

5. OVERVIEW OF AUDIT, REVIEW, AND DOCUMENTATION PROCEDURE . . . . . . . . 14 5.1 Aging Management Programs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14 5.2 Aging Management Reviews . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15 5.3 Time-Limited Aging Analyses . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15 5.4 UFSAR Supplement Review . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16 5.5 Documents Reviewed by the Project Team . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16 5.6 Status Meeting . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16 5.7 Documentation Prepared by the Project Team . . . . . . . . . . . . . . . . . . . . . . . . . . 17 5.7.1 Audit and Review Plan . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17 5.7.2 Worksheets . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17 5.7.3 Questions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17 5.7.4 Work Packages . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17 5.7.5 Requests for Additional Information . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17 5.7.6 Audit and Review Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18 5.7.7 Safety Evaluation Report Input . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18

6. PLANNING, AUDIT, REVIEW, AND DOCUMENTATION PROCEDURE . . . . . . . . . . . 18 6.1 Planning Activities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18 6.1.1 Schedule for Key Milestones and Activities . . . . . . . . . . . . . . . . . . . . . . 18 6.1.2 Work Assignments . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19 6.1.3 Training and Preparation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19 6.2 Aging Management Program (AMP) Audits and Reviews . . . . . . . . . . . . . . . . . 20 6.2.1 Types of AMPs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20 6.2.2 Scope of AMP Elements to be Audited and Reviewed . . . . . . . . . . . . . . 20 6.2.3 Plant AMPs that Are Consistent with the GALL Report . . . . . . . . . . . . . . 20 6.2.4 Plant-Specific AMPs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22 6.3 Aging Management Review (AMR) Audits and Reviews . . . . . . . . . . . . . . . . . . 24 6.3.1 Plant AMRs that Are Consistent with the GALL Report . . . . . . . . . . . . . 24 6.3.2 Plant AMRs that Are Not Consistent with the GALL Report . . . . . . . . . . 27 6.4 Time-Limited Aging Analyses (TLAA) Audits and Reviews . . . . . . . . . . . . . . . . 27 6.4.1 Identify Generic TLAA Issues . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27 6.4.2 Metal Fatigue Analyses . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 30 6.4.3 Environmental Qualification Analyses for Electrical Components . . . . . 32 6.4.4 Other Plant-Specific TLAAs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 34 i

6.5 Audit and Safety Review Documentation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 36 6.5.1 Audit and Review Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 36 6.5.2 Safety Evaluation Report Input . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 37 6.6 Documents Reviewed and Document Retention . . . . . . . . . . . . . . . . . . . . . . . . 42 APPENDIX A PROJECT TEAM MEMBERSHIP . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . A-1 APPENDIX B RLRC SCHEDULE FOR IP2 AND IP3 LRA SAFETY REVIEW . . . . . . . . . . . . . . . . . . B-1 APPENDIX C AGING MANAGEMENT PROGRAM ASSIGNMENTS . . . . . . . . . . . . . . . . . . . . . . . . C-1 APPENDIX D AGING MANAGEMENT REVIEW ASSIGNMENTS . . . . . . . . . . . . . . . . . . . . . . . . . . . D-1 APPENDIX E TIME-LIMITED AGING ANALYSIS REVIEW ASSIGNMENTS . . . . . . . . . . . . . . . . . . E-1 APPENDIX F CONSISTENT WITH GALL REPORT AMP AUDIT/REVIEW WORKSHEET . . . . . . . . F-1 APPENDIX G PLANT-SPECIFIC AMP AUDIT/REVIEW WORKSHEET . . . . . . . . . . . . . . . . . . . . . . . G-1 APPENDIX H AMR COMPARISON WORKSHEETS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . H-1 APPENDIX I ACRONYMS, ABBREVIATIONS, AND INITIALISMS . . . . . . . . . . . . . . . . . . . . . . . . . . . I-1 TABLES Table 1. Aging Management Program Element Descriptions . . . . . . . . . . . . . . . . . . . . . . . . . . 43 Table 2. Notes for License Renewal Application Tables 3.X.2-Y . . . . . . . . . . . . . . . . . . . . . . . 45 FIGURES Figure 1. Audit of AMPs that are Consistent with the GALL Report . . . . . . . . . . . . . . . . . . . . . 46 Figure 2. Audit of Plant-Specific AMPs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 47 Figure 3. Review of AMRs that are Consistent with the GALL Report . . . . . . . . . . . . . . . . . . . 48 Figure 4. Review of TLAAs and Exemptions (from NEI 95-10, Revision 6) . . . . . . . . . . . . . . . 49 ii

Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan Audit and Review Plan for Plant Aging Management Reviews and Programs

1. INTRODUCTION By letter dated April 23, 2007, Entergy Nuclear Operations Inc. submitted to the U.S. Nuclear Regulatory Commission (NRC) its application for renewal of Operating License Nos. DPR-26 and DPR-64 respectively for the Indian Point Nuclear Generating Unit Nos. 2 and 3 (IP2) and (IP3).

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

In support of the staff's safety review of the license renewal application (LRA) for IP2 and IP3, the Division of License Renewal (DLR), Branch C (RLRC), will lead a project team that will audit and review selected aging management reviews (AMRs) and associated aging management programs (AMPs), and time-limited aging analyses (TLAAs) developed by the applicant to support its LRA for IP2 and IP3. The project team will include NRC staff and engineers provided by BNL, RLRCs technical assistance contractor. Appendix A, "Project Team Membership," lists the project team members. This document is the RLRC plan for auditing and reviewing plant aging management reviews and aging management programs for IP2 and IP3.

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

"Requirements for Renewal of Operating Licenses for Nuclear Power Plants;" the guidance provided in NUREG-1800, Revision 1, "Standard Review Plan for Review of License Renewal Application for Nuclear Power Plants" (SRP-LR), dated September 2005; the guidance provided in NUREG-1801, Revision 1, "Generic Aging Lessons Learned (GALL) Report," dated September 2005; and this plan. For the scope of work defined in this audit plan, the project team will verify that the applicant's aging management activities and programs will adequately manage the effects of aging on structures and components, so that their intended functions will be maintained consistent with the IP2 and IP3 current licensing basis (CLB) for the period of extended operation.

The project team will perform its work at NRC Headquarters, Rockville, Maryland; at BNL's offices in Upton, NY; and at the IP2 and IP3 site in Buchanan, NY. The project team will perform its work in accordance with the schedule shown in Appendix B, "Schedule."

This plan includes the following information:

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

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

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Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan

• Summary of Information Provided in License Renewal Application.

Description of the information contained in the license renewal application for IP2 and IP3 that is applicable to this plan.

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

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

• Appendices. Supporting information. The project team membership is shown in Appendix A and the schedule is shown in Appendix B. The team's work assignments are shown in Appendix C, "Aging Management Program Assignments," Appendix D, "Aging Management Review Assignments," Appendix E Time-Limited Aging Analysis Review Assignments. Appendices F, G, and H are the worksheets that the individual team members use to informally document the results of their review and audit work. The application of these worksheets is discussed in Section 6 of this plan. Appendix I is a list of the acronyms, abbreviations, and initialisms used in this plan.

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

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

The SRP-LR provides staff guidance for reviewing applications for license renewal. The GALL Report is a technical basis document. It summarizes staff-approved AMPs for the aging management of a large number of SCs that are subject to an AMR. It also summarizes the aging 2

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

The GALL Report is treated in the same manner as an approved topical report that is generically applicable. An applicant may reference the GALL Report in its LRA to demonstrate that its programs correspond to those that the staff reviewed and approved in the GALL Report. If the material presented in the LRA is consistent with the GALL Report and is applicable to the applicant's facility, the staff will accept the applicant's reference to the GALL Report. In making this determination, the staff considers whether the applicant has identified specific programs described and evaluated in the GALL Report but does not conduct a re-review of the substance of the matters described in the GALL Report. Rather, the staff confirms that the applicant verified that the approvals set forth in the GALL Report apply to its programs.

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

The SRP-LR also provides staff guidance for reviewing TLAAs. Pursuant to 10 CFR 54.21(c)(1),

a license renewal application is required to provide a list of TLAAs, as defined in 10 CFR 54.3. In addition, the applicant must provide a list of plant-specific exemptions granted under 10 CFR 50.12 that are based on TLAAs. The number and type of TLAAs vary depending on the plant-specific CLB.

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

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

2. Consider the effects of aging.

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

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Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan

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

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

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

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

3. OBJECTIVES The overall objective of the audit and review described in this plan is to verify compliance with 10 CFR 54.21(a)(3). Therefore, the audit and review process helps ensure that for each structure and component within the scope of the project team's review, the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB for the period of extended operation.

The audit and review procedure for IP2 and IP3 is described in Sections 5 and 6 of this plan. It is intended to accomplish the following objectives:

• For IP2 and IP3 AMPs that the applicant claims are consistent with GALL AMPs, verify that the plant AMPs contain the program elements of the referenced GALL AMP and that the conditions at the plant are bounded by the conditions for which the GALL AMPs were evaluated.

• For IP2 and IP3 AMPs that the applicant claims are consistent with GALL AMPs with exceptions, verify that the plant AMPs contain the program elements of the referenced GALL AMPs and that the conditions at the plant are bounded by the conditions for which the GALL AMPs were evaluated. In addition, verify that the applicant has documented an acceptable technical basis for each exception.

• For IP2 and IP3 AMPs that the applicant claims will be consistent with GALL AMPs after specified enhancements are implemented, verify that the plant AMPs, with the enhancements, will be consistent with the referenced GALL AMPs, or are acceptable on the basis of a technical review. In addition, verify that the applicant identified the enhancements as commitments in the Updated Final Safety Analysis Report (UFSAR) or other docketed correspondence.

• For plant-specific IP2 and IP3 AMPs, verify the AMPs are acceptable on the basis of a technical review. Use the worksheet provided in Appendix G ro assess the 4

Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan adequacy of the AMPs against 10 program elements described in Branch Technical Position RLSB-1 Aging Management Review - Generic, in Appendix A to the SRP-LR.

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

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

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

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

• For TLAAs, determine that the applicant has properly identified the TLAAs. TLAAs are certain plant-specific safety analyses that are based on explicitly assumed 40-year plant life (for example, aspects of the reactor vessel design). Pursuant to 10 CFR 54.21(c)(1), a license renewal applicant is required to provide a list of TLAAs, as defined in 10 CFR 54.3. The area relating to the identification of TLAAs is reviewed. TLAAs may have developed since issuance of a plants operating license. As indicated in 10 CFR 54.30, the adequacy of the plants CLB, which includes TLAAs, is not an area within the scope of the license renewal review.

Any question regarding the inadequacy of the CLB must be addressed under the backfit rule (10 CFR 50.109) and is separate from the license renewal process.

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

4.

SUMMARY

OF INFORMATION PROVIDED IN THE LICENSE RENEWAL APPLICATION 4.1 Aging Management Review Results The IP2 and IP3 LRA closely follows the standard LRA format presented in NEI 95-10, "Industry Guideline for Implementing the Requirements of 10 CFR Part 54 - The License Renewal Rule,"

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

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Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan LRA Table 3.0-1, Table 3.0-2, and Table 3.0-3 provide descriptions of the mechanical, structural, and electrical and instrument and controls service environments, respectively, used in the AMRs to determine the aging effects requiring management. Results of the AMRs are presented in two different types of tables. The applicant refers to the two types of tables as Table 1 and Table 2.

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

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

Definition 1 Reactor Vessel, Internals, and Reactor Coolant System 2 Engineered Safety Features Systems 3 Auxiliary Systems 4 Steam and Power Conversion Systems 5 Containments, Structures, and Component Supports 6 Electrical and Instrumentation and Controls The second table type is a series of tables labeled Table 3.X.2-Y, where "X" is the system/

component group number, "2" indicates it is a Table 2 type, and "Y" indicates the subgroup number within group "X. For example, within the reactor coolant system subsection, the AMR results for the reactor vessel and internals are presented in Table 3.1.2-1, and the results for the steam generators are in Table 3.1.2-3. In the engineered safety features subsection, the nuclear sampling system results are presented in Table 3.2.2-1, and the containment spray system is in Table 3.2.2-2. For ease of discussion, these table types will hereafter be referred to as "Table 2."

These tables present the results of the AMRs.

4.1.1 IP2 and IP3 AMR Comparison with the GALL Report The applicant compared the IP2 and IP3 AMR results with information set forth in the tables of the GALL Report and provided the results of its comparisons in two table types that correlate with the two table types described above.

To take full advantage of the GALL Report, IP2 and IP3 AMR results have been compared w/

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

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Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan 4.1.1.1 Purpose of Table 1 The purpose of Table 1 is to provide a summary comparison of how the IP2 and IP3 AMR results align with the corresponding table of NUREG-1801, Volume 1. These tables are essentially the same as Tables 1 through 6 provided in NUREG-1801, Volume 1, with the following exceptions:

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

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

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

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

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

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

• The name of a plant-specific program being used.

• Exceptions to the NUREG-1801 assumptions.

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

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

4.1.1.2 Purpose of Table 2 Table 2 provides results of the aging management reviews for those structures and components identified in Section 2 as being subject to aging management review. There is a Table 2 for each aging management review within a NUREG-1801 system group. For example, the engineered safety features system group contains tables specific to nuclear sampling, containment spray, containment integrated leak rate test, decontamination, liquid radwaste, reactor makeup water, containment purge HVAC, breathing air, hydrogen control, high pressure coolant injection, and residual heat removal.

Table 2 consists of the following nine columns:

Component Type 7

Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan Column 1 identifies the component types from Section 2 of this application that are subject to aging management review. Similar to Section 2, component types are listed in alphabetical order. In the Class 1 tables in Section 3.1 and the structural tables in Section 3.5, component types are alphabetical by sub-groups.

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

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

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

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

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

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

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

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

Aging Management Programs (AMP)

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

NUREG-1801, Vol. 2, Item 8

Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan Column 7 documents identified consistencies by noting the appropriate NUREG-1801, Volume 2, item number. If there is no corresponding item number in NUREG-1801, Volume 2, for a particular combination of factors, column 7 indicates None for this item.

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

• Component type.

• Material.

• Environment.

• Aging effect requiring management.

• Aging management program.

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

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

• Component type.

• Material.

• Environment.

• Aging effect requiring management.

• Aging management program.

Notes Column 9 contains notes that are used to describe the degree of consistency with the line items in NUREG-1801, Volume 2. Notes that use letter designations are standard notes based on a letter from A. Nelson, NEI, to P. T. Kuo, NRC, U.S. Nuclear Industrys Proposed Standard License Renewal Application Format Package, Request NRC Concurrence, dated January 24, 2003 (ML030290201). The staff concurred with the NEI standardized format for license renewal applications by letter dated April 7, 2003, from P. T. Kuo, NRC, to A. Nelson, NEI (ML030990052). Notes that use numeric designators are specific to IP2 and IP3.

IP2 and IP3 LRA Table 2 contains the aging management review results and indicates whether the results correspond to line items in Volume 2 of the GALL Report. Correlations between the combination IP2 and IP3 LRA Table 2 and a combination for a line item in Volume 2 of the GALL Report are identified by the GALL Report item number in Column 7. If None is indicated in column 7, the applicant did not identify a corresponding combination in the GALL Report. If the applicant identified a GALL Report line item, the next column provides a reference to a Table 1 row number. This reference corresponds to the GALL Report, Volume 2, roll-up to the GALL Report, Volume 1, tables.

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Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan 4.1.2 Plant-Specific Programs Many of the GALL Report evaluations refer to plant-specific programs. In these cases, the applicant considers the IP2 and IP3 evaluation to be consistent with the GALL Report if the other elements are consistent. Note E is used to indicate that the AMR line-item is consistent with the GALL Report for material, environment, and aging effect, but a different AMP is credited. The project team will evaluate these line-items to determine that the AMP credited by the applicant is applicable.

4.2 Time-Limited Aging Analyses The IP2 and IP3 LRA closely follows the standard LRA format presented in Revision 6 of NEI 95-10, Industry Guidelines for Implementing the Requirements of 10 CFR Part 54 - The License Renewal Rule. Section 4 of the IP2 and IP3 LRA addresses TLAAs. In Section 4.1.1, the IP2 and IP3 LRA states that the calculations and evaluations that could potentially meet the six criteria of 10 CFR 54.3 were identified by searching CLB documents including the following:

A. The Updated Safety Analysis Report (USAR)

B. Technical Specifications C. The NRC Safety Evaluation Report (SER) for the original operating license D. All subsequent NRC Safety Evaluations (SEs)

E. IP2 and IP3 and NRC docketed licensing correspondence.

Also, in Section 4.1.1, the IP2 and IP3 LRA states that as required by 10 CFR 54.21(c)(1), an evaluation of IP2 and IP3-specific TLAAs must be performed to demonstrate that:

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

In the IP2 and IP3 LRA, the applicant summarized the results of the above evaluations in Table 4.1-1. These evaluations are discussed in subsequent sections of IP2 and IP3 LRA Section 4.

Section 10 CFR 54.21(c) also requires that the application for a renewed license includes a list of plant-specific exemptions granted pursuant to 10 CFR 50.12 and in effect that are based on TLAAs as defined in 10 CFR 54.3. The IP2 and IP3 performed this by reviewing IP2 and IP3 docketed correspondence which identified IP2 and IP3 exemptions. Section 4.1.2 of the IP2 and IP3 LRA states that there are no IP2 and IP3 exemptions that depend on TLAAs.

The IP2 and IP3 LRA next includes a separate section for each of the identified TLAAs within the outline of the corresponding NUREG-1800 TLAA category. The TLAA categories are outlined in the next table.

10

Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan TLAA Description Resolution Option Section Reactor Vessel Neutron Embrittlement Analyses 4.2 Charpy upper-shelf energy Analyses projected 4.2.2 10 CFR 54.21(c)(1)(ii)

Pressure/temperature limits P-T limit curves managed 4.2.3 10 CFR 54.21(c)(1)(iii)

Low temperature overpressure LTOP limits managed 4.2.4 protection (LTOP) 10CFR54.21(c)(1)(iii)

Pressurized Thermal Shock IP2: Analysis projected 4.2.5 10 CFR 54.21(c)(1)(ii)

IP3: Aging effects managed 10 CFR 54.21(c)(1)(iii)

Metal Fatigue Analyses 4.3 Reactor vessel Analyses remain valid 4.3.1.1 10 CFR 54.21(c)(1)(i)

Reactor vessel internals Analyses remain valid 4.3.1.2 10 CFR 54.21(c)(1)(i)

Pressurizer Analyses remain valid 4.3.1.3 10 CFR 54.21(c)(1)(i)

Pressurizer insurge/outsurge transients Analyses remain valid 4.3.1.3 10 CFR 54.21(c)(1)(i)

Steam generator Analyses remain valid 4.3.1.4 10 CFR 54.21(c)(1)(i)

Reactor coolant pump Analyses remain valid 4.3.1.5 10 CFR 54.21(c)(1)(i) 11

Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan TLAA Description Resolution Option Section Control rod drive mechanisms Analyses remain valid 4.3.1.6 10 CFR 54.21(c)(1)(i)

Regenerative letdown heat exchanger Analyses remain valid 4.3.1.7 10 CFR 54.21(c)(1)(i)

Class 1 piping and in-line components - ANSI B31.1 Analyses remain valid 4.3.1.8 piping 10 CFR 54.21(c)(1)(i)

Class 1 piping and in-line components - pressurizer Analyses remain valid 4.3.1.8 surge line 10 CFR 54.21(c)(1)(i)

Class 1 piping and in-line components - thermowells Analyses remain valid 4.3.1.8 10 CFR 54.21(c)(1)(i)

Class 1 piping and in-line components - charging Analysis will be updated as part of 4.3.1.8 system environmental fatigue evaluation.

See Section 4.3.3.

Class 1 piping and in-line components - loop 3 Analyses remain valid 4.3.1.8 accumulator nozzle (IP2 only) 10 CFR 54.21(c)(1)(i)

Non-Class 1 piping and in-line components Analyses remain valid 4.3.2 10 CFR 54.21(c)(1)(i)

Non-Class 1, non-piping components - residual heat Analyses remain valid 4.3.2 removal heat exchanger 10 CFR 54.21(c)(1)(i)

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

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

Environmental Qualification of Electrical Aging effect managed 4.4 Components 10 CFR 54.21(c)(1)(iii)

Concrete Containment Tendon Prestress N/A 4.5 12

Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan TLAA Description Resolution Option Section Containment Liner Plate and Penetrations 4.6 Fatigue Analyses IP2: Liner Plate at Containment Penetration IP2: Analyses remain valid (feedwater line #22) 10 CFR 54.21(c)(1)(i) for liner plate; no TLAA for penetration IP3: None IP3: No TLAA Plant-Specific Time-Limited Aging Analyses 4.7 Reactor Coolant Pump Flywheel N/A 4.7.1 Analysis Leak Before Break (LBB) Analysis remains valid 4.7.2 10 CFR 54.21(c)(1)(i)

Steam Generator Flow Induced IP2: Analysis remains valid 4.7.3 Vibration and Tube Wear 10 CFR 54.21(c)(1)(i)

IP3: Analyses projected 10 CFR 54.21(c)(1)(ii)

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

5.1 Aging Management Programs For the IP2 and IP3 AMPs for which the applicant claimed consistency with the AMPs included in the GALL Report, the project team will review the IP2 and IP3 AMP descriptions and compare program elements for the IP2 and IP3 AMPs to the corresponding program elements for the GALL AMPs. The project team will verify that the IP2 and IP3 AMPs contain the program elements of the referenced GALL program and that the conditions at the plant are bounded by the conditions for which the GALL program was evaluated. Table 1 of this audit and review plan summarizes the program elements that comprise an aging management program. The License Renewal Branch C (RLRC) will review and determine the adequacy of the applicants 10 CFR 50, Appendix B Program. Other aspects of these program elements will be reviewed by the project team.

For IP2 and IP3 AMPs that have one or more exception and/or enhancement, the project team will review each exception and/or enhancement to determine whether the exception and/or enhancement is acceptable, and whether the AMP, as modified by the exception and/or the 13

Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan enhancement, would adequately manage the aging effects for which it is credited. In some cases, the project team will identify differences that the applicant did not identify between the IP2 and IP3 AMPs credited by the applicant and the GALL Report AMPs. In these cases, the project team will review the difference to determine whether the IP2 and IP3 AMP, as modified by the difference, would adequately manage the aging effects for which it is credited.

For those IP2 and IP3 AMPs that are not included in the GALL Report (i.e., plant- specific AMPs), the project team will review the AMP against the ten program elements defined in Appendix A of the SRP-LR. The RLRC will review and determine the adequacy of the applicants 10 CFR 50, Appendix B Program. Other aspects of these program elements will be reviewed by the project team. On the basis of its reviews, the project team will determine whether these AMPs will manage the aging effects for which they are credited.

5.2 Aging Management Reviews The AMRs in the IP2 and IP3 LRA fall into three broad categories: (1) AMR results that are consistent with the GALL Report (i.e., those that the GALL Report concludes are adequate to manage aging of the components referenced in the GALL Report), (2) those for which the GALL Report concludes that aging management is adequate, but further evaluation is recommended for certain aspects of the aging management process, and (3) AMR results that are not consistent with or not addressed in the GALL Report. For the first category AMR reviews, the project team will determine (1) whether the AMRs reported by the applicant to be consistent with the GALL Report are indeed consistent with the GALL Report, and (2) whether the AMRs reported by the applicant to be managed using plant-specific AMPs are technically acceptable.

For the second category AMR review, for which the applicant claimed consistency with the GALL Report, and for which the GALL Report recommends further evaluation, the project team will review the applicant's evaluation to determine if it adequately addressed the issues for which the GALL Report recommended further evaluation. For the third category AMR review, the project team will review the results of the AMRs for material, environment, AERM, and AMP combinations to determine the technical adequacy.

5.3 Time-Limited Aging Analyses Generally, the TLAAs in the IP2 and IP3 LRA fall into the broad category of those that are consistent with the NUREG-1800 TLAA categories. However, there are 12 plant-specific exemptions identified in the IP2 and IP3 LRA that depend on TLAAs.

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

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

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

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Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan

2. Consider the effects of aging.

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

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

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

6. Contained or incorporated by reference in the CLB.

In addition, the project team will also review the TLAAs to determine if there are emerging issues that should be further evaluated by technical specialists in the NRC Divisions of Component Integrity (DCI) or the Division of Engineering (DE). This is not expected to be an issue for TLAAs for which the applicant claims consistency with 10 CFR 54.21(c)(I) the analyses remain valid for the period of extended operation or 10 CFR 54.21(c)(iii) the effects of aging on the intended function(s) will be adequately managed for the period of extended operation.

For TLAAs for which the applicant claims consistency with 10 CFR 54.21(c)(ii) - the analyses have been projected to the end of the period of extended operation, the audit team leader will be consulted to determine which TLAAs the audit team will be capable of reviewing. Consideration should be given to project team expertise, past precedent, and complexity of the provided analysis. Candidates for further review by technical specialists could be such as the following:

A. Reactor Vessel Neutron Embrittlement B. Plant-Specific TLAAs 5.4 UFSAR Supplement Review Consistent with the SRP-LR, for the AMRs and associated AMPs that it will review, the project team will review the UFSAR supplement that summarizes the applicant's programs and activities for managing the effects of aging for the extended period of operation. The project team will also review any commitments associated with its programs and activities made by the applicant and verify that they are acceptable for the stated purpose.

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

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Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan 5.6 Status Meeting At the conclusion of its audits and reviews, the project team will debrief the applicant's license renewal staff and management regarding the status of the audits and reviews of the LRA AMPs, AMRs and TLAAs assigned to the project team.

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

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

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

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

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

5.7.5 Requests for Additional Information The review process described in this plan is structured to resolve as many questions as possible during the site visits. As examples, the site visits are used to obtain clarifications about the LRA and explanations as to where certain information may be found in the LRA or its associated documents. Nevertheless, there may be occasions where an RAI is appropriate to obtain information to support a SER finding. The need for RAIs will be determined by the project team 16

Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan leader during the in-office project staff review or during site visits through discussions with the individual project team members. When the project team leader determines that an RAI is needed, the project team member who is responsible for the area of review will prepare the RAI.

RAIs will include the technical and regulatory basis for requesting the information.

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

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

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

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

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

• Receiving the LRA from the applicant.

• Receiving work split tables from the project manager.

• Making individual work assignments.

• Training project team members.

• Holding the project team kickoff meeting.

• Preparing the audit and review plan.

• Scheduling site visits.

• Scheduling in-office review periods.

• Preparing questions.

• Preparing RAIs.

• Issuing audit and review summary report.

• Issuing SER input.

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Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan Site visits will be scheduled on the basis of discussions between the project team leader, the NRC license renewal project manager, and the applicant.

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

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

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

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

A. A description of the audit and review process.

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

1. GALL Report

2. SRP-LR

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

4. LRA AMPs

5. LRA AMRs

6. LRA TLAAs

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

8. Implementing procedures

9. Operating experience reports

10. RAIs, audit reports, and SERs for similar plants

11. Applicant's UFSAR C. The protocol for interfacing with the applicant.

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

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

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Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan F. Process for interfacing with NRC technical reviewers.

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

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

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

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

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

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

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

1. GALL Report

2. SRP-LR

3. ISGs

4. RAIs and SERs for similar plants

5. LRA

6. Basis documents

7. Implementation procedures

8. Operating experience reports (plant-specific and industry) 19

Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan

9. UFSAR Audit/Review A. Confirm that IP2 and IP3 AMP program elements are consistent with the corresponding elements of the GALL Report AMP by answering the following questions and then following the process shown in Figure 1.

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

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

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

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

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

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

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

2. Plant-Specific Operating Experience with existing Aging Management Programs. The operating experience of AMPs, including corrective actions resulting in program enhancements or additional programs, should be considered. The review should provide objective evidence to support the conclusion that the effects of aging will be managed so that the intended function(s) will be maintained during the extended period of operation.

Guidance for reviewing industry operating experience is presented in BTP RLSB-1 in Appendix A.1 of the Branch Technical Positions in NUREG-1800.

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Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan

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

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

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

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

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

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

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

1. GALL Report

2. SRP-LR

3. ISG-LR

4. RAIs and SERs for similar plants 21

Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan

5. LRA

6. Basis documents

7. Implementation procedures

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

9. UFSAR

10. Lessons Learned Developed by RLRC Audit/Review A. Audit/review the IP2 and IP3 AMP program elements and determine that they are in accordance with the acceptance criteria for the corresponding program elements of Section A.1.2.3 of the SRP-LR.

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

The industry guidance (from NEI 95-10, Revision 6) is as follows:

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

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

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

3. Industry Operating Experience. Industry operating experience and its applicability should be assessed to determine whether it changes plant-specific determinations. NUREG-1801 is based upon industry operating experience prior to its date of issue. Operating experience after the issue date of NUREG-1801 should be evaluated and documented as part of the aging management review. In particular, generic 22

Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan communications such as a bulletin, a generic letter, or an information notice should be evaluated for impact upon the AMP. The evaluation should check for new aging effects or a new component or location experiencing an already identified aging effect.

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

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

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

6.3 Aging Management Review (AMR) Audits and Reviews There are two types of AMRs: those that the applicant claims are consistent with the GALL Report, and those that are not consistent with or not included in the GALL Report. Audit and review of both types of AMRs are discussed below.

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

Preparation A. For the IP2 and IP3 AMRs that the applicant claims are consistent with the GALL Report, identify the corresponding AMRs in Volume 2 of the GALL Report.

B. Review the associated GALL AMRs and identify those line items that will be audited/reviewed in conjunction with each of the IP2 and IP3 AMRs.

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

1. GALL Report

2. SRP-LR

3. ISG-LR

4. RAIs and SERs for similar plants 23

Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan

5. LRA

6. Basis documents

7. Implementation procedures

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

9. UFSAR

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

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

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

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

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

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

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

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Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan

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

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

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

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

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

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

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

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

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

25

Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan AMR Audit/Review Worksheets Document the audits/reviews of plant AMRs using the worksheet provided in Appendix H, "AMR Comparison Worksheets," or on spreadsheets containing similar information.

6.3.2 Plant AMRs that Are Not Consistent with the GALL Report Review LRA Tables 3.X.2.1 - X (Table 2s) for LRA Sections 3.1 thru 3.6, where the applicant indicated, via Notes F through J, that the combination of component type, material, environment, and AERM does not correspond to a line item in the GALL Report. Specifically, Note F indicates that the material for the AMR line item component is not evaluated in the GALL Report. Note G indicates that the environment for the AMR line item component and material is not evaluated in the GALL Report. Note H indicates that the aging effect for the AMR line item component, material, and environment combination is not evaluated in the GALL Report. Note I indicates that the aging effect identified in the GALL Report for the line item component, material, and environment combination is not applicable. Note J indicates that neither the component nor the material and environment combination for the line item is evaluated in the GALL Report. For component groups not evaluated in the GALL Report (notes F-J), the project team reviews the applicant's evaluation in accordance with Branch Technical Position RLSB-1 (Appendix A.1 of the SRP-LR) to determine the technical adequacy. If during the review a difference is identified, prepare a question to the applicant, in order to obtain clarification. Review the applicant's response to the question and confirm that it is acceptance in accordance with Appendix A.1 of the SRP-LR.

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

6.4 Time-Limited Aging Analyses (TLAA) Audits and Reviews Audit and review of TLAAs are discussed below. The project team will also review the TLAAs to determine if there are emerging issues that should be further evaluated by technical specialists in the NRC Divisions of Component Integrity (DCI) or the Division of Engineering (DE). In general, the project team will review TLAAs that are for which the applicant claims consistency with 10 CFR 54.21(c)(i) the analyses remain valid for the period of extended operation. or 10 CFR 54.21(c)(iii) the effects of aging on the intended function(s) will be adequately managed for the period of extended operation. For TLAAs for which the applicant claims consistency with 10 CFR 54.21(c)(ii) - the analyses have been projected to the end of the period of extended operation, the audit team leader will be consulted to determine which TLAAs the audit team will be capable of reviewing. Consideration should be given to team expertise, past precedent, and complexity of the provided analysis.

6.4.1 Identify Generic TLAA Issues 26

Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan Figure 4, Evaluation of TLAAs and Exemptions, taken from NEI 95-10, Revision 6, shows the process of evaluating and reviewing TLAAs and also identifying the exemptions in effect. This process flowchart shows the activities and decisions used to audit/review each TLAA that the applicant identifies.

Pre-Review Preparation A. For the IP2 and IP3 TLAAs that the applicant has identified as generic TLAA issues, identify the corresponding TLAAs in NUREG-1800, if appropriate.

B. Review the corresponding TLAAs in NUREG-1800 and identify those that will be audited/reviewed in conjunction with each of the IP2 and IP3 TLAAs.

C. Review the list of the IP2 and IP3 plant-specific exemptions granted pursuant to

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

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

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

2. TLAAs

3. GALL Report

4. SRP-LR

5. ISG-LR

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

7. LRA

8. References listed by applicant for each TLAA

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

10. Basis documents

11. Implementation documents

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

13. Lessons-learned developed by RLRC

14. Applicants UFSAR E. In addition, the project team will also review the TLAAs to determine if there are emerging issues that should be further evaluated by technical specialists in the NRC Divisions of Component Integrity (DCI) or the Division of Engineering (DE).

This is not expected to be an issue for TLAAs for which the applicant claims consistency with 10 CFR 54.21(c)(i) the analyses remain valid for the period of extended operation. or 10 CFR 54.21(c)(iii) the effects of aging on the intended function(s) will be adequately managed for the period of extended operation. For TLAAs for which the applicant claims consistency with 10 CFR 54.21(c)(ii) - the analyses have been projected to the end of the period of extended operation, the 27

Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan audit team leader will be consulted to determine which TLAAs the audit team will be capable of reviewing. Consideration should be given to team expertise, past precedent, and complexity of the provided analysis. Candidates for further review by technical specialists could be such as the following:

1. Reactor Vessel Neutron Embrittlement Analysis (IP2 and IP3 LRA Section 4.2)

Audit/Review A. Confirm that each IP2 and IP3 TLAA listed in this section is appropriate. Refer to any analyses and evaluations created during the acceptance review process.

B. If a TLAA is listed in the SRP-LR or NEI 95-10 and not in its LRA, the IP2 and IP3 should state in this section that it does not apply.

C. Review any industry and plant-specific operating experience associated with the TLAA. This is an area of review emphasis. The project team members should consider the following industry guidance (from NEI 95-10, Table 6.2-2) as follows:

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

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

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

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

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

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Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan D. If it is necessary to ask the applicant a question to clarify the basis for their analyses, follow the logic process shown in Figure 4 of this audit and review plan.

E. If it is necessary for the applicant to submit additional information to support the basis for the conclusions in their TLAA, the applicant may agree to voluntarily submit the required information as a supplement (docketed letter submitted under oath and affirmation) to the IP2 and IP3 LRA. If not, the NRC may issue an RAI to obtain the information.

6.4.2 Metal Fatigue Analyses Figure 4, Evaluation of TLAAs and Exemptions, taken from NEI 95-10, Revision 6, shows the process of evaluating and reviewing TLAAs and also identifying the exemptions in effect. This process flowchart shows the activities and decisions used to audit/review each TLAA that the applicant identifies.

Pre-Review Preparation A. The project team will determine if the TLAAs identified in the IP2 and IP3 LRA to be within the NUREG-1800 TLAA category of metal fatigue have provided adequate information to meet the requirements of 10 CFR 54.21(c)(1) and 10 CFR 54.21(c)(2).

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

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

2. GALL Report, especially Section X.M1

3. SRP-LR

4. ISG-LR

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

6. LRA

7. References listed by applicant for each TLAA

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

9. Basis documents

10. Implementation documents

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

12. Lessons-learned developed by RLRC

13. Applicants UFSAR C. In addition, the project team will also review the IP2 and IP3 TLAAs within the NUREG-1800 TLAA category of metal fatigue to determine if there are emerging issues that should be further evaluated by technical specialists in the NRC Divisions of Component Integrity (DCI) or the Division of Engineering (DE). This is not expected to be an issue for TLAAs for which the applicant claims consistency 29

Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan with 10 CFR 54.21(c)(i) the analyses remain valid for the period of extended operation. or 10 CFR 54.21(c)(iii) the effects of aging on the intended function(s) will be adequately managed for the period of extended operation. For TLAAs for which the applicant claims consistency with 10 CFR 54.21(c)(ii) - the analyses have been projected to the end of the period of extended operation, the audit team leader will be consulted to determine which TLAAs the audit team will be capable of reviewing. Consideration should be given to team expertise, past precedent, and complexity of the provided analysis.

Audit/Review A. Confirm that each IP2 and IP3 TLAA listed in this section is appropriate. Refer to any analyses and evaluations created during the acceptance review process.

B. If a TLAA is listed in the SRP-LR or NEI 95-10 and not in its LRA, the IP2 and IP3 should state in this section that it does not apply.

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

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

2. Consider the effects of aging.

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

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

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

6. Contained or incorporated by reference in the CLB.

D. The project team will ascertain that the IP2 and IP3 satisfactorily demonstrates that (1) the analyses remain valid for the period of extended operation, (2) the analyses have been (or have been identified and will be) projected to the end of the period of extended operation or (3) the effects of aging on the intended function(s) will be adequately managed for the period of extended operation.

E. Review any industry and plant-specific operating experience associated with the TLAA. This is an area of review emphasis. The project team members should 30

Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan consider the following industry guidance on metal fatigue (from NEI 95-10, Table 6.2-2) as follows:

1. Disposition chosen for each of the identified TLAAs. Also, provide a reference to the summary description of TLAA evaluations in the FSAR supplement (Appendix A). Use hypertext to link to the appropriate location in the appendix for electronic submittals [§54.21(c)(1) and §54.21(d)1.

F. If it is necessary to ask the applicant a question to clarify the basis for their analyses, follow the logic process shown in Figure 4 of this audit and review plan.

G. If it is necessary for the applicant to submit additional information to support the basis for the conclusions in their TLAA, the applicant may agree to voluntarily submit the required information as a supplement (docketed letter submitted under oath and affirmation) to the IP2 and IP3 LRA. If not, the NRC may issue an RAI to obtain the information.

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

Pre-Review Preparation A. The project team will determine if the TLAAs identified in the IP2 and IP3 LRA to be within the NUREG-1800 TLAA category of environmental qualification of electric equipment have provided adequate information to meet the requirements of 10 CFR 54.21(c)(1) and 10 CFR 54.21(c)(2).

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

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

2. GALL Report, especially Section X.E1

3. SRP-LR

4. ISG-LR

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

6. LRA

7. References listed by applicant for each TLAA

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

9. Basis documents

10. Implementation documents

11. Operating experience reports (plant-specific and industry) 31

Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan

12. Lessons-learned developed by RLRC

13. Applicants UFSAR C. In addition, the project team will also review the IP2 and IP3 TLAAs within the NUREG-1800 TLAA category of environmental qualification of electric equipment to determine if there are emerging issues that should be further evaluated by technical specialists in the NRC Divisions of Component Integrity (DCI) or the Division of Engineering (DE). This is not expected to be an issue for TLAAs for which the applicant claims consistency with 10 CFR 54.21(c)(i) the analyses remain valid for the period of extended operation. or 10 CFR 54.21(c)(iii) the effects of aging on the intended function(s) will be adequately managed for the period of extended operation. For TLAAs for which the applicant claims consistency with 10 CFR 54.21(c)(ii) - the analyses have been projected to the end of the period of extended operation, the audit team leader will be consulted to determine which TLAAs the audit team will be capable of reviewing.

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

Audit/Review A. Confirm that each IP2 and IP3 TLAA listed in this section is appropriate. Refer to any analyses and evaluations created during the acceptance review process.

B. If a TLAA is listed in the SRP-LR or NEI 95-10 and not in its LRA, the IP2 and IP3 should state in this section that it does not apply.

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

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

2. Consider the effects of aging.

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

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

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

6. Contained or incorporated by reference in the CLB.

32

Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan D. The project team will ascertain that the IP2 and IP3 satisfactorily demonstrates that (1) the analyses remain valid for the period of extended operation, (2) the analyses have been (or have been identified and will be) projected to the end of the period of extended operation or (3) the effects of aging on the intended function(s) will be adequately managed for the period of extended operation.

E. Review any industry and plant-specific operating experience associated with the TLAA. This is an area of review emphasis. The project team members should consider the following industry guidance on environmental qualification of electric equipment (from NEI 95-10, Table 6.2-2) as follows:

1. Disposition chosen for each of the identified TLAAs. Also, provide a reference to the summary description of TLAA evaluations in the FSAR supplement (Appendix A). Use hypertext to link to the appropriate location in the appendix for electronic submittals [§54.21(c)(1) and §54.21(d)1].

F. If it is necessary to ask the applicant a question to clarify the basis for their analyses, follow the logic process shown in Figure 4 of this audit and review plan.

G. If it is necessary for the applicant to submit additional information to support the basis for the conclusions in their TLAA, the applicant may agree to voluntarily submit the required information as a supplement (docketed letter submitted under oath and affirmation) to the IP2 and IP3 LRA. If not, the NRC may issue an RAI to obtain the information.

6.4.4 Other Plant-Specific TLAAs Figure 4, Evaluation of TLAAs and Exemptions, taken from NEI 95-10, Revision 6, shows the process of evaluating and reviewing TLAAs and also identifying the exemptions in effect. This process flowchart shows the activities and decisions used to audit/review each TLAA that the applicant identifies.

Pre-Review Preparation A. The project team will determine if the TLAAs identified in the IP2 and IP3 LRA to be within the NUREG-1800 TLAA category of other plant-specific TLAAs have provided adequate information to meet the requirements of 10 CFR 54.21(c)(1) and 10 CFR 54.21(c)(2).

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

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

2. GALL Report 33

Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan

3. SRP-LR

4. ISG-LR

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

6. LRA

7. References listed by applicant for each TLAA

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

9. Basis documents

10. Implementation documents

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

12. Lessons-learned developed by RLRC

13. Applicants UFSAR C. In addition, the project team will also review the IP2 and IP3 TLAAs within the NUREG-1800 TLAA category of other plant-specific TLAAs to determine if there are emerging issues that should be further evaluated by technical specialists in the NRC Divisions of Component Integrity (DCI) or the Division of Engineering (DE). This is not expected to be an issue for TLAAs for which the applicant claims consistency with 10 CFR 54.21(c)(i) the analyses remain valid for the period of extended operation. or 10 CFR 54.21(c)(iii) the effects of aging on the intended function(s) will be adequately managed for the period of extended operation. For TLAAs for which the applicant claims consistency with 10 CFR 54.21(c)(ii) - the analyses have been projected to the end of the period of extended operation, the audit team leader will be consulted to determine which TLAAs the audit team will be capable of reviewing. Consideration should be given to team expertise, past precedent, and complexity of the provided analysis.

Audit/Review A. Confirm that each IP2 and IP3 TLAA listed in this section is appropriate. Refer to any analyses and evaluations created during the acceptance review process.

B. If a TLAA is listed in the SRP-LR or NEI 95-10 and not in its LRA, the IP2 and IP3 should state in this section that it does not apply.

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

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

2. Consider the effects of aging.

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

34

Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan

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

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

6. Contained or incorporated by reference in the CLB.

D. The project team will ascertain that the IP2 and IP3 satisfactorily demonstrates that (1) the analyses remain valid for the period of extended operation, (2) the analyses have been (or have been identified and will be) projected to the end of the period of extended operation or (3) the effects of aging on the intended function(s) will be adequately managed for the period of extended operation.

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

1. Identify and evaluate any plant-specific TLAAs.

F. If it is necessary to ask the applicant a question to clarify the basis for their analyses, follow the logic process shown in Figure 4 of this audit and review plan.

G. If it is necessary for the applicant to submit additional information to support the basis for the conclusions in their TLAA, the applicant may agree to voluntarily submit the required information as a supplement (docketed letter submitted under oath and affirmation) to the IP2 and IP3 LRA. If not, the NRC may issue an RAI to obtain the information.

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

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

• Members who participated in the on-site audits,

• Dates and location of the audits 35

Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan

• Guidance documents used for the review

• Activities performed

• Documents reviewed

• Availability of question and answer database

• Status of the review 6.5.2 Safety Evaluation Report Input A. General guidance

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

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

3. SER inputs are to be prepared for:

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

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

c. Each plant-specific AMP.

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

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

f. Project team AMR review results.3

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

3. Aging Management Review Results 3

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

36

Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan 3.0 Applicant's Use of the Generic Aging Lessons Learned Report 3.01 Format of the LRA 3.02 Staff's Review Process 3.0.2.1 AMRs in the GALL Report 3.0.2.2 NRC-Approved Precedents 3.0.2.3 UFSAR Supplement 3.0.2.4 Documentation and Documents Reviewed 3.0.3 Aging Management Programs 3.0.3.1 AMPs that are Consistent With the GALL Report 3.0.3.2 AMPs that are Consistent With GALL Report With Exceptions or Enhancements 3.0.3.3 AMPs that are Plant-Specific 3.0.4 Quality Assurance Program Attributes Integral to Aging Management Programs 3.X4 Aging Management of ______

3.X.1 Summary of Technical Information in the Application 3.X.2 Staff Evaluation 3.X.2.1 Aging Management Evaluations that are Consistent with the GALL Report, for Which Further Evaluation is Not Required 3.X.2.2 Aging Management Evaluations that are Consistent with the GALL Report, for Which Further Evaluation is Recommended 3.X.2.3 AMR Results that are Not Consistent with or Not Addressed in the GALL Report 3.X.3 Conclusion 4.0 Time-Limited Aging Analyses 4.1 Identification of Time-Limited Aging Analyses 4.3 Metal Fatigue 4

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

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

37

Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan 4.4 Environmental Qualification of Electrical Components 4.5 Concrete Containment Tendon Prestress 4.6 Containment Liner Plate and Penetrations Fatigue Analyses 4.7 Other Plant-Specific Time-Limited Aging Analyses 4.7.1 Reactor Coolant Pump Flywheel Analysis 4.7.2 Leak Before Break 4.7.3 Steam Generator Flow Induced Vibration and Tube Wear 4.8 Conclusion for Time-Limited Aging Analyses

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

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

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

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

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

B. SER input

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

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

38

Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan

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

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

a. Identify the LRA section reviewed.

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

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

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

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

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

g. A finding that verifies that:

• The applicant identified the applicable aging effects.

• The applicant defined the appropriate combination of materials and environments.

• The applicant specified acceptable AMPs.

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

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

39

Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan

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

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

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

c. For the applicant's further evaluations, provide a summary of the basis for concluding that it satisfied the criteria of Section 3.x.3.2 of the SRP-LR.

d. A statement that the staff audited the applicant's further evaluations against the criteria contained in Section 3.x.3.2 of the SRP-LR.

6. Staff AMR Review Results.6 This section of the SER input documents the reviews of AMRs assigned to the project team that are not consistent with the GALL Report. The audit report should document the following:

a. The LRA section reviewed.

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

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

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

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

• The applicant identified the applicable aging effects.

• The applicant listed the appropriate combination of materials and environments.

• The applicant specified acceptable AMPs.

f. Provide a conclusion stating, if applicable, that the applicant has demonstrated that the effects of aging will be adequately managed 6

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

40

Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan so that the intended functions will be maintained consistent with the CLB for the period of extended operation, and that 10 CFR 54.21(a)(3) has been satisfied.

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

a. Summary of technical information in the application

b. Staff evaluation (i) Regulatory basis (ii) Scope of review and technical evaluation

c. UFSAR supplement review - stating, if applicable, that the applicant has provided a UFSAR supplement summary description of its TLAA evaluation.

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

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

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

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

Table 1. Aging Management Program Element Descriptions 41

Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan Element Description 1 Scope of the program The scope of the program should include the specific structures and components subject to an aging management review.

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

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

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

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

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

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

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

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

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

42

Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan Table 2. Notes for License Renewal Application Tables 3.X.2-Y7 Note Description A Consistent with NUREG-1801 [GALL Report] item for component, material, environment, and aging effect. AMP is consistent with NUREG-1801 AMP.

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

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

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

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

F Material not in NUREG-1801 for this component.

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

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

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

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

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

Nelson, NEI (ML030990052).

43

Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan Start Preparation Steps Identify GALL AMP(s) to which LRA AMP is being compared Note:

Preparation steps may be performed as a Identify elements of GALL AMP(s) single combined attributes to be audited step for each AMP audited. Develop and provide question to Team Obtain response from Leader for PMs applicant Identify LRA AMP support documents submittal to applicant needed to perform audit Yes Did applicant Ask applicant a Notify NRC Team Yes clarifying question to Leader that Audit of identify any exceptions to continue audit? No AMR may not proceed GALL AMP(s)?

No Draft RAI Compare each GALL AMP auditable Is there a technical element to the LRA AMP basis to accept exception No or difference?

Note: If a prior NRC Yes Terminate AMP precedent exists, it may be Is the attribute used as an aid to make the audit element consistent? No technical determination.

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

Document the basis for acceptance of the attribute element in worksheet Have all attribute elements been Write SE input per guidance in No audited? Section G, H, J Yes Provide audit SE input Have all 7 AMP No attributes been audited? Conclusion of AMP Audit Yes Figure 1. Audit of AMPs that are Consistent with the GALL Report 44

Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan Start Preparation Steps Provide question to Develop Obtain response Identify criteria of SRP-LR Appendix A Team Leader for PMs question from applicant elements which are auditable Note: submittal to applicant Preparation steps may be performed as a Identify LRA AMP support documents single combined needed to perform audit step for each Yes AMP audited.

Is it appropriate Notify NRC Team to ask applicant a Leader that review of Compare each SRP-LR AMP criteria clarifying question to No AMR may not proceed element to the LRA AMP continue audit?

Draft RAI Is the AMP No Is there a technical element consistent? basis to accept exception No or difference?

Note: If a prior NRC Yes precedent exists, it may be Yes used as an aid to make the Terminate AMP technical determination. audit Document the basis for acceptance of Documentation of the the element in worksheet acceptance must me made on the technical merits not a citation to the precedent.

Have all element No criteria been audited?

Yes Have all 7 AMP No elements been audited? Write SER input Yes Provide NRC Team Leader and contractor audit SER input Conclusion of AMP review Figure 2. Audit of Plant-Specific AMPs 45

Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan AMR Item Item is No Review corresponding LRA Table 3.X.1 Yes Review referenced LRA subsection and Further assigned to Further Evaluation Recommended and Evaluation compare with SRP subsection for any DE Discussion columns differences Yes No No No No No No Not consistent with Footnote A Footnote B Footnote C Footnote D Footnote E GALL Report.

Evaluate in accordance with Yes Yes Yes Yes Yes Section 6.3.2 of this plan.

Compare item with Compare item with Compare item with Compare item with Compare item with GALL Vol. 2 System GALL Vol. 2 System GALL Vol. 2 System GALL Vol. 2 System GALL Vol. 2 System Table line item for: Table line item for: Table line item for: Table line item for: Table line item for:

component type component type -- -- --

material material material material material environment environment environment environment environment aging effect aging effect aging effect aging effect aging effect AMP -- AMP -- --

Confirm AE still Confirm material, Confirm material, Confirm AMP can AMP is plant- Yes managed despite environment, AE, environment and manage this AE specific AMP exception and method per aging effect are AMP are comparable comparable and AE No still managed despite Confirm that AMP exception AMP will address AE for this component and environment No Acceptable in Document problem in AMR Confirm question Mark for Query Prepare question all aspects? Comparison Checklist is captured Yes Document basis for acceptance AMR line item Mark as Acceptable in AMR Comparison Checklist compelte Out of RLEP Mark as Out of Scope Scope Figure 3. Review of AMRs that are Consistent with the GALL Report 46

Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan Identify generic TLAA issues Identify exemptions in effect Identify potential plant unique TLAA issues Yes Is the exemption based on a TLAA issue?

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

Yes Determine the method of TLAA evaluation Analysis Aging review Justify that the No further Verify that the Verify that the TLAA can be evaluation of the TLAA is TLAA is valid for projected to the exemption is OR OR resolved by extended end of the required for managing the operating period? extended period license renewal aging effects of operation Figure 4.2-1 Document the evaluation Figure 4. Review of TLAAs and Exemptions (from NEI 95-10, Revision 6) 47

Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan APPENDIX A PROJECT TEAM MEMBERSHIP Organization Name Function NRC/NRR/DLR/RLRC Jim Davis Team Leader NRC/NRR/DLR/RLRC Peter Wen Back-up Team Leader NRC/NRR/DLR/RLRC John Fair Reviewer - Mechanical NRC/NRR/DLR/RLRC Yeon-Ki Chung Reviewer - Mechanical NRC/NRR/DLR/RLRC Qi Gan Reviewer - Mechanical NRC/NRR/DLR/RLRC Duc Nguyen Reviewer - Electrical NRC/NRR/DLR/RLRC Surinder Arora Reviewer - Mechanical BNL Rich Morante Contractor lead, Reviewer - Structures BNL Joe Braverman Reviewer - Structures BNL Mano Subudhi Reviewer - Materials BNL Ken Sullivan Reviewer - Mechanical A-1

Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan APPENDIX B RLRC SCHEDULE FOR IP2 AND IP3 LRA SAFETY REVIEW Plant: Indian Point Nuclear TAC: MD5407, MD5408 Generating Unit Nos. 2 and 3 Team Leader: Jim Davis Scope of Work:

Backup Team Leader: Peter Wen AMPs - All, with exception of Rx Vessel Surv, Ni Alloy Insp, Borel, and Fire Protection Project Manager: Kimberly Green TLAAs - 4.1, 4.3 , 4.4, and 4.6 Contractor: BNL AMRs - All Team Members: RAI Target Date: 12/31/2007 NRC: Surinder Arora, Yeon-Ki Chung, SE Input to PM: 3/31/2008 John Fair, Qi Gan, and Duc Nguyen BNL: Joe Braverman, Rich Morante, Mano Subudhi, and Ken Sullivan Activity/Milestone Scheduled Date 1 Received license renewal application (LRA) 4/30/07 2 Complete acceptance review 5/31/07 3 Make review assignments (RLRA Project Manager) 6/15/07 4 Conduct team planning and kick-off meeting 6/29/07 5 Issue audit plan to Project Manager 8/1/07 6 Conduct first site visit (AMP/TLAA audit and review) 8/27-31/2007 7 Draft AMP Audit Report Input 9/27/07 8 Conduct in-office AMR reviews 9/4/07 to 10/12/07 9 Conduct second site visit (AMR/TLAA audit and review) 10/22-26/2007 10 Optional Third site visit to resolve AMR, AMP, and TLAA questions 11/26-28/2007 11 Draft AMR/TLAA SER Input 12/5/07 12 Cutoff for providing RAIs to Project Manager 12/31/07 13 Peer Review of SER Input 12/10-21/07 14 Issue Audit Summary to PM 2/29/08 15 Issue final SER input to Project Manager 3/31/08 16 ACRS subcommittee meeting July 2008 17 ACRS full committee meeting November 2008

• Note: The date for PM to issue SER with open items is 5/30/08.

B-1

Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan APPENDIX C AGING MANAGEMENT PROGRAM ASSIGNMENTS IP2 and GALL IP2 and IP3 Consistent With GALL?

IP3 Report Aging Plant No. LRA Assigned Auditor AMP Management Specific AMP Exceptions Enhancements Number Program Number 1 B.1.1 XI.M29 Aboveground Steel X X Q. Gan/J. Davis Tanks (existing program) 2 B.1.2 XI.M18 Bolting X X Q. Gan/J. Davis Integrity(existing program) 3 B.1.3 XI.M22 Boraflex X DCI Staff Monitoring(existing program) 4 B.1.4 NA Boral Surveillance X DCI Staff (existing program) 5 B.1.5 XI.M10 Boric Acid X J. Davis Corrosion prevention(existing program) 6 B.1.6 XI.M34 Buried Piping and X Q. Gan/J. Davis Tanks Inspection (new program)

C-1

Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan IP2 and GALL IP2 and IP3 Consistent With GALL?

IP3 Report Aging Plant No. LRA Assigned Auditor AMP Management Specific AMP Exceptions Enhancements Number Program Number 7 B.1.7 XI.S4 Containment Leak X J. Braverman/

Rate (existing R. Morante program) 8 B.1.8 XI.S1, Containment J. Braverman/

XI.S2 Inservice X R. Morante Inspection (existing program) 9 B.1.9 XI.M30 Diesel Fuel X X K. Sullivan Monitoring (existing program) 10 B.1.10 X.E1 Environmental D. Nguyen Qualification (EQ) X of Electric Components (existing program) 11 B.1.11 XI.M36 External surfaces X X K. Green Monitoring (existing program) 12 B.1.12 X.M1 Fatigue Monitoring X X P. Wen (existing program) 13 B.1.13 XI.M26 Fire X X N. Iqbal Protection(existing program)

C-2

Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan IP2 and GALL IP2 and IP3 Consistent With GALL?

IP3 Report Aging Plant No. LRA Assigned Auditor AMP Management Specific AMP Exceptions Enhancements Number Program Number 14 B.1.14 XI.M27 Fire Water System X X N. Iqbal (existing program) 15 B.1.15 XI.M17 Flow-Accelerating X S. Arora Corrosion (existing program) 16 B.1.16 XI.M37 Flux Thimble Tube X X M. Subudhi Inspection (existing program) 17 B.1.17 NA Heat Exchanger X J. Braverman/

Monitoring R. Morante (existing program) 18 B.1.18 XI.M1, Inservice X M. Subudhi XI.S3 Inspection (existing program) 19 B.1.19 XI.S5 Masonry Wall X X J. Braverman/

(existing program) R. Morante 20 B.1.20 XI.E4 Metal-Enclosed X X D. Nguyen Bus Inspection (existing program) 21 B.1.21 NA Nickel Alloy X DCI Staff Inspection (existing program)

C-3

Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan IP2 and GALL IP2 and IP3 Consistent With GALL?

IP3 Report Aging Plant No. LRA Assigned Auditor AMP Management Specific AMP Exceptions Enhancements Number Program Number 22 B.1.22 NA Non-EQ Bolted X D. Nguyen Cable Connections (new program) 23 B.1.23 XI.E3 Non-EQ X D. Nguyen Inaccessible Medium-Voltage Cable (new program) 24 B.1.24 XI.E2 Non-EQ X D. Nguyen Instrumentation Circuits Test Review (new program) 25 B.1.25 XI.E1 Non-EQ Insulated X D. Nguyen Cables and Connections (new program) 26 B.1.26 XI.M39 Oil Analysis X X K. Sullivan (existing program) 27 B.1.27 XI.M32 One-Time X S. Arora Inspection (new program)

C-4

Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan IP2 and GALL IP2 and IP3 Consistent With GALL?

IP3 Report Aging Plant No. LRA Assigned Auditor AMP Management Specific AMP Exceptions Enhancements Number Program Number 28 B.1.28 XI.M35 One-time X S. Arora Inspection - Small Bore Piping (new program) 29 B.1.29 NA Periodic X S. Arora Surveillance and Preventive Maintenance (existing program) 30 B.1.30 XI.M3 Reactor Head X M. Subudhi Closure Studs (existing program) 31 B.1.31 XI.M11A Reactor Vessel X M. Subudhi Head Penetration Inspection (existing program) 32 B.1.32 XI.M31 Reactor Vessel X X DCI Staff Surveillance (existing program) 33 B.1.33 XI.M33 Selective Leaching X J. Davis (new program) 34 B.1.34 XI.M20 Service Water X K. Sullivan Integrity (existing program)

C-5

Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan IP2 and GALL IP2 and IP3 Consistent With GALL?

IP3 Report Aging Plant No. LRA Assigned Auditor AMP Management Specific AMP Exceptions Enhancements Number Program Number 35 B.1.35 XI.M19 Steam Generator X X Q. Gan/J. Davis Integrity (existing program) 36 B.1.36 XI.S6 Structures X X J. Braverman/

(XI.S7) Monitoring R. Morante (existing program) 37 B.1.37 XI.M12 Thermal Aging X M. Subudhi embrittlement of Cast Austenitic Stainless Steel (CASS)

(new program) 38 B.1.38 XI.M13 Thermal Aging and X M. Subudhi Neuron Irradiation Embrittlement of Cast Austenitic Stainless Steel (CASS)

(new program) 39 B.1.39 NA Water Chemistry X K. Sullivan Control - Auxiliary Systems (existing program)

C-6

Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan IP2 and GALL IP2 and IP3 Consistent With GALL?

IP3 Report Aging Plant No. LRA Assigned Auditor AMP Management Specific AMP Exceptions Enhancements Number Program Number 40 B.1.40 XI.M21 Water Chemistry X X K. Sullivan Control - Closed Cooling Water (existing program) 41 B.1.41 XI.M2 Water Chemistry X X S. Arora Control - Primary and Secondary (existing program)

C-7

Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan APPENDIX D AGING MANAGEMENT REVIEW ASSIGNMENTS Aging Management Reviews Reviewer 3.1 Aging Management of Reactor Vessel, Internals, and Mano Subudhi Reactor Coolant System 3.2 Aging Management of Engineered Safety Features Qi Gan/Peter Wen 3.3 Aging Management of Auxiliary Systems Ken Sullivan /Rich Morante 3.4 Aging Management of Steam and Power Conversion Surinder Arora Systems 3.5 Aging Management of Containment, Structures, and Joe Braverman /

Component Supports Rich Morante 3.6 Aging Management of Electrical and Instrumentation and Duc Nguyen Controls D-1

Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan The applicant presented the (a)(2) items (Nonsafety-Related Components Potentially Affecting Safety Functions) all in Tables 3.3.2-19-X of AMR Section 3.3. However, the SER preparation is based on systems as defined in SRP-LR, which includes six specific sections (i.e., AMRs 3.1 thru 3.6). To facilitate the LRA review and SER preparation, the following (a)(2) items in Section 3.3 are reassigned to Sections 3.2 and 3.4 reviewers as followed:

Peter Wen (3.2 Reviewer)

IP3: Table 3.3.2-19-10 IP2: Table 3.3.2-19-30 Table 3.3.2-19-43 Table 3.3.2-19-37 Table 3.3.2-19-44 Table 3.3.2-19-53 Table 3.3.2-19-62 Surinder Arora (3.4 Reviewer)

IP3: Table 3.3.2-19-6 IP2: Table 3.3.2-19-4 Table 3.3.2-19-7 Table 3.3.2-19-6 Table 3.3.2-19-8 Table 3.3.2-19-12 Table 3.3.2-19-9 Table 3.3.2-19-15 Table 3.3.2-19-12 Table 3.3.2-19-23 Table 3.3.2-19-14 Table 3.3.2-19-34 Table 3.3.2-19-15 Table 3.3.2-19-36 Table 3.3.2-19-18 Table 3.3.2-19-41 Table 3.3.2-19-22 Table 3.3.2-19-23 Table 3.3.2-19-24 Table 3.3.2-19-27 Table 3.3.2-19-28 Table 3.3.2-19-32 Table 3.3.2-19-34 Table 3.3.2-19-35 Table 3.3.2-19-36 Table 3.3.2-19-45 Table 3.3.2-19-50 Table 3.3.2-19-51 Table 3.3.2-19-57 D-2

Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan APPENDIX E TIME-LIMITED AGING ANALYSIS REVIEW ASSIGNMENTS LRA 10 CFR 54.21(c)(1) Assigned TLAA TLAA Title (i) or (iii) (ii) Reviewer Number Qi Gan/

Identification of TLAAs and 4.1 Peter Wen/

Exemptions John Fair Reactor Vessel Neutron 4.2 (iii) (ii) DCI Embrittlement Qi Gan/

4.3 Metal Fatigue (i) or (iii) Peter Wen/

John Fair Environmental Qualification of 4.4 (iii) D. Nguyen Electrical Components Concrete Containment Tendon 4.5 N/A - -

Prestress Analysis Containment Liner Plate and IP2- (i) J.Braverman/

4.6 Penetrations Fatigue Analysis IP3- N/A R. Morante Other Plant-Specific TLAA Reactor Coolant Pump Flywheel 4.7.1 N/A DCI Analysis 4.7.2 Leak Before Break (i) DCI 4.7.3. Steam generator Flow Induced IP2- (i) IP3- (ii) DCI Vibration and Tube Wear E-1

Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan APPENDIX F CONSISTENT WITH GALL REPORT AMP AUDIT/REVIEW WORKSHEET The worksheet provided in this appendix provides, as an aid for the reviewer, a process for documenting the basis for the assessment of the elements and sub-elements contained in the GALL Report AMPs (Chapter XI of NUREG-1801, Volume 2). The worksheet provides a systematic method for recording the basis for assessments or to identify when the applicant needs to provide clarification or additional information. Information recorded in the worksheets will also be used to prepare the safety evaluation report input.

A complete set of GALL Report AMP worksheets can be found using ADAMS.

F-1

Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan LRA Appendix Subsection: LRA AMP

Title:

GALL Report Subsection: Gall Report

Title:

A. Element Review and Audit Program

Description:

G Consistent with GALL Report G Difference Identified Discussion:

1. Scope of Program:

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

2. Preventive Action:

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

3. Parameters Monitored/Inspected:

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

4. Detection of Aging Effects:

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

5. Monitoring and Trending:

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

6. Acceptance Criteria:

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

7. Corrective Action:

F-2

Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan

8. Confirmation Process:

9. Administrative Controls:

10. Operating Experience:

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

C. Remarks and questions:

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

E. Applicant contact:

Project team member: __________________________________ Date: ______________

F-3

Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan APPENDIX G PLANT-SPECIFIC AMP AUDIT/REVIEW WORKSHEET The worksheet provided in this appendix provides, as an aid for the reviewer, a process for documenting the basis for the assessments concerning individual program elements and sub-elements contained in Branch Technical Position RLSB-1 "Aging Management Review -

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

G-1

Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan Plant-Specific AMP Audit/Review Worksheet AMP

Title:

______________________________________________________________

Appendix Subsection: ____________________________________________________

A. Element Review and Audit

1. Scope of Program:

___ Consistent with SRP-LR ____ Exception ____ Difference Identified Discussion:

SRP Criteria LRA AMP Comment*

2. Preventive Action:

___ Consistent with SRP-LR ____ Exception ____ Difference Identified Discussion:

SRP Criteria LRA AMP Comment*

3. Parameters Monitored/Inspected:

___ Consistent with SRP-LR ____ Exception ____ Difference Identified Discussion:

SRP Criteria LRA AMP Comment*

4. Detection of Aging Effects

___ Consistent with SRP-LR ____ Exception ____ Difference Identified Discussion:

SRP Criteria LRA AMP Comment*

G-2

Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan

5. Monitoring and Trending

___ Consistent with SRP-LR ____ Exception ____ Difference Identified Discussion:

SRP Criteria LRA AMP Comment*

6. Acceptance Criteria

___ Consistent with SRP-LR ____ Exception ____ Difference Identified Discussion:

SRP Criteria LRA AMP Comment*

7. Corrective Action:

8. Confirmation Process:

9. Administrative Controls:

10. Operating Experience:

___ Consistent with SRP-LR ____ Exception ____ Difference Identified Discussion:

SRP Criteria LRA AMP Comment*

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

C. Remarks and questions:

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

E. Applicant

Contact:

Project team member:_________________________________ Date: ______________

G-3

Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan Appendix H AMR Comparison Worksheets H-1

Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan IP2 and IP3 AMR Component (Table 1) Worksheet: Audit Date:

Unit: Table No.: Chapter:

Auditor Name(s):

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

Item No. Further Evaluation Recommended Discussion Audit remarks (Document all questions for applicant here):

Number Question for applicant (draft per RAI guidance) Response (with date)

References/Documents Used:

1.

2.

3.

4.

.

H-2

Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan IP2 and IP3 AMR MEAP Comparison (Table 2) Worksheet Audit Date:

Unit: Table No.: Chapter:

Auditor Name(s):

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

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

LRA Component Material Environment Aging Effect Note: Discussion Page No. Type (draft as Audit Report Insert)

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

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

References/Documents Used:

1.

2.

3.

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

H-3

Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan APPENDIX I ACRONYMS, ABBREVIATIONS, AND INITIALISMS ADAMS Agencywide Documents Access and Management System AMP aging management program AMR aging management review ASME American Society of Mechanical Engineers CLB current licensing basis DE Division of Engineering DLR Division of License Renewal FSAR Final Safety Analysis Report GALL Generic Aging Lessons Learned ISG-LR Interim Staff Guidance for License Renewal IP2 Indian Point Nuclear Generating Unit No. 2 IP3 Indian Point Nuclear Generating Unit No. 3 LRA license renewal application NEI Nuclear Energy Institute NRC U.S. Nuclear Regulatory Commission NRR Office of Nuclear Reactor Regulation RAI request for additional information RLRC License Renewal Branch C RLSB License Renewal and Standardization Branch SC structures and components SER safety evaluation report SRP-LR Standard Review Plan - License Renewal SSC structure, system, and component I-1

Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan TLAA Time Limited Aging Analysis UFSAR Updated Final Safety Analysis Report I-2