ML061020366

2006/04/11-License Renewal Audit and Review Plan for Plant Aging Management Programs and Reviews for the Vermont Yankee Nuclear Power Station Docket No. 50-271

ML061020366
Person / Time
Site:	Vermont Yankee File:NorthStar Vermont Yankee icon.png
Issue date:	04/11/2006
From:	Information Systems Labs
To:	NRC/NRR/ADRO/DLR/RLRC
Morgan M, NRR/NRC/DRIP/RLEP, 415-2232
References
%dam200611, DR-03-05-026
Download: ML061020366 (96)

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Audit and Review Plan forPlant Aging Management Programsand ReviewsVermont Yankee Nuclear Power StationDocket No.: 50-271April 11, 2006Revision 0Prepared byInformation Systems Laboratories, Inc.11140 Rockville PikeRockville, MD 20852Contract No. DR-03-05-026Prepared forLicense Renewal Branch CDivision of License RenewalOffice of Nuclear Reactor RegulationU.S. Nuclear Regulatory CommissionWashington, D.C. 20555-0001 iiTable of Contents1. Introduction

.............................................................12. Background

.............................................................23. Objectives..............................................................4

4. Summary of Information Provided in the License Renewal Application

................64.1 Aging Management Review Results

....................................64.2 Time-Limited Aging Analyses.........................................85. Overview of Audit, Review, and Documentation Procedure.......................115.1 Aging Management Programs.......................................115.2 Aging Management Reviews........................................115.3 Time-Limited Aging Analyses........................................12 5.4 NRC-Approved Precedents.........................................135.5 UFSAR Supplement Review........................................135.6 Documents Reviewed by the Project Team.............................14 5.7 Public Exit Meeting................................................14 5.8 Documentation Prepared by the Project Team..........................145.8.1 Audit and Review Plan......................................145.8.2 Worksheets..............................................145.8.3 Questions...............................................14 5.8.4 Work Packages...........................................155.8.5 Request for Additional Information............................155.8.6 Audit and Review Report....................................155.8.7 Safety Evaluation Report Input...............................156. Planning, Audit, Review, and Documentation Procedure.........................156.1 Planning Activities................................................166.1.1 Schedule for Key Milestones and Activities......................166.1.2 Work Assignments.........................................16 6.1.3 Training and Preparation....................................166.2 Aging Management Program Audits and Reviews........................176.2.1 Types of AMPs...........................................17 6.2.2 Scope of AMP Program Elements to be Audited And Reviewed......176.2.3 Plant AMPs that are Consistent with the GALL Report.............176.2.4 Plant-Specific AMPs.......................................196.3 AMR Audits and Reviews...........................................216.3.1 Plant AMRs that are Consistent with the GALL Report.............216.3.2 AMRs Based on NRC-Approved Precedents.....................246.4 Time-Limited Aging Analyses (TLAA) Audits and Reviews.................256.4.1 Identify Generic TLAA Issues................................256.4.2 Reactor Vessel Neutron Embrittlement Analyses.................27 6.4.3 Metal Fatigue Analyses.....................................306.4.4 Environmental Qualification Analyses for Electrical Components.....32 iii6.4.5 Concrete Containment Tendon Prestress Analysis................346.4.6 Containment Liner Plate, Metal Containment, and Penetrations FatigueAnalyses...............................................366.4.7 Other Plant-Specific TLAAs..................................386.5 Audit and Safety Review Documentation...............................406.4.1 Audit and Review Report....................................406.4.2 Safety Evaluation Report Input...............................436.5 Documents Reviewed and Document Retention......................48Appendix A Project Team Members..........................................A-1Appendix B RLRC Schedule for LRA Safety Review..............................B-1Appendix C Aging Management Program Assignments...........................C-1Appendix D Aging Management Review Assignments............................D-1Appendix E Time-Limited Aging Analyses Review Assignments.....................E-1Appendix F Consistent with GALL Report AMP Audit/Review Worksheet..............F-1Appendix G Plant-Specific AMP Audit/Review Worksheet.........................G-1Appendix H Aging Management Review Worksheets.............................H-1Appendix I Abbreviations and Acronyms.......................................I-1TablesTable 1. Aging Management Program Element Descriptions........................49Table 2. Notes for License Renewal Application Tables 3.X.2-Y......................50FiguresFigure 1. Audit of AMPs That Are Consistent With the GALL Report..................51Figure 2. Audit of Plant-Specific AMPs.........................................52 Figure 3. Review of AMRs That Are Consistent With the GALL Report.................53Figure 4. Review of AMRs Using NRC-Approved Precedents........................54Figure 5. Review of TLAAs and Exemptions (from NEI 95-10, Revision 6)..............55 1Audit and Review Plan for Plant Aging Management Programs and ReviewsVermont Yankee Nuclear Power Stations1. IntroductionBy letter dated January 27, 2006 (Agencywide Documents Access and Management System[ADAMS] Accession Number ML060300082), Entergy Nuclear Vermont Yankee, LLC (Entergy VY), the applicant, submitted to the U.S. Nuclear Regulatory Commission (NRC) its applicationfor renewal of Operating License DPR-28 for Vermont Yankee Nuclear Power Station (VYNPS)

(ML060300085). The applicant requested renewal of its operating license for an additional 20 years beyond the 40-year current license term.In support of the staff's safety review of the license renewal application (LRA) for VYNPS, theDivision of License Renewal (DLR), License Renewal Branch C (RLRC), will lead a project teamthat will audit and review aging management reviews (AMRs), aging management programs(AMPs), and time-limited aging analyses (TLAAs) developed by the applicant to support its LRA for VYNPS. The project team will incl ude NRC staff and contractor personnel provided byInformation Systems Laboratories, Inc. (ISL), RLRC's technical contractor. Appendix A,"Project Team Members," lists the project team members. This document is the RLRC plan for auditing and reviewing of assigned aging management reviews, aging management programs, and time-limited aging analysis for VYNPS.The project team will audit and review its assigned AMRs, AMPs and TLAAs against 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 Revision 1 of NUREG-1800, "Standard Review Plan for Review of License RenewalApplication for Nuclear Power Plants" (SRP-LR); the guidance provided in Revision 1 of NUREG-1801, "Generic Aging Lessons Learned (GALL) Report," and this audit and reviewplan. In the following sections of this document, references to NUREG-1800 and NUREG-1801will be to the Revision 1 versions of these documents. For the scope of work defined in thisaudit and review plan, the project team will determine that the applicant's aging managementactivities and programs will adequately manage the effects of aging on structures andcomponents, so that their intended functions will be maintained consistent with the VYNPScurrent licensing basis (CLB) for the period of extended operation.The project team will perform its work at NRC Headquarters, Rockville, Maryland; at ISL'soffices in Rockville, Maryland; and at the VYNPS site near Brattleboro, Vermont. The projectteam will perform its work in accordance with the schedule shown in Appendix B, "RLRCSchedule for LRA Safety Review." The project team will conduct a public exit meeting at theapplicant's offices in Brattleboro, Vermont, after it completes its on-site work. This plan includes the following information:Introduction and Backgr ound. 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 describedin this plan.

2Objectives. The objectives of the audits and reviews addressed by this auditand review plan.Summary of Information Provided in License Renewal Application. Description of the information contained in the license renewal application forVYNPS that is applicable to this plan.Overview of the Audit, Review, and Documentation Procedure. Summary ofthe process that the project team will follow to conduct its audit and review of theVYNPS LRA.Planning, Audit, Review, and Documentation Procedure. The procedure thatthe project team will use to plan and schedule its work, to audit and review theVYNPS LRA information that is within its scope of review, and to document the results of its work.Appendices. Supporting information. The project team members are shown inAppendix A and the schedule is shown in Appendix B. The project team's workassignments are shown in Appendices C, D and E. Appendices F, G and H are the worksheets that the individual project team members use to document theresults of their audit and review audit work. The application of these worksheets is discussed in Section 6 of this audit and review plan. Appendix I is a list of the abbreviations and acronyms used in this audit and review plan.2. Backgr oundIn 10 CFR 54.4, the scope of license renewal is defined as those systems, structures 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 forfire protection, environmental qualification, pressurized thermal shock, anticipated transientswithout scram, and station blackout. An applicant for a renewed license must review all SSCs within the scope of license renewal to identify those structures and components (SCs) subject to an AMR. SCs subject to an AMR are those that perform an intended function without moving parts or without a change in configuration or properties (passive), and that are not subject to replacement based on qualified life or specified time period (long-lived). Pursuant to 10 CFR 54.21(a)(3), an applicant for a renewed license must demonstrate that the effects of aging willbe managed in such a way that the intended function or functions of those SCs will bemaintained, consistent with the CLB, for the period of extended operation.License renewal also requires the identification and updating of the TLAAs. During the designphase for a plant, certain assumptions are made about the length of time the plant can operate.

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

3In addition, 10 CFR 54.21(d) requires that the applicant submit a supplement (docketed lettersubmitted under oath and affirmation) to the final safety analysis report (FSAR) that contains a summary description of the programs and activities that it credited to manage the effects of aging and the evaluation of time-limited aging analyses for the extended period of operation.The SRP-LR provides staff guidance for reviewing applications for license renewal. The GALLReport is a technical basis document. It summarizes staff-approved AMPs for the aging management of a large number of SCs that are subject to an AMR. It also summarizes the aging management evaluations, programs, and activities credited for managing aging of most of the SCs used by commercial nuclear power plants, and serves as a reference for both the applicant and staff reviewers to quickly identify those AMPs and activities that the staff has determined will provide adequate aging management during the period of extended operation. If an applicant commits to implementing these staff-approved AMPs, the time, effort, and resources used to review an applicant's LRA will be greatly reduced, thereby improving theefficiency and effectiveness of the license renewal review process. The GALL Report identifies (1) SSCs, (2) component materials, (3) environments to which the components are exposed, (4) the aging effects/aging mechanisms associated with the materials and environments, (5) AMPs that are credited with managing the aging effects, and (6) recommendations for further applicant evaluations of aging effects and their management for certain component types.The GALL Report is treated in the same manner as an NRC-approved topical report that 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 makingthis determination, the staff considers whether the applicant has identified specific programsdescribed and evaluated in the GALL Report but does not conduct a re-review of the substanceof the matters described in the GALL Report. Rather, the staff determines that the applicantestablished that the approvals set forth in the GALL Report apply to its programs.If an applicant takes credit for a GALL Report program, it is incumbent on the applicant toensure that its plant program addresses all ten program elements of the referenced GALLReport program. These elements are described in the SRP-LR, Appendix A.1, "Aging Management Review - Generic (Branch Technical Position RLSB-1)." In addition, the conditions at the plant must be bounded by the conditions for which the GALL Report program was evaluated. The applicant must certify in its LRA that it completed the appropriateverifications and that those verifications are documented and retained by the applicant in an auditable form.The SRP-LR also provides staff guidance for reviewing time-limited aging analyses. Pursuantto 10 CFR 54.21(c)(1), a license renewal application is required to provide a list of TLAAs, as defined in 10 CFR 54.3. In addition, the applicant must provide a list of plant-specific exemptions granted under 10 CFR 50.12 that are based on TLAAs. The number and type of TLAAs vary depending on the plant-specific CLB. All six criteria set forth in 10 CFR 54.3 must be satisfied to conclude that a calculation oranalysis is a TLAA. Pursuant to 10 CFR 54.3, TLAAs are those licensee calculations and analyses that:

41.Involve systems, structures, and components within the scope of licenserenewal, 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, forexample, 40 years;4.Were determined to be relevant by the licensee 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), asdelineated in 10 CFR 54.4(b); and6.Are contained or incorporated by reference in the CLB.Finally, the applicant must demonstrated that the TLAAs remain valid for the period of extendedoperation; the TLAAs have been projected to the end of the period of extended operation; orthe aging effects of aging on the intended function(s) will be adequately managed for the periodof 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 omitany TLAAs, as defined in 10 CFR 54.3.3. Objectives The overall objective of the audit and review described in this audit and review plan is todetermine compliance with 10 CFR 54.21(a)(3) and 10 CFR 54.21(c)(1). Therefore, the audit and review process helps ensure that for each structure and component within the scope of the project team's review, the effects of aging will be adequately managed so that the intendedfunction(s) will be maintained consistent with the CLB for the period of extended operation.The audit and review procedure for VYNPS is described in Sections 5 and 6 of this audit andreview plan. It is intended to accomplish the following objectives:For VYNPS AMPs that the applicant claims are consistent with GALL ReportAMPs, determine that the plant AMPs contain the program elements of thereferenced GALL Report AMP and that the conditions at the plant are boundedby the conditions for which the GALL Report AMPs were evaluated.For VYNPS AMPs that the applicant claims are consistent with GALL ReportAMPs with exceptions, determine that the plant AMPs contain the programelements of the referenced GALL Report AMPs and that the conditions at the plant are bounded by the conditions for which the GALL Report AMPs were evaluated. In addition, determine and evaluate that the applicant hasdocumented an acceptable technical basis for each exception.

5For VYNPS AMPs that the applicant claims will be consistent with GALL ReportAMPs after specified enhancements are implemented, determine that the plantAMPs, with the enhancements, will be consistent with the referenced GALLReport AMPs. In addition, determine that the applicant identified the enhancements as commitments in the Updated Final Safety Analysis Report (UFSAR) or other docketed correspondence.For plant-specific VYNPS AMPs determine that these AMPs are acceptable onthe basis of a technical review.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 thebasis of a technical review.For AMR line items that the applicant claims consistent with AMR line items thatthe staff has previously approved for another plant, determine that these AMR line items are acceptable on the basis of a technical review.For AMR line items for which the GALL Report recommends further evaluation,determine that the applicant has addressed the further evaluation, andevaluating the AMRs in accordance with the SRP-LR.For TLAAs, determine that the applicant has properly identified the TLAAs.TLAAs are certain plant-specific safety analyses that are based on an explicitly assumed 40-year plant life (for example, aspects of the reactor vessel design).

Pursuant to 10 CFR 54.21(c)(1), a license renewal applicant is required to provide a list of TLAAs, as defined in 10 CFR 54.3. The area relating to the identification of TLAAs is reviewed. TLAAs may have developed since issuance of a plant's operating license. As indicated in 10 CFR 54.30, the adequacy of theplant's CLB, which includes TLAAs, is not an area within the scope of the license renewal review. Any question regarding the adequacy of the CLB must be addressed under the backfit rule (10 CFR 50.109) and is separate from the license renewal process.Determine that the applicant has demonstrated that (1) the TLAAs remain validfor the period of extended operation; (2) the TLAAs have been projected to theend 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 extendedoperation.

64. Summary of Information Provided in the License Renewal Application4.1 Aging Management Review ResultsThe VYNPS LRA closely follows the standard LRA format presented in Revision 6 of NuclearEnergy Institute (NEI) 95-10, "Industry Guidelines for Implementing the Requirements of 10 CFR Part 54 - The License Renewal Rule." Section 3 of the VYNPS LRA provides the results of the aging management review for structures and components that the applicant identified asbeing subject to aging management review. Section 4 VYNPS LRA addressed time-limited aging analyses.VYNPS LRA Table 3.0-1, Table 3.0-2, and Table 3.0-3 provide descriptions of the subject(s) forthese table(s) - environments used in the AMRs to determine the aging effects requiringmanagement. 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 thesystem/component group number (see table below), and "1" indicates it is a Table 1 type. Forexample, in the reactor coolant system subsection of the VYNPS LRA Section 3, this is Table3.1.1, and in the engineered safety features subsection of VYNPS LRA Section 3, this is Table 3.2.1. For ease of discussion, these table types will hereafter be referred to as "Table 1."

These tables are derived from the corresponding tables in NUREG-1801, Volume 1, andpresent summary information from the AMRs.XDefinition1Reactor Vessel, Internals and Reactor Coolant System2Engineered Safety Features 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 thesystem/component group number, "2" indicates it is a Table 2 type, and "Y" indicates thesubgroup number within group "X". For example, within the reactor coolant system, the AMRresults for the reactor vessel are presented in VYNPS LRA Table 3.1.2-1, and the results for the reactor vessel internals are presented in VYNPS LRA Table 3.1.2-2. In the engineered safety features, the residual heat removal system results are presented in Table 3.2.2-1 of theVYNPS LRA, and the core spray system is in Table 3.2.2-2 of the VYNPS LRA. For ease ofdiscussion, these table types will hereafter be referred to as "Table 2." These tables present the results of the AMRs.VYNPS LRA Tables 3.1.1 through 3.6.1 (Table 1 types) provide a summary comparison of howthe VYNPS AMR results align with Tables 1 through 6 of the GALL Report, Volume 1. These VYNPS LRA tables are essentially the same as Tables 1 through 6 of the GALL Report, 7Volume 1, except that the "Type" column has been replaced by an "Item Number" column, theGALL Volume 2 Item Number column has been deleted, and a "Discussion" column has been added. The "Item Number" column provides a means to cross-reference between VYNPS LRA Table 3.X.2-Y (Table 2 type) and VYNPS LRA Table 3.X.1 (Table 1 type). The "Discussion" column includes further information. The following are examples of information that might be contained within the "Discussion" column:Any "Further Evaluation Recommended" information or reference to the locationof that informationThe name of a plant-specific program being usedExceptions to the GALL Report recommendationsA discussion of how the line item is consistent with the corresponding line item inthe GALL Report, when it may not be intuitively obviousA discussion of how the line item differs from the corresponding line item in theGALL Report, when it may appear to be consistent.VYNPS LRA Table 2 types provide the detailed results of the AMRs for those SCs that aresubject to an aging management review. There is a Table 2 for each subgroup within the six system/component groups. For example, the engineered safety features system groupcontains tables specific to residual heat removal, core spray, automatic depressurization, high pressure coolant injection, reactor core isolation cooling, standby gas treatment, and primary containment penetrations. Table 2 of the VYNPS LRA consists of the following nine columns.Component Type. Column 1 identifies the component types that are subject toan AMR. The component types are listed in alphabetical order. In the structural tables, component types are sub-grouped by material.Intended Function. Column 2 identifies the license renewal intended functionsfor the listed component types. Definitions and abbreviations of intended functions are listed in Table 2.0-1 in Section 2 of the VYNPS LRA.Material. Column 3 lists the particular materials of construction for thecomponent type being evaluated.Environment. Column 4 lists the environment to which the component types areexposed. Internal and external service environments are indicated. A description of these environments is provided in VYNPS LRA Table 3.0-1, Table 3.0-2, and Table 3.0-3 for mechanical, structural, and electrical components, respectively.Aging Effect Requiring Management. Column 5 lists the aging effects identifiedas requiring management for the material and environment combinations of each component type.Aging Management Programs. Column 6 lists the programs used to manage theaging effects requiring management.

8GALL Report (Vol. 2) Item. Each combination of the following factors listed inLRA Table 2 is compared to the GALL Report to identify consistencies:

component type, material, environment, aging effect requiring management, and aging management program. Column 7 documents identified consistencies by noting the appropriate GALL Report item number. If there is no corresponding item number in the GALL Report for a particular combination of factors, column 7 is left blank.LRA Table 1 Item. Each combination of the following that has an identifiedGALL Report item number also has a Table 1 line item reference number:

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

column 8 is left blank.Notes. Column 9 contains notes that are used to describe the degree ofconsistency with the line items in the GALL Report.4.2 Time-Limited Aging Analyses The VYNPS LRA closely follows the standard LRA format presented in Revision 6 of NEI 95-10,"Industry Guidelines for Implementing the Requirements of 10 CFR Part 54 - The License Renewal Rule." Section 4 of the VYNPS LRA addresses time-limited aging analyses. In Section 4.1.1, the VYNPS LRA states that the calculations and evaluations that could potentiallymeet the six criteria of 10 CFR 54.3 were identified by searching CLB documents including the following:Technical SpecificationsUFSARdocketed licensing correspondencefire protection program documentsNRC safety evaluation reportsBWRVIP documentsIn Section 4.1, the VYNPS LRA states that as required by 10 CFR 54.21(c)(1), an evaluation ofVYNPS-specific time-limited aging analyses must be performed to demonstrate that:(i)The analyses remain valid for the period of extended operation; (ii)The analyses have been projected to the end of the period of extendedoperation; or(iii)The effects of aging on the intended functions(s) will be adequately managed forthe period of extended operation.In the VYNPS LRA, the applicant summarized the results of the above evaluations in Table4.1-1. These evaluations are discussed in subsequent sections of VYNPS LRA Section 4.

9Following the section identifying the TLAAs, the VYNPS LRA next includes a section identifyingany exemptions. 54.21(c) also requires that the application for a renewed license includes a listof plant-specific exemptions granted pursuant to 10 CFR 50.12 and in effect that are based ontime-limited aging analyses as defined in 10 CFR 54.3. The VYNPS performed this by reviewing VYNPS docketed correspondence which identified VYNPS exemptions. The results of this review determined that no VYNPS exemptions depend on time-limited aging analyses.The VYNPS LRA next includes a separate section for each of the identified TLAAs within theoutline of the corresponding NUREG-1800 TLAA category. The TLAA categories are outlinedin the next table.TLAA DescriptionResolution OptionSectionReactor Vessel Neutron Embrittlement Analyses 4.2Pressure-temperature limitsAnalyses remain valid10 CFR 54.21(c)(1)(i) 4.2.2Charpy upper-shelf energy Analyses projected10 CFR 54.21(c)(1)(ii) 4.2.3Adjusted reference temperatureAnalyses projected10 CFR 54.21(c)(1)(ii) 4.2.4Reactor vessel circumferential weldsinspection reliefAnalysis projected10 CFR 54.21(c)(1)(ii) 4.2.5Reactor vessel axial welds failureprobabilityAnalysis projected10 CFR 54.21(c)(1)(ii) 4.2.6Metal Fatigue Analyses 4.3Class 1 fatigueAnalyses remain valid10 CFR 54.21(c)(1)(i)

OR Aging effect managed 10 CFR 54.21(c)(1)(iii) 4.3.1Non-Class 1 fatigueAnalyses remain valid10 CFR 54.21(c)(1)(i) 4.3.2Effects of reactor water environmenton fatigue lifeAnalyses remain valid10 CFR 54.21(c)(1)(i)

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

OR Aging effect managed 10 CFR 54.21(c)(1)(iii) 4.3.3 TLAA DescriptionResolution OptionSection 10Environmental Qualification Analysesfor Electrical ComponentsAging effect managed10 CFR 54.21(c)(1)(iii) 4.4Containment Liner Plate, Metal Containment, and PenetrationsFatigue Analyses 4.6Fatigue of the torus Analysis projected10 CFR 54.21(c)(1)(ii) 4.6.1Fatigue of safety relief valve (SRV)discharge pipingAnalysis remains valid10 CFR 54.21(c)(1)(i)

AND Analysis projected 10 CFR 54.21(c)(1)(ii) 4.6.2Fatigue of other torus-attached pipingAnalysis projected10 CFR 54.21(c)(1)(ii) 4.6.3Other TLAA 4.7Reflood thermal shock of the reactorvessel internalsAnalysis remains valid10 CFR 54.21(c)(1)(i) 4.7.1TLAA in BWRVIPs4.7.2BWRVIP-05, RPV circumferentialwelds analysisUpdated by BWRVIP-74. SeeBWRVIP-74 entry.

4.7.2.1BWRVIP-25, core plate rim holddownbolts loss of preload analysisAnalysis projected10 CFR 54.21(c)(1)(ii) 4.7.2.2BWRVIP-38, shroud support fatigueanalysisAnalysis remains valid10 CFR 54.21(c)(1)(i) 4.7.2.3BWRVIP-47, lower plenum fatigueanalysisAnalysis remains valid10 CFR 54.21(c)(1)(i) 4.7.2.4BWRVIP-48, vessel ID attachmentwelds fatigue analysisAnalysis remains valid10 CFR 54.21(c)(1)(i) 4.7.2.5BWRVIP-49, instrument penetrationsfatigue analysisAnalysis projected10 CFR 54.21(c)(1)(ii) 4.7.2.6BWRVIP-74, reactor vesselP/T curves analysis Fatigue analysis CVUSE analysis Circ/Axial welds analysisAddressed in Section 4.2.2Addressed in Section 4.3.1 Addressed in Section 4.2.3 Addressed in Sections 4.2.5 and 4.2.6 4.7.2.7 TLAA DescriptionResolution OptionSection 11BWRVIP-76, core shroud Analysis remains valid10 CFR 54.21(c)(1)(i) 4.7.2.85. Overview of Audit, Review, and Documentation ProcedureThe project team will follow the process specified in Section 6 of this audit and review plan toperform its audits and reviews and to document the results of its work. The process is summarized below.5.1 Aging Management Programs Table 1 of this audit and review plan summarizes the ten program elements that comprise anaging management program. For the VYNPS AMPs for which the applicant claimed consistency with the AMPs included in the GALL Report, the project team will review theVYNPS AMP descriptions and compare program elements for the VYNPS AMPs to the corresponding program elements for the GALL Report AMPs. The review will be documentedusing the worksheet as discussed in Appendix F. The project team will determine that theVYNPS AMPs contain the program elements of the referenced GALL Report AMP and that the conditions at the plant are bounded by the conditions for which the GALL Report program was evaluated. The Division of Engineering will review and determine the adequacy of theapplicant's 10 CFR 50, Appendix B Program. Other aspect of these program elements will bereview by the project team.For VYNPS AMPs that have one or more exceptions and/or enhancements, the project teamwill review each exception and/or enhancement to determine whether the exception and/orenhancement is acceptable and whether the VYNPS AMP, as modified by the exception and/orenhancement, would adequately manage the aging effects for which it is credited. The review will be documented using the worksheet as discussed in Appendix F. In some cases, theproject team will identify differences that the applicant did not identify between the VYNPSAMPs credited by the applicant and the GALL Report AMPs. The review will be documentedusing the worksheet as discussed in Appendix F. In these cases, the project team will reviewthe difference to determine whether or not it is acceptable and whether or not the VYNPS AMP,as modified with the difference, would adequately manage the aging effects.For those VYNPS AMPs that are not included in the GALL Report (i.e., plant-specific AMPs, noprecedent), the project team will review the VYNPS AMP against the ten program elementsdefined in Appendix A of the SRP-LR. The review will be documented using the works heetshown in Appendix G. The Division of Engineering will review and determine the adequacy ofthe applicant's 10 CFR 50, Appendix B Program. Other aspect of these program elements willbe review by the project team. On the basis of its reviews, the project team will determine whether these AMPs will manage the aging effects for which they are credited.5.2 Aging Management Reviews The AMRs in the GALL Report fall into two broad categories: (1) those that the GALL Reportconcludes are adequate to manage aging of the components referenced in the GALL Report, 12and (2) those for which the GALL Report concludes that aging management is adequate, butfurther 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 theapplicant to be consistent with the GALL Report are indeed consistent with the GALL Report,and (2) whether the plant-specific AMRs (includes formerly past precedent material) are technically acceptable and applicable based on a technical review by the project team. For component groups evaluated in the GALL Report for which the applicant claimed consistencywith the GALL Report, and for which the GALL Report recommends further evaluation, the project team will review the applicant's evaluation to determine if it adequately addressed theissues for which the GALL Report recommended further evaluation.In addition, the project team will also review the AMRs that the applicant claims that are notapplicable to its plant.5.3 Time-Limited Aging Analyses The TLAAs in the VYNPS LRA fall into the broad category of those that are consistent with theNUREG-1800 TLAA categories. There are no plant-specific exemptions identified in theVYNPS 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(a).(2)consider the effects of aging.

(3)involve time-limited assumptions defined by the current operating term(40 years).(4)are determined to be relevant by the applicant in making a safety determination.

(5)involve conclusions, or provide the basis for conclusions, related to the capabilityof the system, structure, and component to perform its intended functions, asdelineated in 10 CFR 54.4(b).(6)are contained or incorporated by reference in the CLB.In addition, the project team will also review the TLAAs to determine if there are emergingissues that should be further evaluated by technical specialists in the NRC Divisions ofComponent 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 effectsof aging on the intended function(s) will be adequately managed for the period of extended 13operation."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 willbe consulted to determine which TLAAs the audit team will be capable of reviewing.Consideration should be given to project team expertise, past precedent, and complexity of the provided analysis. Candidates/Examples for further review by technical specialists could be such as the following:Reactor Vessel Neutron Embrittlement AnalysisEQ for Electrical Equipment (unless audit team is capable)

Intergranular separation in the Heat-Affected Zone (HAZ) of Reactor Vessel Low-Alloy Steel under Austenitic SS Cladding Silting of the Ultimate Heat Sink5.4 NRC-Approved Precedents To help facilitate the project team staff review of its LRA, an applicant may reference NRC-approved precedents to demonstrate that its non-GALL programs correspond to reviewsthat the staff had approved for other plants during its review of previous applications for licenserenewal. When an applicant elects to provide precedent information, the project team willreview and determine whether the material presented in the precedent is applicable to the applicant's facility, determine whether the plant program is bounded by the conditions for whichthe precedent was evaluated and approved, and determine that the plant program contains theprogram elements of the referenced precedent. In general, if the project team determines that these conditions are satisfied, it will use the information in the precedent to frame and focus itsreview of the applicant's program.It is important to note that precedent information is not a part of the LRA; it is supplementaryinformation voluntarily provided by the applicant as a reviewer's aid. The existence of aprecedent, in and of itself, is not a sufficient basis to accept the applicant's program. Rather,the precedent facilitates the review of the substance of the matters described in the applicant'sprogram. As such, in its documentation of its reviews of programs that are based on precedents, the precedent information is typically implicit in the evaluation rather than explicit. If the project team determines that a precedent identified by the applicant is not applicable tothe particular plant program for which it is credited, it may refer the program to the Office ofNuclear Reactor Regulation (NRR) DE for review in the traditional manner, i.e., as described inthe SRP-LR, without consideration of the precedent information.5.5 UFSAR Supplement Review In accordance with the SRP-LR, for the AMRs and associated AMPs and the TLAAs that it willreview, the project team will review the UFSAR supplement that summarizes the applicant'sprograms 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 activitiesmade by the applicant and determine that they are acceptable for the stated purpose. In 14addition, the project team will determine that the applicant identified the enhancements ascommitments in the Updated Final Safety Analysis Report (UFSAR) or other docketed correspondence.5.6 Documents Reviewed by the Project Team In performing its work, the project team will rely heavily on the VYNPS LRA, the audit andreview plan, the SRP-LR, and the GALL Report. The project team will also examine theapplicant's precedent review documents, its AMP, AMR, and TLAA basis documents (catalogs of the documentation used by the applicant to develop or justify its AMPs, AMRs, and TLAAs),

and other applicant documents, including selected implementing documents, to determine thatthe applicant's activities and programs will adequately manage the effects of aging onstructures and components. To review the TLAAs, the review team will also study theappropriate sections in the VYNPS UFSAR, as well as referring back to appropriate sections in the SRP-LR, GALL Report, and NEI 95-10, Revision 6.5.7 Public Exit Meeting After it completes its audits and reviews, the project team will hold a public exit meeting todiscuss the scope and results of its audits and reviews.5.8 Documentation Prepared by the Project Team The project team will prepare an audit and review plan, worksheets, work packages, requestsfor additional information (RAIs), an audit and review report, and a safety evaluation report (SER) input. The project team will also prepare questions during site visits and will track theapplicant's responses to these questions.5.8.1 Audit and Review Plan The project team leader will prepare a plant-specific audit and review plan as described herein.5.8.2 Worksheets Each project team member will document the results of his or her work on a variety ofworksheets. The worksheets are discussed in Appendix F, "Consistent with GALL Report AMP Audit/Review Worksheet;" Appendix G, "Plant-Specific AMP Audit/Review Worksheet;" and Appendix H, "Aging Management Review Worksheets." The use of the worksheets is described in Section 6 of this audit and review plan.5.8.3 Questions As specified in Section 6 of this audit and review plan, the project team will ask the applicantquestions, while on-site, as appropriate, to facilitate its audit and review activities. The projectteam will also track and review the applicant's answers to these questions. If an applicantresponse is necessary to support a finding made by the project team, the applicant may voluntarily submit the response to the NRC under oath and affirmation. As an alternate, theproject team may use the RAI process to obtain this response under oath and affirmation.

155.8.4 Work PackagesDuring the audit and review process, the project team leader, in conjunction with the NRClicense renewal project manager, will assemble work packages for any work that the projectteam will refer to the NRR DE for review. Each work pack age will include a work request andany applicable background information on the review item that was gathered by the project team.5.8.5 Request for Additional Information The audit and review process described in this audit and review plan is structured to resolve asmany questions as possible during the on-site visits. As examples, the on-site visits are used to obtain clarifications about the VYNPS LRA and explanations as to where certain information may be found in the VYNPS LRA or its associated documents. Nevertheless, there may be occasions where an RAI is appropriate to obtain information to support an SER finding. The need for RAIs will be determined by the project team leader through discussions with theindividual 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 theRAI. RAIs will include the technical and regulatory basis for requesting the information. After the project team receives a response to an RAI from the applicant, the project team leaderwill provide the response to the project team member who prepared the RAI. The project teamwill review the response and determine if it resolves the issue that was the reason for the RAI. The project team will document the disposition of the RAI in the audit and review report (unlessthe report was issued before the RAI response was received) and in the SER input. If the audit and review report was issued before the applicant submitted its response to an RAI, the review of the project team's evaluation of the response will be documented in the SER related to theVYNPS LRA.5.8.6 Audit and Review Report The project team will document the results of its work in an audit and review report. The projectteam will prepare its report as described in Section 6.5.1 of this audit and review plan and thelatest version of the RLRC Guidelines For Preparing Audit and Review Reports

.5.8.7 Safety Evaluation Report Input The project team will prepare SER input, based on the audit and review report, as described inSection 6.5.2 of this plan.6. Planning, Audit, Review, and Documentation Procedure This section of the audit and review plan contains the detailed procedures that the project teamwill follow to plan, conduct, and document its audit and review work.

166.1 Planning Activities6.1.1 Schedule 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 renewal decision. Key milestones and activities include, as a minimum:A.receiving the LRA from the applicantB.receiving work split tables from the NRC license renewal project managerC.making individual work assignments D.training project team members E.holding the project team kickoff meeting F.preparing the audit and review plan G.scheduling on-site visits H.scheduling in-office review periods I.preparing questions J.preparing RAIs K.preparing draft and final audit and review report L.preparing draft and final SER inputOn-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.6.1.2 Work Assignments The NRC technical assistance contractor will provide a proposed project team member workassignments to the NRC project team leader. The NRC project team leader will approve allwork assignments. After the audit and review plan is issued, the NRC project team leader mayreassign work as necessary.The NRC technical assistance contractor will develop assignment tables that show whichproject team member will review each of the VYNPS AMPs and AMRs. Appendix A of this auditand review plan shows the project team members. Appendix C shows the project team member assignments for the AMPs, Appendix D of this audit and review plan shows the project team member assignments for the AMRs, and Appendix E shows the project team member assignments for TLAAs.6.1.3 Training and Preparation The training and preparation will include the following:A.A description of the audit and review process.

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

17(1)GALL Report(2)SRP-LR (3)Interim Staff Guidance for License Renewal (ISG-LR)

(4)LRA AMPs (5)LRA TLAAs (6)LRA AMRs (7)Basis documents (catalogs of information assembled by the applicant todemonstrate the bases for its programs and activities)(8)Implementing procedures (9)Operating experience (Licensee Event Reports)

(10)RAIs, audit and review reports, and SERs for other plants (11)Applicant's UFSARC.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 DE and DCI technical reviewers.6.2 Aging Management Program Audits and Reviews6.2.1 Types 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 andreviewing both types of AMPs is presented in the following sections of this audit and review plan.6.2.2 Scope of AMP Program Elements to be Audited And Reviewed Table 1 of this plan shows the ten program elements that are used to evaluate the adequacy ofeach aging management program. These program elements are also presented in Branch Technical Position (BTP) RLSB-1, "Aging Management Review - Generic," in Appendix A of the SRP-LR, and are summarized in the GALL Report.The program elements audited or reviewed is the same for both AMPs that are consistent withthe GALL Report and for plant-specific AMPs. The Division of Engineering will review anddetermine the adequacy of the applicant's 10 CFR 50, Appendix B Program. Other aspects of these program elements will be reviewed by the project team.6.2.3 Plant AMPs that are Consistent with the GALL Report Figure 1, "Audit of AMPs That Are Consistent with the GALL Report," is the process flowchartthat shows the activities and decisions used by the project team to audit and review each plant AMP that the applicant claims is consistent with the GALL Report.

18PreparationA.For the VYNPS AMP being reviewed, identify the corresponding GALL ReportAMP.B.Review the associated GALL Report AMP and identify those elements that willbe audited.C.Identify the documents needed to perform the audit. These may include, but arenot limited to, the following:(1)GALL Report(2)SRP-LR (3)ISG-LR (4)RAIs, audit and review reports, and SERs for similar plants (5)LRA (6)basis documents (7)implementation documents (8)operating experience reports (plant-specific and industry)

(9)applicant's UFSARAudit/ReviewA.Confirm that VYNPS 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 identify any enhancements to the GALL Report AMP?

(3)Are the program elements consistent with the GALL Report AMP?B.If the above questions result in the identification of an exception/enhancement ora difference to the GALL Report AMP, determine whether it is acceptable on the basis of an adequate technical justification.C.If an acceptable basis exists for an exception/enhancement or difference,document the basis in the worksheet and later in the audit and review report and the SER input.D.Review the industry and plant-specific operating experience associated with 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 confirm the effectiveness of aging management programs. The project team members should consider the industry guidance when assessing operating experience and formulating questions for the applicant. The industry guidance (NEI 95-10, Revision 6) is as follows:(1)Plant-Specific Operating Experience with Aging Effects RequiringManagement. The review should assess the operating and maintenance 19history. A review of the prior five to ten years of operating andmaintenance history should be sufficient. The results of the review should confirm consistency with reported industry operating experience.

Differences with previously reported industry experience, such as new aging effects or lack of aging effects, allow for consideration in the plant-specific aging management requirements.(2)Plant-Specific Operating Experience with Existing Aging ManagementPrograms. The operating experience of aging management programs, including corrective actions resulting in program enhancements or additional programs, should be considered. The review should provide objective evidence to support the conclusion that the effects of aging willbe managed so that the intended function(s) will be maintained during theextended 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 changesplant-specific determinations. NUREG-1801 is based upon industryoperating experience prior to its date of issuance. Operating experience after the issuance date of NUREG-1801 should be evaluated anddocumented as part of the aging management review. In particular, generic communications such as a Bulletin or an Information Notice should be evaluated for impact upon the AMP. The evaluation should check for new aging effects or a new component or location experiencing an already identified aging effect.E.If it is necessary to ask the applicant a question to clarify the basis for acceptingthe justification, an exception, or a difference to the program element of theGALL Report, 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 programelement, the applicant may agree to voluntarily submit the required information as a supplement (docketed letter submitted under oath and affirmation) to the VYNPS LRA. If not, the NRC may issue an RAI to obtain the informationAMP Audit WorksheetsDocument the audits/reviews using the worksheet provided in Appendix F, "Consistent withGALL Report AMP Audit/Review Worksheet."6.2.4 Plant-Specific AMPs Figure 2, "Audit of Plant-Specific AMPs," is the process flowchart that shows the activities anddecisions used to audit/review each plant-specific AMP.

20Pre-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 Report(2)SRP-LR (3)ISG-LR (4)RAIs, audit and review reports, and SERs for similar plants (5)LRA (6)basis documents (7)implementation documents (8)operating experience reports (plant-specific and industry)

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

Differences with previously reported industry experience, such as new aging effects or lack of aging effects, allow for consideration in the plant-specific aging management requirements.(2)Plant-Specific Operating Experience with Existing Aging ManagementPrograms. The operating experience of aging management programs, including corrective actions resulting in program enhancements or additional programs, should be considered. The review should provide objective evidence to support the conclusion that the effects of aging willbe managed so that the intended function(s) will be maintained during theextended period of operation. Guidance for reviewing industry operating experience is presented in BTP RLSB-1 in Appendix A.1 of the Branch 21Technical Positions in NUREG-1800.(3)Industry Operating Experience. Industry operating experience and itsapplicability should be assessed to determine whether it changesplant-specific determinations. NUREG-1801 is based upon industryoperating experience prior to its date of issuance. Operating experience after the issuance date of NUREG-1801 should be evaluated anddocumented as part of the aging management review. In particular, generic communications such as a Bulletin or an Information Notice should be evaluated for impact upon the AMP. The evaluation should check for new aging effects or a new component or location experiencing an already identified aging effect.C.If it is necessary to ask the applicant a question to clarify the basis for acceptingthe justification, an exception, or a difference to the program element of theGALL Report, follow the logic process shown in Figure 1.D.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 programelement, the applicant may agree to voluntarily submit the required information as a supplement (docketed letter submitted under oath and affirmation) to the VYNPS LRA. If not, the NRC may issue an RAI to obtain the information.AMP Review WorksheetsDocument the audit/review using the worksheet provided in Appendix G, "Plant-Specific AMPAudit/Review Worksheet."6.3 AMR Audits and Reviews There 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.6.3.1 Plant AMRs that are Consistent with the GALL Report Figure 3, "Review of AMRs That Are Consistent with the GALL Report," is the process flowchartthat shows the activities and decisions used to audit/review each AMR that the applicant claimsis consistent with the GALL Report.PreparationA.For the VYNPS 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 Report AMRs and identify those line items that willbe audited/reviewed in conjunction with each of the VYNPS AMRs.

1 The AMR line item letter notes are based on a letter from A. Nelson, NEI, to P. T. Kuo, NRC, "U.S. NuclearIndustry'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 LRAs by letterdated April 7, 2003, from P.T. Kuo, NRC, to A. Nelson, NEI (ML030990052).

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

22C.Identify the documents needed to perform the review. These may include, butare not limited to, the following:(1)GALL Report(2)SRP-LR (3)ISG-LR (4)RAIs, audit and review reports, and SERs for similar plants (5)LRA (6)basis documents (7)implementation documents (8)operating experience reports (plant-specific and industry)

(9)applicant's UFSAR (10)lessons learned developed by 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 classified as "consistent with the GALL Report," and will be reviewed inaccordance with the guidance contained in this plan.B.The AMR review involves determination that the applicant has satisfied therequirements of 10 CFR 54.21(a)(3). This requirement states that, for "each structure and component [within the scope of license renewal], demonstrate that the effects of aging will be adequately managed so that the intended function(s)will be maintained consistent with the CLB for the extended period of operation."C.Determine compliance by following the process shown in Figure 3. The 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 ,determine if the component is within the scope of the cited plant AMP. Ifthe component is within the scope of the plant AMP, the AMR line item isacceptable. If not acceptable, go to Step (7) below.(3)If Note B applies, review the LRA exceptions and document the basis for 23acceptance in the worksheet, and later in the audit and review report. Ifnot 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)below. 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 (docketed letter submitted under oath and affirmation) to the LRA or the NRC may issue an RAI to obtain the information. The team leader should be consulted if docketed information may be needed.(d)If the applicant's response is relied upon as the basis for a findingmade by the project team, the applicant's response needs to be docketed under oath and affirmation. This may be reached through the applicant voluntarily submitting the response to the

NRC under oath and affirmation, or by the staff using the RAIprocess.(8)Review LRA Table 3.X.1. For AMR line items (Table 1s) that theapplicant claims are not applicable with the GALL Report, determine that these AMR line items are acceptable on the basis of a technical review.AMR Audit/Review WorksheetsDocument the audits/reviews of VYNPS AMRs using the worksheet provided in Appendix H,"Aging Management Review Worksheets." As an alternate, the project team reviewer may document its review electronically in the AMR spreadsheets.

3 Applicant identified NRC-approved precedents are only to be used as an aid for performing AMR audits. The auditconclusions will be based on the technical basis of the AMR and its applicability to the plant being reviewed. It is notacceptable to simply cite the NRC-approved precedent as its basis.

246.3.2 AMRs Based on NRC-Approved PrecedentsFigure 4, "AMR Review Using NRC-Approved Precedent," is the process flowchart that showsthe activities and decisions used to review VYNPS AMRs that the applicant has identified as being consistent with an NRC-approved precedent.

3PreparationIdentify the documents needed to perform the audit/review. These may include, but are notlimited to, the following:(1)GALL Report(2)SRP-LR (3)ISG-LR (4)RAIs and SERs for similar plants (5)LRA (6)basis documents (7)implementation documents (8)operating experience reports (plant-specific and industry)

(9)applicant's UFSAR (10)lessons learned developed by RLRCAudit/ReviewA.The AMR audit/review involves determination that the requirements of10 CFR 54.21(a)(3) are satisfied. This criterion states that, "For each structure and component [within the scope of license renewal], demonstrate that the effects of aging will be adequately managed so that the intended function(s) willbe maintained consistent with the CLB for the period of extended operation."B.For AMRs with an NRC-approved precedent, this may be achieved by answeringthe following questions while following the assessment process shown in Figure 4.(1)Is the precedent appropriate for the VYNPS AMR being reviewed?(2)Is the NRC-approved precedent sufficiently documented or understood totechnically support the adequacy of the VYNPS AMR being reviewed?(3)Is the VYNPS AMR within the bounds of the chosen NRC-approvedprecedent?(4)If any of these questions results in a 'No' answer, then additionalinformation is required to make a determination that the AMR is acceptable.(5)If it is necessary to ask the applicant a question to obtain clarification onthe basis for accepting the VYNPS AMR, the process shown in Figure 4 25should be used.(6)If it is necessary for the applicant's response to be docketed as a basisfor accepting the exception or difference, the applicant may voluntarilydocket the response or the NRC may issue an RAI.AMR Audit/Review WorksheetsDocument the audits/reviews using the worksheet provided in Appendix H, "Aging ManagementReview Worksheets. As an alternate, the project team member may document its review electronically in the AMR spreadsheets.6.4 Time-Limited Aging Analyses (TLAA) Audits and Reviews Audit and review of TLAAs are discussed below. The project team will also review the TLAAsto determine if there are emerging issues that should be further evaluated by technical specialists in the NRC Divisions of Component Integrity (DCI) or the Division of Engineering(DE). In general, the project team will review TLAAs that are for which the applicant claimsconsistency 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 beadequately managed for the period of extended operation." For TLAAs for which the applicantclaims 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 whichTLAAs the audit team will be capable of reviewing. Consideration should be given to teamexpertise, past precedent, and complexity of the provided analysis.6.4.1 Identify Generic TLAA Issues Figure 5, "Evaluation of TLAAs and Exemptions," taken from NEI 95-10, Revision 6, shows 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 VYNPS TLAAs that the applicant has identified as generic TLAA issues,identify the corresponding TLAAs in NUREG-1800, if appropriate.B.Review the corresponding TLAAs in NUREG-1800 and identify those that will beaudited/reviewed in conjunction with each of the VYNPS TLAAs.C.Review the list of the VYNPS plant-specific exemptions granted pursuant to§50.12 and in effect that are based on TLAAs as defined in §54.3. The application shall include an evaluation that justifies the continuation of theseexemptions 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:

26Excel database on TLAAs summarizing how earlier LRAs and SERspresented and reviewedTLAAsGALL ReportSRP-LRISGsRAIs, audit and review reports, and SERs for similar plantsLRAReferences listed by applicant for each TLAANEI 95-10, Section 5.1 and Table 6.2-2basis documentsimplementation documentsoperating experience reports (plant-specific and industry)lessons learned developed by RLRCapplicant'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 Divisions of Component Integrity (DCI) or the Division of Engineering (DE).This is not expected to be an issue for TLAAs for which the applicant claims consistency with 10 CFR 54.21(c)(i) "the analyses remain valid for the period of extended operation." or 10 CFR 54.21(c)(iii) "the effects of aging on the int endedfunction(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 theaudit team will be capable of reviewing. Consideration should be given to teamexpertise, past precedent, and complexity of the provided analysis. Candidates for further review by technical specialists could be such as the following:

Reactor Vessel Neutron Embrittlement AnalysisEQ for Electrical Equipment (unless audit team is capable)Intergranular separation in the Heat-Affected Zone (HAZ) of ReactorVesselLow-Alloy Steel under Austenitic SS CladdingSilting of the Ultimate Heat SinkAudit/ReviewA.Confirm that each VYNPS 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 VYNPSshould 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:

27The application shall include a list of time-limited aging analyses, asdefined by §54.3. The application should include the identification of theaffected systems, structures, and components, an explanation of the timedependent 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.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 endof the period of extended operation or (3) the effects of aging on the intended function(s) will be adequately managed for the period ofextended operation.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. 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 submit the required information as a supplement (docketed letter submitted under oath and affirmation) to the VYNPS LRA. If not, the NRC may issue anRAI to obtain the information.TLAA Audit WorksheetsDocument the audits/reviews using a worksheet which contains, as a minimum, the projectteam's question(s) related to the particular TLAA, the applicant's response(s) and notation ofdocuments reviewed.6.4.2 Reactor Vessel Neutron Embrittlement Analyses 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.

28Pre-Review PreparationA.The project team will determine if the TLAAs identified in the VYNPS LRA to bewithin the NUREG-1800 TLAA category of "reactor vessel neutron embrittlement"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:

Excel database on TLAAs summarizing how earlier LRAs and SERspresented and reviewed TLAAsGALL ReportSRP-LRISGsRAIs, audit and review reports, and SERs for similar plantsLRAReferences listed by applicant for each TLAANEI 95-10, Section 5.1 and Table 6.2-2basis documentsimplementation documentsoperating experience reports (plant-specific and industry)lessons learned developed by RLRCapplicant's UFSARC.In addition, the project team will also review the VYNPS TLAAs within theNUREG-1800 TLAA category of "reactor vessel neutron embrittlement" todetermine if there are emerging issues that should be further evaluated by technical specialists in the NRC Divisions of Component Integrity (DCI) or theDivision 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) "theeffects of aging on the intended function(s) will be adequately managed for theperiod 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 consultedto 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 VYNPS 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 VYNPSshould state in this section that it does not apply.

29C.The project team will conduct both regulatory evaluations and technicalevaluations to determine, as defined in 10 CFR 54.3, that each TLAA meets thefollowing 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)are 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 intendedfunctions, as delineated in 10 CFR 54.4(b)(6)are contained or incorporated by reference in the CLB.D.The project team will ascertain that the VYNPS satisfactorily demonstrates that(1) the analyses remain valid for the period of extended operation, (2) the analyses have been (or have been identified and will be [§54.29(a)]) projected 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 extendedoperation.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 reactor vessel neutron embrittlement (from NEI 95-10, Table 6.2-2) as follows:

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

§54.21(d)1.F.If it is necessary to ask the applicant a question to clarify the basis for 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 VYNPS LRA. If not, the NRC may issue anRAI to obtain the information.TLAA Audit WorksheetsDocument the audits/reviews using a worksheet which contains, as a minimum, the projectteam's question(s) related to the particular TLAA, the applicant's response(s) and notation ofdocuments reviewed.

306.4.3 Metal Fatigue AnalysesFigure 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 VYNPS LRA to bewithin the NUREG-1800 TLAA category of "metal fatigue" have providedadequate 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:

Excel database on TLAAs summarizing how earlier LRAs and SERspresented and reviewed TLAAsGALL Report, especially Section X.M1SRP-LRISGsRAIs, audit and review reports, and SERs for similar plantsLRAReferences listed by applicant for each TLAANEI 95-10, Section 5.1 and Table 6.2-2basis documentsimplementation documentsoperating experience reports (plant-specific and industry)lessons learned developed by RLRCapplicant's UFSARC.In addition, the project team will also review the VYNPS TLAAs within theNUREG-1800 TLAA category of "metal fatigue" to determine if there areemerging issues that should be further evaluated by technical specialists in the NRC Divisions of Component Integrity (DCI) or the Division of Engineering (DE).This is not expected to be an issue for TLAAs for which the applicant claims consistency with 10 CFR 54.21(c)(i) "the analyses remain valid for the period of extended operation." or 10 CFR 54.21(c)(iii) "the effects of aging on the int endedfunction(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 theaudit team will be capable of reviewing. Consideration should be given to teamexpertise, past precedent, and complexity of the provided analysis.

31Audit/ReviewA.Confirm that each VYNPS 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 VYNPSshould 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 thefollowing 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)are 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 intendedfunctions, as delineated in 10 CFR 54.4(b)(6)are contained or incorporated by reference in the CLBD.The project team will ascertain that the VYNPS satisfactorily demonstrates that(1) the analyses remain valid for the period of extended operation, (2) the analyses have been (or have been identified and will be [§54.29(a)]) projected 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 extendedoperation.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:

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

§54.21(d)1.F.If it is necessary to ask the applicant a question to clarify the basis for 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 VYNPS LRA. If not, the NRC may issue anRAI to obtain the information.

32TLAA Audit WorksheetsDocument the audits/reviews using a worksheet which contains, as a minimum, the projectteam's question(s) related to the particular TLAA, the applicant's response(s) and notation ofdocuments reviewed.6.4.4 Environmental Qualification Analyses for Electrical Components Figure 5, "Evaluation of TLAAs and Exemptions," taken from NEI 95-10, Revision 6, shows 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 VYNPS LRA to bewithin the NUREG-1800 TLAA category of "environmental qualification of electricequipment" 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:

Excel database on TLAAs summarizing how earlier LRAs and SERspresented and reviewed TLAAsGALL Report, especially Section X.E1SRP-LRISGsRAIs, audit and review reports, and SERs for similar plantsLRAReferences listed by applicant for each TLAANEI 95-10, Section 5.1 and Table 6.2-2basis documentsimplementation documentsoperating experience reports (plant-specific and industry)lessons learned developed by RLRCapplicant's UFSARC.In addition, the project team will also review the VYNPS TLAAs within theNUREG-1800 TLAA category of "environmental qualification of electricequipment" to determine if there are emerging issues that should be further evaluated by technical specialists in the NRC Divisions of Component Integrity(DCI) or the Division of Engineering (DE). This is not expected to be an issue for TLAAs for which the applicant claims consistency with 10 CFR 54.21(c)(i) "the analyses remain valid for the period of extended operation." or 10 CFR 54.21(c)(iii) "the effects of aging on the intended function(s) will be adequatelymanaged 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 33will be consulted to determine which TLAAs the audit team will be capable ofreviewing. Consideration should be given to team expertise, past precedent, and complexity of the provided analysis.Audit/ReviewA.Confirm that each VYNPS 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 VYNPSshould 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 thefollowing 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)are 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 intendedfunctions, as delineated in 10 CFR 54.4(b)(6)are contained or incorporated by reference in the CLBD.The project team will ascertain that the VYNPS satisfactorily demonstrates that(1) the analyses remain valid for the period of extended operation, (2) the analyses have been (or have been identified and will be [§54.29(a)]) projected 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 extendedoperation.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:

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

§54.21(d)1.F.If it is necessary to ask the applicant a question to clarify the basis for theiranalyses, follow the logic process shown in Figure 5 of this audit and review plan.

34G.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 VYNPS LRA. If not, the NRC may issue anRAI to obtain the information.TLAA Audit WorksheetsDocument the audits/reviews using a worksheet which contains, as a minimum, the projectteam's question(s) related to the particular TLAA, the applicant's response(s) and notation ofdocuments reviewed.6.4.5 Concrete Containment Tendon Prestress Analysis The applicant states in the VYNPS LRA that this TLAA is not applicable for VYNPS. So thematerial in the following paragraphs is not pertinent to the project team review for this LRA.Figure 5, "Evaluation of TLAAs and Exemptions," taken from NEI 95-10, Revision 6, shows 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 VYNPS LRA to bewithin the NUREG-1800 TLAA category of "concrete containment tendonprestress" 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:

Excel database on TLAAs summarizing how earlier LRAs and SERspresented and reviewed TLAAsGALL Report, especially Section X.S1SRP-LRISGsRAIs, audit and review reports, and SERs for similar plantsLRAReferences listed by applicant for each TLAANEI 95-10, Section 5.1 and Table 6.2-2basis documentsimplementation documentsoperating experience reports (plant-specific and industry)lessons learned developed by RLRCapplicant's UFSARC.In addition, the project team will also review the VYNPS TLAAs within theNUREG-1800 TLAA category of "concrete containment tendon prestress" to 35determine if there are emerging issues that should be further evaluated bytechnical specialists in the NRC Divisions of Component Integrity (DCI) or theDivision 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) "theeffects of aging on the intended function(s) will be adequately managed for theperiod 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 consultedto 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 VYNPS TLAA listed in this section is appropriate. Refer to anyanalyses 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 VYNPSshould 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 thefollowing 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)are 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 intendedfunctions, as delineated in 10 CFR 54.4(b)(6)are contained or incorporated by reference in the CLBD.The project team will ascertain that the VYNPS satisfactorily demonstrates that(1) the analyses remain valid for the period of extended operation, (2) the analyses have been (or have been identified and will be [§54.29(a)]) projected 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 extendedoperation.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 "concrete containment tendon prestress" (from NEI 95-10, Table 6.2-2) as follows:

Disposition chosen for each of the identified TLAAs. Also, provide areference to the summary description of TLAA evaluations in the UFSAR 36supplement (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 VYNPS LRA. If not, the NRC may issue anRAI to obtain the information.TLAA Audit WorksheetsDocument the audits/reviews using a worksheet which contains, as a minimum, the projectteam's question(s) related to the particular TLAA, the applicant's response(s) and notation ofdocuments reviewed.6.4.6 Containment Liner Plate, Metal Containment, and Penetrations Fatigue Analyses Figure 5, "Evaluation of TLAAs and Exemptions," taken from NEI 95-10, Revision 6, shows 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 VYNPS LRA to bewithin the NUREG-1800 TLAA category of "containment liner plate, metalcontainments, and penetrations fatigue analysis" have provided adequate information to meet the requirements of 10 CFR 54.21(c)(1) and 10 CFR 54.21(c)(2).B.Identify and locate the documents needed to perform the review. These mayinclude, but are not limited to, the following:

Excel database on TLAAs summarizing how earlier LRAs and SERspresented and reviewed TLAAsGALL Report, especially Section X.E1SRP-LRISGsRAIs, audit and review reports, and SERs for similar plantsLRAReferences listed by applicant for each TLAANEI 95-10, Section 5.1 and Table 6.2-2basis documentsimplementation documents 37operating experience reports (plant-specific and industry)lessons learned developed by RLRCapplicant's UFSARC.In addition, the project team will also review the VYNPS TLAAs within theNUREG-1800 TLAA category of "containment liner plate, metal containments,and penetrations fatigue analysis" to determine if there are emerging issues that should be further evaluated by technical specialists in the NRC Divisions ofComponent 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 int endedfunction(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 theaudit 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 VYNPS 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 VYNPSshould 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 thefollowing 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)are 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 intendedfunctions, as delineated in 10 CFR 54.4(b)(6)are contained or incorporated by reference in the CLBD.The project team will ascertain that the VYNPS satisfactorily demonstrates that(1) the analyses remain valid for the period of extended operation, (2) the analyses have been (or have been identified and will be [§54.29(a)]) projected 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 extendedoperation.

38E.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 "containment liner plate, metal containments, and penetrations fatigue analysis" (from NEI 95-10, Table 6.2-2) as follows:

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

§54.21(d)1.F.If it is necessary to ask the applicant a question to clarify the basis for 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 VYNPS LRA. If not, the NRC may issue anRAI to obtain the information.TLAA audit worksheetsDocument the audits/reviews using a worksheet which contains, as a minimum, the projectteam's question(s) related to the particular TLAA, the applicant's response(s) and notation ofdocuments reviewed.6.4.7 Other Plant-Specific TLAAs 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.The project team will determine if the TLAAs identified in the VYNPS LRA to bewithin the NUREG-1800 TLAA category of "other plant-specific TLAAs" haveprovided 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:

Excel database on TLAAs summarizing how earlier LRAs and SERspresented and reviewed TLAAsGALL ReportSRP-LRISGs 39RAIs, audit and review reports, and SERs for similar plantsLRAReferences listed by applicant for each TLAANEI 95-10, Section 5.1 and Table 6.2-2basis documentsimplementation documentsoperating experience reports (plant-specific and industry)lessons learned developed by RLRCapplicant's UFSARC.In addition, the project team will also review the VYNPS TLAAs within theNUREG-1800 TLAA category of "other plant-specific TLAAs" to determine ifthere are emerging issues that should be further evaluated by technical specialists in the NRC Divisions of Component Integrity (DCI) or the Division ofEngineering (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 agingon the intended function(s) will be adequately managed for the period ofextended 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 determinewhich TLAAs the audit team will be capable of reviewing. Consideration shouldbe given to team expertise, past precedent, and complexity of the provided analysis.Audit/ReviewA.Confirm that each VYNPS 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 VYNPSshould 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 thefollowing 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)are 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 intendedfunctions, as delineated in 10 CFR 54.4(b)(6)are contained or incorporated by reference in the CLB 40D.The project team will ascertain that the VYNPS satisfactorily demonstrates that(1) the analyses remain valid for the period of extended operation, (2) the analyses have been (or have been identified and will be [§54.29(a)]) projected 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 extendedoperation.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:

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 VYNPS LRA. If not, the NRC may issue anRAI to obtain the information.TLAA Audit WorksheetsDocument the audits/reviews using a worksheet which contains, as a minimum, the projectteam's question(s) related to the particular TLAA, the applicant's response(s) and notation ofdocuments reviewed.6.5 Audit and Safety Review Documentation As noted in Section 5.7 of this audit and review plan, the project team will prepare an audit andreview plan, worksheets, work packages, requests for additional information, an audit and review report, and a SER input. This section of the audit and review plan addresses the preparation of the audit and review report and the SER input.6.4.1 Audit and Review Report Details on documentation of the audit and review report can be found in the latest version of theRLRC Guidelines For Preparing Audit and Review Reports.In general, the audit and review report should include the following:A.Cover pageB.Table of Contents C.1.Introduction and General Information1.1Introduction 1.2Background 41D.2.Audit and Review ScopeE.3.Aging Management Review Audit and Review Results3.0Applicant's Use of Generic Aging Lesson-Learned Report3.0.1Format of the Applicant's License Renewal Application3.0.1.1 Overview of Table 1 3.0.1.2 Overview of Table 23.0.2Audit and Review Process3.0.2.1 Review of AMPs 3.0.2.2 Review of AMR Results 3.0.2.3 NRC-Approved Prec edents3.0.2.4 UFSAR Supplement 3.0.2.5 Documentation and Documents Reviewed 3.0.2.6 Commitments to be Included in the Safety Evaluation Report3.0.2.7 Exit Meeting3.0.3Aging Management Programs3.0.3.1 AMPs That Are Consistent with the GALL Report3.0.3.2 AMPs That Are Consistent with the GALL Report with Exceptions or Enhancements3.0.3.3 AMPs That Are Not Consistent with or Not Addressed in the GALL Report3.1Applicant's LRA Section 3.1 - Aging Management of ReactorCoolant System 3.1.1Summary of Technical Information in the Application 3.1.2Project Team Evaluation3.1.2.1 AMR Results That Are Consistent with the GALL Report3.1.2.2 AMR Results for Which Further Evaluation is Recommended3.1.2.3 AMR Results That Are Not Consistent with or Not Addressed in the GALL Report3.1.3Conclusion3.2Applicant's LRA Section 3.2 - Aging Management of EngineeredSafety Features Systems 3.2.1Summary of Technical Information in the Application 3.2.2Project Team Evaluation3.2.2.1 AMR Results That Are Consistent with the GALL Report3.2.2.2 AMR Results for Which Further Evaluation is Recommended3.2.2.3 AMR Results That Are Not Consistent with or Not Addressed in the GALL Report3.2.3Conclusion3.3Applicant's LRA Section 3.3 - Auxiliary Systems3.3.1Summary of Technical Information in the Application 3.3.2Project Team Evaluation3.3.2.1 AMR Results That Are Consistent with the GALL Report 423.3.2.2 AMR Results for Which Further Evaluation is Recommended3.3.2.3 AMR Results That Are Not Consistent with or Not Addressed in the GALL Report3.3.3Conclusion3.4Applicant's LRA Section 3.4 - Aging Management of Steam andPower Conversion System 3.4.1Summary of Technical Information in the Application 3.4.2Project Team Evaluation3.4.2.1 AMR Results That Are Consistent with the GALL Report3.4.2.2 AMR Results for Which Further Evaluation is Recommended3.4.2.3 AMR Results That Are Not Consistent with or Not Addressed in the GALL Report3.4.3Conclusion3.5Applicant's LRA Section 3.5 - Aging Management of Containment,Structures and Component Supports 3.5.1Summary of Technical Information in the Application 3.5.2Project Team Evaluation3.5.2.1 AMR Results That Are Consistent with the GALL Report3.5.2.2 AMR Results for Which Further Evaluation is Recommended3.5.2.3 AMR Results That Are Not Consistent with or Not Addressed in the GALL Report3.5.3Conclusion3.6Applicant's LRA Section 3.6 - Aging Management of Electrical andInstrumentation and Controls 3.6.1Summary of Technical Information in the Application 3.6.2Project Team Evaluation3.6.2.1 AMR Results That Are Consistent with the GALL Report3.6.2.2 AMR Results for Which Further Evaluation is Recommended3.6.2.3 AMR Results That Are Not Consistent with or Not Addressed in the GALL Report3.6.3ConclusionF.4.Time-Limited Aging Analysis4.1 Identification of Time-Limited Aging Analyses and Exemptions4.1.1Identification of TLAA 4.1.2Identification of Exemptions4.2Reactor Vessel Neutron Embrittlement Analyses4.2.1Reactor Vessel Fluence 4.2.2Pressure/Temperature Limits 4.2.3Charpy Upper-Shelf Energy (CVUSE) 4.2.4Adjusted Reference Temperature 434.2.5Reactor Vessel Circumferential Welds4.2.6Reactor Vessel Axial Weld Failure Probability4.2.7References4.3Metal Fatigue Analyses4.3.1Class 1 Fatigue 4.3.2Non-Class 1 Fatigue 4.3.3Effects of Reactor Water Environment on Fatigue Life 4.3.4References4.4Environmental Qualification of Electrical Components 4.5Concrete Containment Tendon Prestress Analysis 4.6Containment Liner Plate, Metal Containment, and PenetrationsFatigue Analyses 4.6.1Fatigue of the Torus 4.6.2Fatigue of Safety Relief Valve (SRV) Discharge Piping 4.6.3Fatigue of Other Torus-Attached Piping4.7Other Plant-specific Time-limited Aging Analyses4.7.1Reflood Thermal Shock of the Reactor Vessel Internals 4.7.2TLAA in BWRVIP Documents 4.7.3ReferencesG.AttachmentsAttachment 1 Abbreviations and Acronyms Project Team and Applicant Personnel A Members of the Public Elements of an Aging Management Program for License RenewalAttachment 4 Disposition of Requests for Additional Information, LRA Supplements, and Open or Confirmatory ItemsAttachment 5 List of Documents Reviewed List of Commitments6.4.2 Safety Evaluation Report Input1.General guidanceA.The project team will prepare the SER input for the AMP and AMR auditsand reviews. The technical assistance contractor shall collect, assemble, and prepare the complete SER input.B.In general, the data and information needed to prepare the SER inputshould be available in the project team's audit and review report and the project team member's worksheets.

4 AMRs that are not consistent with the GALL Report.

5 The LRA AMR results are broken down into six sections and address the following system/structure groups: (1)Section 3.1, reactor vessel, internals and reactor coolant system, (2) Section 3.2, engineering safety featuressystems, (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.

44C.SER inputs are to be prepared for:(1)each VYNPS AMP that was determined to be consistent with theGALL Report, which has no exceptions or enhancements.(2)each VYNPS AMP that was determined to be consistent with theGALL Report, which has exceptions (identified by either the applicant or the project team) or enhancements.(3)each plant-specific AMP (4)AMRs that are consistent with the GALL Report (5)project team AMR review results 4D.RLRA/RLRB will prepare an SER shell for the entire SER. The projectteam is to enter its SER input directly into the RLRA/RLRB shell. The SER input placed into the SER shell should typically contain the following sections. (Note: The following section numbers (3. through 3.X.3 and 4) are based on the numbering system for the SER shell. They are not a continuation of the numbering convention used throughout this plan.)3.Aging Management Review Results3.0Applicant's Use of the Generic Aging Lessons LearnedReport 3.0.1Format of the LRA 3.0.2Staff's Review Process3.0.2.1 AMRs in the GALL Report 3.0.2.2 NRC-Approved Prec edents3.0.2.3 UFSAR Supplement 3.0.2.4 Documentation and Documents Reviewed3.0.3Aging Management Programs3.0.3.1 AMPs that are Consistent With the GALL Report3.0.3.2 AMPs that are Consistent With GALL Report With Exceptions or Enhancements3.0.3.3 AMPs that are Plant-Specific3.0.4Quality Assurance Program Attributes Integral toAging Management Programs 3.X.5Aging Management of 3.X.1Summary of Technical Information in theApplication3.X.2Staff Evaluation3.X.2.1 Aging Management Review Results that are Consistent with the GALL Report 453.X.2.2 Aging Management Review Results For Which Further Evaluation is Recommended by the GALL Report3.X.2.3 Aging Management Review Results that are Not Consistent with or Not Addressed in the GALL Report3.X.3Conclusion4.Time-Limited Aging Analyses4.1Identification of Time-Limited Aging Analyses andExemptions 4.1.1Identification of TLAA 4.1.2Identification of Exemptions4.2Reactor Vessel Neutron Embrittlement Analysis4.2.1Reactor Vessel Fluence 4.2.2Pressure/Temperature Limits 4.2.3Charpy Upper-Shelf Energy (CVUSE) 4.2.4Adjusted Reference Temperature 4.2.5Reactor Vessel Circumferential Welds 4.2.6Reactor Vessel Axial Weld Failure Probability4.2.7References4.3Metal Fatigue Analysis4.3.1Class 1 Fatigue 4.3.2Non-Class 1 Fatigue 4.3.3Effects of Reactor Water Environment on FatigueLife4.3.4References4.4Environmental Qualification of Electrical Components 4.5Concrete Containment Tendon Prestress Analysis 4.6Containment Liner Plate, Metal Containment, andPenetrations Fatigue Analyses 4.6.1Fatigue of the Torus 4.6.2Fatigue of Safety Relief Valve (SRV) DischargePiping4.6.3Fatigue of Other Torus-Attached Piping4.7Other Plant-specific Time-limited Aging Analyses4.7.1Reflood Thermal Shock of the Reactor VesselInternals4.7.2TLAA in BWRVIP Documents 4.7.3References 6 The audit results documented in this section address the AMRs consistent with the GALL Report for which nofurther evaluation is recommended.

46E.For each AMP audited/reviewed by the project team, the SER input shallinclude a discussion of the project team's review of the operating experience program element.F.If the applicant submitted a supplement (docketed letter submitted underoath and affirmation) to its LRA that is associated with the project team's audit or review activities, document the submittal (include the date and ADAMS Accession Number) and explain the issue that the submittal resolved and discuss the basis for the resolution.G.If an RAI was issued, identify the RAI number and briefly discuss the RAI.State if the RAI remains open or if the applicant response has been received and accepted. If the response was acceptable, identify the submittal (including the date and the ADAMS accession number) that provided the response and document the basis for its acceptance.H.Issues (e.g., RAIs) that have not been resolved by the applicant at thetime the SER input is prepared should be identified as open items.2.SER inputA.For VYNPS AMPs determined to be consistent with the GALL Report,without exceptions, include the AMP title, the plant AMP paragraph number, and a discussion of the basis for concluding that the UFSAR update (Appendix A of the VYNPS LRA) is acceptable. This SER input documents that the AMP is consistent with the GALL Report.B.For VYNPS AMPs determined to be consistent with the GALL Report,with exceptions or enhancement, the SER input should include a statement that the audit found the VYNPS AMP consistent with the GALLReport and that any applicant-identified exceptions to the GALL Reportwere 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 alsoaddress the UFSAR supplement, and document the basis for concluding that it is acceptable.C.For plant-specific AMPs, the SER input should document the basis foraccepting each the program elements reviewed by the project team. The SER input should also include a discussion concerning the adequacy of the UFSAR supplement.D.For aging management evaluations that are consistent with the GALLReport, 6 the SER input should include the following:

7 This section documents reviews of AMRs assigned to the project team that are not consistent with the GALLReport.47(1)Identify the VYNPS LRA section reviewed (2)A summary of the type of information provided in the section ofthe VYNPS LRA reviewed, including a listing of the VYNPS AMPs reviewed.(3)Identify the VYNPS LRA Tables 3.X.2-Y reviewed.

(4)A summary review of the AMR Notes A through E used to classifythe AMR line items used in these tables.(5)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 thatlists the details of the documents reviewed.(6)The bases for accepting any exceptions to GALL Report AMRsthat were identified by the applicant or the project team member.(7)A finding that determines that:(a)the applicant identified the applicable aging effects (b)the applicant defined the appropriate combination ofmaterials and environments(c)the applicant specified acceptable AMPs(8)A conclusion stating, if applicable, that the applicant hasdemonstrated that the effects of aging will be adequatelymanaged so that the intended functions will be maintainedconsistent with the CLB for the period of extended operation, andthat 10 CFR 54.21(a)(3) has been satisfied.E.For aging management evaluations that are consistent with the GALLReport, for which further evaluation is recommended, the SER input should include the following:(1)The VYNPS LRA section containing the applicant's furtherevaluations of AMRs for which further evaluation is required.(2)A list of the aging effects for which the further evaluation apply.

(3)For the applicant's further evaluations, provide a summary of thebasis for concluding that it satisfied the criteria of Section 3.1.3.2 of the SRP-LR.(4)A statement that the staff audited the applicant's furtherevaluations against the criteria contained in Section 3.1.3.2 of the SRP-LR.(5)A statement that the audit and review report contains additionalinformation. Also identify the issue date and the ADAMS accession number for the audit and review report.F.Staff AMR Review Results.

7 This section of the SER input documentsthe reviews of AMRs assigned to the project team that are not consistentwith the GALL Report. The audit report should document the following, based on a precedent identified by the applicant:

48(1)The VYNPS LRA section reviewed(2)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.(3)Identify the VYNPS LRA Tables 3.X.2-Y documented by this auditwriteup. (4)A brief summary of what the staff (project team) reviewed, i.e.,LRA and applicant basis documents and other implementation documents.(5)A finding that determines, if true, that:(a)The applicant identified the applicable aging effects (b)The applicant listed the appropriate combination ofmaterials and environments(c)The applicant specified acceptable AMPs(6)Provide a conclusion stating, if applicable, that the applicant hasdemonstrated that the effects of aging will be adequatelymanaged so that the intended functions will be maintainedconsistent with the CLB for the period of extended operation, andthat 10 CFR 54.21(a)(3) has been satisfied.G.Staff TLAA Review Results. For TLAAs for which the applicant claimsconsistency 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 willbe consulted to determine which TLAAs the audit team will be capable ofreviewing. Consideration should be given to team expertise, past precedent, and complexity of the provided analysis. Candidates for further review by technical specialists could be such as the following:

Reactor Vessel Neutron Embrittlement AnalysisEQ for Electrical Equipment (unless audit team is capable)Intergranular separation in the Heat-Affected Zone (HAZ) ofReactor VesselLow-Alloy Steel under Austenitic SS CladdingSilting of the Ultimate Heat Sink6.5 Documents Reviewed and Document Retention Any 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 audit and review report.Upon issuance of the audit and review report, all worksheets that were completed by contractor and NRC personnel shall be given to the project team leader.After the NRC has made its licensing decision, all copies of documents collected and alldocuments generated to complete the audit and review report, such as audit worksheets, question and answer tracking documentation, etc., are to be discarded.

49Table 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 theapplicable aging effects.3Parameters monitoredor inspectedParameters monitored or inspected should be linked to theeffects of aging on the intended functions of the particular structure and component.4Detection of agingeffectsDetection of aging effects should occur before there is lossof any structure and component intended function. This includes aspects such as method or technique (i.e., visual, volumetric, surface inspection), frequency, sample size, data collection and timing of new/one-time inspections to ensure timely detection of aging effects.5Monitoring andtrendingMonitoring and trending should provide prediction of theextent of 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 particularstructure and component intended functions are maintained under all current licensing basis design conditions during the period of extended operation.7*Corrective actionsCorrective actions, including root cause determination andprevention of recurrence, should be timely.8*Confirmation processThe confirmation process should ensure that preventiveactions are adequate and appropriate corrective actions have been completed and are effective.9*AdministrativecontrolsAdministrative 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 thestructure and component intended functions will bemaintained during the period of extended operation.* The adequacy of the applicant's 10 CFR 50, Appendix B Program associated with thisprogram element is audited by the Division of Engineering.

8 Each AMR line item is coded with a letter which represents a standard note designation based on a letter from A.Nelson, NEI, to P.T. Kuo, NRC, "U.S. Nuclear Industry's Proposed Standard License Renewal Application FormatPackage, Request NRC Concurrence," dated January 24, 2003 (ML030290201). The staff concurred in the formatof the standardized format for license renewal applications by letter dated April 7, 2003, from P.T. Kuo, NRC, toA. Nelson, NEI (ML030990052).

50Table 2. Notes for License Renewal Application Tables 3.X.2-Y 8NoteDescriptionAConsistent 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, andaging effect. 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-1801AMP.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 isevaluated in NUREG-1801.

51Yes NoYes NoStartDid applicant identify any exceptions to GALL AMP(s)?Review the basis documents and compare each GALL AMP program element to the LRA AMP Document the basis for acceptance of the program element in worksheetHave all attribute elements been audited?YesPreparation StepsIdentify GALL Report AMP(s) to which LRA AMP is being compared Identify LRA AMP support documents needed to perform audit Is there a technicalbasis to accept exception or difference?Note: If an NRC precedent exists, it may be used as an aid to make the technical determination. Documentation of the acceptance must be made on the technical merits not a citation to the precedent.Notify project team leader Provide RAI to NRC project manager Develop and provide questions to project team leader to submittal to applicantObtain and review response from applicant Draft RAI NoNote: Preparation steps may be performed as a single combined step for each AMP audited.Yes NoIs the program element consistent?Write audit and review report input per guidance in Section 6.4.1Conclusion of AMP auditProvide audit and review report inputWrite SE input per guidance in Section 6.4.2Provide SE input NoIs response acceptable?Yes NoFigure 1. Audit of AMPs That Are Consistent With the GALL Report 52Yes No NoStartReview the basis documents and each LRA AMP program element against the applicable acceptance criteria in the SRP-LR Document the basis for acceptance of the program element in worksheetHave all LRA AMP program elements been audited?Preparation StepsIdentify the program elements acceptance criteria SRP-LR, Appendix A Identify supporting documents for the LRA AMP to be performed Note: If an NRC precedent exists, it may be used as an aid to make the technical determination.

Documentation of the acceptance must be made on the technical merits not a citation to the precedent.Develop and provide questions to project team leader to submittal to applicant NoObtain and review response from applicantDraft RAI Note: Preparation steps may be performed as a single combined step for each AMP audited.Yes NoIs there a technical basis to accept the LRA AMP program element? Write audit and review report input using guidance in Section 6.4.1Conclusion of AMP auditProvide input to NRC project team leader Write SE input using guidance in Section 6.4.2 Provide NRC project team leader YesIs the response acceptable?Notify project team leader Provide RAI to NRC project manager YesYesFigure 2. Audit of Plant-Specific AMPs 53AMR line-itemIs this AMR line-item assigned to NRR/DE?Review corresponding LRA Table 3.X.1, "Further Evaluation Recommended" and "Discussion" Columns Further Evaluation RecommendedNote ANote CNote BNote ENote DIs AMP plan-specific?Acceptable in all aspect?Not in RLEP-B scopeAMR line-item completeConfirm question is capturedReview referenced LRA subsection and compare with SRP subsection for any differences Compare item with GALL Report Vol. 2 system Table item for:Component type, material, environment, aging effects AMPCompare item with GALL Report Vol. 2 system Table item for:Component type, material, environment, aging effects- Compare item with GALL Report Vol. 2 system Table item for:

- material, environment, aging effectsAMPs Compare item with GALL Report Vol. 2 system Table item for:Component type, material, environment, aging effects- Confirm AE still ma nage despite AMP exceptionConfirm that AMP will address AE for this component type and environmentCompare item with GALL Report Vol. 2 system Table item for:

- material, environment, aging effects-s Confirm AMP can manage the AEConfirm material, environment, aging effect are comparable and AE still managed despite AMP exceptionConfirm material, environment, AE, and method per AMP are comparableDocument basis for acceptance in AMR Comparison ChecklistDocument in AMR Comparison ChecklisttPrepare questionMark as outside of scopeMark as acceptableMark for query No No No No No No No No NoYesYesYes Yes YesYes YesYes YesFigure 3. Review of AMRs That Are Consistent With the GALL Report 54Review cited SERRAI exists?Reviewed cited LRA (may not required in all casesValid precedentAdditional information needed?Reviewed relevant RAIsIdentify or request alternative precedentAlternative precedent identified?Mark as acceptable Document basis for acceptance in AMR Comparison ChecklistMark for queryDocument in AMR Comparison ChecklistMark as open itemDocument absence of precedent in AMR Comparison ChecklistPrepare questionPropose assignment to DENot in RLEP-B scopeConfirm question is capturedAMR line-item complete No No No No YesYesYesYesApplicant proposes precedentFigure 4. Review of AMRs Using NRC-Approved Precedents 55Figure 5. Review of TLAAs and Exemptions (from NEI 95-10, Revision 6)

Appendix AProject Team Members A-1Appendix AProject Team MembersOrganizationNameFunctionNRC/NRR/DLR/RLRCMike MorganProject Team LeaderNRC/NRR/DLR/RLRCKaihwa (Robert) HsuBackup Team LeaderNRC/NRR/DLR/RLRCMark LintzReviewer NRC/NRR/DLR/RLRCDuc NguyenReviewer Information SystemsLaboratories, Inc.Mike KennedyContractor Lead, ReviewerInformation SystemsLaboratories, Inc.Malcolm PattersonReviewerInformation SystemsLaboratories, Inc.Jon WoodfieldReviewer Appendix BRLRC Schedule for LRA Safety Review B-1Appendix BRLRC Schedule for LRA Safety ReviewPlant: Vermont YankeeTAC: MC9668Team Leader: Michael MorganScope of Work:Backup Team Leader: Kaihwa (Robert) HsuAMPs/TLAAs - 36 of 37Project Manager: Johnny EadsAMRs - 2378 of 2378 line itemsContractor: Information Systems Laboratories (ISL)RAI Target Date:

11/01/06Assignments: Mike Kennedy (ISL), MalcolmSE Input to PM:

02/01/07Patterson (ISL), Jon Woodfield (ISL), Mark Lintz (NRC)Duc Nguyen (NRC)ACTIVITY/MILESTONEPLAN SCHEDULE1Receive LRA1/25/20062Complete Acceptance Review2/25/2006 3Make Review Assignments 3/8/2006 4Conduct Team Planning Meeting3/21-3/22/2006 5Issue Audit Plan to PM3/31/2006 6Conduct Site Visit 1(AMP audit and review)4/17-4/21/20067Draft AMP Audit Report Input5/1-5/5/20068Conduct in-office AMR reviews5/8-5/12/2006 9Site Visit 2(AMR audit and review)5/15-5/19/200610Draft AMR Audit Report Input6/5-6/9/200611Optional Site Visit 3 (resolve AMR and AMP questions)6/26-6/29/2006 12Public Exit Meeting6/29/2006 13Cutoff for providing RAIs to PM 14Peer Review of Final Draft Audit and Review Report7/24-7/28/2006 15Issue Final Audit and Review Report8/4/2006 16Draft SER input (AMPs/AMRs)8/9-9/11/2006 17Issue Final Draft SER Input to PM9/15/2006 18ACRS Subcommittee Meeting5/1/2007 19ACRS Full Committee Meeting9/1/2007 Appendix CAging Management Program Assignments C-1Appendix CAging Management Program AssignmentsThe following AMPs have been assigned to the project team for review.

LRAAMP NumberGALLReport AMP NumberAMP TitleConsistentwith GALL ReportAssignedReviewerYesNoB.1.1XI.M34Buried Piping InspectionProgramXMark LintzB.1.2XI.M6BWR CRD Return LineNozzle ProgramXMalcolmPattersonB.1.3XI.M5BWR Feedwater NozzleProgramXMalcolmPattersonB.1.4XI.M8BWR Penetrations ProgramXRobert Hsu B.1.5XI.M7BWR Stress CorrosionCracking ProgramXRobert HsuB.1.6XI.M4BWR Vessel ID AttachmentWelds ProgramXRobert HsuB.1.7XI.M9BWR Vessel InternalsProgramXRobert HsuB.1.8XI.S4Containment Leak RateProgramXMark LintzB.1.9XI.M30Diesel Fuel MonitoringProgramXMike KennedyB.1.10X.E1Environmental Qualification(EQ) of Electric Components ProgramYesDuc NguyenB.1.11X.M1Fatigue Monitoring ProgramXMalcolmPattersonB.1.12.1XI.M26Fire Protection - FireProtection ProgramXMark LintzB.1.12.2XI.M27Fire Protection - Fire WaterSystem ProgramXMark LintzB.1.13XI.M17Flow-Accelerated CorrosionProgramYesMark LintzB.1.14NAHeat Exchanger MonitoringProgramPSMike Kennedy LRAAMP NumberGALLReport AMP NumberAMP TitleConsistentwith GALL ReportAssignedReviewerYesNo C-2B.1.15.1XI.S1Inservice Inspection -Containment Inservice Inspection (CII) ProgramPSJon WoodfieldB.1.15.2XI.M1XI.S3Inservice Inspection -Inservice Inspection (ISI)

ProgramPSMalcolmPattersonB.1.16NAInstrument Air QualityProgramPSMalcolmPattersonB.1.17XI.E3Non-EQ InaccessibleMedium-Voltage Cable ProgramYesDuc NguyenB.1.18XI.E2Non-EQ InstrumentationCircuits Test Review ProgramYesDuc NguyenB.1.19XI.E1Non-EQ Insulated Cablesand Connections ProgramYesDuc NguyenB.1.20XI.M39Oil Analysis ProgramXMike KennedyB.1.21XI.M32XI.M35One-Time InspectionProgramYesMike KennedyB.1.22NAPeriodic Surveillance andPreventive Maintenance ProgramPSMike MorganB.1.23XI.M3Reactor Head Closure StudsProgramXMike MorganB.1.24XI.M31Reactor Vessel SurveillanceProgramYesDEB.1.25XI.M33Selective Leaching ProgramYesMalcolmPattersonB.1.26XI.M20Service Water IntegrityProgramXJon WoodfieldB.1.27.1XI.S5Structures Monitoring - Masonry Wall ProgramYesJon WoodfieldB.1.27.2XI.S6Structures Monitoring - Structures Monitoring ProgramYesJon Woodfield LRAAMP NumberGALLReport AMP NumberAMP TitleConsistentwith GALL ReportAssignedReviewerYesNo C-3B.1.27.3NAStructures Monitoring - Vernon Dam FERC InspectionPSJon WoodfieldB.1.28XI.M36System Walkdown ProgramYesMark LintzB.1.29XI.M13Thermal Aging and NeutronIrradiation Embrittlement of Cast Austenitic Stainless Steel (CASS) ProgramYesRobert HsuB.1.30.1NAWater Chemistry Control -Auxiliary Systems ProgramPSMike MorganB.1.30.2XI.M2Water Chemistry Control -BWR ProgramYesMike MorganB.1.30.3XI.M21Water Chemistry Control -Closed Cooling Water ProgramYesMike MorganDE = Division of EngineeringPS = plant-specific X = with exceptions Appendix DAging Management Review Assignments D-1Appendix DAging Management Review AssignmentsAMR Section TitleReviewer3.1Reactor Vessel, Internals, and Reactor Coolant SystemM. Patterson3.2Engineering Safety Features SystemsM. Lintz 3.3Auxiliary SystemsM. K ennedy3.4Steam and Power Conversion SystemsM. Morgan 3.5Structures and Component SupportsJ. Woodfield 3.6Electrical and Instrumentation and ControlsD. Nguyen Appendix ETime-Limited Aging Analyses Review Assignments E-1Appendix ETime-Limited Aging Analyses Review Assignments LRATLAANumberGALLReportTLAANumberTLAA TitleAssignedReviewer4.1---Identification of TLAAs and ExemptionsHsu4.2---Reactor Vessel Neutron EmbrittlementDE 4.3X.M1Metal FatigueHsu 4.4X.E1Environmental Qualification of ElectricalComponentsNguyen4.5X.S1Concrete Containment Tendon PrestressNotapplicable to VYNPS4.6---Containment Liner Plate, Metal Containment, andPenetrations Fatigue AnalysesDE/Hsu4.7.1---Reflood Thermal Shock of the Reactor VesselInternals DE4.7.2.1---BWRVIP-05, RPV Circumferential WeldsAnalysis DE4.7.2.2---BWRVIP-25, Core Plate Rim Holddown BoltsLoss of Preload Analysis DE4.7.2.3---BWRVIP-38, Shroud Support Fatigue AnalysisHsu4.7.2.4---BWRVIP-47, Lower Plenum Fatigue AnalysisHsu 4.7.2.5---BWRVIP-48, Vessel ID Attachment WeldsFatigue Analysis Hsu4.7.2.6---BWRVIP-49, Instrument Penetrations FatigueAnalysis Hsu4.7.2.7---BWRVIP-74, Reactor VesselP/T Curves Analysis Fatigue Analysis CVUSE Analysis Circ/Axial Welds Analysis DE4.7.2.8---BWRVIP-76, Core ShroudHsu Appendix FConsistent with GALL Report AMP Audit/Review Worksheet F-1Appendix FConsistent with GALL Report AMP Audit/Review WorksheetThe example worksheet provided in this appendix provides, as an aid for the reviewer, aprocess for documenting the basis for the assessment of the program elements contained inthe GALL Report AMPs (Chapter XI of NUREG-1801, Volume 2). The worksheet provides asystematic method for recording the basis for assessments or to identify when the applicantneeds to provide clarification or additional information. Information recorded in the worksheets will also be used to prepare the audit and review report and the safety evaluation report input.The entire collection of the GALL Report AMP worksheets can be found at ADAMS AccessionNo. ML060950189. Table B-2 in the VYNPS LRA identifies the relationship of the VYNPS AMPs to the applicable GALL AMPs so that the appropriate worksheet can be selected by the project team reviewer.

F-2Audit WorksheetGALL Report AMPPlant: LRA AMP: Reviewer: GALL AMP: X.E1, Environmental Qualification (EQ) of Electric ComponentsDate: ProgramElementAuditable GALL CriteriaDocumentation of Audit FindingProgramDescriptionA. The reanalysis of an aging evaluation is normally performed to extend thequalification by reducing excess conservatism incorporated in the prior evaluation. Reanalysis of an aging evaluation to extend the qualification of a component is performed on a routine basis pursuant to 10 CFR 50.49(e) as part of an EQ program. While a component life limiting condition may be due to thermal, radiation, or cyclical aging, the vast majority of component aging limits are based on thermal conditions. Conservatism may exist in aging evaluation parameters, such as the assumed ambient temperature of the component, an unrealistically low activation energy, or in the application of a component (de-energized versus energized). The reanalysis of an aging evaluation is documented according to the station's quality assurance program requirements, which requires the verification of assumptions and conclusions. As already noted, important attributes of a reanalysis include analytical methods, data collection and reduction methods, underlying assumptions, acceptance criteria, and corrective actions (if acceptance criteria are not met).Consistent with GALL AMP:

G Yes G NoDocument(s) used to confirm Criteria:Comment:"B. All operating plants must meet the requirements of 10 CFR 50.49 forcertain electrical components important to safety. 10 CFR 50.49 defines the scope of components to be included, requires the preparation and maintenance of a list of in-scope components, and requires the preparation and maintenance of a qualification file that includes component performance specifications, electrical characteristics, and the environmental conditions to which the components could be subjected.Consistent with GALL AMP:

G Yes G NoDocument(s) used to confirm Criteria:Comment:

ProgramElementAuditable GALL CriteriaDocumentation of Audit Finding F-3"C. 10 CFR 50.49(e)(5) contains provisions for aging that require, in part,consideration of all significant types of aging degradation that can affect component functional capability. 10 CFR 50.49(e) also requires replacementor refurbishment of components not qualified for the current license term prior to the end of designated life, unless additional life is established through ongoing qualification.Consistent with GALL AMP:

G Yes G NoDocument(s) used to confirm Criteria:Comment"D. 10 CFR 50.49(f) establishes four methods of demonstrating qualificationfor aging and accident conditions.Consistent with GALL AMP:

G Yes G NoDocument(s) used to confirm Criteria:Comment"E. 10 CFR 50.49(k) and (l) permit different qualification criteria to applybased on plant and component vintage. Supplemental EQ regulatory guidance for compliance with these different qualification criteria is provided in the DOR Guidelines, Guidelines for Evaluating Environmental Qualification of Class 1E Electrical Equipment in Operating Reactors; NUREG-0588, Interim Staff Position on Environmental Qualification of Safety-Related Electrical Equipment; and Regulatory Guide 1.89, Rev. 1, Environmental Qualification of Certain Electric Equipment Important to Safety for Nuclear Power Plants. Compliance with 10 CFR 50.49 provides reasonable assurance that the component can perform its intended functions during accident conditions after experiencing the effects of inservice aging.Consistent with GALL AMP:

G Yes G NoDocument(s) used to confirm Criteria:Comment"F. EQ programs manage component thermal, radiation, and cyclical agingthrough the use of aging evaluations based on 10 CFR 50.49(f) qualification methods. As required by 10 CFR 50.49, EQ components not qualified for the current license term are to be refurbished, replaced, or have their qualification extended prior to reaching the aging limits established in the evaluation. Aging evaluations for EQ components that specify a qualification of at least 40 years are considered time-limited aging analyses (TLAAs) for license renewal.Consistent with GALL AMP:

G Yes G NoDocument(s) used to confirm Criteria:Comment ProgramElementAuditable GALL CriteriaDocumentation of Audit Finding F-4"G. Under 10 CFR 54.21(c)(1)(iii), plant EQ programs, which implement therequirements of 10 CFR 50.49 (as further defined and clarified by the DOR Guidelines, NUREG-0588, and Regulatory Guide 1.89, Rev. 1), are viewed as aging management programs (AMPs) for license renewal. Reanalysis of an aging evaluation to extend the qualification of components under 10 CFR 50.49(e) is performed on a routine basis as part of an EQ program.

Important attributes for the reanalysis of an aging evaluation include analytical methods, data collection and reduction methods, underlying assumptions, acceptance criteria, and corrective actions (if acceptance criteria are not met). These attributes are discussed in the "EQ Component Reanalysis Attributes" section.Consistent with GALL AMP:

G Yes G NoDocument(s) used to confirm Criteria:Comment"H. This reanalysis program can be applied to EQ components now qualifiedfor the current operating term (i.e., those components now qualified for 40 years or more). As evaluated below, this is an acceptable AMP. Thus, no further evaluation is recommended for license renewal if an applicant elects this option under 10 CFR 54.21(c)(1)(iii) to evaluate the TLAA of EQ ofelectric equipment.Consistent with GALL AMP:

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

G Yes G NoDocument(s) used to confirm Criteria:Comment ProgramElementAuditable GALL CriteriaDocumentation of Audit Finding F-5"B. Analytical Methods: The analytical models used in the reanalysis of anaging evaluation are the same as those previously applied during the prior evaluation. The Arrhenius methodology is an acceptable thermal model for performing a thermal aging evaluation. The analytical method used for a radiation aging evaluation is to demonstrate qualification for the total integrated dose (that is, normal radiation dose for the projected installed life plus accident radiation dose). For license renewal, one acceptable method of establishing the 60-year normal radiation dose is to multiply the 40-year normal radiation dose by 1.5 (that is, 60 years/40 years). The result is added to the accident radiation dose to obtain the total integrated dose for the component. For cyclical aging, a similar approach may be used. Other models may be justified on a case-by-case basis.Consistent with GALL AMP:

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

G Yes G NoDocument(s) used to confirm Criteria:Comment ProgramElementAuditable GALL CriteriaDocumentation of Audit Finding F-6"D. Underlying Assumptions: EQ component aging evaluations containsufficient conservatism to account for most environmental changes occurring due to plant modifications and events. When unexpected adverse conditions are identified during operational or maintenance activities that affect the normal operating environment of a qualified component, the affected EQ component is evaluated and appropriate corrective actions are taken, which may include changes to the qualification bases and conclusions.Consistent with GALL AMP:

G Yes G NoDocument(s) used to confirm Criteria:Comment"E. Acceptance Criteria and Corrective Actions: The reanalysis of an agingevaluation could extend the qualification of the component. If the qualification cannot be extended by reanalysis, the component is to be refurbished, replaced, or requalified prior to exceeding the period for which the current qualification remains valid. A reanalysis is to be performed in a timely manner (that is, sufficient time is available to refurbish, replace, or requalify the component if the reanalysis is unsuccessful).Consistent with GALL AMP:

G Yes G NoDocument(s) used to confirm Criteria:Comment1. Scope ofProgramA. EQ programs apply to certain electrical components that are important tosafety and could be exposed to harsh environment accident conditions, as defined in 10 CFR 50.49 and Regulatory Guide 1.89, Revision 1.Consistent with GALL AMP:

G Yes G NoDocument(s) used to confirm Criteria:Comment2. PreventiveActionsA. 10 CFR 50.49 does not require actions that prevent aging effects. EQprogram actions that could be viewed as preventive actions include (a) establishing the component service condition tolerance and aging limits (for example, qualified life or condition limit) and (b) where applicable, requiring specific installation, inspection, monitoring or periodic maintenance actions to maintain component aging effects within the bounds of the qualification basis.Consistent with GALL AMP:

G Yes G NoDocument(s) used to confirm Criteria:Comment:3. ParametersMonitored/

InspectedA. EQ component qualified life is not based on condition or performancemonitoring. However, pursuant to Regulatory Guide 1.89, Rev. 1, such monitoring programs are an acceptable basis to modify a qualified life through reanalysis. Monitoring or inspection of certain environmental conditions or component parameters may be used to ensure that the component is within the bounds of its qualification basis, or as a means to modify the qualified life.Consistent with GALL AMP:

G Yes G NoDocument(s) used to confirm Criteria:Comment:

ProgramElementAuditable GALL CriteriaDocumentation of Audit Finding F-74. Detection ofAging EffectsA. 10 CFR 50.49 does not require the detection of aging effects for in-servicecomponents. Monitoring or inspection of certain environmental conditions or component parameters may be used to ensure that the component is within the bounds of its qualification basis, or as a means to modify the qualified life.Consistent with GALL AMP:

G Yes G NoDocument(s) used to confirm Criteria:Comment:5. Monitoringand TrendingA. 10 CFR 50.49 does not require monitoring and trending of componentcondition or performance parameters of in-service components to manage the effects of aging. EQ program actions that could be viewed as monitoring include monitoring how long qualified components have been installed.

Monitoring or inspection of certain environmental, condition, or component parameters may be used to ensure that a component is within the bounds of its qualification basis, or as a means to modify the qualification.Consistent with GALL AMP:

G Yes G NoDocument(s) used to confirm Criteria:Comment:6. AcceptanceCriteriaA. 10 CFR 50.49 acceptance criteria are that an inservice EQ component ismaintained within the bounds of its qualification basis, including (a) its established qualified life and (b) continued qualification for the projected accident conditions. 10 CFR 50.49 requires refurbishment, replacement, or requalification prior to exceeding the qualified life of each installed device.Consistent with GALL AMP:

G Yes G NoDocument(s) used to confirm Criteria:Comment:"B. When monitoring is used to modify a component qualified life,plant-specific acceptance criteria are established based on applicable 10 CFR 50.49(f) qualification methods.Consistent with GALL AMP:

G Yes G NoDocument(s) used to confirm Criteria:Comment:

ProgramElementAuditable GALL CriteriaDocumentation of Audit Finding F-87. CorrectiveActionsA. If an EQ component is found to be outside the bounds of its qualificationbasis, corrective actions are implemented in accordance with the station's corrective action program. When unexpected adverse conditions are identified during operational or maintenance activities that affect the environment of a qualified component, the affected EQ component is evaluated and appropriate corrective actions are taken, which may include changes to the qualification bases and conclusions. When an emerging industry aging issue is identified that affects the qualification of an EQ component, the affected component is evaluated and appropriate corrective actions are taken, which may include changes to the qualification bases and conclusions. Confirmatory actions, as needed, are implemented as part of the station's corrective action program, pursuant to 10 CFR 50, Appendix B.

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

G Yes G NoDocument(s) used to confirm Criteria:Comment:8. ConfirmationProcessA. Confirmatory actions, as needed, are implemented as part of the station'scorrective action program, pursuant to 10 CFR 50, Appendix B. As discussed in the appendix to this report, the staff finds the requirements of 10 CFR Part 50, Appendix B, acceptable to address the confirmation process.Consistent with GALL AMP:

G Yes G NoDocument(s) used to confirm Criteria:Comment: 9.Administrative ControlsA. EQ programs are implemented through the use of station policy,directives, and procedures. EQ programs will continue to comply with 10 CFR 50.49 throughout the renewal period, including development and maintenance of qualification documentation demonstrating reasonable assurance that a component can perform required functions during harsh accident conditions. EQ program documents identify the applicable environmental conditions for the component locations. EQ program qualification files are maintained at the plant site in an auditable form for the duration of the installed life of the component. EQ program documentation is controlled under the station's quality assurance program. As discussed in the appendix to this report, the staff finds the requirements of 10 CFR Part 50, Appendix B, acceptable to address the administrative controls.Consistent with GALL AMP:

G Yes G NoDocument(s) used to confirm Criteria:Comment:10. OperatingExperienceA. EQ programs include consideration of operating experience to modifyqualification bases and conclusions, including qualified life. Compliance with 10 CFR 50.49 provides reasonable assurance that components can perform their intended functions during accident conditions after experiencing the effects of inservice aging.Consistent with GALL AMP:

G Yes G NoDocument(s) used to confirm Criteria:Comment:

F-9 EXCEPTIONSItem NumberProgramElementsLRA Exception DescriptionBasis for Accepting ExceptionDocuments Reviewed(Identifier, Para. # and/or Page #)

1.

2.

-E NHANCEMENTSItem NumberProgramElementsLRA Enhancement DescriptionBasis for Accepting EnhancementDocuments Reviewed(Identifier, Para.# and/or Page #)

1.

2.

-D OCUMENTS REVIEWED DURING AUDITDocument NumberIdentifier (number)TitleRevision and/or Date

1.

2.

3.

4.

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Appendix GPlant-Specific AMP Audit/Review Worksheet G-1Appendix GPlant-Specific AMP Audit/Review WorksheetThe example worksheet provided in this appendix provides, as an aid for the reviewer, aprocess for documenting the basis for the assessments concerning individual program elements contained in Branch Technical Position RLSB-1 "Aging Management Review -

Generic," in Appendix A to the SRP-LR. The worksheet provides a systematic method torecord 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 auditand review report and the safety evaluation report input.

G-2 AUDIT W ORKSHEETGALL R EPORT AMPPlant: LRA AMP: Reviewer: GALL AMP: Plant-specific Program Date: ProgramElementAuditable GALL CriteriaDocumentation of Audit FindingProgramDescription1. Scope ofProgramA. The specific program necessary for license renewal should be identified.The scope of the program should include the specific structures and components of which the program manages the aging.Consistent with GALL AMP:

G Yes G NoDocument(s) used to confirm Criteria:Comment:2. PreventiveActionsA. The activities for prevention and mitigation programs should be described.These actions should mitigate or prevent aging degradation.Consistent with GALL AMP:

G Yes G NoDocument(s) used to confirm Criteria:Comment: "B. For condition or performance monitoring programs, they do not rely onpreventive actions and thus, this information need not be provided. More than one type of aging management program may be implemented to ensure that aging effects are managed.Consistent with GALL AMP:

G Yes G NoDocument(s) used to confirm Criteria:Comment:3. ParametersMonitored/

InspectedA. The parameters to be monitored or inspected should be identified andlinked to the degradation of the particular structure and component intended function(s).Consistent with GALL AMP:

G Yes G NoDocument(s) used to confirm Criteria:Comment:

ProgramElementAuditable GALL CriteriaDocumentation of Audit FindingG-3"B. For a condition monitoring program, the parameter monitored or inspectedshould detect the presence and extent of aging effects. Some examples are measurements of wall thickness and detection and sizing of cracks.Consistent with GALL AMP:

G Yes G NoDocument(s) used to confirm Criteria:Comment: "C. For a performance monitoring program, a link should be establishedbetween the degradation of the particular structure or component intended function(s) and the parameter(s) being monitored. A performance monitoring program may not ensure the structure and component intended function(s) without linking the degradation of passive intended functions with the performance being monitored.Consistent with GALL AMP:

G Yes G NoDocument(s) used to confirm Criteria:Comment: "D. For prevention and mitigation programs, the parameters monitored shouldbe the specific parameters being controlled to achieve prevention or mitigation of aging effects.Consistent with GALL AMP:

G Yes G NoDocument(s) used to confirm Criteria:Comment:4. Detection ofAging EffectsA. The parameters to be monitored or inspected should be appropriate toensure that the structure and component intended function(s) will beadequately maintained for license renewal under all CLB design conditions.Consistent with GALL AMP:

G Yes G NoDocument(s) used to confirm Criteria:Comment: "B. Provide information that links the parameters to be monitored or inspectedto the aging effects being managed.Consistent with GALL AMP:

G Yes G NoDocument(s) used to confirm Criteria:Comment: "C. Thus, the effects of aging on a structure or component should be managedto ensure its availability to perform its intended function(s) as designed when called upon.Consistent with GALL AMP:

G Yes G NoDocument(s) used to confirm Criteria:Comment: "D. A program based solely on detecting structure and component failureshould not be considered as an effective aging management program for license renewal.Consistent with GALL AMP:

G Yes G NoDocument(s) used to confirm Criteria:Comment:

ProgramElementAuditable GALL CriteriaDocumentation of Audit FindingG-4"E. This program element describes "when," "where," and "how" program dataare collected (i.e., all aspects of activities to collect data as part of the program).Consistent with GALL AMP:

G Yes G NoDocument(s) used to confirm Criteria:Comment: "F. Provide justification, including codes and standards referenced, that thetechnique and frequency are adequate to detect the aging effects before a loss of SC intended function. A program based solely on detecting SC failures is not considered an effective aging management program.Consistent with GALL AMP:

G Yes G NoDocument(s) used to confirm Criteria:Comment: "G. When sampling is used to inspect a group of SCs, provide the basis for theinspection population and sample size. The inspection population should be based on such aspects of the SCs as a similarity of materials of construction, fabrication, procurement, design, installation, operating environment, or aging effects. The sample size should be based on such aspects of the SCs as the specific aging effect, location, existing technical information, system and structure design, materials of construction, service environment, or previous failure history. Consistent with GALL AMP:

G Yes G NoDocument(s) used to confirm Criteria:Comment: "H. The samples should be biased toward concern in the period of extendedoperation. Provisions should also be included on expanding the sample size when degradation is detected in the initial sample.Consistent with GALL AMP:

G Yes G NoDocument(s) used to confirm Criteria:Comment:5. Monitoringand TrendingA. Monitoring and trending activities should be described, and they shouldprovide predictability of the extent of degradation and thus effect timely corrective or mitigative actions. Plant-specific and/or industry-wide operating experience may be considered in evaluating the appropriateness of the technique and frequency.Consistent with GALL AMP:

G Yes G NoDocument(s) used to confirm Criteria:Comment:"B. This program element describes "how" the data collected are evaluatedand may also include trending for a forward look. This includes an evaluation of the results against the acceptance criteria and a prediction regarding the rate of degradation in order to confirm that timing of the next scheduled inspection will occur before a loss of SC intended function.Consistent with GALL AMP:

G Yes G NoDocument(s) used to confirm Criteria:Comment:

ProgramElementAuditable GALL CriteriaDocumentation of Audit FindingG-5"C. The parameter or indicator trended should be described. Consistent with GALL AMP:

G Yes G NoDocument(s) used to confirm Criteria:Comment: "D. The methodology for analyzing the inspection or test results against theacceptance criteria should be described.Consistent with GALL AMP:

G Yes G NoDocument(s) used to confirm Criteria:Comment: "E. Trending is a comparison of the current monitoring results with previousmonitoring results in order to make predictions for the future.Consistent with GALL AMP:

G Yes G NoDocument(s) used to confirm Criteria:Comment: "E. Trending is a comparison of the current monitoring results with previousmonitoring results in order to make predictions for the future.Consistent with GALL AMP:

G Yes G NoDocument(s) used to confirm Criteria:Comment:6. AcceptanceCriteriaA. The acceptance criteria of the program and its basis should be described. Consistent with GALL AMP:

G Yes G NoDocument(s) used to confirm Criteria:Comment: "B. The acceptance criteria, against which the need for corrective actions willbe evaluated, should ensure that the structure and component intended function(s) are maintained under all CLB design conditions during the period of extended operation.Consistent with GALL AMP:

G Yes G NoDocument(s) used to confirm Criteria:Comment: "C. The program should include a methodology for analyzing the resultsagainst applicable acceptance criteria.Consistent with GALL AMP:

G Yes G NoDocument(s) used to confirm Criteria:Comment:

ProgramElementAuditable GALL CriteriaDocumentation of Audit FindingG-6"D. Corrective action is taken, such as piping replacement, before reachingthis acceptance criterion.Consistent with GALL AMP:

G Yes G NoDocument(s) used to confirm Criteria:Comment: "E. Acceptance criteria could be specific numerical values, or could consist ofa discussion of the process for calculating specific numerical values of conditional acceptance criteria to ensure that the structure and component intended function(s) will be maintained under all CLB design conditions.Information from available references may be cited.Consistent with GALL AMP:

G Yes G NoDocument(s) used to confirm Criteria:Comment: "F. It is not necessary to justify any acceptance criteria taken directly from thedesign basis information that is included in the UFSAR because that is a part of the CLB. Also, it is not necessary to discuss CLB design loads if the acceptance criteria do not permit degradation because a structure and component without degradation should continue to function as originally designed.Consistent with GALL AMP:

G Yes G NoDocument(s) used to confirm Criteria:Comment: "G. Acceptance criteria, which do permit degradation, are based onmaintaining the intended function under all CLB design loads.Consistent with GALL AMP:

G Yes G NoDocument(s) used to confirm Criteria:Comment: "H. Qualitative inspections should be performed to same predetermined criteriaas quantitative inspections by personnel in accordance with ASME Code and through approved site specific programs.Consistent with GALL AMP:

G Yes G NoDocument(s) used to confirm Criteria:Comment:7. CorrectiveActionsA. Corrective actions, including root cause determination andprevention of recurrence, should be timely.Consistent with GALL AMP:

G Yes G NoDocument(s) used to confirm Criteria:Comment:

ProgramElementAuditable GALL CriteriaDocumentation of Audit FindingG-78. ConfirmationProcessA. Confirmation process should ensure that preventive actions areadequate and that appropriate corrective actions have been completed and are effective.Consistent with GALL AMP:

G Yes G NoDocument(s) used to confirm Criteria:Comment: 9.Administrative ControlsA. Administrative controls should provide a formal review andapproval process.Consistent with GALL AMP:

G Yes G NoDocument(s) used to confirm Criteria:Comment:10. OperatingExperienceA. Operating experience with existing programs should be discussed. Theoperating experience of aging management programs, including past corrective actions resulting in program enhancements or additional programs, should be considered. A past failure would not necessarily invalidate an aging management program because the feedback from operating experience should have resulted in appropriate program enhancements or new programs.

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

G Yes G NoDocument(s) used to confirm Criteria:Comment:

G-8 EXCEPTIONSItem NumberProgramElementsLRA Exception DescriptionBasis for Accepting ExceptionDocuments Reviewed(Identifier, Para.# and/or Page #)

1.

2.

-E NHANCEMENTSItem NumberProgramElementsLRA Enhancement DescriptionBasis for Accepting EnhancementDocuments Reviewed(Identifier, Para.# and/or Page #)

1.

2.

-Document Reviewed During AuditDocument NumberIdentifier (number)TitleRevision and/orDate 1.

2.

3.

4.

-.

Appendix HAging Management Review Worksheets H-1Appendix HAging Management Review WorksheetsThe project team reviewer should document its AMR reviews determination in spreadsheets ofthe Table 1 and Table 2 AMR line items. The documentation should contain the same information as would have been captured in the Table provided in this appendix.The project team reviewer should use the tables provided in this appendix if the electronicspreadsheet format is not used.

H-2VYNPS AMR Component (Table 1) WorksheetAudit Date:Unit:Table No.: Chapter:Auditor Name(s) : The audit team verified that items in Table 3.x.1 (Table 1) correspond to items in the GALL Volume 1, Table X. All items applicablein Table 1 were reviewed and are addressed in the following table.Item No.Further EvaluationRecommendedDiscussionAudit Remarks (Document all questions for the applicant here):No.Question for applicant (draft per RAI guidance)Response (with date)References/Documents Used:

1.2.3.4.

H-3VYNPS AMR MEAP Comparison (Table 2) WorksheetAudit Date:Unit:Table No.: Chapter:Auditor Name(s): Line items to which Notes A, B, C, D, and E are applied or for which a precedent was cited (except for those assigned to DE) we rereviewed for: 1) consistency with NUREG-1801, Volume 2 tables, and 2) adequacy of the aging managing programs. All items in theTable 2 of the system named above are acceptable with the exception of items in boldface type. (Reviewers need not duplicateinformation in the 2nd-5th columns that are reflected in the discussion/draft audit report.)

LRAPageNo.ComponentTypeMaterialEnvironmentAging EffectNoteDiscussion (draft as Audit Report input)Audit Remarks (Document all questions for the applicant here):No.Question for applicant (draft per RAI guidance)Response (with date)References/Documents Used:

5.6.7.

I-1Appendix IAbbreviations and AcronymsADAMSAgencywide Documents Access and Management SystemAMPaging management program AMRaging management review ASMEAmerican Society of Mechanical EngineersB&PVboiler and pressure vesselBTPBranch Technical Position BWRboiling water reactorCASScast austenitic stainless steelCIIcontainment inservice inspection CLBcurrent licensing basis CVUSEcharpy upper-shelf energyDCIDivisions of Component IntegrityDEDivision of Engineering DLRDivision of License RenewalEQenvironmental qualification FSARfinal safety analysis report GALLGeneric Aging Lessons LearnedGLGeneric LetterHAZheat affected zone ISGinterim staff guidanceISG-LRInterim Staff Guidance for License Renewal ISIinservice inspection ISLInformation Systems Laboratories, Inc.LRAlicense renewal application NEINuclear Energy InstituteNRCU.S. Nuclear Regulatory Commission NRROffice of Nuclear Reactor RegulationRAIrequest for additional information RLRCLicense Renewal Branch C RLSBLicense Renewal and Standardization BranchSCstructures and components I-2SERsafety evaluation reportSRP-LRStandard Review Plan-License Renewal SRVsafety relief valve SSCsystems, structures, and componentsTLAAtime-limited aging analysis UFSARupdated final safety analysis report VYVermont YankeeVYNPSVermont Yankee Nuclear Power Station