ML062780155

License Renewal Audit and Review Plan

ML062780155
Person / Time
Site:	FitzPatrick
Issue date:	10/23/2006
From:	NRC/NRR/ADRO/DLR
To:
Mathew R, K, NRR/DLR/RLRC, 415-2965
Shared Package
ML062780166	List: ML062780155 ML062780187
References
Download: ML062780155 (73)

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Audit and Review Plan forPlant Aging Management Programs, Aging Management Reviews, andTime-Limited Aging AnalysesJames A. FitzPatrick Nuclear Power PlantDocket No.: 50-333 TABLE OF CONTENTS1.INTRODUCTION................................................12.BACKGROUND.................................................2 3.OBJECTIVES..................................................4 4.

SUMMARY

OF INFORMATION PROVIDED IN THE LICENSE RENEWALAPPLICATION..................................................54.1Aging Management Review Results..................................54.1.1JAFNPP AMR Comparison with GALL..........................6 4.1.2Plant-Specific Programs.....................................94.2 Time-Limited Aging Analyses......................................105.OVERVIEW OF AUDIT, REVIEW, AND DOCUMENTATION PROCEDURE..135.1Aging Management Programs.....................................13 5.2Aging Management Reviews......................................13 5.3Time-Limited Aging Analyses......................................14 5.4UFSAR Supplement Review......................................15 5.5Documents Reviewed by the Project Team...........................15 5.6Status Meeting.................................................15 5.7Documentation Prepared by the Project Team........................155.7.1Audit and Review Plan.....................................15 5.7.2Worksheets.............................................15 5.7.3Questions...............................................16 5.7.4Work Packages..........................................16 5.7.5Requests for Additional Information...........................16 5.7.6Audit and Review Summary.................................16 5.7.7Safety Evaluation Report input...............................166.PLANNING, AUDIT, REVIEW, AND DOCUMENTATION PROCEDURE.....176.1Planning Activities..............................................176.1.1Schedule for Key Milestones and Activities.....................176.1.2Work Assignments........................................17 6.1.3Training and Preparation...................................176.2Aging Management Program (AMP) Audits and Reviews................186.2.1Types of AMPs...........................................18 6.2.2Scope of AMP elements to be audited and reviewed..............186.2.3Plant AMPs that Are Consistent with the GALL Report.............196.2.4Plant-Specific AMPs.......................................216.3Aging Management Review (AMR) Audits and Reviews.................23 6.3.1Plant AMRs that Are Consistent with the GALL Report............236.3.2Plant AMRs that Are Not Consistent with the GALL Report.........256.4Time-Limited Aging Analyses (TLAA) Audits and Reviews...............266.4.1Identify Generic TLAA Issues................................266.4.2Metal Fatigue Analyses....................................29 6.4.3Environmental Qualification Analyses for Electrical Components.....316.4.4Other Plant-Specific TLAAs.................................336.5Audit and Safety Review Documentation.............................356.5.1Audit and Review Summary.................................36 6.5.2Safety Evaluation Report Input...............................366.6Documents Reviewed and Document Retention.......................42APPENDIX APROJECT TEAM MEMBERSHIP.......................................A-1APPENDIX BRLRC SCHEDULE FOR FITZPATRICK LRA SAFETY REVIEW...............B-1APPENDIX CAGING MANAGEMENT PROGRAM ASSIGNMENTS .......................C-1APPENDIX DAGING MANAGEMENT REVIEW ASSIGNMENTS..........................D-1APPENDIX ETIME-LIMITED AGING ANALYSIS REVIEW ASSIGNMENTS.................E-1APPENDIX FCONSISTENT WITH GALL REPORT AMP AUDIT/REVIEW WORKSHEET......F-1APPENDIX GPLANT-SPECIFIC AMP AUDIT/REVIEW WORKSHEET.....................G-1Appendix HAMR Comparison Worksheets.........................................H-1APPENDIX IACRONYMS, ABBREVIATIONS, AND INITIALISMS........................I-1 TABLESTable 1. Aging Management Program Element Descriptions.........................43Table 2. Notes for License Renewal Application Tables 3.X.2-Y

......................44FIGURESFigure 1. Audit of AMPs that are Consistent with the GALL Report....................45Figure 2. Audit of Plant-Specific AMPs .........................................46 Figure 3. Review of AMRs that are Consistent with the GALL Report ..................47 Figure 4. Review of TLAAs and Exemptions (from NEI 95-10, Revision 6) ..............48 1Audit and Review Plan for Plant Aging Management Programs, AgingManagement Reviews, and Time-Limited Aging Analyses1.INTRODUCTIONBy letter dated July 31, 2006, (ADAMS Accession Number ML062160494), Entergy NuclearOperations, Inc., submitted to the U.S. Nuclear Regulatory Commission (NRC) its application for renewal of Entergy Nuclear Operations, Inc., application for renewal of Operating License No.DPR-59 for the James A. FitzPatrick Nuclear Power Plant (JAFNPP). The applicant requested renewal of the operating license 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 JAFNPP, theDivision 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 JAFNPP. The project team will include NRC staff and engineers provided by Brookhaven National Laboratory (BNL), RLRC's 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 JAFNPP. The project team will audit and review its assigned AMPs, AMRs, and TLAAs against therequirements 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 JAFNPP current licensing basis (CLB) for the period of extended operation.The project team will perform its work at NRC Headquarters, Rockville, Maryland; atBrookhaven National Laboratory offices in Upton, New York; and at the JAFNPP site near Oswego, New York. 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 documentsthat 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.

James A. FitzPatrick Nuclear Power Plant AMP and AMR Audit and Review Plan 2Summary of Information Provided in License Renewal Application. Description of the information contained in the license renewal application forJAFNPP that is applicable to this plan.Overview of the Audit, Review, and Documentation Procedure. Summary ofthe process the project team will follow to audit and review the LRA informationthat is within its scope of review.

Planning, Audit, Review, and Documentation Procedure. The procedure thatthe project team will use to plan and schedule its work, to audit and review theLRA information that is within its scope of review, and to document the results of its work.Appendices. Supporting information. The project team membership is shownin Appendix A and the schedule is shown in Appendix B. The team's workassignments 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 or this plan. Appendix I is a list of the acronyms, abbreviations, and initialisms used in this plan.2.BACKGROUNDIn 10 CFR 54.4, the scope of license renewal is defined as those structures, systems, andcomponents (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 toidentify those structures and components (SCs) subject to an AMR. SCs subject to an AMR are those that perform an intended function without moving parts or without a change in configuration or properties (passive), and that are not subject to replacement based on qualified life or specified time period (long-lived). Pursuant to 10 CFR 54.21(a)(3), an applicant for a renewed license must demonstrate that the effects of aging will be managed in such a way that the intended function or functions of those SCs will be maintained, consistent with the CLB, for the period of extended operation. 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 James A. FitzPatrick Nuclear Power Plant AMP and AMR Audit and Review Plan 3Report is a technical basis document. It summarizes staff-approved AMPs for the agingmanagement of a large number of SCs that are subject to an AMR. It also summarizes the aging management evaluations, programs, and activities acceptable to the NRC staff for managing aging of most of the SCs used in commercial nuclear power plants, and serves as a reference for both the applicant and staff reviewers to quickly identify those AMPs and activities that the staff has determined will provide adequate aging management during the 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 isgenerically 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 theplant 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 CFR54.21(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 oranalysis 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 licenserenewal, as delineated in 10 CFR 54.4(a).2.Consider the effects of aging.

James A. FitzPatrick Nuclear Power Plant AMP and AMR Audit and Review Plan 43.Involve time-limited assumptions defined by the current operating term, forexample, 40 years. 4.Were determined to be relevant by the licenses in making a safetydetermination.5.Involve conclusions or provide the basis for conclusions related to the capabilityof 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 extendedoperation; the TLAAs have been projected to the end of the period of extended operation; or the aging effects of aging on the intended function(s) will be adequately managed for the period of extended operation. The staff performs a technical review as well as reviews the area relating to the identification of TLAAs. The staff also confirms that the applicant did not omit any TLAAs, as defined in 10 CFR 54.3.3.OBJECTIVES The overall objective of the audit and review described in this plan is to verify compliance with10 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 JAFNPP is described in Sections 5 and 6 of this plan. It isintended to accomplish the following objectives:For JAFNPP AMPs that the applicant claims are consistent with GALL AMPs,verifying 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 JAFNPP AMPs that the applicant claims are consistent with GALL AMPswith exceptions, verifying 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, verifying that the applicant has documented an acceptable technical basis for each exception.For JAFNPP AMPs that the applicant claims will be consistent with GALL AMPsafter specified enhancements are implemented, verifying that the plant AMPs, with the enhancements, will be consistent with the referenced GALL AMPs, or James A. FitzPatrick Nuclear Power Plant AMP and AMR Audit and Review Plan 5are acceptable on the basis of a technical review. In addition, verifying that theapplicant identified the enhancements as commitments in the Updated Final Safety Analysis Report (UFSAR) or other docketed correspondence.For AMR line items that the applicant claims are consistent with the GALLReport, 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 withthe GALL Report, 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 54.219(c)(1), a license renewal applicant is required to provide a list of TLAAs, as defined in 10 CFR 54.3. The area relating to the identification of TLAAs is reviewed. TLAAs may have developed since issuance of a plant's operating license. As indicated in 10 CFR 54.30, the adequacy of the plant's CLB, which includes TLAAs, is not an area within the scope of the license renewal review. Any question regarding the 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 validfor the period of extended operation; (2) the TLAAs have been projected to the end of the period of extended operation; or (3) the aging effects of aging on the intended function(s) will be adequately managed for the period of extended operation.4.

SUMMARY

OF INFORMATION PROVIDED IN THE LICENSE RENEWALAPPLICATION4.1Aging Management Review ResultsThe JAFNPP 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.

James A. FitzPatrick Nuclear Power Plant AMP and AMR Audit and Review Plan 6LRA Table 3.0-1, Table 3.0-2, and Table 3.0-3 provide descriptions of the mechanical,structural, and electrical 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. Definition1Reactor Vessel, Internals, and Reactor Coolant System2Engineered Safety Features Systems 3Auxiliary Systems 4Steam and Power Conversion Systems 5Structures and Component Supports 6Electrical and Instrumentation and ControlsThe 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 are presented in Table 3.1.2-1, and the results for the reactor vessel internals are in Table 3.1.2-2. In the engineered safety features subsection, the residual heat removal system results are presented in Table 3.2.2-1, and the core 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.4.1.1JAFNPP AMR Comparison with GALLThe applicant compared the JAFNPP AMR results with information set forth in the tables of theGALL 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, JAFNPP AMR results have been compared with/information set forth in the tables of NUREG-1801. Results of that comparison are provided in the following two table types, Table 1 and Table 2.

James A. FitzPatrick Nuclear Power Plant AMP and AMR Audit and Review Plan 74.1.1.1Purpose of Table 1The purpose of Table 1 is to provide a summary comparison of how the JAFNPP AMR resultsalign 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 toinclude the table number.The "Type" column has been deleted. Items applicable to PWRs only are noted as such.The "Related Item" column has 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 ofinformation that might be contained within this column:Any "Further Evaluation Recommended" information or reference to the locationof 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 inNUREG-1801, Volume 1, when it may not be intuitively obvious.A discussion of how the line item is different than the corresponding line item inNUREG-1801, Volume 1, when it may appear to be consistent.4.1.1.2Purpose of Table 2 Table 2 provides results of the aging management reviews for those structures andcomponents 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 residual heat removal, core spray, automatic depressurization, high pressure coolant injection, reactor core isolation cooling, standby gas treatment, and primary containment penetrations.Table 2 consists of the following nine columns:

Component Type James A. FitzPatrick Nuclear Power Plant AMP and AMR Audit and Review Plan 8Column 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. Incases 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 accumulatorson LRA drawings.Intended Function Column 2 identifies the license renewal intended functions (using abbreviations wherenecessary) 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 particular materials of construction for the component type being evaluated.

Environment Column 4 lists the environment to which the component types are exposed. Internal/externalservice 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 components, respectively.Aging Effect Requiring Management Column 5 lists the aging effects requiring management for material and environmentcombinations 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 James A. FitzPatrick Nuclear Power Plant AMP and AMR Audit and Review Plan 9Column 7 documents identified consistencies by noting the appropriate NUREG-1801, Volume2, item number. If there is no corresponding item number in NUREG-1801, Volume 2, for a particular combination of factors, column 7 is left blank.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 inNUREG-1801, Volume 1, column 8 is left blank.Each combination of the following that has an identified NUREG-1801, Volume 2 item numberalso 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 itemsin 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 Industry's 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 JAFNPP.JAFNPP LRA Table 2 contains the aging management review results and indicates whether theresults correspond to line items in Volume 2 of the GALL Report. Correlations between the combination JAFNPP 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 Column 7 is blank, the applicant did not identify a corresponding combination in the GALL Report. If the applicant identified a GALL Report line item, 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.

James A. FitzPatrick Nuclear Power Plant AMP and AMR Audit and Review Plan 104.1.2Plant-Specific ProgramsMany of the GALL Report evaluations refer to plant-specific programs. In these cases, theapplicant considers the JAFNPP evaluation to be consistent with the GALL Report if the other elements are consistent. Any appropriate AMP is considered to be a match to the GALL program for line items referring to a plant-specific program. Note E is used for correlations between the combination in Table 2 and a combination for a line item in NUREG-1801, Volume

2. 4.2 Time-Limited Aging AnalysesThe JAFNPP LRA closely follows the standard LRA format presented in Revision 6 of NEI95-10, "Industry Guidelines for Implementing the Requirements of 10 CFR Part 54 - The License Renewal Rule." Section 4 of the JAFNPP LRA addresses time-limited aging analyses.

In Section 4.1.1, the JAFNPP LRA states that the calculations and evaluations that couldpotentially meet the six criteria of 10 CFR 54.3 were identified by searching CLB documents including the following:A.Technical SpecificationsB.UFSAR C.docketed licensing correspondence D.Fire protection program documents E.NRC safety evaluation reports F.BWRVIP documentsIn Section 4.1, the JAFNPP LRA states that as required by 10 CFR 54.21(c)(1), an evaluationof JAFNPP-specific time-limited aging analyses must be performed to demonstrate that:A.The analyses remain valid for the period of extended operation; B.The analyses have been projected to the end of the period of extendedoperation; orC.The effects of aging on the intended functions(s) will be adequately managed forthe period of extended operation.In the JAFNPP LRA, the applicant summarized the results of the above evaluations in Table4.1-1. These evaluations are discussed in subsequent sections of JAFNPP LRA Section 4.Following the section identifying the TLAAs, the JAFNPP LRA next includes a sectionidentifying any exemptions. 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 time-limited aging analyses as defined in 10 CFR 54.3. The JAFNPP performed this by reviewing JAFNPP docketed correspondence which identified JAFNPP exemptions. The results of this review determined that no JAFNPP exemptions depend on TLAAs.

James A. FitzPatrick Nuclear Power Plant AMP and AMR Audit and Review Plan 11The JAFNPP LRA next includes a separate section for each of the identified TLAAs within theoutline of the corresponding NUREG-1800 TLAA category. The TLAA categories are outlined in the next table.TLAA DescriptionResolution OptionSectionReactor Vessel Neutron Embrittlement Analyses 4.2Pressure/temperature limits Analysis will be projected4.2.2Charpy upper-shelf energy Analysis projected10CFR54.21(c)(1)(ii) 4.2.3Adjusted reference temperature Analysis projected10CFR54.21(c)(1)(ii) 4.2.4Reactor vessel circumferential weldinspection relief Analysis projected10CFR54.21(c)(1)(ii) 4.2.5Reactor vessel axial weld failureprobabilityAnalysis projected10CFR54.21(c)(1)(ii) 4.2.6Metal Fatigue Analyses 4.3Class 1 fatigue Analysis remains valid 10CFR54.21(c)(1)(i)

OR Analysis projected 10CFR54.21(c)(1)(ii) 4.3.1Non-Class 1 fatigue Analyses remain valid 10CFR54.21(c)(1)(i) 4.3.2Effects of reactor water environment onfatigue lifeAnalysis projected10CFR54.21(c)(1)(ii)

OR Analyses will be projected

OR Aging effect managed 10CFR54.21(c)(1)(iii) 4.3.3Environmental QualificationAnalyses of Electrical Equipment Aging effect managed10CFR54.21(c)(1)(iii) 4.4Concrete Containment TendonPrestress AnalysesNot applicable for JAFNPP4.5Containment Liner Plate, Metal Containment, and Penetrations Fatigue 4.6 James A. FitzPatrick Nuclear Power Plant AMP and AMR Audit and Review PlanTLAA DescriptionResolution OptionSection 12AnalysesFatigue of primary containment Analysis projected10CFR54.21(c)(1)(ii) 4.6.1Other TLAA 4.7Recirculation valves fatigue evaluationAnalyses remain valid10CFR54.21(c)(1)(i) 4.7.1Leak before breakAnalysis will be projected4.7.2TLAA in BWRVIPs 4.7.3BWRVIP-05, RPV circumferentialwelds analysisAnalysis projected10CFR54.21(c)(1)(ii).

4.7.3.1BWRVIP-25, core plate (loss of preloadon the core plate rim hold-down bolts)Analysis will be projected4.7.3.2BWRVIP-38, shroud support fatigueanalysisAnalyses remain valid10CFR54.21(c)(1)(i) 4.7.3.3BWRVIP-47-A, lower plenum fatigueanalysisAnalyses remain valid10CFR54.21(c)(1)(i) 4.7.3.4BWRVIP-74, reactor vesselP/T curves analysis Fatigue analysis C VUSE analysis Circ/axial welds analysisAnalysis will be projected. Analyses remains valid 10 CFR 54.21(c)(1)(i) OR Analyses projected 10 CFR 54.21(c)(1)(ii)

OR Analyses managed 10 CFR 54.21(c)(1)(iii) OR Analyses will be projected Analyses projected 10 CFR 54.21(c)(1)(ii)

Analyses projected 10 CFR 54.21(c)(1)(ii) 4.7.3.5BWRVIP-76, core shroud fatigueanalysisAnalysis projected10CFR54.21(c)(1)(ii).

4.7.3.6 James A. FitzPatrick Nuclear Power Plant AMP and AMR Audit and Review Plan 135.OVERVIEW OF AUDIT, REVIEW, AND DOCUMENTATION PROCEDUREThe project team will follow the procedure specified in Section 6 of this plan to perform itsaudits and reviews and to document the results of its work. The process covered by the procedure is summarized below.5.1Aging Management ProgramsTable 1 of this audit and review plan summarizes the program elements that comprise an agingmanagement program. For the JAFNPP AMPs for which the applicant claimed consistency with the AMPs included in the GALL Report, the project team will review the JAFNPP AMP descriptions and compare program elements for the JAFNPP AMPs to the corresponding program elements for the GALL AMPs. The project team will verify that the JAFNPP 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. The Division of Engineering will review and determine the adequacy of the applicant's 10 CFR 50, Appendix B Program. Other aspects of these program elements will be reviewed by the project team. For JAFNPP AMPs that have one or more exception and/or enhancement, the project team willreview 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 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 identiry between the JAFNPP AMPs credited by the applicant and the GALL Report AMPs. In these cases, the project team will review the difference to determine whether the JAFNPP AMP, as modified by the difference, would adequately manage the aging effects for which it is credited.For those JAFNPP 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 Division of Engineering will review and determine the adequacy of the applicant's 10 CFR 50, Appendix B Program. Other aspect of these program elements will be 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.5.2Aging Management ReviewsThe AMRs in the GALL Report fall into two broad categories: (1) those that the GALL Reportconcludes are adequate to manage aging of the components referenced in the GALL Report, and (2) those for which the GALL Report concludes that aging management is adequate, but further evaluation is recommended for certain aspects of the aging management process. For its AMR reviews, the project team will determine (1) whether the AMRs reported by the applicant to be consistent with the GALL Report are indeed consistent with the GALL Report, and (2) whether the plant-specific AMRs reported by the applicant to be based on a previously-approved precedent are technically acceptable and applicable. For component groups evaluated in the GALL Report for which the applicant claimed consistency with the GALL Report, and for which the GALL Report recommends further evaluation, the project team James A. FitzPatrick Nuclear Power Plant AMP and AMR Audit and Review Plan 14will review the applicant's evaluation to determine if it adequately addressed the issues forwhich the GALL Report recommended further evaluation.5.3Time-Limited Aging AnalysesThe TLAAs in the JAFNPP LRA fall into the broad category of those that are consistent with theNUREG-1800 TLAA categories. There are no plant-specific exemptions identified in the JAFNPP LRA that depend on time-limited aging analyses.For its TLAA reviews, the project team will determine if the applicant had provided adequateinformation 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 todetermine, 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 licenserenewal, as delineated in 10 CFR 54.4(e).2.Consider the effects of aging.

3.Involve time-limited assumptions defined by the current operating term (40years).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 capabilityof the system, structure, and component to perform its intended fucntions, 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 emergingissues that should be further evaluated by technical specialists in the NRC Division of Component Integrity (DCI) or the Division of Engineering (DE). This is not expected to be an issue for TLAAs for which the applicant claims consistency with 10 CFR 54.21(c)(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 analyseshave 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:

James A. FitzPatrick Nuclear Power Plant AMP and AMR Audit and Review Plan 15A.Reactor Vessel Neutron Embrittlement AnalysisB.TLAA in BWRVIP-74, Reactor Vessel5.4UFSAR Supplement ReviewConsistent with the SRP-LR, for the AMRs and associated AMPs that it will review, the projectteam 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.5.5Documents Reviewed by the Project TeamIn 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. 5.6Status MeetingAt the conclusion of its audits and reviews, the project team will debrief the applicant's licenserenewal staff and management regarding the status of the audits and reviews of the LRA AMPs, AMRs and TLAAs assigned to the project team. 5.7Documentation Prepared by the Project TeamThe project team will prepare an audit and review plan, worksheets, work packages, requestsfor 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. 5.7.1Audit and Review Plan The project team leader will prepare a plant-specific audit and review plan as described herein.

5.7.2Worksheets Each project team member will informally document the results of his or her work on a variety ofworksheets. The worksheets are shown in Appendix F, "Consistent with GALL Report AMP Audit/Review Worksheet," Appendix G, "Plant-Specific AMP Audit/Review Worksheet," and James A. FitzPatrick Nuclear Power Plant AMP and AMR Audit and Review Plan 16Appendix H, "Aging Management Review Comparison Worksheets." The use of theworksheets is described in Section 6 of this plan. 5.7.3Questions As specified in Section 6 of this plan, the project team members will ask the applicant questionsduring 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.5.7.4Work Packages After each site visit, the project team leader, in conjunction with the project manager, willassemble work packages for any work that the team will refer to the 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.5.7.5Requests for Additional Information The review process described in this plan is structured to resolve as many questions aspossible during the site visits. As examples, the site visits are used to obtain clarificationsabout 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 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 providethe 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.5.7.6Audit and Review Summary At the conclusion of the audits and reviews, the project team will prepare a summary of theaudits and reviews highlighting the status of its review and any potential RAIs.5.7.7Safety Evaluation Report input The project team will prepare a SER input, based on the audits and reviews, as described inSection 6.4.2 of this plan.

James A. FitzPatrick Nuclear Power Plant AMP and AMR Audit and Review Plan 176.PLANNING, AUDIT, REVIEW, AND DOCUMENTATION PROCEDUREThis section of the audit and review plan contains the detailed procedures that the project teamwill follow to plan, perform, and document its work.6.1Planning Activities6.1.1Schedule for Key Milestones and ActivitiesThe 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:oReceiving the LRA from the applicant.oReceiving work split tables from the project manager.

oMaking individual work assignments.

oTraining project team members.

oHolding the project team kickoff meeting.

oPreparing the audit and review plan.

oScheduling site visits.

oScheduling in-office review periods.

oPreparing questions.

oPreparing RAIs.

oPreparing draft and final audit and review report.

oPreparing draft and final SER input.Site visits will be scheduled on the basis of discussions between the project team leader, theNRC license renewal project manager, and the applicant.Appendix B of this plan contains the target schedule for the key milestones and activities.

6.1.2Work Assignments The technical assistance contractor will propose team member work assignments to the NRCproject 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 and the project team leader will develop assignment tables that show whichproject 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.6.1.3Training and Preparation The training and preparation will include the following:

James A. FitzPatrick Nuclear Power Plant AMP and AMR Audit and Review Plan 18A.A description of the audit and review process.B.An overview of audit/review-related documentation and the documentation thatthe project team will audit and review.1.GALL Report2.SRP-LR 3.Interim Staff Guidance for License Renewal (ISG-LR) 4.LRA AMPs 5.LRA AMRs 6.Basis documents (catalogues of information assembled by the applicantto demonstrate the bases for its programs and activities)7.Implementing procedures 8.Operating experience reports 9.RAIs, audit reports, and SERs for other plants 10.Applicant's UFSAR 11.LRA TLAAs 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 report, and SERinput.F.Process for interfacing with NRC technical reviewers.6.2Aging Management Program (AMP) Audits and Reviews6.2.1Types of AMPsThere are two types of AMPs: those that the applicant claims are consistent with AMPscontained 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.6.2.2Scope 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 ofeach 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 withthe GALL Report and for plant-specific AMPs. The Division of Engineering will reveiw and determine the adequacy of the applicant's 10 CFR 50, Appendix B Program. Other aspects of these program elements will be reviewed by the project team.

James A. FitzPatrick Nuclear Power Plant AMP and AMR Audit and Review Plan 196.2.3Plant AMPs that Are Consistent with the GALL ReportFigure 1, "Audit of AMPs that Are Consistent with the GALL Report," is the process flowchartthat 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.PreparationA.For the plant AMP being reviewed, identify the corresponding GALL AMP.

B.Review the associated GALL AMP and identify those elements that will beaudited.C.Identify the documents needed to perform the audit. These may include, but arenot limited to, the following:1.GALL Report2.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) 9.UFSARAudit/ReviewA.Confirm that JAFNPP AMP program elements are consistent with thecorresponding 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 anexception/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 in the SER input.D.Review the industry and plant-specific operating experience associated with theAMP. The review is to identify aging effects requiring management that are not identified by the industry guidance documents (such as EPRI tools) and to James A. FitzPatrick Nuclear Power Plant AMP and AMR Audit and Review Plan 20confirm the effectiveness of aging management programs. The project teammembers 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 RequiringManagement. 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 ManagementPrograms. 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-1800.3.Industry Operating Experience. Industry operating experience and itsapplicability 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 acceptinga 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 thebasis 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.

James A. FitzPatrick Nuclear Power Plant AMP and AMR Audit and Review Plan 21AMP audit worksheets Document the audits/reviews using the worksheet provided in Appendix F, "Consistent withGALL Report AMP Audit/Review Worksheet."6.2.4Plant-Specific AMPs Figure 2, "Audit of Plant-Specific AMPs," is the process flowchart that shows the activities anddecisions used to audit/review each plant-specific AMP.Pre-review preparationA.Review Section A.1.2.3 of the SRP-LR and identify those element criteria thatwill be reviewed.B.Identify the documents needed to perform the audit. These may include, but arenot limited to, the following:1.GALL Report2.SRP-LR 3.ISG-LR 4.RAIs and SERs for similar plants 5.LRA 6.Basis documents 7.Implementation procedures 8.Operating experience reports (plant-specific and industry) 9.UFSAR 10.Lessons Learned Developed by RLRCAudit/ReviewA.Audit/review the JAFNPP AMP program elements and determine that they are inaccordance 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 theAMP. This is an area of review emphasis. They require review to identify aging effects requiring management that are not identified by the industry guidance documents (such as EPRI tools) and to confirm the effectiveness of aging management programs. The project team members should consider the industry guidance when assessing operating experience and formulating questions for the applicant. The industry guidance (from NEI 95-10, Revision 6) is as follows:1.Plant-Specific Operating Experience with Aging Effects RequiringManagement. The review should assess the operating and maintenance James A. FitzPatrick Nuclear Power Plant AMP and AMR Audit and Review Plan 22history. A review of the prior 5 to 10 years of operating and maintenancehistory 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 itsapplicability should be assessed to determine whether it changes plant-specific determinations. NUREG-1801 is based upon industry operating experience prior to its date of issue. Operating experience after the issue date of NUREG-1801 should be evaluated and documented as part of the aging management review. In particular, generic communications such as a bulletin, a generic letter, or an information notice should be evaluated for impact upon the AMP. The evaluation should check for new aging effects or a new component or location experiencing an already identified aging effect.C.If it is necessary to ask the applicant a question, follow the process shown inFigure 2.E.If it is necessary for the applicant to submit additional information to resolve aquestion 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 AMPAudit/Review Worksheet."

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

236.3Aging Management Review (AMR) Audits and ReviewsThere are two types of AMRs: those that the applicant claims are consistent with the GALLReport, and those that are plant-specific. Audit and review of both types of AMRs are discussed below. 6.3.1Plant AMRs that Are Consistent with the GALL Report Figure 3, "Review of AMRs that Are Consistent with the GALL Report," is the process flowchartthat shows the activities and decisions used to audit/review each AMR that the applicant claims is consistent with the GALL Report.PreparationA.For the JAFNPP AMRs that the applicant claims are consistent with the GALLReport, identify the corresponding AMRs in Volume 2 of the GALL Report.B.Review the associated GALL AMRs and identify those line items that will beaudited/reviewed in conjunction with each of the JAFNPP AMRs.C.Identify the documents needed to perform the review. These may include, butare not limited to, the following:1.GALL Report2.SRP-LR 3.ISG-LR 4.RAIs and SERs for similar plants 5.LRA 6.Basis documents 7.Implementation procedures 8.Operating experience reports (plant-specific and industry) 9.UFSAR 10.Lessons Learned Developed by RLRCAudit/ReviewA.Each AMR line item is coded with a letter which represents a standard notedesignation.

1 The letter notes are described in Table 2 of this plan. Notes thatuse numeric designators are plant-specific. The note codes A though E are James A. FitzPatrick Nuclear Power Plant AMP and AMR Audit and Review Plan 2Some GALL AMRs reference the use of a plant-specific AMP. In such cases the AMR auditrequires the project team member to confirm that the plant-specific AMP is appropriate to manage the aging effects during the period of extended operation.

24classified as "consistent with the GALL Report," and will be reviewed inaccordance with the guidance contained in this plan.B.The AMR review involves verification that the applicant has satisfied therequirements of 10 CFR 54.21(a)(3). This requirement states: "For each

structure and component ... [within the scope of this part ... and ... subject to anaging 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 processis summarized below:1.For each AMR line item, perform the review associated with the letternote (A through E) assigned to the AMR line item. Specifically, determine if the AMR is consistent with the GALL Report for the elements associated with its note.2.If Note A applies, and the applicant uses a plant-specific AMP 2 determineif the component is within the scope of the cited plant AMP. If the component is within the scope of the plant AMP, the AMR line item is acceptable. If not acceptable, go to Step (7) below.3.If Note B applies, review the LRA exceptions and document the basis foracceptance in the worksheet, and later in the audit and review report. If not acceptable, go to Step (7) below.4.If Note C or D applies, determine if the component type is acceptable forthe material, environment, and aging effect. If Note D applies, also review the LRA exceptions and document the basis for acceptance in the worksheet, and later in the audit and review report. If not acceptable, go to Step (7) below.5.If Note E applies, review the AMP audit report findings to determine if thescope 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 inLRA 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)

James A. FitzPatrick Nuclear Power Plant AMP and AMR Audit and Review Plan 25below. If the LRA section does not meet the acceptance criteria ofAppendix A of the SRP-LR, go to Step (7) below.7.If during the review a difference is identified, prepare a question to theapplicant, in order to obtain clarification. a.Review the applicant's response to the question. If it appearsacceptable, re-start the audit/review for the AMR line item from Step (1) above. b.If the applicant's response does not resolve the question or issue,prepare an additional question to obtain the information needed to achieve resolution. Review the applicant's response to the second question. If it appears acceptable, re-start the audit/review for the AMR line item from Step (1) above. c.If it is necessary for the applicant to submit additional informationto 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 applicantclaims are not applicable with the GALL Report, determine that the AMR line items are acceptable on the basis of a technical review. For component groups evaluated in the GALL Report for which the applicant claimedconsistency with the GALL Report, and for which the GALL Report recommends further evaluation, the project team reviews the applicant's evaluation to determine if it adequately addressed the issues for which the GALL Report recommended further evaluation, specifically that the applicant has addressed the further evaluation and has evaluated the AMRs in accordance with the SRP-LR Sections 3.X.2.2 and 3.X.3.2AMR audit/review worksheets Document the audits/reviews of plant AMRs using the worksheet provided in Appendix H, "Aging Management Review Comparison Worksheets."6.3.2Plant 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 applicantindicated, 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 James A. FitzPatrick Nuclear Power Plant AMP and AMR Audit and Review Plan 26not evaluated in the GALL Report. Note H indicates that the aging effect for the AMR line itemcomponent, 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 the acceptance criteria described in Branch Technical Position RLSB-1 (Appendix A.1 of the SRP-LR). 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 acceptance criteria specified in Appendix A.1 of the LRA are met.The AMR review involves verification that the applicant has satisfied the requirements of 10CFR 54.21(a)(3) . This requirement states: "For each structure and component ... [within thescope 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."

6.4Time-Limited Aging Analyses (TLAA) Audits and ReviewsAudit and review of TLAAs are discussed below. The project team will also review the TLAAsto determine if there are emerging issues that should be further evaluated by technical specialists in the NRC Division of Component Integrity (DCI) or the Division of Engineering (DE). 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.6.4.1Identify Generic TLAA Issues Figure 5, "Evaluation of TLAAs and Exemptions," taken from NEI 95-10, Revision 6, shows theprocess 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 PreparationA.For the JAFNPP TLAAs that the applicant has identified as generic TLAA issues,identify the corresponding TLAAs in NUREG-1800, if appropriate.

James A. FitzPatrick Nuclear Power Plant AMP and AMR Audit and Review Plan 27B.Review the corresponding TLAAs in NUREG-1800 and identify those that will beaudited/reviewed in conjunction with each of the JAFNPP TLAAs.C.Review the list of the JAFNPP 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 mayinclude, but are not limited to, the following:1.Excel database on TLAAs summarizing how earlier LRAs and SERs werepresented 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. Applicant's UFSARE.In addition, the project team will also review the TLAAs to determine if there areemerging issues that should be further evaluated by technical specialists in the NRC Division of Component Integrity (DCI) or the Division of Engineering (DE).

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

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

"the analyses have been projected to the end of the period of extended operation," the audit team leader will be consulted to determine which TLAAs the audit team will be capable of reviewing. Consideration should be given to team expertise, past precedent, and complexity of the provided analysis. Candidates for further review by technical specialists could be such as the following:1.Reactor Vessel Neutron Embrittlement Analysis (JAFNPP LRA Section4.2) 2.TLAAs in BWRVIPs 05 and 74 (JAFNPP LRA Section 4.7.3)

James A. FitzPatrick Nuclear Power Plant AMP and AMR Audit and Review Plan 28Audit/ReviewA.Confirm that each JAFNPP TLAA listed in this section is appropriate. Refer toany 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 JAFNPPshould state in this section that it does not apply.C.Review any industry and plant-specific operating experience associated with theTLAA. 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, asdefined 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)) arelocated. 2.The application shall include a demonstration that (1) the analysesremain valid for the period of extended operation, (2) the analyses have been (or have been identified and will be [§54.29(a)]) projected to the end of the period of extended operation or (3) the effects of aging on the intended function(s) will be adequately managed for the period of extended operation. 3.The application shall include a list of plant-specific exemptions grantedpursuant 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 ofextended operation shall be included in the UFSAR supplement (Appendix A).D.If it is necessary to ask the applicant a question to clarify the basis for theiranalyses, follow the logic process shown in Figure 5 of this audit and review

plan.E.If it is necessary for the applicant to submit additional information to support thebasis for the conclusions in their TLAA, the applicant may agree to voluntarily James A. FitzPatrick Nuclear Power Plant AMP and AMR Audit and Review Plan 29submit the required information as a supplement (docketed letter submittedunder oath and affirmation) to the JAFNPP LRA. If not, the NRC may issue an RAI to obtain the information.6.4.2 Metal Fatigue Analyses Figure 5, "Evaluation of TLAAs and Exemptions," shows the process of evaluating andreviewing 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 PreparationA.The project team will determine if the TLAAs identified in the JAFNPP LRA to bewithin 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 mayinclude, but are not limited to, the following: 1.Excel database on TLAAs summarizing how earlier LRAs and SERspresented 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.Applicant's UFSARC.In addition, the project team will also review the JAFNPP TLAAs within theNUREG-1800 TLAA category of "metal fatigue" to determine if there are emerging issues that should be further evaluated by technical specialists in the NRC Division of Component Integrity (DCI) or the Division of Engineering (DE).

This is not expected to be an issue for TLAAs for which the applicant claims consistency with 10 CFR 54.21(c)(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 James A. FitzPatrick Nuclear Power Plant AMP and AMR Audit and Review Plan 30audit team will be capable of reviewing. Consideration should be given to teamexpertise, past precedent, and complexity of the provided analysis.Audit/ReviewA.Confirm that each JAFNPP TLAA listed in this section is appropriate. Refer toany 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 JAFNPPshould state in this section that it does not apply.C.The project team will conduct both regulatory evaluations and technicalevaluations 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 oflicense 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 safetydetermination. 5.Involve conclusions, or provide the basis for conclusions, related to thecapability 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 JAFNPP satisfactorily demonstrates that(1) the analyses remain valid for the period of extended operation, (2) the analyses have been (or have been identified and will be [§54.29(a)]) projected to the end of the period of extended operation or (3) the effects of aging on the intended function(s) will be adequately managed for the period of extended operation.E.Review any industry and plant-specific operating experience associated with theTLAA. This is an area of review emphasis. The project team members should consider the following industry guidance on metal fatigue (from NEI 95-10, Table 6.2-2) as follows: 1.Disposition chosen for each of the identified TLAAs. Also, provide areference to the summary description of TLAA evaluations in the FSAR James A. FitzPatrick Nuclear Power Plant AMP and AMR Audit and Review Plan 31supplement (Appendix A). Use hypertext to link to the appropriatelocation 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 theiranalyses, follow the logic process shown in Figure 5 of this audit and review

plan.G.If it is necessary for the applicant to submit additional information to support thebasis 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 JAFNPP 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," shows the process of evaluating andreviewing 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 PreparationA.The project team will determine if the TLAAs identified in the JAFNPP LRA to bewithin 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 mayinclude, but are not limited to, the following: 1.Excel database on TLAAs summarizing how earlier LRAs and SERspresented 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)

12. Lessons learned developed by RLRC

13. Applicant's UFSAR James A. FitzPatrick Nuclear Power Plant AMP and AMR Audit and Review Plan 32C.In addition, the project team will also review the JAFNPP TLAAs within theNUREG-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 Division of Component Integrity (DCI) or the Division of Engineering (DE). This is not expected to be an issue for TLAAs for which the applicant claims consistency with 10 CFR 54.21(c)(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/ReviewA.Confirm that each JAFNPP TLAA listed in this section is appropriate. Refer toany 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 JAFNPPshould state in this section that it does not apply.C.The project team will conduct both regulatory evaluations and technicalevaluations 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 oflicense 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 safetydetermination. 5.Involve conclusions, or provide the basis for conclusions, related to thecapability 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 JAFNPP satisfactorily demonstrates that(1) the analyses remain valid for the period of extended operation, (2) the James A. FitzPatrick Nuclear Power Plant AMP and AMR Audit and Review Plan 33analyses have been (or have been identified and will be [§54.29(a)]) projected tothe 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 theTLAA. 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 areference 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 theiranalyses, follow the logic process shown in Figure 5 of this audit and review

plan.G.If it is necessary for the applicant to submit additional information to support thebasis 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 JAFNPP LRA. If not, the NRC may issue an RAI to obtain the information.6.4.4 Other Plant-Specific TLAAsFigure 5, "Evaluation of TLAAs and Exemptions," taken from NEI 95-10, Revision 6, shows theprocess 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 PreparationA.The project team will determine if the TLAAs identified in the JAFNPP LRA to bewithin 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 mayinclude, but are not limited to, the following: 1.Excel database on TLAAs summarizing how earlier LRAs and SERspresented and reviewed TLAAs James A. FitzPatrick Nuclear Power Plant AMP and AMR Audit and Review Plan 342.GALL Report 3.SRP-LR 4.ISG-LR 5.RAIs, audit and review reports, and SERs for similar plants 6.LRA 7.References listed by applicant for each TLAA 8.NEI 95-10, Section 5.1 and Table 6.2-2 9.Basis documents 10.Implementation documents 11.Operating experience reports (plant-specific and industry) 12.Lessons learned developed by RLRC

13. Applicant's UFSARC.In addition, the project team will also review the JAFNPP TLAAs within theNUREG-1800 TLAA category of "other plant-specific TLAAs" to determine if there are emerging issues that should be further evaluated by technical specialists in the NRC Division of Component Integrity (DCI) or the Division of Engineering (DE). This is not expected to be an issue for TLAAs for which the applicant claims consistency with 10 CFR 54.21(c)(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/ReviewA.Confirm that each JAFNPP TLAA listed in this section is appropriate. Refer toany 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 JAFNPPshould state in this section that it does not apply.C.The project team will conduct both regulatory evaluations and technicalevaluations 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 oflicense renewal, as delineated in 10 CFR 54.4(a). 2.Consider the effects of aging.

James A. FitzPatrick Nuclear Power Plant AMP and AMR Audit and Review Plan 353.Involve time-limited assumptions defined by the current operating term(40 years). 4.Determined to be relevant by the applicant in making a safetydetermination. 5.Involve conclusions, or provide the basis for conclusions, related to thecapability 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 JAFNPP satisfactorily demonstrates that(1) the analyses remain valid for the period of extended operation, (2) the analyses have been (or have been identified and will be [§54.29(a)]) projected to the end of the period of extended operation or (3) the effects of aging on the intended function(s) will be adequately managed for the period of extended operation.E.Review any industry and plant-specific operating experience associated with theTLAA. 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 theiranalyses, follow the logic process shown in Figure 5 of this audit and review

plan.G.If it is necessary for the applicant to submit additional information to support thebasis 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 JAFNPP LRA. If not, the NRC may issue an RAI to obtain the information.6.5Audit and Safety Review DocumentationAs 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.

James A. FitzPatrick Nuclear Power Plant AMP and AMR Audit and Review Plan 3AMRs that are not consistent with the GALL Report.

366.5.1 Audit and Review SummaryThe project team should prepare an audit and review summary upon completion of the on-siteaudits and reviews of the AMPs, AMRs, and TLAAs assigned to the project team. This summary should provide the following information: Members who participated in the on-site audits, Dates and location of the audits Guidance documents used for the review Activities performed Documents reviewed Availability of question and answer database Status of the review6.5.2Safety Evaluation Report InputA.General guidance1.Each project team member should prepare the SER input for the AMPAMR, and TLAA 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 inputshould 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 GALLReport, which has no exceptions or enhancements.b.Each AMP that was determined to be consistent with the GALLReport, 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.

e.Project team AMR review results.

3 James A. FitzPatrick Nuclear Power Plant AMP and AMR Audit and Review Plan 4The LRA AMR results are broken down into six sections and address the followingsystem/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.

374.The SER input should contain the following sections. (Note: Thefollowing 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 Results3.0Applicant's Use of the Generic Aging Lessons LearnedReport 3.01Format of the LRA 3.02Staff's Review Process3.0.2.1AMRs in the GALL Report 3.0.2.2NRC-Approved Precedents 3.0.2.3UFSAR Supplement 3.0.2.4Documentation andDocuments Reviewed3.0.3Aging Management Programs3.0.3.1AMPs that are ConsistentWith the GALL Report3.0.3.2AMPs that are ConsistentWith GALL Report With Exceptions or Enhancements3.0.3.3AMPs that are Plant-Specific3.0.4Quality Assurance Program Attributes Integral toAging Management Programs3.X 4Aging Management of_____ 3.X.1Summary of Technical Information in theApplication3.X.2Staff Evaluation3.X.2.1Aging ManagementEvaluations that are Consistent with the GALL Report, for Which Further Evaluation is Not Required3.X.2.2Aging ManagementEvaluations that are Consistent with the GALL Report, for Which Further Evaluation is Recommended3.X.2.3AMR Results that are NotConsistent with or Not James A. FitzPatrick Nuclear Power Plant AMP and AMR Audit and Review Plan 38Addressed in the GALLReport3.X.3Conclusion4.0 Time-Limited Aging Analyses4.1 Identification of Time-Limited Aging Analyses 4.3 Metal Fatigue 4.4 Environmental Qualification Environmental Qualification Analyses of Electrical Equipment4.6 Containment Liner Plate, Metal Containment, and Penetrations Fatigue Analysis 4.7 Other Plant-Specific Time-Limited Aging Analyses4.7.3.2 TLAA in BWRVIP-25 4.7.3.3 TLAA in BWRVIP-38 4.7.3.5 TLAA in BWRVIP-74 (fatigue only) 4.7.3.6 TLAA in BWRVIP -764.8 Conclusion for Time-Limited Aging Analyses5.For each AMP audited/reviewed by the project team, the SER shallinclude 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 thatis 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 thetime the SER input is prepared should be identified as open items.B.SER input1.For AMPs determined to be consistent with the GALL Report, withoutexceptions, 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.

James A. FitzPatrick Nuclear Power Plant AMP and AMR Audit and Review Plan 5The audit results documented in this section address the AMRs consistent with the GALLReport for which no further evaluation is recommended.

392.For AMPs determined to be consistent with the GALL Report, withexceptions 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.3.For plant-specific AMPs, the SER input should document the basis foraccepting 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 GALLReport, 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 ofthe 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 classifythe AMR line items used in these tables.e.A brief summary of what the staff (project team) reviewed toperform 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 wereidentified by the applicant or the project team member.g.A finding that verifies that: The applicant identified the applicable aging effects.

James A. FitzPatrick Nuclear Power Plant AMP and AMR Audit and Review Plan 6This section documents reviews of AMRs assigned to the project team that are not consistentwith the GALL Report.

40The applicant defined the appropriate combination ofmaterials and environments. The applicant specified acceptable AMPs.h.A conclusion stating, if applicable, that the applicant hasdemonstrated that the effects of aging will be adequately managed so that the intended functions will be maintained consistent with the CLB for the period of extended operation, and that 10 CFR 54.21(a)(3) has been satisfied.5.For aging management evaluations that are consistent with the GALLReport, for which further evaluation is recommended, the SER input should include the following:a.The LRA section containing the applicant's further evaluations ofAMRs 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 thebasis for concluding that it satisfied the criteria of Section 3.1.3.2 of the SRP-LR. d.A statement that the staff audited the applicant's furtherevaluations against the criteria contained in Section 3.1.3.2 of the SRP-LR.6.Staff AMR Review Results.

6 This section of the SER input documents thereviews of AMRs assigned to the project team that are not consistent with the GALL Report. The SER input document the following, based on a precedent identified by the applicant:a.The LRA section reviewed.

b.A summary of the type of information provided in the section ofthe 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.

James A. FitzPatrick Nuclear Power Plant AMP and AMR Audit and Review Plan 41d.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 ofmaterials and environments. The applicant specified acceptable AMPs.f.Provide a conclusion stating, if applicable, that the applicant hasdemonstrated that the effects of aging will be adequately managed so that the intended functions will be maintained consistent with the CLB for the period of extended operation, and that 10 CFR 54.21(a)(3) has been satisfied.7.TLAA Reviews - This section of the SER input documents the reviews ofTLAAs assigned to the project team. The SER input should include the following:a. Summary of technical informationin the application

b. Staff evaluation(i) Regulatory basis (ii) Scope of review and technical evaluationc. UFSAR supplement review - stating, if applicable, that theapplicant has provided a UFSAR supplement summary description of its TLAA evaluation.

James A. FitzPatrick Nuclear Power Plant AMP and AMR Audit and Review Plan 42d. Provide a conclusion stating, if applicable, that the applicanthas 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)(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 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).6.6Documents Reviewed and Document RetentionAny documents reviewed that were used to formulate the basis for resolution of an issue, suchas 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 NRCpersonnel shall be given to the NRC project team leader.After the NRC has made its licensing decision, all copies of documents collected and alldocuments generated to complete the SER input, such as audit worksheets, question and answer tracking documentation, etc., are to be discarded.

James A. FitzPatrick Nuclear Power Plant AMP and AMR Audit and Review Plan 43Table 1. Aging Management Program Element DescriptionsElementDescription1Scope of the programThe scope of the program should include the specificstructures and components subject to an aging management review. 2Preventive actionsPreventive actions should mitigate or prevent the applicableaging effects. 3Parameters monitored orinspectedParameters monitored or inspected should be linked to theeffects of aging on the intended functions of the particular structure and component. 4Detection of aging effectsDetection of aging effects should occur before there is loss ofany 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. 5Monitoring and trendingMonitoring and trending should provide prediction of the extentof the effects of aging and timely corrective or mitigative actions. 6Acceptance criteriaAcceptance criteria, against which the need for correctiveaction 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. 7Corrective actionsCorrective actions, including root cause determination andprevention of recurrence, should be timely.8Confirmation processThe confirmation process should ensure that preventiveactions are adequate and appropriate corrective actions have been completed and are effective. 9Administrative controlsAdministrative controls should provide a formal review andapproval process. 10Operating experienceOperating experience involving the aging managementprogram, 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.

James A. FitzPatrick Nuclear Power Plant AMP and AMR Audit and Review Plan 7Each AMR line item is coded with a letter which represents a standard note designation basedon 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," datedJanuary 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).

44Table 2. Notes for License Renewal Application Tables 3.X.2-Y 7NoteDescriptionAConsistent with NUREG-1801 [GALL Report] item for component, material,environment, and aging effect. AMP is consistent with NUREG-1801 AMP.BConsistent with NUREG-1801 item for component, material, environment, and agingeffect. AMP takes some exceptions to NUREG-1801 AMP.CComponent is different, but consistent with NUREG-1801 item for material,environment, and aging effect. AMP is consistent with NUREG-1801 AMP.DComponent is different, but consistent with NUREG-1801 item for material,environment, and aging effect. AMP takes some exceptions to NUREG-1801 AMP.EConsistent with NUREG-1801 for material, environment, and aging effect, but adifferent aging management program is credited.FMaterial not in NUREG-1801 for this component.GEnvironment not in NUREG-1801 for this component and material.HAging effect not in NUREG-1801 for this component, material and environmentcombination.IAging effect in NUREG-1801 for this component, material and environmentcombination is not applicable.JNeither the component nor the material and environment combination is evaluated inNUREG-1801.

James A. FitzPatrick Nuclear Power Plant AMP and AMR Audit and Review Plan 45Figure 1. Audit of AMPs that are Consistent with the GALL Report Yes NoYesYes No Yes NoStartDid applicant identifyany exceptions to GALLAMP(s)?Compare each GALL AMPauditable element to the LRAAMPDocument the basis foracceptance of the attributeelement in worksheetHave all attribute elementsbeen audited?

YesPreparation StepsIdentify GALL AMP(s) towhich LRA AMP is beingcomparedIdentify elements of GALLAMP(s) attributes to beauditedIdentify LRA AMP supportdocuments needed toperform auditIs there a technicalbasis to accept exception ordifference?Note: If a prior NRCprecedent exists, it maybe used as an aid to make the technical determination.

Documentation of theacceptance must bemade on the technicalmerits not a citation tothe precedent.Ask applicant a clarifyingquestion to continue audit?

NoNotify NRCTeam Leaderthat Audit ofAMR may notproceed.Terminate AMPauditDevelop andprovide questionto Team Leaderfor PM's submittalto applicantObtainresponse fromapplicantDraft RAI NoNote; Preparation stepsmay be performed as asingle combined step foreach AMP audited.

Yes NoIs the attributeelement consistent?Write audit report input perguidance in Section D.E.FConclusion ofAMP auditProvide audit report inputWrite SE input per guidance inSection G.H.JProvide audit SE inputHave all 7 AMPattributes been audited?

No James A. FitzPatrick Nuclear Power Plant AMP and AMR Audit and Review Plan 46Yes NoYes NoYesYes No NoStartCompare each SRP-LR AMPcriteria element to the LRAAMPDocument the basis foracceptance of the element inworksheetHave all element criteriabeen audited?Preparation StepsIdentify criteria of SRP-LR,Appendix A elemets whichare auditableIdentify LRA AMP supportdocuments needed toperform auditIs there a technical basisto accept exception ordifference?Note: If a prior NRCprecedent exist, it maybe used as an aid tomake the technicaldetermination.

Documentation of the acceptance must be made on the technical merits not a citation to the precedent.Is it appropriateto ask applicant a clarifyingquestion to continue audit?Developquestion NoNotify NRCTeam Leader that review ofAMP may notproceed.Terminate AMP auditProvidequestion toTeam leaderfor PM'ssubmittal toapplicantObtainresponse fromapplicantDraft RAINote; Preparation stepsmay be performed as asingle combined step foreach AMP audited.Yes NoIs the AMP elementconsistent?Write audit and review reportinputConclusion ofAMP reviewProvide NRC team leader andcontractor audit report inputWrite SER inputProvide NRC team leader andcontractor audit SER inputHave all 7 AMPelements been audited?Figure 2. Audit of Plant-Specific AMPs James A. FitzPatrick Nuclear Power Plant AMP and AMR Audit and Review Plan 47Footnote AConfirm that AMP willaddress AE for thiscomponent andenvironmentCompare line item withGALL Vol. 2 SystemTable line item for:component type materialenvironmentaging effect

-Confirm AE stillmanaged despiteAMP exceptionConfirm material,environment, AE, andmethod per AMP arecomparableConfirm material,environment and agingeffect are comparable andAE still managed despiteAMP exceptionConfirm AMP can managethis AEFootnote BFootnote CFootnote DFootnote ECompare line item withGALL Vol. 2 SystemTable line item for:

- materialenvironmentaging effectAMPCompare line item withGALL Vol. 2 SystemTable line item for:

- materialenvironmentaging effect

-Compare line item withGALL Vol. 2 SystemTable line item for:

- materialenvironmentaging effect

-Compare item withGALL Vol. 2 SystemTable item for:component type materialenvironmentaging effect AMPItem isassigned to DE NoDocument basis for acceptancein AMR Comparison ChecklistPrepare questionReview corresponding LRA Table3.X.1"Further Evaluation Recommended"and "Discussion" columnsReview referenced LRA subsection andcompare with SRP subsection for anydifferencesAcceptable inall aspects NoMark as Out of ScopeOut of RLEPScopeMark as AcceptableMark for queryDocument problem inAMR Comparison ChecklistConfirm questionis capturedAMR line itemcompleteAMR item AMPis Plant-Specific NoYesYesYes NoNoNoNoNoYesYesYesYesYesYes NoFurtherEvaluation Figure 3. Review of AMRs that are Consistent with the GALL Report James A. FitzPatrick Nuclear Power Plant AMP and AMR Audit and Review Plan 48Figure 4. Review of TLAAs and Exemptions (from NEI 95-10, Revision 6)

James A. FitzPatrick Nuclear Power Plant AMP and AMR Audit and Review PlanA-1APPENDIX APROJECT TEAM MEMBERSHIPOrganizationNameFunctionNRC/NRR/DLR/RLRCRoy MathewTeam leaderNRC/NRR/DLR/RLRCJames MedoffBack-up Team Leader, Reviewer-Materials, MechanicalNRC/NRR/DLR/RLRCDan HoangReviewer - Structures NRC/NRR/DLR/RLRCDuc NguyenReviewer - Electrical NRC/NRR/DLR/RLRCJim CanadyReviewer - Systems NRC/NRR/DLR/RLRCSam AroraReviewer - Mechanical BNLRobert LofaroContractor lead, Reviewer - Mechanical,Materials BNLMano SubudhiReviewer - Systems, Materials BNLMichael VillaranReviewer -Systems James A. FitzPatrick Nuclear Power Plant AMP and AMR Audit and Review PlanB-1APPENDIX BPlant: FitzPatrickTeam Leader: Roy MathewBackup Team Leader: Jim MedoffProject Manager: Tommy LeContractor: BNLAssignments:

BNL: Bob Lofaro (Lead), Mike Villaran, andMano Subudhi, NRC: Jim Medoff, Dan Hoang, Duc Nguyen,Jim Canady, and Shyam AroraTAC: MD2666 Scope of Work:AMPs - 34 of 35AMRs - 2657/2665 TLAAs - 8 of 13RAI Target Date: 12/15/06SE Input to PM:

4/15/07ACTIVITY/MILESTONESCHEDULEActualScheduleStatus1Receive LRA7/31/0608/01/06Complete2Complete Sufficiency Review8/30/068/23/06Complete 3Make Review Assignments (RLRB PM)9/11/068/29/06Complete 4Conduct Contracts kick-off meeting with BNL9/22/069/22/06Complete 5Conduct Team Planning and Kick-off Meeting9/25/069/25/069/25/066Conduct Planning meeting with the applicant 10/3/0610/3/06Complete7Issue Audit Questions to PM10/26/06 8Issue Audit Plan to PM 10/31/06

9Conduct Site Visit 1(AMP audit & review)

• 11/13 -17/0610Draft AMP SER Input12/1/0611Conduct in-office AMR reviews11/28-12/8/06

12Conduct Site Visit 2(AMR/TLAA audit & review)*12/11 -15/0613Cutoff for providing RAIs to PM12/29/0614Draft AMR/TLAA SER Input1/5/07 15Optional Site Visit 3 (resolve AMR and AMPquestions)TBD16Peer Review of SER Input 1/11-19/0717Issue Audit Summary to PM1/30/07 James A. FitzPatrick Nuclear Power Plant AMP and AMR Audit and Review PlanB-218Final Draft SER from BNL with peer reviewcomments and RAI responses incorporated 2/26/0719Issue Final SER Input to PM4/15/0720ACRS Subcommittee Meeting9/07 21ACRS Full Committee Meeting2/08* Audit postponed due to applicant's request James A. FitzPatrick Nuclear Power Plant AMP and AMR Audit and Review Plan C-1APPENDIX CAGING MANAGEMENT PROGRAM ASSIGNMENTS No.JAFNPP LRAAMPNumberGALL ReportAMPNumberJAFNPPAging Management Program Consistent WithGALL?Assigned AuditorExcepti on Enhancement 1B.1.1XI.M34Buried Piping and TanksInspection Program (new program)XR. Lofaro 2B.1.2XI.M6BWR CRD Return Line NozzleProgram (existing program)

X XM. Subudhi 3B.1.3XI.M5BWR Feedwater NozzleProgram (existing program)

XM. Subudhi 4B.1.4 XI.M8BWR Penetrations Program(existing program)

XM. Subudhi 5B.1.5XI.M7BWR Stress Corrosion CrackingProgram (existing program)

XM. Subudhi 6B.1.6 XI.M4BWR Vessel ID AttachmentWelds Program (existing program)XS. Arora /J. Medoff 7B.1.7XI.M9BWR Vessel Internals Program(existing program)

XJ. Medoff 8 B.1.8 XI.S4Containment Leak RateProgram (existing program)

YD. Hoang James A. FitzPatrick Nuclear Power Plant AMP and AMR Audit and Review Plan No.JAFNPP LRAAMPNumberGALL ReportAMPNumberJAFNPPAging Management Program Consistent WithGALL?Assigned AuditorExcepti on Enhancement C-2 9B.1.9XI.M30Diesel Fuel Monitoring Program(existing program)X XR. Lofaro 10B.1.10 X.E1Environmental Qualification (EQ)of Electric Components Program (existing program)

YD.Nguyen 11B.1.11 XI.M36External Surfaces MonitoringProgram (existing program)

XM. Villaran 12B.1.12 X.M1Fatigue Monitoring Program(existing program)

XJ. Medoff 13B.1.13.1XI.M26Fire Protection - Fire ProtectionProgram (existing program)

XJ. Canady/R.Mathew 14B.1.13.2 XI.M27Fire Protection - Fire WaterSystem Program (existing program)X XJ. Canady/R.Mathew 15B.1.14XI.M17Flow-Accelerated CorrosionProgram (existing program)

YS. Arora /J. Medoff 16B.1.15 Plant-specificHeat Exchanger MonitoringProgram ( new program)N/APlant- specificR. Lofaro 17B.1.16.1 Plant-specificInservice Inspection -Containment Inservice Inspection (CII) Program (existing program)N/APlant- specificD. Hoang James A. FitzPatrick Nuclear Power Plant AMP and AMR Audit and Review Plan No.JAFNPP LRAAMPNumberGALL ReportAMPNumberJAFNPPAging Management Program Consistent WithGALL?Assigned AuditorExcepti on Enhancement C-3 18B.1.16.2Plant-specificInservice Inspection - InserviceInspection (ISI) Program (existing program)N/APlant- specificJ. Medoff 19B.1.17 XI.E4Metal-Enclosed Bus InspectionProgram (new program)

XD.Nguyen 20B.1.18 XI.E2Non-EQ Instrumentation CircuitsTest Review Program (new program)YD.Nguyen 21B.1.19 XI.E1Non-EQ Insulated Cables andConnections Program (newprogram)YD.Nguyen 22B.1.20 XI.M39Oil Analysis Program (existingprogram)X X J.Canady/R.Mathew 23B.1.21 XI.M32 XI.M35One-Time Inspection Program(new program)

YR. Lofaro 24B.1.22 Plant- specificPeriodic Surveillance andPreventive Maintenance Program (existing program)N/APlant- specificR. Lofaro James A. FitzPatrick Nuclear Power Plant AMP and AMR Audit and Review Plan No.JAFNPP LRAAMPNumberGALL ReportAMPNumberJAFNPPAging Management Program Consistent WithGALL?Assigned AuditorExcepti on Enhancement C-4 25B.1.23 X1.M3Reactor Head Closure StudsProgram (existing program)

XJ. Medoff 26B.1.24 XI.M31Reactor Vessel SurveillanceProgram (existing program)

X DCI 27B.1.25 XI.M33Selective Leaching Program(new program)

YS. Arora/ J. Medoff 28B.1.26 XI.M20Service Water Integrity Program(existing program)

XM. Villaran 29B.1.27.1 XI.S5Structures Monitoring - MasonryWall Program existing YD. Hoang 30B.1.27.2 XI.S6Structures Monitoring -Structures Monitoring Program (existing program)

XD. Hoang 31B.1.28 XI.M13Thermal Aging and NeutronIrradiation Embrittlement of Cast

Austenitic Stainless Steel (CASS) Program (new program)YM. Villaran James A. FitzPatrick Nuclear Power Plant AMP and AMR Audit and Review Plan No.JAFNPP LRAAMPNumberGALL ReportAMPNumberJAFNPPAging Management Program Consistent WithGALL?Assigned AuditorExcepti on Enhancement C-5 32B.1.29.1Plant-specificWater Chemistry Control -Auxiliary Systems Program (existing program)Plant- specificM. Villaran 33B.1.29.2X1.M2Water Chemistry Control - BWRProgram (existing program)

YM. Subudhi 34B.1.29.3XI.M21Water Chemistry Control -Closed Cooling Water Program (existing program)

XM. Villaran 35B.1.30 XI.M18Bolting Integrity Program(existing program)

XS. Arora/J. Medoff James A. FitzPatrick Nuclear Power Plant AMP and AMR Audit and Review Plan D-1APPENDIX DAGING MANAGEMENT REVIEW ASSIGNMENTSAging Management ReviewsReviewer3.1Aging Management of Reactor Vessel, Internals, and ReactorCoolant System CRD RL Cap in Table 3.1.2-1 and Core plate holdown bolts in Table 3.1.2-2 and 3.1.2-3 Mano Subudhi DCI3.2Aging Management of Engineered Safety FeaturesAMR Tables 3.3.2-14-1, 2, 3, 4, 7, 8, 10 and 14 Robert Lofaro/Sam Arora3.3Aging Management of Auxiliary SystemsM. Villaran /R. Lofaro 3.4Aging Management of Steam and Power Conversion Systems AMR Tables 3.3.2-14-16, 17,19, 20, 21, 22, 42, and 44 Jim CanadySam Arora3.5Aging Management of Containment, Structures, andComponent Supports Torus and Drywell Shell (Table 1- 3.5.1-5

)Dan Hoang DE 3.6Aging Management of Electrical and Instrumentation andControlsDuc Nguyen James A. FitzPatrick Nuclear Power Plant AMP and AMR Audit and Review PlanE-1APPENDIX ETIME-LIMITED AGING ANALYSIS REVIEW ASSIGNMENTS LRATLAANumberTLAA Title10 CFR 54.21(c)(1)AssignedReviewer(i) or (iii)(ii)4.1Identification of TLAAs andExemptionsJ. Medoff4.2Reactor Vessel NeutronEmbrittlement Analyses(i)(ii)DCI4.3Metal Fatigue Analyses(i) or (iii)(ii)J. Medoff4.4Environmental QualificationAnalyses of Electrical Equipment(iii)D. Nguyen4.5Concrete Containment TendonPrestress Not Applicableto JAFNPPN/AN/A4.6Containment Liner Plate, MetalContainment, and Penetrations Fatigue Analyses (ii)D. HoangOther TLAA4.7.1Recirculation valves fatigueevaluation(i)(iii)DE4.7.2Leak before break DCI4.7.3.1TLAA in BWRVIP-05, RPVcircumferential welds(ii)DCI4.7.3.2TLAA in BWRVIP-25, Core plate(loss of preload on the core plate rim hold-down bolts)projectedJ. Medoff4.7.3.3TLAA in BWRVIP-38, Shroudsupport(i)J. Medoff4.7.3.4TLAA in BWRVIP-47-A, Lowerplenum (i)DCI4.7.3.5TLAA in BWRVIP-74, Reactor Pressure Vessel(i)DCIJ. Medoff(fatigue only)4.7.3.6TLAA in BWRVIP -76, CoreShroud(ii)J. Medoff James A. FitzPatrick Nuclear Power Plant AMP and AMR Audit and Review Plan F-1APPENDIX FCONSISTENT WITH GALL REPORT AMP AUDIT/REVIEW WORKSHEETThe worksheet provided in this appendix provides, as an aid for the reviewer, a process fordocumenting 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 audit and review report and the safety evaluation report input. A complete set of GALL Report AMP worksheets can be found at ADAMS Accession NumberML060950189.

James A. FitzPatrick Nuclear Power Plant AMP and AMR Audit and Review Plan F-2LRA Appendix Subsection: LRA AMP Title: GALL Report Subsection:Gall Report Title:A. Element Review and AuditProgram

Description:

G Consistent with GALL Report G Difference Identified Discussion: 1. Scope of Program:

G Consistent with GALL Report G Exception G Enhancement G DifferenceIdentified Discussion:2. Preventive Action:

G Consistent with GALL Report G Exception G Enhancement G DifferenceIdentified Discussion:3. Parameters Monitored/Inspected:

G Consistent with GALL Report G Exception G Enhancement G DifferenceIdentified Discussion:4. Detection of Aging Effects:

G Consistent with GALL Report G Exception G Enhancement G DifferenceIdentified Discussion:5. Monitoring and Trending:

G Consistent with GALL Report G Exception G Enhancement G DifferenceIdentified Discussion:

James A. FitzPatrick Nuclear Power Plant AMP and AMR Audit and Review Plan F-36. Acceptance Criteria:

G Consistent with GALL Report G Exception G Enhancement G DifferenceIdentified Discussion:7. Corrective Action: ___ Consistent with 10 CFR 50, Appendix B8. Confirmation Process: ___ Consistent with 10 CFR 50, Appendix B

9. Administrative Controls: ___ Consistent with 10 CFR 50, Appendix B10. Operating Experience:B. FSAR supplement review: (Include any commitments.)C.Remarks and questions:

D.References/documents used: (Include number designation, full title, revisionnumber, date, and page numbers, and ADAMS accession number.)E.Applicant contact:Project team member: __________________________________ Date: ______________

James A. FitzPatrick Nuclear Power Plant AMP and AMR Audit and Review Plan G-1APPENDIX GPLANT-SPECIFIC AMP AUDIT/REVIEW WORKSHEETThe worksheet provided in this appendix provides, as an aid for the reviewer, a process fordocumenting the basis for the assessments concerning individual program elements and sub-elements contained in Branch Technical Position RLSB-1 "Aging Management Review -

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

James A. FitzPatrick Nuclear Power Plant AMP and AMR Audit and Review Plan G-2Plant-Specific AMP Audit/Review Worksheet AMP Title: ______________________________________________________________

Appendix Subsection: ____________________________________________________A.Element Review and Audit1.Scope of Program:

___ Consistent with SRP-LR____ Exception____ Difference Identified Discussion:SRP CriteriaLRA AMPComment*2.Preventive Action:

___ Consistent with SRP-LR____ Exception____ Difference Identified Discussion:SRP CriteriaLRA AMPComment*3.Parameters Monitored/Inspected:

___ Consistent with SRP-LR____ Exception____ Difference Identified Discussion:SRP CriteriaLRA AMPComment*4.Detection of Aging Effects

___ Consistent with SRP-LR____ Exception____ DifferenceIdentified Discussion: SRP CriteriaLRA AMPComment*

James A. FitzPatrick Nuclear Power Plant AMP and AMR Audit and Review Plan G-35.Monitoring and Trending___ Consistent with SRP-LR____ Exception____ Difference Identified Discussion:SRP CriteriaLRA AMPComment*6.Acceptance Criteria___ Consistent with SRP-LR____ Exception____ Difference Identified Discussion:SRP CriteriaLRA AMPComment*7.Corrective Action:___ Consistent with 10 CFR 50, Appendix B8.Confirmation Process:___ Consistent with 10 CFR 50, Appendix B9.Administrative Controls:___ Consistent with 10 CFR 50, Appendix B10.Operating Experience:

___ Consistent with SRP-LR____ Exception____ Difference Identified Discussion:SRP CriteriaLRA AMPComment**Consistent or technical basis for acceptance exception or differenceB.FSAR supplement review: (Include any committments.)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: ______________

James A. FitzPatrick Nuclear Power Plant AMP and AMR Audit and Review Plan H-1Appendix HAMR Comparison Worksheets James A. FitzPatrick Nuclear Power Plant AMP and AMR Audit and Review Plan H-2JAFNPP 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 itemsapplicable to BWRs in Table 1 were reviewed and are addressed in the following table.

Item No.Further Evaluation RecommendedDiscussionAudit Remarks (Document all questions for applicant here):

NumberQuestion for applicant (draft per RAI guidance)Response (with date) References/Documents Used:

1.

2.

3.

4.

James A. FitzPatrick Nuclear Power Plant AMP and AMR Audit and Review Plan H-3JAFNPP 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 were reviewed for: 1) consistency with NUREG-1801, Volume 2tables, and 2) adequacy of the aging managing programs. All items in the Table 2 of the system named above areacceptable with the exception of items in boldface type. (Reviewers need not duplicate information in the 2nd-5th columns thatare reflected in the discussion/draft audit report.)

LRAPage No.ComponentTypeMaterialEnvironmentAging EffectNote:Discussion (draft as SER Input)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.

James A. FitzPatrick Nuclear Power Plant AMP and AMR Audit and Review PlanI-1APPENDIX IACRONYMS, ABBREVIATIONS, AND INITIALISMSADAMSAgencywide Documents Access and Management SystemAMPaging management program AMRaging management review ASMEAmerican Society of Mechanical Engineers BNLBrookhaven National Laboratory BTPBranch Technical Position CLBcurrent licensing basis DCIDivision of Component Integrity DEDivision of Engineering DIPMDivision of Inspection Program Management DLRDivision of License Renewal FSARfinal safety analysis report GALLGeneric Aging Lessons Learned ISGinterim staff guidance JAFNPPJames A. Fitzpatrick Nuclear Power Plant LRAlicense renewal application NEINuclear Energy Institute NRCNuclear Regulatory Commission NRRNRC Office of Nuclear Reactor Regulation NUREGNRC technical report designation RAIrequest for additional information RLRCLicense Renewal Branch C RLSBLicense Renewal and Standardization Branch TLAAtime-limited aging analyses SCstructures and components SERsafety evaluation report SRP-LRstandard review plan for license renewal SSCstructure, system, and component James A. FitzPatrick Nuclear Power Plant AMP and AMR Audit and Review PlanI-2TLAAtime- limited aging analysisUFSARupdated final safety analysis report