ML12339A668

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

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

Text

Audit and Review Plan for Plant Aging Management Reviews and Programs Indian Point Nuclear Generating Unit Nos. 2 and 3 Docket No.: 50-247 50-286 NRC000123 Submitted: March 31, 2012 United States Nuclear Regulatory Commission Official Hearing Exhibit In the Matter of

Entergy Nuclear Operations, Inc. (Indian Point Nuclear Generating Units 2 and 3)

ASLBP #:07-858-03-LR-BD01 Docket #:05000247 l 05000286 Exhibit #:

Identified:

Admitted: Withdrawn:

Rejected: Stricken: Other: NRC000123-00-BD01 10/15/2012 10/15/2012 i TABLE OF CONTENTS1.INTRODUCTION.......................................................12.BACKGROUND........................................................23.OBJECTIVES..........................................................4 4.

SUMMARY

OF INFORMATION PROVIDED IN THE LICENSE RENEWAL APPLICATION.........................................................64.1Aging Management Review Results...................................64.1.1IP2 and IP3 AMR Comparison with the GALL Report................74.1.2Plant-Specific Programs.....................................104.2Time-Limited Aging Analyses.......................................105.OVERVIEW OF AUDIT, REVIEW, AND DOCUMENTATION PROCEDURE........145.1Aging Management Programs......................................145.2Aging Management Reviews.......................................155.3Time-Limited Aging Analyses.......................................155.4UFSAR Supplement Review........................................165.5Documents Reviewed by the Project Team............................165.6Status Meeting..................................................16 5.7Documentation Prepared by the Project Team..........................175.7.1Audit and Review Plan......................................175.7.2Worksheets...............................................175.7.3Questions................................................17 5.7.4Work Packages............................................175.7.5Requests for Additional Information............................175.7.6Audit and Review Summary..................................185.7.7Safety Evaluation Report Input................................186.PLANNING, AUDIT, REVIEW, AND DOCUMENTATION PROCEDURE...........186.1Planning Activities................................................186.1.1Schedule for Key Milestones and Activities......................186.1.2Work Assignments.........................................196.1.3Training and Preparation.....................................196.2Aging Management Program (AMP) Audits and Reviews.................206.2.1Types of AMPs............................................206.2.2Scope of AMP Elements to be Audited and Reviewed..............206.2.3Plant AMPs that Are Consistent with the GALL Report..............206.2.4Plant-Specific AMPs........................................226.3Aging Management Review (AMR) Audits and Reviews..................246.3.1Plant AMRs that Are Consistent with the GALL Report.............246.3.2Plant AMRs that Are Not Consistent with the GALL Report..........276.4Time-Limited Aging Analyses (TLAA) Audits and Reviews................276.4.1Identify Generic TLAA Issues.................................27 6.4.2 Metal Fatigue Analyses......................................30 6.4.3 Environmental Qualification Analyses for Electrical Components.....326.4.4 Other Plant-Specific TLAAs..................................34 ii6.5Audit and Safety Review Documentation..............................366.5.1Audit and Review Summary..................................366.5.2Safety Evaluation Report Input................................376.6Documents Reviewed and Document Retention........................42APPENDIX APROJECT TEAM MEMBERSHIP.........................................A-1APPENDIX BRLRC SCHEDULE FOR IP2 AND IP3 LRA SAFETY REVIEW..................B-1APPENDIX C AGING MANAGEMENT PROGRAM ASSIGNMENTS ........................C-1APPENDIX D AGING MANAGEMENT REVIEW ASSIGNMENTS...........................D-1APPENDIX E TIME-LIMITED AGING ANALYSIS REVIEW ASSIGNMENTS..................E-1APPENDIX FCONSISTENT WITH GALL REPORT AMP AUDIT/REVIEW WORKSHEET........F-1APPENDIX G PLANT-SPECIFIC AMP AUDIT/REVIEW WORKSHEET.......................G-1APPENDIX HAMR COMPARISON WORKSHEETS.....................................H-1APPENDIX I ACRONYMS, ABBREVIATIONS, AND INITIALISMS...........................I-1 TABLES Table 1. Aging Management Program Element Descriptions..........................43Table 2. Notes for License Renewal Application Tables 3.X.2-Y.......................45 FIGURES Figure 1. Audit of AMPs that are Consistent with the GALL Report.....................46Figure 2. Audit of Plant-Specific AMPs ...........................................47 Figure 3. Review of AMRs that are Consistent with the GALL Report ...................48 Figure 4. Review of TLAAs and Exemptions (from NEI 95-10, Revision 6) ...............49 Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan 1 Audit and Review Plan for Plant Aging Management Reviews and Programs 1.INTRODUCTION By letter dated April 23, 2007, Entergy Nuclear Operations Inc. submitted to the U.S. Nuclear Regulatory Commission (NRC) its application for renewal of Operating License Nos. DPR-26 and

DPR-64 respectively for the Indian Point Nuclear Generating Unit Nos. 2 and 3 (IP2) and (IP3).

The applicant requested renewal of the operating licenses for an additional 20 years beyond the

40-year current license term.

In support of the staff's safety review of the license renewal application (LRA) for IP2 and IP3, the Division of License Renewal (DLR), Branch C (RLRC), will lead a project team that will audit and review selected aging management reviews (AMRs) and associated aging management

programs (AMPs), and time-limited aging analyses (TLAAs) developed by the applicant to

support its LRA for IP2 and IP3. The project team will include NRC staff and engineers provided

by BNL, RLRC's technical assistance contractor. Appendix A, "Project Team Membership," lists

the project team members. This document is the RLRC plan for auditing and reviewing plant

aging management reviews and aging management programs for IP2 and IP3.

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

"Requirements for Renewal of Operating Licenses for Nuclear Power Plants;" the guidance

provided in NUREG-1800, Revision 1, "Standard Review Plan for Review of License Renewal

Application for Nuclear Power Plants" (SRP-LR), dated September 2005; the guidance provided

in NUREG-1801, Revision 1, "Generic Aging Lessons Learned (GALL) Report," dated

September 2005; and this plan. For the scope of work defined in this audit plan, the project team

will verify that the applicant's aging management activities and programs will adequately manage

the effects of aging on structures and components, so that their intended functions will be

maintained consistent with the IP2 and IP3 current licensing basis (CLB) for the period of

extended operation.The project team will perform its work at NRC Headquarters, Rockville, Maryland; at BNL's offices in Upton, NY; and at the IP2 and IP3 site in Buchanan, NY. The project team will perform

its work in accordance with the schedule shown in Appendix B, "Schedule."

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

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

Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan 2Summary of Information Provided in License Renewal Application

.Description of the information contained in the license renewal application for IP2 and IP3 that is applicable to this plan.Overview of the Audit, Review, and Documentation Procedure. Summary of the process the project team will follow to audit and review the LRA information

that is within its scope of review.

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

its work.Appendices. Supporting information. The project team membership is shown in Appendix A and the schedule is shown in Appendix B. The team's work

assignments are shown in Appendix C, "Aging Management Program

Assignments," Appendix D, "Aging Management Review Assignments," Appendix

E "Time-Limited Aging Analysis Review Assignments." Appendices F, G, and H

are the worksheets that the individual team members use to informally document

the results of their review and audit work. The application of these worksheets is

discussed in Section 6 of this plan. Appendix I is a list of the acronyms, abbreviations, and initialisms used in this plan.2.BACKGROUND In 10 CFR 54.4, the scope of license renewal is defined as those structures, systems, and components (SSCs) (1) that are safety-related, (2) whose failure could affect safety-related

functions, and (3) that are relied on to demonstrate compliance with the NRC's regulations for

fire protection, environmental qualification, pressurized thermal shock, anticipated transients

without scram, and station blackout.

An applicant for a renewed license must review all SSCs within the scope of license renewal to identify those structures and components (SCs) subject to an AMR. SCs subject to an AMR are

those that perform an intended function without moving parts or without a change in configuration

or properties (passive), and that are not subject to replacement based on qualified life or

specified time period (long-lived). Pursuant to 10 CFR 54.21(a)(3), an applicant for a renewed

license must demonstrate that the effects of aging will be managed in such a way that the

intended function(s) of those SCs will be maintained, consistent with the CLB, for the period of

extended operation. 10 CFR 54.21(d) requires that the applicant submit a supplement to the final

safety analysis report (FSAR) that contains a summary description of the programs and activities

that it credited to manage the effects of aging during the extended period of operation.

The SRP-LR provides staff guidance for reviewing applications for license renewal. The GALL Report is a technical basis document. It summarizes staff-approved AMPs for the aging

management of a large number of SCs that are subject to an AMR. It also summarizes the aging Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan 3 management evaluations, programs, and activities acceptable to the NRC staff for managing aging of most of the SCs used in commercial nuclear power plants, and serves as a reference for

both the applicant and staff reviewers to quickly identify those AMPs and activities that the staff

has determined will provide adequate aging management during the extended period of

operation. If an applicant commits to implementing these staff-approved AMPs, the time, effort, and resources needed to review an applicant's LRA will be greatly reduced, thereby improving

the efficiency and effectiveness of the license renewal review process. The GALL Report

identifies (1) systems, structures, and components, (2) component materials, (3) the

environments to which the components are exposed, (4) the aging effects associated with the

materials & environments, (5) the AMPs that are credited to manage the aging effects, and (6)

recommendations for further applicant evaluations of aging effects and their management for

certain component types.

The GALL Report is treated in the same manner as an approved topical report that is generically applicable. An applicant may reference the GALL Report in its LRA to demonstrate that its

programs correspond to those that the staff reviewed and approved in the GALL Report. If the

material presented in the LRA is consistent with the GALL Report and is applicable to the

applicant's facility, the staff will accept the applicant's reference to the GALL Report. In making

this determination, the staff considers whether the applicant has identified specific programs

described and evaluated in the GALL Report but does not conduct a re-review of the substance

of the matters described in the GALL Report. Rather, the staff confirms that the applicant verified

that the approvals set forth in the GALL Report apply to its programs.

If an applicant takes credit for a GALL AMP, it is incumbent on the applicant to ensure that the plant AMP contains all the program elements of the referenced GALL AMP. In addition, the

conditions at the plant must be bounded by the conditions for which the GALL AMP was

evaluated. The applicant must certify in its LRA that it completed the verifications and that they

are documented onsite in an auditable form.

The SRP-LR also provides staff guidance for reviewing TLAAs. Pursuant to 10 CFR 54.21(c)(1), a license renewal application is required to provide a list of TLAAs, as defined in 10 CFR 54.3. In

addition, the applicant must provide a list of plant-specific exemptions granted under 10 CFR

50.12 that are based on TLAAs. The number and type of TLAAs vary depending on the plant-

specific CLB.

All six criteria set forth in 10 CFR 54.3 must be satisfied to conclude that a calculation or analysis is a TLAA. Pursuant to 10 CFR 54.3, TLAAs are those licensee calculations and analyses that:1. Involve systems, structures, and components within the scope of license renewal, as delineated in 10 CFR 54.4(a).2.Consider the effects of aging.3.Involve time-limited assumptions defined by the current operating term, for example, 40 years.

Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan 44.Were determined to be relevant by the licenses in making a safety determination.5.Involve conclusions or provide the basis for conclusions related to the capability of the system, structure, or component to perform its intended function(s), as delineated in 10 CFR 54.4(b).6.Are contained or incorporated by reference in the CLB.

Finally, the applicant must demonstrate that the TLAAs remain valid for the period of extended operation; the TLAAs have been projected to the end of the period of extended operation; or the

effects of aging on the intended function(s) will be adequately managed for the period of

extended operation. The staff performs a technical review as well as reviews the area relating to

the identification of TLAAs. The staff also confirms that the applicant did not omit any TLAAs, as

defined in 10 CFR 54.3.3.OBJECTIVES The overall objective of the audit and review described in this plan is to verify compliance with 10 CFR 54.21(a)(3). Therefore, the audit and review process helps ensure that for each structure

and component within the scope of the project team's review, the effects of aging will be

adequately managed so that the intended function(s) will be maintained consistent with the CLB

for the period of extended operation.

The audit and review procedure for IP2 and IP3 is described in Sections 5 and 6 of this plan. It is intended to accomplish the following objectives:For IP2 and IP3 AMPs that the applicant claims are consistent with GALL AMPs, verify that the plant AMPs contain the program elements of the referenced GALL

AMP and that the conditions at the plant are bounded by the conditions for which

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

conditions for which the GALL AMPs were evaluated. In addition, verify that the

applicant has documented an acceptable technical basis for each exception.For IP2 and IP3 AMPs that the applicant claims will be consistent with GALL AMPs after specified enhancements are implemented, verify that the plant AMPs, with the enhancements, will be consistent with the referenced GALL AMPs, or are

acceptable on the basis of a technical review. In addition, verify that the applicant

identified the enhancements as commitments in the Updated Final Safety

Analysis Report (UFSAR) or other docketed correspondence.For plant-specific IP2 and IP3 AMPs, verify the AMPs are acceptable on the basis of a technical review. Use the worksheet provided in Appendix G ro assess the Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan 5 adequacy of the AMPs against 10 program elements described in Branch Technical Position RLSB-1 "Aging Management Review - Generic," in Appendix A

to the SRP-LR.For AMR line items that the applicant claims are consistent with the GALL Report, determine that these AMR line items are consistent with the recommendation of

the GALL Report.For AMR line items (Table 1s) that the applicant claims are not applicable with the GALL Report, determine that these AMR line items are acceptable on the basis of a technical review.For AMR line items that the applicant claims consistent with AMR line items that the staff has previously approved for another plant, determine that these AMR line

items are acceptable on the basis of a technical review.For AMR line items for which the GALL Report recommends further evaluation, determine that the applicant has addressed the further evaluation, and evaluating the AMRs in accordance with the SRP-LR.For TLAAs, determine that the applicant has properly identified the TLAAs. TLAAs are certain plant-specific safety analyses that are based on explicitly assumed 40-

year plant life (for example, aspects of the reactor vessel design). Pursuant to 10

CFR 54.21(c)(1), a license renewal applicant is required to provide a list of

TLAAs, as defined in 10 CFR 54.3. The area relating to the identification of TLAAs

is reviewed. TLAAs may have developed since issuance of a plant's operating

license. As indicated in 10 CFR 54.30, the adequacy of the plant's CLB, which

includes TLAAs, is not an area within the scope of the license renewal review.

Any question regarding the inadequacy of the CLB must be addressed under the

backfit rule (10 CFR 50.109) and is separate from the license renewal process.Determine that the applicant has demonstrated that (1) the TLAAs remain valid for the period of extended operation; (2) the TLAAs have been projected to the end of the period of extended operation; or (3) the effects of aging on the intended

function(s) will be adequately managed for the period of extended operation.4.

SUMMARY

OF INFORMATION PROVIDED IN THE LICENSE RENEWAL APPLICATION4.1Aging Management Review Results The IP2 and IP3 LRA closely follows the standard LRA format presented in NEI 95-10, "Industry Guideline for Implementing the Requirements of 10 CFR Part 54 - The License Renewal Rule,"

Revision 6, June 2005. Section 3 of the LRA provides the results of the aging management

review for structures and components that the applicant identified as being subject to aging

management review.

Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan 6 LRA Table 3.0-1, Table 3.0-2, and Table 3.0-3 provide descriptions of the mechanical, structural,and electrical and instrument and controls service environments, respectively, used in the AMRs

to determine the aging effects requiring management. Results of the AMRs are presented in two

different types of tables. The applicant refers to the two types of tables as Table 1 and Table 2.The first table type is a series of six tables labeled Table 3.X.1, where "X" is the system/

component group number (see table below), and "1" indicates it is a Table 1 type. For example, in the reactor coolant system subsection of the LRA Section 3, this is Table 3.1.1, and in the

engineered safety features subsection of LRA Section 3, this is Table 3.2.1. For ease of

discussion, these table types will hereafter be referred to as "Table 1." These tables are derived

from the corresponding tables in NUREG-1801, Volume 1, and present summary information

from the AMRs.

Definition1Reactor Vessel, Internals, and Reactor Coolant System2Engineered Safety Features Systems 3Auxiliary Systems 4Steam and Power Conversion Systems 5Containments, Structures, and Component Supports 6Electrical and Instrumentation and ControlsThe second table type is a series of tables labeled Table 3.X.2-Y, where "X" is the system/

component group number, "2" indicates it is a Table 2 type, and "Y" indicates the subgroup number within group "X." For example, within the reactor coolant system subsection, the AMR

results for the reactor vessel and internals are presented in Table 3.1.2-1, and the results for the

steam generators are in Table 3.1.2-3. In the engineered safety features subsection, the nuclear

sampling system results are presented in Table 3.2.2-1, and the containment spray system is in

Table 3.2.2-2. For ease of discussion, these table types will hereafter be referred to as "Table 2."

These tables present the results of the AMRs.4.1.1IP2 and IP3 AMR Comparison with the GALL Report

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

with the two table types described above.

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

information set forth in the tables of NUREG-1801. Results of that comparison are provided in

the following two table types, Table 1 and Table 2.

Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan 74.1.1.1Purpose of Table 1 The purpose of Table 1 is to provide a summary comparison of how the IP2 and IP3 AMR results align with the corresponding table of NUREG-1801, Volume 1. These tables are essentially the

same as Tables 1 through 6 provided in NUREG-1801, Volume 1, with the following exceptions:The "ID" column is labeled "Item Number" and the spacing has been expanded to include the table number.The "Type" column has been deleted. Items applicable to BWRs only are noted as such.The "Related Generic Item" and "Unique Item" columns have been replaced by a"Discussion" column.

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

Further information is provided in the "Discussion" column. The following are examples of information that might be contained within this column:Any "Further Evaluation Recommended" information or reference to the location of that information.The name of a plant-specific program being used.Exceptions to the NUREG-1801 assumptions.

A discussion of how the line item is consistent with the corresponding line item in NUREG-1801, Volume 1, when it may not be intuitively obvious.A discussion of how the line item is different than the corresponding line item in NUREG-1801, Volume 1, when it may appear to be consistent.4.1.1.2Purpose of Table 2

Table 2 provides results of the aging management reviews for those structures and components identified in Section 2 as being subject to aging management review. There is a Table 2 for each

aging management review within a NUREG-1801 system group. For example, the engineered

safety features system group contains tables specific to nuclear sampling, containment spray, containment integrated leak rate test, decontamination, liquid radwaste, reactor makeup water, containment purge HVAC, breathing air, hydrogen control, high pressure coolant injection, and

residual heat removal.

Table 2 consists of the following nine columns:

Component Type Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan 8 Column 1 identifies the component types from Section 2 of this application that are subject to aging management review. Similar to Section 2, component types are listed in alphabetical

order. In the Class 1 tables in Section 3.1 and the structural tables in Section 3.5, component

types are alphabetical by sub-groups.

The term "piping" in component lists may include pipe, pipe fittings (such as elbows & reducers), flow elements, orifices, and thermowells. If such components have unique tag numbers or the

specific component has a function other than pressure boundary, then flow elements, orifices

and thermowells are identified as a separate component type.

The term "heat exchanger (shell)" may include the bonnet/channel head and tubesheet. In cases where the bonnet/channel head and tubesheet provide a unique material and environment

combination, they will be uniquely identified as a separate component type.

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

Intended Function Column 2 identifies the license renewal intended functions (using abbreviations where necessary) for the listed component types. Definitions and abbreviations of intended functions

are listed in Table 2.0-1 in Section 2.

Material Column 3 lists the specific materials of construction for the component type being evaluated.Environment Column 4 lists the environment to which the component types are exposed. Internal/external service environments are indicated. A description of these environments is provided in Tables

3.0-1, 3.0-2, and 3.0-3 for mechanical, structural, and electrical and instrument and controls

components, respectively.Aging Effect Requiring Management Column 5 lists the aging effects requiring management for material and environment combinations for each component type.Aging Management Programs (AMP)

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

NUREG-1801, Vol. 2, Item Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan 9 Column 7 documents identified consistencies by noting the appropriate NUREG-1801, Volume 2, item number. If there is no corresponding item number in NUREG-1801, Volume 2, for a

particular combination of factors, column 7 indicates "None" for this item.

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

Material.

Environment.

Aging effect requiring management.

Aging management program.

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

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

Environment.

Aging effect requiring management.

Aging management program.

Notes Column 9 contains notes that are used to describe the degree of consistency with the line items in NUREG-1801, Volume 2. Notes that use letter designations are standard notes based on a

letter from A. Nelson, NEI, to P. T. Kuo, NRC, "U.S. Nuclear Industry's Proposed Standard

License Renewal Application Format Package, Request NRC Concurrence," dated January 24, 2003 (ML030290201). The staff concurred with the NEI standardized format for license renewal

applications by letter dated April 7, 2003, from P. T. Kuo, NRC, to A. Nelson, NEI (ML030990052). Notes that use numeric designators are specific to IP2 and IP3.

IP2 and IP3 LRA Table 2 contains the aging management review results and indicates whether the results correspond to line items in Volume 2 of the GALL Report. Correlations between the

combination IP2 and IP3 LRA Table 2 and a combination for a line item in Volume 2 of the GALL

Report are identified by the GALL Report item number in Column 7. If "None" is indicated in

column 7, the applicant did not identify a corresponding combination in the GALL Report. If the

applicant identified a GALL Report line item, the next column provides a reference to a Table 1

row number. This reference corresponds to the GALL Report, Volume 2, "roll-up" to the GALL

Report, Volume 1, tables.

Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan 104.1.2Plant-Specific Programs Many of the GALL Report evaluations refer to plant-specific programs. In these cases, the applicant considers the IP2 and IP3 evaluation to be consistent with the GALL Report if the other

elements are consistent. Note E is used to indicate that the AMR line-item is consistent with the

GALL Report for material, environment, and aging effect, but a different AMP is credited. The

project team will evaluate these line-items to determine that the AMP credited by the applicant is

applicable.4.2 Time-Limited Aging Analyses The IP2 and IP3 LRA closely follows the standard LRA format presented in Revision 6 of NEI 95-10, "Industry Guidelines for Implementing the Requirements of 10 CFR Part 54 - The License

Renewal Rule." Section 4 of the IP2 and IP3 LRA addresses TLAAs. In Section 4.1.1, the IP2

and IP3 LRA states that the calculations and evaluations that could potentially meet the six

criteria of 10 CFR 54.3 were identified by searching CLB documents including the following:A.The Updated Safety Analysis Report (USAR)B.Technical Specifications C.The NRC Safety Evaluation Report (SER) for the original operating license D.All subsequent NRC Safety Evaluations (SEs)

E.IP2 and IP3 and NRC docketed licensing correspondence.

Also, in Section 4.1.1, the IP2 and IP3 LRA states that as required by 10 CFR 54.21(c)(1), an

evaluation of IP2 and IP3-specific TLAAs must be performed to demonstrate that:(i)The analyses remain valid for the period of extended operation;(ii)The analyses have been projected to the end of the period of extended operation; or(iii)The effects of aging on the intended function(s) will be adequately managed for the period of extended operation.

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

Section 10 CFR 54.21(c) also requires that the application for a renewed license includes a list of plant-specific exemptions granted pursuant to 10 CFR 50.12 and in effect that are based on

TLAAs as defined in 10 CFR 54.3. The IP2 and IP3 performed this by reviewing IP2 and IP3

docketed correspondence which identified IP2 and IP3 exemptions. Section 4.1.2 of the IP2 and

IP3 LRA states that there are no IP2 and IP3 exemptions that depend on TLAAs.

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

the next table.

Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan 11 TLAA DescriptionResolution OptionSectionReactor Vessel Neutron EmbrittlementAnalyses 4.2 Charpy upper-shelf energy Analyses projected 10 CFR 54.21(c)(1)(ii) 4.2.2 Pressure/temperature limits P-T limit curves managed 10 CFR 54.21(c)(1)(iii) 4.2.3 Low temperature overpressure protection (LTOP)

LTOP limits managed 10CFR54.21(c)(1)(iii) 4.2.4 Pressurized Thermal Shock IP2: Analysis projected 10 CFR 54.21(c)(1)(ii)

IP3: Aging effects managed 10 CFR 54.21(c)(1)(iii) 4.2.5Metal Fatigue Analyses 4.3 Reactor vessel Analyses remain valid 10 CFR 54.21(c)(1)(i) 4.3.1.1 Reactor vessel internals Analyses remain valid 10 CFR 54.21(c)(1)(i) 4.3.1.2 PressurizerAnalyses remain valid 10 CFR 54.21(c)(1)(i) 4.3.1.3 Pressurizer insurge/outsurge transients Analyses remain valid 10 CFR 54.21(c)(1)(i) 4.3.1.3 Steam generator Analyses remain valid 10 CFR 54.21(c)(1)(i) 4.3.1.4 Reactor coolant pump Analyses remain valid 10 CFR 54.21(c)(1)(i) 4.3.1.5 Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan TLAA DescriptionResolution OptionSection 12 Control rod drive mechanisms Analyses remain valid 10 CFR 54.21(c)(1)(i) 4.3.1.6 Regenerative letdown heat exchanger Analyses remain valid 10 CFR 54.21(c)(1)(i) 4.3.1.7 Class 1 piping and in-line components - ANSI B31.1 piping Analyses remain valid 10 CFR 54.21(c)(1)(i) 4.3.1.8 Class 1 piping and in-line components - pressurizer surge line Analyses remain valid 10 CFR 54.21(c)(1)(i) 4.3.1.8Class 1 piping and in-line components - thermowellsAnalyses remain valid 10 CFR 54.21(c)(1)(i) 4.3.1.8 Class 1 piping and in-line components - chargingsystemAnalysis will be updated as part of environmental fatigue evaluation.

See Section 4.3.3.

4.3.1.8 Class 1 piping and in-line components - loop 3

accumulator nozzle (IP2 only)

Analyses remain valid 10 CFR 54.21(c)(1)(i) 4.3.1.8 Non-Class 1 piping and in-line components Analyses remain valid 10 CFR 54.21(c)(1)(i) 4.3.2 Non-Class 1, non-piping components - residual heat

removal heat exchanger Analyses remain valid 10 CFR 54.21(c)(1)(i) 4.3.2 Effects of reactor water environment on fatigue life Analyses remain valid 10 CFR 54.21(c)(1)(i)

OR Aging effect managed 10 CFR 54.21(c)(1)(iii) 4.3.3 Environmental Qualification of Electrical Components Aging effect managed 10 CFR 54.21(c)(1)(iii) 4.4 Concrete Containment Tendon PrestressN/A4.5 Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan TLAA DescriptionResolution OptionSection 13 Containment Liner Plate and PenetrationsFatigue Analyses IP2: Liner Plate at Containment Penetration (feedwater line #22)

IP3: None IP2: Analyses remain valid 10 CFR 54.21(c)(1)(i) for liner plate; no TLAA for penetration IP3: No TLAA 4.6Plant-Specific Time-Limited Aging Analyses 4.7 Reactor Coolant Pump Flywheel AnalysisN/A4.7.1Leak Before Break (LBB)Analysis remains valid 10 CFR 54.21(c)(1)(i) 4.7.2 Steam Generator Flow Induced

Vibration and Tube Wear IP2: Analysis remains valid 10 CFR 54.21(c)(1)(i)

IP3: Analyses projected 10 CFR 54.21(c)(1)(ii) 4.7.35.OVERVIEW OF AUDIT, REVIEW, AND DOCUMENTATION PROCEDURE The project team will follow the procedure specified in Section 6 of this plan to perform its audits and reviews and to document the results of its work. The process covered by the procedure is

summarized below.5.1Aging Management Programs For the IP2 and IP3 AMPs for which the applicant claimed consistency with the AMPs included in the GALL Report, the project team will review the IP2 and IP3 AMP descriptions and compare

program elements for the IP2 and IP3 AMPs to the corresponding program elements for the

GALL AMPs. The project team will verify that the IP2 and IP3 AMPs contain the program

elements of the referenced GALL program and that the conditions at the plant are bounded by

the conditions for which the GALL program was evaluated. Table 1 of this audit and review plan

summarizes the program elements that comprise an aging management program. The License

Renewal Branch C (RLRC) will review and determine the adequacy of the applicant's 10 CFR 50, Appendix B Program. Other aspects of these program elements will be reviewed by the

project team.

For IP2 and IP3 AMPs that have one or more exception and/or enhancement, the project team will review each exception and/or enhancement to determine whether the exception and/or

enhancement is acceptable, and whether the AMP, as modified by the exception and/or the Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan 14 enhancement, would adequately manage the aging effects for which it is credited. In some cases, the project team will identify differences that the applicant did not identify between the IP2

and IP3 AMPs credited by the applicant and the GALL Report AMPs. In these cases, the project

team will review the difference to determine whether the IP2 and IP3 AMP, as modified by the

difference, would adequately manage the aging effects for which it is credited.

For those IP2 and IP3 AMPs that are not included in the GALL Report (i.e., plant- specific AMPs), the project team will review the AMP against the ten program elements defined in

Appendix A of the SRP-LR. The RLRC will review and determine the adequacy of the applicant's

10 CFR 50, Appendix B Program. Other aspects of these program elements will be reviewed by

the project team. On the basis of its reviews, the project team will determine whether these

AMPs will manage the aging effects for which they are credited.5.2Aging Management Reviews The AMRs in the IP2 and IP3 LRA fall into three broad categories: (1) AMR results that are consistent with the GALL Report (i.e., those that the GALL Report concludes are adequate to

manage aging of the components referenced in the GALL Report), (2) those for which the GALL

Report concludes that aging management is adequate, but further evaluation is recommended

for certain aspects of the aging management process, and (3) AMR results that are not

consistent with or not addressed in the GALL Report. For the first category AMR reviews, the

project team will determine (1) whether the AMRs reported by the applicant to be consistent with

the GALL Report are indeed consistent with the GALL Report, and (2) whether the AMRs

reported by the applicant to be managed using plant-specific AMPs are technically acceptable.

For the second category AMR review, for which the applicant claimed consistency with the GALL

Report, and for which the GALL Report recommends further evaluation, the project team will

review the applicant's evaluation to determine if it adequately addressed the issues for which the

GALL Report recommended further evaluation. For the third category AMR review, the project

team will review the results of the AMRs for material, environment, AERM, and AMP

combinations to determine the technical adequacy.5.3Time-Limited Aging Analyses Generally, the TLAAs in the IP2 and IP3 LRA fall into the broad category of those that are consistent with the NUREG-1800 TLAA categories. However, there are 12 plant-specific

exemptions identified in the IP2 and IP3 LRA that depend on TLAAs.

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

Further, the project team will conduct both regulatory evaluations and technical evaluations to determine, as defined in 10 CFR 54.3, that each TLAA meets the following six criteria:1.Involve systems, structures, and components that are within the scope of license renewal, as delineated in 10 CFR 54.4(e).

Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan 152.Consider the effects of aging.3.Involve time-limited assumptions defined by the current operating term (40 years).

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

5.Involve conclusions, or provide the basis for conclusions, related to the capability of the system, structure, and component to perform its intended functions, as delineated in 10 CFR 54.4(b).6.Contained or incorporated by reference in the CLB.

In addition, the project team will also review the TLAAs to determine if there are emerging issues that should be further evaluated by technical specialists in the NRC Divisions of Component

Integrity (DCI) or the Division of Engineering (DE). This is not expected to be an issue for TLAAs for which the applicant claims consistency with 10 CFR 54.21(c)(I) "the analyses remain valid for

the period of extended operation" or 10 CFR 54.21(c)(iii) "the effects of aging on the intended

function(s) will be adequately managed for the period of extended operation."

For TLAAs for which the applicant claims consistency with 10 CFR 54.21(c)(ii) - "the analyses have been projected to the end of the period of extended operation," the audit team leader will be

consulted to determine which TLAAs the audit team will be capable of reviewing. Consideration

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

analysis. Candidates for further review by technical specialists could be such as the following:A.Reactor Vessel Neutron Embrittlement B.Plant-Specific TLAAs5.4UFSAR Supplement Review Consistent with the SRP-LR, for the AMRs and associated AMPs that it will review, the project team will review the UFSAR supplement that summarizes the applicant's programs and activities

for managing the effects of aging for the extended period of operation. The project team will also

review any commitments associated with its programs and activities made by the applicant and

verify that they are acceptable for the stated purpose.5.5Documents Reviewed by the Project Team In performing its work, the project team will rely heavily on the LRA, the audit and review plan, the SRP-LR, and the GALL Report. The project team will also examine the applicant's precedent

review documents, its AMP, AMR, and TLAA basis documents (catalogs of the documentation

used by the applicant to develop or justify its AMPs, AMRs, and TLAAs), and other applicant

documents, including selected implementing procedures, to verify that the applicant's activities

and programs will adequately manage the effects of aging on structures and components.

Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan 165.6Status Meeting At the conclusion of its audits and reviews, the project team will debrief the applicant's license renewal staff and management regarding the status of the audits and reviews of the LRA AMPs, AMRs and TLAAs assigned to the project team. 5.7Documentation Prepared by the Project Team The project team will prepare an audit and review plan, worksheets, work packages, requests for additional information (RAIs), an audit and review summary, and a safety evaluation report (SER) input. The project team will also prepare questions during site visits and will track the

applicant's responses to the questions.5.7.1Audit and Review Plan

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

5.7.2Worksheets

Each project team member will informally document the results of his or her work on a variety of worksheets. The worksheets are shown in Appendix F, "Consistent with GALL Report AMP

Audit/Review Worksheet"; Appendix G, "Plant-Specific AMP Audit/Review Worksheet"; and

Appendix H, "AMR Comparison Worksheets." The use of the worksheets is described in Section

6 of this plan.5.7.3Questions

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

also track the applicant's answers to the questions.5.7.4Work Packages

After each site visit, the project team leader, in conjunction with the project manager, will assemble work packages for any work that the team will refer to the Office of Nuclear Reactor

Regulation (NRR) Division of Engineering (DE) or the Division of Component Integrity (DCI) for

review. Each work package will include a work request and any applicable background

information on the review item that was gathered by the project team.5.7.5Requests for Additional Information

The review process described in this plan is structured to resolve as many questions as possible during the site visits. As examples, the site visits are used to obtain clarifications about the LRA

and explanations as to where certain information may be found in the LRA or its associated

documents. Nevertheless, there may be occasions where an RAI is appropriate to obtain

information to support a SER finding. The need for RAIs will be determined by the project team Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan 17 leader during the in-office project staff review or during site visits through discussions with the individual project team members. When the project team leader determines that an RAI is

needed, the project team member who is responsible for the area of review will prepare the RAI.

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

After the NRC receives a response to an RAI from the applicant, the team leader will provide the response to the team member who prepared the RAI. The team member will review the response

and determine if it resolves the issue that was the reason for the RAI. The team member will

document the disposition of the RAI in the SER input.5.7.6Audit and Review Summary

At the conclusion of the audits and reviews, the project team will prepare a summary of the audits and reviews highlighting the status of its review and any potential RAIs.5.7.7Safety Evaluation Report Input

The project team will prepare SER input, based on its audit and review, as described in Section 6.5.2 of this plan.6.PLANNING, AUDIT, REVIEW, AND DOCUMENTATION PROCEDURE This section of the audit and review plan contains the detailed procedures that the project team will follow to plan, perform, and document its work.6.1Planning Activities6.1.1Schedule for Key Milestones and Activities The project team leader will establish the schedule for the key milestones and activities, consistent with the overall schedule for making the licensing decision. Key milestones and activities include, as a minimum:Receiving the LRA from the applicant.

Receiving work split tables from the project manager.

Making individual work assignments.

Training project team members.

Holding the project team kickoff meeting.

Preparing the audit and review plan.

Scheduling site visits.

Scheduling in-office review periods.

Preparing questions.

Preparing RAIs.

Issuing audit and review summary report.

Issuing SER input.

Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan 18 Site visits will be scheduled on the basis of discussions between the project team leader, the NRC license renewal project manager, and the applicant.

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

6.1.2Work Assignments

The technical assistance contractor will propose team member work assignments to the NRC project team leader. The NRC project team leader will approve all work assignments. After the

audit plan is issued, the team leader may reassign work as necessary.

The contractor will develop assignment tables that show which project team member will review each AMP and AMR. Appendix A of this plan shows the project team membership. Appendix C

shows the team member assignments for the AMPs. Appendix D of this plan shows the team

member assignments for the AMRs. Appendix E shows the project team member assignments

for TLAAs.6.1.3Training and Preparation

The training and preparation will include the following:A.A description of the audit and review process.

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

1.GALL Report2.SRP-LR 3.Interim Staff Guidance for License Renewal (ISG-LR) 4.LRA AMPs 5.LRA AMRs 6.LRA TLAAs 7.Basis documents (catalogues of information assembled by the applicant to demonstrate the bases for its programs and activities)8.Implementing procedures 9.Operating experience reports 10.RAIs, audit reports, and SERs for similar plants 11.Applicant's 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 summary report, and SER input.

Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan 19F.Process for interfacing with NRC technical reviewers.6.2Aging Management Program (AMP) Audits and Reviews6.2.1Types of AMPs There are two types of AMPs: those that the applicant claims are consistent with AMPs contained in the GALL Report, and those that are plant-specific. The process for auditing and

reviewing both types of AMPs is presented in the following sections of this plan.6.2.2Scope of AMP Elements to be Audited and Reviewed

Table 1 of this plan shows the 10 program elements that are used to evaluate the adequacy of each aging management program. These program elements are presented in Branch Technical

Position (BTP) RLSB-1, "Aging Management Review - Generic," in Appendix A of the SRP-LR, and are summarized in the GALL Report.

The program elements audited or reviewed is the same for both AMPs that are consistent with the GALL Report and for plant-specific AMPs. The RLRC will review and determine the

adequacy of the applicant's 10 CFR 50, Appendix B Program. Other aspects of these program

elements will be reviewed by the project team.6.2.3Plant AMPs that Are Consistent with the GALL Report

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

that the applicant claims is consistent with the GALL Report.

PreparationA.For the plant AMP being reviewed, identify the corresponding GALL AMP.

B.Review the associated GALL AMP and identify those elements that will be audited.C.Identify the documents needed to perform the audit. These may include, but are not limited to, the following:1.GALL Report2.SRP-LR 3.ISGs 4.RAIs and SERs for similar plants 5.LRA 6.Basis documents 7.Implementation procedures 8.Operating experience reports (plant-specific and industry)

Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan 209.UFSAR Audit/ReviewA.Confirm that IP2 and IP3 AMP program elements are consistent with the corresponding elements of the GALL Report AMP by answering the following questions and then following the process shown in Figure 1.1.Did the applicant identify any exceptions to the GALL Report AMP?2.Did the applicant identity any enhancements to the GALL Report AMP?

3.Are the elements consistent with the GALL Report AMP?B.If either of the above questions results in the identification of an exception/enhancement or a difference to the GALL AMP, determine whether it is

acceptable on the basis of an "adequate technical justification."C.If an acceptable basis exists for an exception/enhancement or difference, document the basis in the worksheet and later the SER input.D.Review the industry and plant-specific operating experience associated with the AMP. The review is to identify aging effects requiring management that are not identified by the industry guidance documents (such as EPRI tools) and to confirm

the effectiveness of aging management programs. The project team members

should consider the industry guidance when assessing operating experience and

formulating questions for the applicant. The industry guidance (from NEI 95-10, Revision 6) is as follows:1.Plant-Specific Operating Experience with Aging Effects Requiring Management. A plant-specific operating experience review should assess the operating and maintenance history. A review of the prior 5 to 10 years

of operating and maintenance history should be sufficient. The results of

the review should confirm consistency with documented industry operating

experience. Differences with previously documented industry experience

such as new aging effects or lack of aging effects allow consideration of

plant-specific aging management requirements.2.Plant-Specific Operating Experience with existing Aging Management Programs. The operating experience of AMPs, including corrective actions

resulting in program enhancements or additional programs, should be

considered. The review should provide objective evidence to support the

conclusion that the effects of aging will be managed so that the intended

function(s) will be maintained during the extended period of operation.

Guidance for reviewing industry operating experience is presented in BTP

RLSB-1 in Appendix A.1 of the Branch Technical Positions in

NUREG-1800.

Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan 213.Industry Operating Experience. Industry operating experience and its applicability should be assessed to determine whether it changes plant-specific determinations. NUREG-1801 is based upon industry

operating experience prior to its date of issue. Operating experience after

the issue date of NUREG-1801 should be evaluated and documented as

part of the aging management review. In particular, generic

communications such as a bulletin, a generic letter, or an information

notice should be evaluated for impact upon the AMP. The evaluation

should check for new aging effects or a new component or location

experiencing an already identified aging effect.E.If it is necessary to ask the applicant a question to clarify the basis for accepting a program element, or an exception or a difference to the GALL Report AMP, follow

the logic process shown in Figure 1.F.If it is necessary for the applicant to submit additional information to support the basis for accepting the justification, an exception, or a difference to a program

element, the applicant may agree to voluntarily submit the required information as

a supplement (docketed letter submitted under oath and affirmation) to the LRA. If

not, the NRC may issue an RAI to obtain the information.

AMP Audit Worksheets Document the audits/reviews using the worksheet provided in Appendix F, "Consistent with

GALL Report AMP Audit/Review Worksheet."6.2.4Plant-Specific AMPs

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

Pre-Review PreparationA.Review Section A.1.2.3 of the SRP-LR and identify those element criteria that will be reviewed.B.Identify the documents needed to perform the audit. These may include, but are not limited to, the following:

1.GALL Report2.SRP-LR 3.ISG-LR 4.RAIs and SERs for similar plants Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan 225.LRA6.Basis documents 7.Implementation procedures 8.Operating experience reports (plant-specific and industry) 9.UFSAR 10.Lessons Learned Developed by RLRC Audit/ReviewA.Audit/review the IP2 and IP3 AMP program elements and determine that they are in accordance with the acceptance criteria for the corresponding program

elements of Section A.1.2.3 of the SRP-LR. B.Review the industry and plant-specific operating experience associated with the AMP. This is an area of review emphasis. The review is to identify aging effects

requiring management that are not identified by the industry guidance documents (such as EPRI tools) and to confirm the effectiveness of aging management

programs. The project team members should consider the industry guidance

when assessing operating experience and formulating questions for the applicant.

The industry guidance (from NEI 95-10, Revision 6) is as follows:1.Plant-Specific Operating Experience with Aging Effects Requiring Management. The review should assess the operating and maintenance history. A review of the prior 5 to 10 years of operating and maintenance

history should be sufficient. The results of the review should confirm

consistency with documented industry operating experience. Differences

with previously documented industry experience such as new aging effects

or lack of aging effects allow consideration of plant-specific aging

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

The operating experience of aging management programs, including past corrective actions resulting in program enhancements or additional

programs, should be considered. The review should provide objective

evidence to support the conclusion that the effects of aging will be

managed so that the intended function(s) will be maintained during the

extended period of operation. Guidance for reviewing industry operating

experience is presented in BTP RLSB-1 in Appendix A.1 of the Branch

Technical Positions in NUREG-1800.3.Industry Operating Experience. Industry operating experience and its applicability should be assessed to determine whether it changes

plant-specific determinations. NUREG-1801 is based upon industry

operating experience prior to its date of issue. Operating experience after

the issue date of NUREG-1801 should be evaluated and documented as

part of the aging management review. In particular, generic Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan 23 communications such as a bulletin, a generic letter, or an information notice should be evaluated for impact upon the AMP. The evaluation

should check for new aging effects or a new component or location

experiencing an already identified aging effect.C.If it is necessary to ask the applicant a question, follow the process shown in Figure 2.E.If it is necessary for the applicant to submit additional information to resolve a question or an issue or to support the basis or conclusion, the applicant may voluntarily submit the information as a supplement (docketed letter submitted

under oath and affirmation) to the LRA. If not, the NRC may issue an RAI to obtain

the information.

AMP Review Worksheets Document the audit/review using the worksheet provided in Appendix G, "Plant-Specific AMP Audit/Review Worksheet." 6.3Aging Management Review (AMR) Audits and Reviews There are two types of AMRs: those that the applicant claims are consistent with the GALL Report, and those that are not consistent with or not included in the GALL Report. Audit and

review of both types of AMRs are discussed below. 6.3.1Plant AMRs that Are Consistent with the GALL Report

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

is consistent with the GALL Report.

PreparationA.For the IP2 and IP3 AMRs that the applicant claims are consistent with the GALL Report, identify the corresponding AMRs in Volume 2 of the GALL Report.B.Review the associated GALL AMRs and identify those line items that will be audited/reviewed in conjunction with each of the IP2 and IP3 AMRs.C.Identify the documents needed to perform the review. These may include, but are not limited to, the following:1.GALL Report2.SRP-LR 3.ISG-LR 4.RAIs and SERs for similar plants Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan 1 The AMR line item letter notes are based on a letter from A. Nelson, NEI, to P. T. Kuo, NRC,"U.S. Nuclear Industry's Proposed Standard License Renewal Application Format Package, Request NRC Concurrence," dated January 24, 2003 (ML030290201). The staff concurred in

the format of the standardized format for LRAs by letter dated April 7, 2003, from P.T. Kuo, NRC, to A. Nelson, NEI (ML030990052).

2 Some GALL AMRs reference the use of a plant-specific AMP. In such cases the AMR audit

requires the project team member to confirm that the plant-specific AMP is appropriate to

manage the aging effects during the period of extended operation.

245.LRA6.Basis documents 7.Implementation procedures 8.Operating experience reports (plant-specific and industry) 9.UFSAR 10.Lessons Learned Developed by RLRC Audit/ReviewA.Each AMR line item is coded with a letter which represents a standard note designation.

1 The letter notes are described in Table 2 of this plan. Notes that use numeric designators are plant-specific. The note codes A though E are classified as "consistent with the GALL Report," and will be reviewed in accordance with the

guidance contained in this plan.B.The AMR review involves verification that the applicant has satisfied the requirements of 10 CFR 54.21(a)(3). This requirement states: "For each structure

and component ... [within the scope of this part ... and ... subject to an aging

management review] (the applicant) demonstrate(s) that the effects of aging will

be adequately managed so that the intended function(s) will be maintained

consistent with the CLB for the period of extended operation." C.Determine compliance by following the process shown in Figure 3. The process is summarized below:1.For each AMR line item, perform the review associated with the letter note (A through E) assigned to the AMR line item. Specifically, determine if the AMR is consistent with the GALL Report for the elements associated with

its note.2.If Note A applies, and the applicant uses a plant-specific AMP 2 determine if the component is within the scope of the cited plant AMP. If the

component is within the scope of the plant AMP, the AMR line item is

acceptable. If not acceptable, go to Step (7) below.

Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan 253.If Note B applies, review the LRA exceptions and document the basis for acceptance in the worksheet, and later in the SER input. If not acceptable, go to Step (7) below.4.If Note C or D applies, determine if the component type is acceptable for the material, environment, and aging effect. If Note D applies, also review

the LRA exceptions and document the basis for acceptance in the

worksheet, and later in the SER input. If not acceptable, go to Step (7)

below.5.If Note E applies, review the AMP audit report findings to determine if the scope of the alternate AMP envelopes the AMR line item being reviewed and satisfies 10 CFR 54.21(a)(3). If it does not, go to Step (7) below. 6.Review the corresponding LRA Table 3.X.1 entry that is referenced in LRATable 3.X.2.Y. If applicable, determine whether the applicant's "FurtherEvaluation Recommended" response in LRA Section 3.X.2.2.Z is enveloped by Section 3.X.2.2.Z of the SRP-LR. If not, go to Step (7)

below. If the LRA section does not meet the acceptance criteria of

Appendix A of the SRP-LR, go to Step (7) below.7.If during the review a difference is identified, prepare a question to the applicant, in order to obtain clarification. a.Review the applicant's response to the question. If it appears acceptable, document the basis for acceptance and re-start the audit/review for the AMR line item from Step (1) above. b.If the applicant's response does not resolve the question or issue, prepare an additional question to obtain the information needed to

achieve resolution. Review the applicant's response to the second

question. If it appears acceptable, document the basis for

acceptance and re-start the audit/review for the AMR line item from

Step (1) above. c.If it is necessary for the applicant to submit additional information to resolve a question or an issue or to support a basis or conclusion, the applicant may submit the information as a supplement to the

LRA or the NRC may issue an RAI to obtain the information. The

team leader should be consulted if docketed information may be

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

Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan 26 AMR Audit/Review Worksheets Document the audits/reviews of plant AMRs using the worksheet provided in Appendix H, "AMR Comparison Worksheets," or on spreadsheets containing similar information.6.3.2Plant AMRs that Are Not Consistent with the GALL Report Review LRA Tables 3.X.2.1 - X (Table 2s) for LRA Sections 3.1 thru 3.6, where the applicant indicated, via Notes F through J, that the combination of component type, material, environment, and AERM does not correspond to a line item in the GALL Report. Specifically, Note F indicates

that the material for the AMR line item component is not evaluated in the GALL Report. Note G

indicates that the environment for the AMR line item component and material is not evaluated in

the GALL Report. Note H indicates that the aging effect for the AMR line item component, material, and environment combination is not evaluated in the GALL Report. Note I indicates that

the aging effect identified in the GALL Report for the line item component, material, and

environment combination is not applicable. Note J indicates that neither the component nor the

material and environment combination for the line item is evaluated in the GALL Report. For

component groups not evaluated in the GALL Report (notes F-J), the project team reviews the

applicant's evaluation in accordance with Branch Technical Position RLSB-1 (Appendix A.1 of

the SRP-LR) to determine the technical adequacy. If during the review a difference is identified, prepare a question to the applicant, in order to obtain clarification. Review the applicant's

response to the question and confirm that it is acceptance in accordance with Appendix A.1 of

the SRP-LR.

The AMR review involves verification that the applicant has satisfied the requirements of 10 CFR 54.21(a)(3) . This requirement states: "For each structure and component ... [within the scope of

this part ... and ... subject to an aging management review] (the applicant) demonstrate(s) that

the effects of aging will be adequately managed so that the intended function(s) will be

maintained consistent with the CLB for the period of extended operation." 6.4Time-Limited Aging Analyses (TLAA) Audits and Reviews Audit and review of TLAAs are discussed below. The project team will also review the TLAAs to determine if there are emerging issues that should be further evaluated by technical specialists in

the NRC Divisions of Component Integrity (DCI) or the Division of Engineering (DE). In general, the project team will review TLAAs that are for which the applicant claims consistency with 10

CFR 54.21(c)(i) "the analyses remain valid for the period of extended operation." or 10 CFR

54.21(c)(iii) "the effects of aging on the intended function(s) will be adequately managed for the

period of extended operation." For TLAAs for which the applicant claims consistency with 10

CFR 54.21(c)(ii) - "the analyses have been projected to the end of the period of extended

operation," the audit team leader will be consulted to determine which TLAAs the audit team will

be capable of reviewing. Consideration should be given to team expertise, past precedent, and

complexity of the provided analysis.6.4.1Identify Generic TLAA Issues Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan 27 Figure 4, "Evaluation of TLAAs and Exemptions," taken from NEI 95-10, Revision 6, shows the process of evaluating and reviewing TLAAs and also identifying the exemptions in effect. This

process flowchart shows the activities and decisions used to audit/review each TLAA that the

applicant identifies.

Pre-Review PreparationA.For the IP2 and IP3 TLAAs that the applicant has identified as generic TLAA issues, identify the corresponding TLAAs in NUREG-1800, if appropriate.B.Review the corresponding TLAAs in NUREG-1800 and identify those that will be audited/reviewed in conjunction with each of the IP2 and IP3 TLAAs.C.Review the list of the IP2 and IP3 plant-specific exemptions granted pursuant to

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

the period of extended operation.D.Identify and locate the documents needed to perform the review. These may include, but are not limited to, the following:1.Excel database on TLAAs summarizing how earlier LRAs and SERs were presented and reviewed 2.TLAAs 3.GALL Report 4.SRP-LR 5.ISG-LR 6.RAIs, audit and review reports, and SERs for similar plants 7.LRA 8.References listed by applicant for each TLAA 9.NEI 95-10, Section 5.1 and Table 6.2-2

10. Basis documents 11.Implementation documents

12. Operating experience reports (plant-specific and industry) 13.Lessons-learned developed by RLRC 14.Applicant's UFSARE.In addition, the project team will also review the TLAAs to determine if there are emerging issues that should be further evaluated by technical specialists in the NRC Divisions of Component Integrity (DCI) or the Division of Engineering (DE).

This is not expected to be an issue for TLAAs for which the applicant claims

consistency with 10 CFR 54.21(c)(i) "the analyses remain valid for the period of

extended operation." or 10 CFR 54.21(c)(iii) "the effects of aging on the intended

function(s) will be adequately managed for the period of extended operation." For

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

analyses have been projected to the end of the period of extended operation," the Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan 28 audit team leader will be consulted to determine which TLAAs the audit team will be capable of reviewing. Consideration should be given to team expertise, past

precedent, and complexity of the provided analysis. Candidates for further review

by technical specialists could be such as the following:1.Reactor Vessel Neutron Embrittlement Analysis (IP2 and IP3 LRA Section 4.2)Audit/ReviewA.Confirm that each IP2 and IP3 TLAA listed in this section is appropriate. Refer to any analyses and evaluations created during the acceptance review process.B.If a TLAA is listed in the SRP-LR or NEI 95-10 and not in its LRA, the IP2 and IP3 should state in this section that it does not apply.C.Review any industry and plant-specific operating experience associated with the TLAA. This is an area of review emphasis. The project team members should consider the following industry guidance (from NEI 95-10, Table 6.2-2) as follows:1.The application shall include a list of time-limited aging analyses, as defined by §54.3. The application should include the identification of the affected systems, structures, and components, an explanation of the time

dependent aspects of the calculation or analysis, and a discussion of the

TLAA's impact on the associated aging effect. The identification of the

results of the time-limited aging analysis review, which may be provided in

tabular form, may reference the section in the Integrated Plant

Assessment-Aging Management Review chapter where more details of the

actual review and disposition (as required by §54.21(c)(1)(i)-(iii)) are

located.2.The application shall include a demonstration that (1) the analyses remain valid for the period of extended operation, (2) the analyses have been (or have been identified and will be) projected to the end of the period of

extended operation or (3) the effects of aging on the intended function(s)

will be adequately managed for the period of extended operation. 3.The application shall include a list of plant-specific exemptions granted pursuant to §50.12 and in effect that are based on TLAAs as defined in

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

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

Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan 29D.If it is necessary to ask the applicant a question to clarify the basis for their analyses, follow the logic process shown in Figure 4 of this audit and review plan.E.If it is necessary for the applicant to submit additional information to support the basis for the conclusions in their TLAA, the applicant may agree to voluntarily submit the required information as a supplement (docketed letter submitted under

oath and affirmation) to the IP2 and IP3 LRA. If not, the NRC may issue an RAI to

obtain the information.

6.4.2 Metal Fatigue Analyses Figure 4, "Evaluation of TLAAs and Exemptions," taken from NEI 95-10, Revision 6, shows the process of evaluating and reviewing TLAAs and also identifying the exemptions in effect. This

process flowchart shows the activities and decisions used to audit/review each TLAA that the

applicant identifies.

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

10 CFR 54.21(c)(2).B.Identify and locate the documents needed to perform the review. These may include, but are not limited to, the following: 1.Excel database on TLAAs summarizing how earlier LRAs and SERs presented and reviewed TLAAs 2.GALL Report, especially Section X.M13.SRP-LR 4.ISG-LR 5.RAIs, audit and review reports, and SERs for similar plants 6.LRA 7.References listed by applicant for each TLAA 8.NEI 95-10, Section 5.1 and Table 6.2-2 9.Basis documents 10.Implementation documents 11.Operating experience reports (plant-specific and industry) 12.Lessons-learned developed by RLRC 13.Applicant's UFSARC.In addition, the project team will also review the IP2 and IP3 TLAAs within the NUREG-1800 TLAA category of "metal fatigue" to determine if there are emerging

issues that should be further evaluated by technical specialists in the NRC

Divisions of Component Integrity (DCI) or the Division of Engineering (DE). This is

not expected to be an issue for TLAAs for which the applicant claims consistency Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan 30 with 10 CFR 54.21(c)(i) "the analyses remain valid for the period of extended operation." or 10 CFR 54.21(c)(iii) "the effects of aging on the intended function(s)

will be adequately managed for the period of extended operation." For TLAAs for

which the applicant claims consistency with 10 CFR 54.21(c)(ii) - "the analyses

have been projected to the end of the period of extended operation," the audit

team leader will be consulted to determine which TLAAs the audit team will be

capable of reviewing. Consideration should be given to team expertise, past

precedent, and complexity of the provided analysis.

Audit/ReviewA.Confirm that each IP2 and IP3 TLAA listed in this section is appropriate. Refer to any analyses and evaluations created during the acceptance review process.B.If a TLAA is listed in the SRP-LR or NEI 95-10 and not in its LRA, the IP2 and IP3 should state in this section that it does not apply.C.The project team will conduct both regulatory evaluations and technical evaluations to determine, as defined in 10 CFR 54.3, that each TLAA meets the following six criteria: 1.Involve systems, structures, and components that are within the scope of license renewal, as delineated in 10 CFR 54.4(a). 2.Consider the effects of aging. 3.Involve time-limited assumptions defined by the current operating term (40 years).4.Determined to be relevant by the applicant in making a safety determination.5.Involve conclusions, or provide the basis for conclusions, related to the capability of the system, structure, and component to perform its intended functions, as delineated in 10 CFR 54.4(b). 6.Contained or incorporated by reference in the CLB.D.The project team will ascertain that the IP2 and IP3 satisfactorily demonstrates that (1) the analyses remain valid for the period of extended operation, (2) the

analyses have been (or have been identified and will be) projected to the end of

the period of extended operation or (3) the effects of aging on the intended

function(s) will be adequately managed for the period of extended operation.E.Review any industry and plant-specific operating experience associated with the TLAA. This is an area of review emphasis. The project team members should Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan 31 consider the following industry guidance on metal fatigue (from NEI 95-10, Table 6.2-2) as follows: 1.Disposition chosen for each of the identified TLAAs. Also, provide a reference to the summary description of TLAA evaluations in the FSAR supplement (Appendix A). Use hypertext to link to the appropriate location

in the appendix for electronic submittals [§54.21(c)(1) and §54.21(d)1.F.If it is necessary to ask the applicant a question to clarify the basis for their analyses, follow the logic process shown in Figure 4 of this audit and review plan.G.If it is necessary for the applicant to submit additional information to support the basis for the conclusions in their TLAA, the applicant may agree to voluntarily submit the required information as a supplement (docketed letter submitted under

oath and affirmation) to the IP2 and IP3 LRA. If not, the NRC may issue an RAI to

obtain the information.

6.4.3 Environmental Qualification Analyses for Electrical Components Figure 5, "Evaluation of TLAAs and Exemptions," taken from NEI 95-10, Revision 6, shows the process of evaluating and reviewing TLAAs and also identifying the exemptions in effect. This

process flowchart shows the activities and decisions used to audit/review each TLAA that the

applicant identifies.

Pre-Review PreparationA.The project team will determine if the TLAAs identified in the IP2 and IP3 LRA to be within the NUREG-1800 TLAA category of "environmental qualification of electric equipment" have provided adequate information to meet the requirements

of 10 CFR 54.21(c)(1) and 10 CFR 54.21(c)(2).B.Identify and locate the documents needed to perform the review. These may include, but are not limited to, the following: 1.Excel database on TLAAs summarizing how earlier LRAs and SERs presented and reviewed TLAAs 2.GALL Report, especially Section X.E1 3.SRP-LR 4.ISG-LR 5.RAIs, audit and review reports, and SERs for similar plants 6.LRA 7.References listed by applicant for each TLAA 8.NEI 95-10, Section 5.1 and Table 6.2-2 9.Basis documents 10.Implementation documents 11.Operating experience reports (plant-specific and industry)

Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan 3212.Lessons-learned developed by RLRC 13.Applicant's UFSARC.In addition, the project team will also review the IP2 and IP3 TLAAs within the NUREG-1800 TLAA category of "environmental qualification of electric equipment" to determine if there are emerging issues that should be further

evaluated by technical specialists in the NRC Divisions of Component Integrity (DCI) or the Division of Engineering (DE). This is not expected to be an issue for

TLAAs for which the applicant claims consistency with 10 CFR 54.21(c)(i) "the

analyses remain valid for the period of extended operation." or 10 CFR

54.21(c)(iii) "the effects of aging on the intended function(s) will be adequately

managed for the period of extended operation." For TLAAs for which the applicant claims consistency with 10 CFR 54.21(c)(ii) - "the analyses have been projected

to the end of the period of extended operation," the audit team leader will be

consulted to determine which TLAAs the audit team will be capable of reviewing.

Consideration should be given to team expertise, past precedent, and complexity

of the provided analysis.

Audit/ReviewA.Confirm that each IP2 and IP3 TLAA listed in this section is appropriate. Refer to any analyses and evaluations created during the acceptance review process.B.If a TLAA is listed in the SRP-LR or NEI 95-10 and not in its LRA, the IP2 and IP3 should state in this section that it does not apply.C.The project team will conduct both regulatory evaluations and technical evaluations to determine, as defined in 10 CFR 54.3, that each TLAA meets the following six criteria: 1.Involve systems, structures, and components that are within the scope of license renewal, as delineated in 10 CFR 54.4(a). 2.Consider the effects of aging. 3.Involve time-limited assumptions defined by the current operating term (40 years).4.Determined to be relevant by the applicant in making a safety determination.5.Involve conclusions, or provide the basis for conclusions, related to the capability of the system, structure, and component to perform its intended functions, as delineated in 10 CFR 54.4(b). 6.Contained or incorporated by reference in the CLB.

Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan 33D.The project team will ascertain that the IP2 and IP3 satisfactorily demonstrates that (1) the analyses remain valid for the period of extended operation, (2) the analyses have been (or have been identified and will be) projected to the end of

the period of extended operation or (3) the effects of aging on the intended

function(s) will be adequately managed for the period of extended operation.E.Review any industry and plant-specific operating experience associated with the TLAA. This is an area of review emphasis. The project team members should

consider the following industry guidance on environmental qualification of electric

equipment (from NEI 95-10, Table 6.2-2) as follows: 1.Disposition chosen for each of the identified TLAAs. Also, provide a reference to the summary description of TLAA evaluations in the FSAR supplement (Appendix A). Use hypertext to link to the appropriate location

in the appendix for electronic submittals [§54.21(c)(1) and §54.21(d)1].F.If it is necessary to ask the applicant a question to clarify the basis for their analyses, follow the logic process shown in Figure 4 of this audit and review plan.G.If it is necessary for the applicant to submit additional information to support the basis for the conclusions in their TLAA, the applicant may agree to voluntarily submit the required information as a supplement (docketed letter submitted under

oath and affirmation) to the IP2 and IP3 LRA. If not, the NRC may issue an RAI to

obtain the information.6.4.4Other Plant-Specific TLAAs Figure 4, "Evaluation of TLAAs and Exemptions," taken from NEI 95-10, Revision 6, shows the process of evaluating and reviewing TLAAs and also identifying the exemptions in effect. This

process flowchart shows the activities and decisions used to audit/review each TLAA that the

applicant identifies.

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

and 10 CFR 54.21(c)(2).B.Identify and locate the documents needed to perform the review. These may include, but are not limited to, the following: 1.Excel database on TLAAs summarizing how earlier LRAs and SERs presented and reviewed TLAAs 2.GALL Report Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan 343.SRP-LR 4.ISG-LR 5.RAIs, audit and review reports, and SERs for similar plants 6.LRA 7.References listed by applicant for each TLAA 8.NEI 95-10, Section 5.1 and Table 6.2-2 9.Basis documents

10. Implementation documents

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

12. Lessons-learned developed by RLRC

13. Applicant's UFSARC.In addition, the project team will also review the IP2 and IP3 TLAAs within the NUREG-1800 TLAA category of "other plant-specific TLAAs" to determine if there are emerging issues that should be further evaluated by technical specialists in

the NRC Divisions of Component Integrity (DCI) or the Division of Engineering (DE). This is not expected to be an issue for TLAAs for which the applicant claims

consistency with 10 CFR 54.21(c)(i) "the analyses remain valid for the period of

extended operation." or 10 CFR 54.21(c)(iii) "the effects of aging on the intended

function(s) will be adequately managed for the period of extended operation." For

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

analyses have been projected to the end of the period of extended operation," the

audit team leader will be consulted to determine which TLAAs the audit team will

be capable of reviewing. Consideration should be given to team expertise, past

precedent, and complexity of the provided analysis.

Audit/ReviewA.Confirm that each IP2 and IP3 TLAA listed in this section is appropriate. Refer to any analyses and evaluations created during the acceptance review process.B.If a TLAA is listed in the SRP-LR or NEI 95-10 and not in its LRA, the IP2 and IP3 should state in this section that it does not apply.C.The project team will conduct both regulatory evaluations and technical evaluations to determine, as defined in 10 CFR 54.3, that each TLAA meets the following six criteria:1.Involve systems, structures, and components that are within the scope of license renewal, as delineated in 10 CFR 54.4(a). 2.Consider the effects of aging.

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

Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan 354.Determined to be relevant by the applicant in making a safety determination.5.Involve conclusions, or provide the basis for conclusions, related to the capability of the system, structure, and component to perform its intended functions, as delineated in 10 CFR 54.4(b). 6.Contained or incorporated by reference in the CLB.D.The project team will ascertain that the IP2 and IP3 satisfactorily demonstrates that (1) the analyses remain valid for the period of extended operation, (2) the analyses have been (or have been identified and will be) projected to the end of

the period of extended operation or (3) the effects of aging on the intended

function(s) will be adequately managed for the period of extended operation.E.Review any industry and plant-specific operating experience associated with the TLAA. This is an area of review emphasis. The project team members should consider the following industry guidance on "other plant-specific TLAAs" (from NEI

95-10, Table 6.2-2) as follows: 1.Identify and evaluate any plant-specific TLAAs.F.If it is necessary to ask the applicant a question to clarify the basis for their analyses, follow the logic process shown in Figure 4 of this audit and review plan.G.If it is necessary for the applicant to submit additional information to support the basis for the conclusions in their TLAA, the applicant may agree to voluntarily submit the required information as a supplement (docketed letter submitted under

oath and affirmation) to the IP2 and IP3 LRA. If not, the NRC may issue an RAI to

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

summary and the SER input.6.5.1Audit and Review Summary

The project team should prepare an audit and review summary upon completion of the on-site audits and reviews of the AMPs, AMRs, and TLAAs assigned to the project team. This summary

should provide the following information:

Members who participated in the on-site audits, Dates and location of the audits Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan 3 AMRs that are not consistent with the GALL Report or not addressed in the GALL Report.

36 Guidance documents used for the review Activities performed

Documents reviewed

Availability of question and answer database

Status of the review6.5.2Safety Evaluation Report InputA.General guidance1.Each project team member should prepare the SER input for the AMP and AMR audits and reviews that he or she performed. The technical

assistance contractor shall collect, assemble, and prepare the complete

SER input.2.In general, the data and information needed to prepare the SER input should be available in the project team's audit and review question and answer database and the team member's worksheets. 3.SER inputs are to be prepared for:a.Each AMP that was determined to be consistent with the GALL Report, which has no exceptions or enhancements.b.Each AMP that was determined to be consistent with the GALL Report, which has exceptions (identified by either the applicant or

the project team) or enhancements.c.Each plant-specific AMP.d.AMRs that are consistent with the GALL Report, for which no further evaluation is recommended. e.AMRs that are consistent with the GALL Report, for which further evaluation is recommended.f.Project team AMR review results.

34.The SER input should contain the following sections. (Note: The followingsection numbers (3. through 3.X.3) are based on the numbering system for the SER input. They are not a continuation of the numbering convention

used throughout this plan.)3.Aging Management Review Results Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan 4 The LRA AMR results are broken down into six sections and address the following system/structure groups: (1) Section 3.1, reactor vessel, internals and reactor coolant system, (2) Section 3.2, engineering safety features systems, (3) Section 3.3, auxiliary systems, (4)

Section 3.4, steam power and conversion systems, (5) Section 3.5, structures and component

supports, (6) Section 3.6, electrical and instrumentation and controls.

37 3.0 Applicant's Use of the Generic Aging Lessons Learned Report3.01Format of the LRA 3.02Staff's Review Process3.0.2.1AMRs in the GALL Report 3.0.2.2NRC-Approved Precedents 3.0.2.3UFSAR Supplement 3.0.2.4Documentation and Documents Reviewed3.0.3Aging Management Programs3.0.3.1AMPs that are Consistent With the GALL Report3.0.3.2AMPs that are Consistent With GALL Report With Exceptions or Enhancements3.0.3.3AMPs that are Plant-Specific3.0.4Quality Assurance Program Attributes Integral to Aging Management Programs 3.X 4 Aging Management of ______ 3.X.1Summary of Technical Information in the Application3.X.2Staff Evaluation3.X.2.1Aging Management Evaluations that are Consistent with the GALL

Report, for Which Further

Evaluation is Not Required3.X.2.2Aging Management Evaluations that are Consistent with the GALL

Report, for Which Further

Evaluation is Recommended3.X.2.3AMR Results that are Not Consistent with or Not

Addressed in the GALL

Report3.X.3Conclusion 4.0 Time-Limited Aging Analyses 4.1 Identification of Time-Limited Aging Analyses

4.3 Metal Fatigue Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan 38 4.4 Environmental Qualification of Electrical Components 4.5 Concrete Containment Tendon Prestress

4.6 Containment Liner Plate and Penetrations Fatigue Analyses

4.7 Other Plant-Specific Time-Limited Aging Analyses4.7.1Reactor Coolant Pump Flywheel Analysis 4.7.2Leak Before Break 4.7.3Steam Generator Flow Induced Vibration and Tube Wear 4.8 Conclusion for Time-Limited Aging Analyses5.For each AMP audited/reviewed by the project team, the SER shall include a discussion of the team's review of the operating experience program element.6.If the applicant submitted an amendment or a supplement to its LRA that is associated with the project team's audit or review activities, document the

submittal (include the date and ADAMS accession number) and explain

the issue that the submittal resolved and discuss the basis for the

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

State if the RAI remains open or if the applicant response has been received and accepted. If the response was acceptable, identify the

submittal (including the date and the ADAMS accession number) that

provided the response and document the basis for its acceptance.8.Issues (e.g., RAIs) that have not been resolved by the applicant at the time the SER input is prepared should be identified as open items.B.SER input 1.For AMPs determined to be consistent with the GALL Report, without exceptions, include the AMP title, the plant AMP paragraph number, and a discussion of the basis for concluding that the UFSAR update (Appendix A

of the LRA) is acceptable. This SER input documents that the AMP is

consistent with the GALL Report. 2.For AMPs determined to be consistent with the GALL Report, with exceptions or enhancement, the SER input should include a statement that the audit found the AMP consistent with the GALL Report and that any

applicant-identified exceptions to the GALL Report were found technically

acceptable to manage the aging effect during the period of extended

operation. The SER input should identify the exceptions and provide the

basis for acceptance. The SER input will also address the UFSAR

supplement, and document the basis for concluding that it is acceptable.

Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan 5 The audit results documented in this section address the AMRs consistent with the GALL Report for which no further evaluation is recommended.

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

the UFSAR supplement.4.For aging management evaluations that are consistent with the GALL Report, 5 the SER input should include the following: a.Identify the LRA section reviewed. b.A summary of the type of information provided in the section of the LRA reviewed, including a listing of the AMPs reviewed. c.Identify the LRA Tables 3.X.2-Y reviewed.

d.A summary review of the AMR Notes A through E used to classify the AMR line items used in these tables.e.A brief summary of what the staff (project team) reviewed to perform the audit (i.e., LRA and applicant basis documents and other implementation documents). Reference the appendix that

lists the details of the documents reviewed.f.The bases for accepting any exceptions to GALL AMRs that were identified by the applicant or the project team member.g.A finding that verifies that: The applicant identified the applicable aging effects. The applicant defined the appropriate combination of materials and environments. The applicant specified acceptable AMPs.h.A conclusion stating, if applicable, that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended functions will be maintained consistent with the

CLB for the period of extended operation, and that 10 CFR

54.21(a)(3) has been satisfied.

Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan 6 This section documents reviews of AMRs assigned to the project team that are not consistent with the GALL Report.

405.For aging management evaluations that are consistent with the GALL Report, for which further evaluation is recommended, the SER input should include the following:a.The LRA section containing the applicant's further evaluations of AMRs for which further evaluation is required.b.A list of the aging effects for which the further evaluation apply.

c.For the applicant's further evaluations, provide a summary of the basis for concluding that it satisfied the criteria of Section 3.x.3.2 of the SRP-LR. d.A statement that the staff audited the applicant's further evaluations against the criteria contained in Section 3.x.3.2 of the SRP-LR.6.Staff AMR Review Results.

6 This section of the SER input documents the reviews of AMRs assigned to the project team that are not consistent with

the GALL Report. The audit report should document the following:a.The LRA section reviewed.

b.A summary of the type of information provided in the section of the LRA, reviewed, including a listing of the AMPs reviewed for this LRA section. c.Identify the LRA Tables 3.X.2-Y documented by this audit writeup.d.A brief summary of what the staff (project team) reviewed (i.e., LRA and applicant basis documents and other implementation documents).e.A finding that verifies, if true, that: The applicant identified the applicable aging effects. The applicant listed the appropriate combination of materials and environments. The applicant specified acceptable AMPs.f.Provide a conclusion stating, if applicable, that the applicant has demonstrated that the effects of aging will be adequately managed Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan 41 so that the intended functions will be maintained consistent with the CLB for the period of extended operation, and that 10 CFR

54.21(a)(3) has been satisfied.7.TLAA Reviews - This section of the SER input documents the reviews of TLAAs assigned to the project team. The SER input should include the

following:a.Summary of technical information in the application b.Staff evaluation (i) Regulatory basis (ii) Scope of review and technical evaluationc.UFSAR supplement review - stating, if applicable, that the applicant has provided a UFSAR supplement summary description of its

TLAA evaluation. d.Provide a conclusion stating, if applicable, that the applicant has demonstrated that TLAAs that are for which the applicant claims

consistency with 10 CFR 54.21(c)(i) "the analyses remain valid for

the period of extended operation," or 10 CFR 54.21(c)(ii) "the

analyses have been projected to the end of the period of extended

operation," or 10 CFR 54.21(c)(iii) "the effects of aging on the

intended function(s) will be adequately managed for the period of

extended operation." The staff also concludes that the UFSAR

supplement contains an appropriate summary description of the

activities for managing the effects of aging and the TLAA

evaluation, as required by 10 CFR 54.21(d).6.6Documents Reviewed and Document Retention Any documents reviewed that were used to formulate the basis for resolution of an issue, such as the basis for a technical resolution, the basis for the acceptance of an exception or an

enhancement, etc., should be documented as a reference in the SER input.

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

After the NRC has made its licensing decision, all copies of documents collected and all documents generated to complete the SER input, such as audit worksheets, question and

answer tracking documentation, etc., are to be discarded.

Table 1. Aging Management Program Element Descriptions Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan 42 Element Description1Scope of the programThe scope of the program should include the specific structures and components subject to an aging management review. 2Preventive actionsPreventive actions should mitigate or prevent the applicable aging effects. 3Parameters monitored or inspected Parameters monitored or inspected should be linked to the effects of aging on the intended functions of the particular

structure and component. 4Detection of aging effectsDetection of aging effects should occur before there is loss of any structure and component intended function. This includes aspects such as method or technique (i.e., visual, volumetric, surface inspection), frequency, sample size, data collection and

timing of new/one-time inspections to ensure timely detection

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

actions.6Acceptance criteriaAcceptance criteria, against which the need for corrective action will be evaluated, should ensure that the particular

structure and component intended functions are maintained

under all current licensing basis design conditions during the

period of extended operation. 7Corrective actionsCorrective actions, including root cause determination and prevention of recurrence, should be timely.8Confirmation processThe confirmation process should ensure that preventive actions are adequate and appropriate corrective actions have been

completed and are effective. 9Administrative controlsAdministrative controls should provide a formal review and approval process. 10Operating experienceOperating experience involving the aging management program, including past corrective actions resulting in program

enhancements or additional programs, should provide objective

evidence to support a determination that the effects of aging

will be adequately managed so that the structure and

component intended functions will be maintained during the

period of extended operation.

Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan 7 Each AMR line item is coded with a letter which represents a standard note designation basedon a letter from A. Nelson, NEI, to P.T. Kuo, NRC, "U.S. Nuclear Industry's Proposed Standard License Renewal Application Format Package, Request NRC Concurrence," dated

January 24, 2003 (ML030290201). The staff concurred in the format of the standardized format for license renewal applications by letter dated April 7, 2003, from P.T. Kuo, NRC, to A.

Nelson, NEI (ML030990052).

43Table 2. Notes for License Renewal Application Tables 3.X.2-Y 7 Note DescriptionAConsistent with NUREG-1801 [GALL Report] item for component, material, environment, and aging effect. AMP is consistent with NUREG-1801 AMP.BConsistent with NUREG-1801 item for component, material, environment, and aging 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-1801 AMP.EConsistent with NUREG-1801 for material, environment, and aging effect, but a different 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 environment combination.IAging effect in NUREG-1801 for this component, material and environment combination is not applicable.JNeither the component nor the material and environment combination is evaluated in NUREG-1801.

Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan 44Figure 1. Audit of AMPs that are Consistent with the GALL ReportStartIdentify GALL AMP(s) to which LRA AMP is being comparedIdentify elements of GALL AMP(s) attributes to be auditedIdentify LRA AMP support documents needed to perform auditDid applicant identify any exceptions to GALL AMP(s)?Compare each GALL AMP auditable element to the LRA AMPIs the attribute element consistent?Document the basis for acceptance of the attribute element in worksheetHave all attribute elements been audited?Have all 7 AMP attributes been audited?Write SE input per guidance in Section G, H, JProvide audit SE inputConclusion of AMP AuditIs there a technical basis to accept exception or difference?Ask applicant a clarifying question to continue audit?Develop and provide question to Team Leader for PMs submittal to applicantObtain response from applicantNotify NRC Team Leader that Audit of AMR may not proceedDraft RAITerminate AMP auditPreparation StepsNote: Preparation steps may be performed as a single combined step for each AMP audited.Note: If a prior NRC precedent exists, it may be used as an aid to make the technical determination. Documentation of the acceptance must me made on the technical merits not a citation to the precedent.

Yes Yes No No Yes Yes No No Yes No No Yes Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan 45 Figure 2. Audit of Plant-Specific AMPsStartIdentify criteria of SRP-LR Appendix A elements which are auditableIdentify LRA AMP support documents needed to perform auditCompare each SRP-LR AMP criteria element to the LRA AMPIs the AMPelement consistent?Document the basis for acceptance of the element in worksheetHave all element criteria been audited?Have all 7 AMP elements been audited?Write SER inputProvide NRC Team Leader and contractor audit SER inputConclusion of AMP reviewIs there a technical basis to accept exception or difference?Is it appropriate to ask applicant a clarifying question to continue audit?Provide question to Team Leader for PM's submittal to applicantObtain response from applicantNotify NRC Team Leader that review of AMR may not proceedDraft RAITerminate AMP auditPreparation StepsNote: Preparation steps may be performed as a single combined step for each AMP audited.Note: If a prior NRC precedent exists, it may be used as an aid to make the technical determination. Documentation of the acceptance must me made on the technical merits not a citation to the precedent.

Yes No Yes Yes No No Yes No No YesDevelop question Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan 46Figure 3. Review of AMRs that are Consistent with the GALL ReportAMR ItemItem is assigned to DEReview corresponding LRA Table 3.X.1 "Further Evaluation Recommended" and "Discussion" columnsFurther EvaluationReview referenced LRA subsection and compare with SRP subsection for any differencesFootnote AFootnote BFootnote CFootnote DFootnote ENot consistent with GALL Report. Evaluate in accordance with Section 6.3.2 of this plan.Yes No Yes NoNoNoNoNoNoYesYesYesYesYesCompare item with GALL Vol. 2 System Table line item for: component type material environment aging effect AMPAMP is plant-specificCompare item with GALL Vol. 2 System Table line item for: component type material environment aging effect

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

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

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

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

Yes No NoYesMark for QueryMark as AcceptableMark as Out of ScopeDocument problem in AMR Comparison ChecklistDocument basis for acceptance in AMR Comparison ChecklistPrepare questionConfirm question is capturedAMR line item compelteOut of RLEP Scope Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan 47Figure 4. Review of TLAAs and Exemptions (from NEI 95-10, Revision 6)Identify generic TLAA issues NoIdentify potential plant unique TLAA issuesIdentify exemptions in effectIs the exemption based on a TLAA issue?Does the TLAA meet the criteria of §54.3?No further evaluationDetermine the method of TLAA evaluationAnalysisVerify that the TLAA is valid for extended operating period?Aging reviewJustify that the TLAA can be projected to the end of the extended period of operationVerify that the TLAA is resolved by managing the aging effectsNo further evaluation of the exemption is required for license renewalFigure 4.2-1Document the evaluation Yes Yes No OROR Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan A-1 APPENDIX A PROJECT TEAM MEMBERSHIPOrganizationNameFunctionNRC/NRR/DLR/RLRCJim DavisTeam LeaderNRC/NRR/DLR/RLRCPeter WenBack-up Team Leader NRC/NRR/DLR/RLRCJohn FairReviewer - Mechanical NRC/NRR/DLR/RLRCYeon-Ki ChungReviewer - Mechanical NRC/NRR/DLR/RLRCQi GanReviewer - Mechanical NRC/NRR/DLR/RLRCDuc NguyenReviewer - Electrical NRC/NRR/DLR/RLRCSurinder AroraReviewer - Mechanical BNLRich MoranteContractor lead, Reviewer - Structures BNLJoe BravermanReviewer - Structures BNLMano SubudhiReviewer - Materials BNLKen SullivanReviewer - Mechanical Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan B-1 APPENDIX B RLRC SCHEDULE FOR IP2 AND IP3 LRA SAFETY REVIEW Plant: Indian Point Nuclear TAC: Generating Unit Nos. 2 and 3 MD5407, MD5408 Team Leader:

Jim Davis Scope of Work:

Backup Team Leader:

Peter Wen AMPs - All, with exception of Rx Vessel Surv, Ni Alloy Insp, Borel, and Fire Protection Project Manager:

Kimberly Green TLAAs - 4.1, 4.3 , 4.4, and 4.6 Contractor:

BNL AMRs - AllTeam Members:RAI Target Date:

12/31/2007 NRC: Surinder Arora, Yeon-Ki Chung, John Fair, Qi Gan, and Duc Nguyen SE Input to PM:

3/31/2008 BNL: Joe Braverman, Rich Morante, Mano Subudhi, and Ken Sullivan Activity/MilestoneScheduled Date1Received license renewal application (LRA)4/30/072Complete acceptance review5/31/07 3Make review assignments (RLRA Project Manager)6/15/07 4Conduct team planning and kick-off meeting 6/29/07 5Issue audit plan to Project Manager 8/1/07 6Conduct first site visit (AMP/TLAA audit and review)8/27-31/2007

7 Draft AMP Audit Report Input 9/27/078Conduct in-office AMR reviews9/4/07 to 10/12/07 9Conduct second site visit (AMR/TLAA audit and review)10/22-26/200710Optional Third site visit to resolve AMR, AMP, and TLAA questions11/26-28/2007 11Draft AMR/TLAA SER Input12/5/07 12Cutoff for providing RAIs to Project Manager12/31/07 13Peer Review of SER Input12/10-21/07 14Issue Audit Summary to PM2/29/08 15Issue final SER input to Project Manager3/31/08 16ACRS subcommittee meetingJuly 2008 17ACRS full committee meetingNovember 2008

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

Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan C-1 APPENDIX C AGING MANAGEMENT PROGRAM ASSIGNMENTS No.IP2 and IP3 LRA AMP Number GALL Report AMP Number IP2 and IP3 Aging Management Program Plant Specific Consistent With GALL?

Assigned AuditorExceptionsEnhancements 1B.1.1XI.M29Aboveground Steel Tanks (existing program)XXQ. Gan/J. Davis 2B.1.2XI.M18Bolting Integrity(existing

program)XXQ. Gan/J. Davis 3B.1.3XI.M22Boraflex Monitoring(existing

program)XDCI Staff 4B.1.4NABoral Surveillance (existing program)XDCI Staff 5B.1.5XI.M10Boric Acid Corrosion prevention(existing

program)XJ. Davis 6B.1.6XI.M34Buried Piping and Tanks Inspection (new program)XQ. Gan/J. Davis Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan No.IP2 and IP3 LRA AMP Number GALL Report AMP Number IP2 and IP3 Aging Management Program Plant Specific Consistent With GALL?

Assigned AuditorExceptionsEnhancements C-2 7B.1.7XI.S4Containment Leak Rate (existing program)XJ. Braverman/

R. Morante 8B.1.8XI.S1,XI.S2 Containment

Inservice Inspection (existing

program)X J. Braverman/

R. Morante 9B.1.9XI.M30Diesel Fuel Monitoring (existingprogram

)XXK. Sullivan 10B.1.10X.E1Environmental Qualification (EQ)

of Electric

Components (existing program)

X D. Nguyen 11B.1.11XI.M36External surfaces Monitoring (existing program)XXK. Green 12B.1.12X.M1Fatigue Monitoring (existing program)XXP. Wen 13B.1.13XI.M26Fire Protection(existing

program)XXN. Iqbal Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan No.IP2 and IP3 LRA AMP Number GALL Report AMP Number IP2 and IP3 Aging Management Program Plant Specific Consistent With GALL?

Assigned AuditorExceptionsEnhancements C-3 14B.1.14XI.M27Fire Water System (existing program)XXN. Iqbal 15B.1.15XI.M17Flow-Accelerating Corrosion (existing program)XS. Arora 16B.1.16XI.M37Flux Thimble Tube Inspection (existing program)XXM. Subudhi 17B.1.17NAHeat Exchanger Monitoring (existing program)XJ. Braverman/

R. Morante 18B.1.18XI.M1,XI.S3 Inservice Inspection (existing

program)XM. Subudhi 19B.1.19XI.S5Masonry Wall (existing program)XXJ. Braverman/

R. Morante 20B.1.20XI.E4Metal-Enclosed Bus Inspection (existing program)XXD. Nguyen 21B.1.21NANickel Alloy Inspection (existing

program)XDCI Staff Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan No.IP2 and IP3 LRA AMP Number GALL Report AMP Number IP2 and IP3 Aging Management Program Plant Specific Consistent With GALL?

Assigned AuditorExceptionsEnhancements C-4 22B.1.22NANon-EQ Bolted Cable Connections (new program)XD. Nguyen 23B.1.23XI.E3Non-EQ Inaccessible

Medium-Voltage

Cable (new

program)XD. Nguyen 24B.1.24XI.E2Non-EQ Instrumentation

Circuits Test

Review (new

program)XD. Nguyen 25B.1.25XI.E1Non-EQ Insulated Cables and

Connections (new

program)XD. Nguyen 26B.1.26XI.M39Oil Analysis (existing program)XXK. Sullivan 27B.1.27XI.M32One-Time Inspection (new

program)XS. Arora Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan No.IP2 and IP3 LRA AMP Number GALL Report AMP Number IP2 and IP3 Aging Management Program Plant Specific Consistent With GALL?

Assigned AuditorExceptionsEnhancements C-5 28B.1.28XI.M35One-time Inspection - Small Bore Piping (new

program)XS. Arora 29B.1.29NAPeriodic Surveillance and

Preventive

Maintenance (existing program)XS. Arora 30B.1.30XI.M3Reactor Head Closure Studs (existing program)XM. Subudhi 31B.1.31XI.M11AReactor Vessel Head Penetration Inspection (existing

program)XM. Subudhi 32B.1.32XI.M31Reactor Vessel Surveillance (existing program)XXDCI Staff 33B.1.33XI.M33Selective Leaching (new program)XJ. Davis 34B.1.34XI.M20Service Water Integrity (existing

program)XK. Sullivan Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan No.IP2 and IP3 LRA AMP Number GALL Report AMP Number IP2 and IP3 Aging Management Program Plant Specific Consistent With GALL?

Assigned AuditorExceptionsEnhancements C-6 35B.1.35XI.M19Steam Generator Integrity (existing program)XXQ. Gan/J. Davis 36B.1.36XI.S6(XI.S7)Structures

Monitoring (existing program)XXJ. Braverman/

R. Morante 37B.1.37XI.M12Thermal Aging embrittlement of

Cast Austenitic

Stainless Steel (CASS)

(new program)XM. Subudhi 38B.1.38XI.M13Thermal Aging and Neuron Irradiation Embrittlement of

Cast Austenitic

Stainless Steel (CASS)

(new program)XM. Subudhi 39B.1.39NAWater Chemistry Control - Auxiliary Systems (existing

program)XK. Sullivan Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan No.IP2 and IP3 LRA AMP Number GALL Report AMP Number IP2 and IP3 Aging Management Program Plant Specific Consistent With GALL?

Assigned AuditorExceptionsEnhancements C-7 40B.1.40XI.M21Water Chemistry Control - Closed Cooling Water (existing program)XXK. Sullivan 41B.1.41XI.M2Water Chemistry Control - Primary

and Secondary (existing program)XXS. Arora Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan D-1 APPENDIX D AGING MANAGEMENT REVIEW ASSIGNMENTSAging Management ReviewsReviewer3.1Aging Management of Reactor Vessel, Internals, and Reactor Coolant System Mano Subudhi3.2Aging Management of Engineered Safety FeaturesQi Gan/Peter Wen3.3Aging Management of Auxiliary SystemsKen Sullivan /Rich Morante 3.4Aging Management of Steam and Power Conversion Systems Surinder Arora3.5Aging Management of Containment, Structures, and Component Supports Joe Braverman /

Rich Morante3.6Aging Management of Electrical and Instrumentation and Controls Duc Nguyen Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan D-2 The applicant presented the (a)(2) items (Nonsafety-Related Components Potentially AffectingSafety Functions) all in Tables 3.3.2-19-X of AMR Section 3.3. However, the SER preparation is

based on systems as defined in SRP-LR, which includes six specific sections (i.e., AMRs 3.1

thru 3.6). To facilitate the LRA review and SER preparation, the following (a)(2) items in Section

3.3 are reassigned to Sections 3.2 and 3.4 reviewers as followed:

Peter Wen (3.2 Reviewer)IP3:Table 3.3.2-19-10IP2:Table 3.3.2-19-30Table 3.3.2-19-43Table 3.3.2-19-37 Table 3.3.2-19-44

Table 3.3.2-19-53

Table 3.3.2-19-62 Surinder Arora (3.4 Reviewer)IP3:Table 3.3.2-19-6IP2:Table 3.3.2-19-4Table 3.3.2-19-7Table 3.3.2-19-6 Table 3.3.2-19-8Table 3.3.2-19-12 Table 3.3.2-19-9Table 3.3.2-19-15 Table 3.3.2-19-12Table 3.3.2-19-23 Table 3.3.2-19-14Table 3.3.2-19-34 Table 3.3.2-19-15Table 3.3.2-19-36 Table 3.3.2-19-18Table 3.3.2-19-41

Table 3.3.2-19-22

Table 3.3.2-19-23

Table 3.3.2-19-24

Table 3.3.2-19-27

Table 3.3.2-19-28

Table 3.3.2-19-32

Table 3.3.2-19-34

Table 3.3.2-19-35

Table 3.3.2-19-36

Table 3.3.2-19-45

Table 3.3.2-19-50

Table 3.3.2-19-51

Table 3.3.2-19-57 Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan E-1 APPENDIX E TIME-LIMITED AGING ANALYSIS REVIEW ASSIGNMENTS LRA TLAA Number TLAA Title 10 CFR 54.21(c)(1)

AssignedReviewer(i) or (iii)(ii) 4.1 Identification of TLAAs and Exemptions Qi Gan/

Peter Wen/

John Fair 4.2 Reactor Vessel Neutron Embrittlement(iii)(ii)DCI4.3Metal Fatigue (i) or (iii)

Qi Gan/Peter Wen/

John Fair 4.4 Environmental Qualification of Electrical Components(iii)D. Nguyen 4.5 Concrete Containment Tendon Prestress AnalysisN/A--4.6 Containment Liner Plate and

Penetrations Fatigue Analysis IP2- (i)IP3- N/A J.Braverman/

R. Morante Other Plant-Specific TLAA 4.7.1 Reactor Coolant Pump Flywheel AnalysisN/ADCI4.7.2Leak Before Break(i)DCI4.7.3.Steam generator Flow Induced Vibration and Tube WearIP2- (i)IP3- (ii)DCI Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan F-1 APPENDIX F CONSISTENT WITH GALL REPORT AMP AUDIT/REVIEW WORKSHEET The worksheet provided in this appendix provides, as an aid for the reviewer, a process for documenting the basis for the assessment of the elements and sub-elements contained in the GALL Report AMPs (Chapter XI of NUREG-1801, Volume 2). The worksheet provides a

systematic method for recording the basis for assessments or to identify when the applicant

needs to provide clarification or additional information. Information recorded in the worksheets

will also be used to prepare the safety evaluation report input.

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

Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan F-2LRA Appendix Subsection: LRA AMP Title: GALL Report Subsection:Gall Report Title:A. Element Review and Audit Program

Description:

G Consistent with GALL Report G Difference Identified Discussion:

1. Scope of Program:

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

2. Preventive Action:

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

3. Parameters Monitored/Inspected:

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

4. Detection of Aging Effects:

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

5. Monitoring and Trending:

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

6. Acceptance Criteria:

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

7. Corrective Action:

Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan F-3 8. Confirmation Process:

9. Administrative Controls:

10. Operating Experience:B. FSAR supplement review: (Include any commitments.)C.Remarks and questions:D.References/documents used: (Include number designation, full title, revision number, date, and page numbers, and ADAMS accession number.)E.Applicant contact:

Project team member: __________________________________ Date: ______________

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

sub-elements contained in Branch Technical Position RLSB-1 "Aging Management Review -

Generic," in Appendix A to the SRP-LR. The worksheet provides a systematic method to record

the basis for assessments or identifying when the applicant needs to provide additional

information. Information recorded in these worksheets will be used when preparing the safety

evaluation report input.

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

Appendix Subsection: ____________________________________________________A.Element Review and Audit1.Scope of Program:___ Consistent with SRP-LR____ Exception____ Difference Identified Discussion:SRP CriteriaLRA AMPComment*2.Preventive Action:___ Consistent with SRP-LR____ Exception____ Difference Identified Discussion:SRP CriteriaLRA AMPComment*3.Parameters Monitored/Inspected:___ Consistent with SRP-LR____ Exception____ Difference Identified Discussion:SRP CriteriaLRA AMPComment*4.Detection of Aging Effects ___ Consistent with SRP-LR____ Exception____ Difference Identified Discussion:SRP CriteriaLRA AMPComment*

Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan G-35.Monitoring and Trending___ Consistent with SRP-LR____ Exception

____ Difference Identified Discussion:

SRP Criteria LRA AMP Comment*6.Acceptance Criteria

___ Consistent with SRP-LR____ Exception

____ Difference Identified Discussion:

SRP Criteria LRA AMP Comment*7.Corrective Action:

8.Confirmation Process:

9.Administrative Controls:10.Operating Experience:___ Consistent with SRP-LR____ Exception

____ Difference Identified Discussion:

SRP Criteria LRA AMP Comment**Consistent or technical basis for acceptance exception or differenceB.FSAR supplement review: (Include any commitments.)C.Remarks and questions:D.References/Documents used: (Include number designation, full title, revision number, date, page numbers, and ADAMS accession number.)E.Applicant Contact:

Project team member:

_________________________________

Date: ______________

Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan H-1 Appendix H AMR Comparison Worksheets Indian Point Nuclear Generating Unit Nos. 2 and 3AMP and AMR Audit and Review Plan H-2 IP2 and IP3 AMR Component (Table 1) Worksheet: Audit Date:Unit:Table No.: Chapter:

Auditor Name(s):

The audit team verified that items in Table 3.X.1 (Table 1) correspond to items in the GALL Volume 1, Table X. All itemsapplicable to PWRs in Table 1 were reviewed and are addressed in the following table.Item No.Further Evaluation RecommendedDiscussion Audit remarks (Document all questions for applicant here): NumberQuestion for applicant (draft per RAI guidance)Response (with date)

References/Documents Used:

1.2.

3.

4..

Indian Point Nuclear Generating Unit Nos. 2 and 3AMP and AMR Audit and Review Plan H-3 IP2 and IP3 AMR MEAP Comparison (Table 2) Worksheet Audit Date:Unit:Table No.:Chapter:

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

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

LRA Page No.Component TypeMaterialEnvironmentAging EffectNote:Discussion (draft as Audit Report Insert)

Audit remarks (Document all questions for the applicant here):No.Question for applicant (draft per RAI guidance)Response (with date)

References/Documents Used:

1.2.

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

Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan I-1 APPENDIX I ACRONYMS, ABBREVIATIONS, AND INITIALISMSADAMSAgencywide Documents Access and Management SystemAMPaging management program AMRaging management review ASMEAmerican Society of Mechanical EngineersCLBcurrent licensing basis DEDivision of EngineeringDLRDivision of License Renewal FSARFinal Safety Analysis Report GALLGeneric Aging Lessons Learned ISG-LRInterim Staff Guidance for License RenewalIP2Indian Point Nuclear Generating Unit No. 2 IP3Indian Point Nuclear Generating Unit No. 3 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 componentsSERsafety evaluation report SRP-LRStandard Review Plan - License Renewal SSCstructure, system, and component Indian Point Nuclear Generating Unit Nos. 2 and 3 AMP and AMR Audit and Review Plan I-2TLAATime Limited Aging AnalysisUFSARUpdated Final Safety Analysis Report