**NRC INSPECTION MANUAL** RLEP

INSPECTION PROCEDURE 71002

LICENSE RENEWAL INSPECTION

PROGRAM APPLICABILITY: IMC 2516

71002‑01 INSPECTION OBJECTIVES

01.01 To verify the applicant=s license renewal program, including
supporting activities, are implemented consistent with the requirements
of Title 10 of the *Code of Federal Regulation (10 CFR)*, Part 54,
\@Requirements for the Renewal of Operating Licenses for Nuclear Power
Plants@, hereinafter referred to as the Arule@, and the applicant=s
license renewal application (LRA).

01.02 To verify the material condition of the systems, structures and
components (SSCs) that require an aging management review, will be
adequately maintained consistent with the rule, the staff=s safety
evaluations, and the applicant=s license renewal program.

01.03 To verify the information and documentation required by, or
necessary to document compliance with the provisions of the rule are
retrievable, auditable and consistent with the rule and applicant
approved programs and procedures.

71002-02 DEFINITIONS

[Passive Structures and Components (SCs)]{.underline}. Structures and
Components which perform an intended function without moving parts or
without a change in configuration, change in properties, or change of
state. These may include SCs which are classified as inherently reliable
under the maintenance rule, or SCs for which aging degradation is not
readily monitored.

[Long-lived Structures and Components]{.underline}. Structures and
components which are not subject to replacement based on a qualified
life or specified time period.

[Current Licensing Basis(CLB)]{.underline}. As defined in 10 CFR 54.3,
CLB is the set of NRC requirements applicable to a specific plant and a
licensee=s written commitments for ensuring compliance with and
operation within applicable NRC requirements and the plant-specific
design basis (including all modifications and additions to such
commitments over the life of the license) that are docketed and in
effect.

71002-03 INSPECTION REQUIREMENTS

03.01 [General Inspection Requirements]{.underline}

The License Renewal Inspections (LRIs) verify, on a sampling basis:

a.  The applicant=s implementation of the scoping and screening
    methodology includes nonsafety-related systems, structures, and
    components (SSCs) whose failure could prevent safety-related SSCs
    from accomplishing a safety function.

b.  Passive, long lived SSCs within the scope of license renewal are
    subject to an aging management review (AMR), and have existing or
    planned aging management programs (AMPs) that conform with
    descriptions contained in the LRA. The AMPs can reasonably manage
    the effects of aging.

c.  The documentation used to support the application is auditable and
    retrievable and contains information that supports the application.

03.02 [Specific Inspection Requirements]{.underline}

a.  [Scoping and Screening Inspection]{.underline}. The LRI verifies on
    a sampling basis, through onsite review and walk-down of selected
    areas of the plant, that the SSCs required by the rule have been
    adequately documented. In addition, the inspection should verify
    that nonsafety-related SSCs whose failure could prevent
    safety-related SSCs from accomplishing a safety function are
    correctly included within scope of license renewal. Depending on
    insights gained from the staff=s review, the inspection may also
    include safety-related SSCs and SSCs relied on to mitigate regulated
    events as specified in 10 CFR 54.4(a). The LRI verifies that there
    is reasonable assurance that the applicant has adequately documented
    all the identified passive and long-lived SSCs requiring an AMR. The
    LRI verifies, through review of supporting documents and a walk-down
    of select systems, that the effects of aging can be adequately
    managed in the period of extended operation. Using a set of samples
    selected based on insights from the staff=s review of the LRA,
    uniqueness, safety impact, and risk insights, the inspection should
    emphasize evaluation of whether the scoping process adequately
    includes nonsafety-related SSCs whose failure could prevent
    safety-related SSCs from accomplishing a safety function. These
    nonsafety-related SSCs should be included in order to provide
    protection against safety function failure in cases where the
    safety-related structure or component is not itself impaired by
    age-related degradation, but is vulnerable to failure from the
    failure of another structure or component that may be so impaired.
    Consideration of hypothetical failures that could result from system
    interdependencies that are not part of the current licensing bases
    and that have not been previously experienced is not required. The
    scoping criterion required under 10 CFR 54.4(a)(2) does not apply to
    functions identified in 10 CFR 54.4(a)(3) ARegulated Events@.

> One of the samples selected should include at least one system,
> structure, or commodity group not identified as being within the scope
> of license renewal.

b.  [Aging Management Programs Inspection]{.underline}. This inspection
    is intended to assess the adequate implementation of the aging
    management programs (AMPs) resulting from the applicant=s license
    renewal program, and may be performed in conjunction with the
    scoping and screening inspection. For selected SSCs within the scope
    of the rule the following inspection activities should be
    undertaken:

    1.  For the selected SSCs, determine from the LRA which AMPs are
        credited with preventing applicable aging effects. Verify the
        AMPs will ensure the aging effects will be managed so that there
        is reasonable assurance that the intended function will be
        maintained consistent with the CLB throughout the period of
        extended operation.

    2.  Review the description of these AMPs from the LRA, UFSAR, plant
        procedures, and related engineering support documentation.
        Interview the on-site engineering staff responsible for
        implementation of these AMPs to assess their knowledge and
        involvement in the license renewal effort. Discuss AMP program
        methods, past results, past weaknesses and corrections, and
        future plans.

    3.  Verify the applicant evaluated site-specific information such as
        surveillance test results, preventive maintenance records,
        corrective maintenance records, equipment history files,
        inservice test and inspection results in determining aging
        effects. Verify the applicant evaluated industry operational
        experience such as generic communications, vendor notifications,
        INPO notifications, etc., in determining aging effects.

    4.  Perform walk-downs of selected in-scope SSCs to verify that any
        observable aging effects were identified by the applicant for
        these SSCs. If possible, the inspector should have a
        representative from the on-site responsible engineering staff
        accompany the inspector during the walk-down to discuss
        observations at the equipment location. The purpose of these
        walk-downs is to assess how plant equipment is currently being
        maintained and to visually observe examples of nonsafety-related
        equipment determined to be in scope due to their proximity to
        safety-related equipment and their potential for failure due to
        aging effects. If possible, a part of this inspection should be
        performed during a unit outage, to allow visual observation of
        equipment inaccessible during power operation, i.e., inside
        containment, normal high radiation areas, etc. Containment
        inspection shall be performed if (a) there is evidence that some
        aging effects are not adequately addressed in the application,
        or (b) there is an open item, generated either by the inspection
        or the application review, that is related to an area
        inaccessible during the regularly scheduled inspection, and (c)
        the areas of interest in the facility will become available
        prior to the final inspection exit meeting observed by the
        public. Observed aging effects not addressed by the LRA and
        resulting AMPs should be discussed and addressed to the
        applicant and resolved with the support of NRR.

    5.  For previously existing AMPs, review the results of past tests
        and inspections. Verify the proposed and existing programs
        adequately demonstrate ample opportunity to detect, monitor,
        trend, and correct age related degradations through performance
        and/or condition monitoring, technical specification
        surveillances, and other aging management activities.

c.  [Annual Update/Open Item Inspection]{.underline}. The applicant may
    make changes to the plant or the current licensing basis while the
    NRC performs its review of the LRA. Annually, after the initial
    application, the applicant is required to submit an amendment to the
    original application describing any change that materially affects
    the contents of the original application. The applicant may also
    make changes or commitments to satisfy an issue raised during the
    NRC review process or raised during a previous LRI. This inspection
    will be conducted at the option of the Regional Administrator.
    During this LRI the following inspection tasks should be
    accomplished:

    1.  Select a sample of plant modifications and CLB changes the
        applicant made since the date of the original LRA submittal.
        Determine that these changes were included in an annual LRA
        update. For newly installed plant equipment required to be in
        the scope of license renewal, verify that the equipment is
        included in appropriate aging management programs.

    2.  Compile the issues raised by previous LRIs and determine the
        current status from the applicant. Determine if the issue has
        been resolved. If the issue has not been resolved, determine
        what the applicant=s plans are to resolve the issue and
        coordinate with NRR to determine the acceptability of those
        plans.

    3.  Determine that the applicant has compiled a list of future tasks
        to be accomplished as a result of commitments made during the
        license renewal process and loaded this list into an official
        plant work tracking system. This review is to ensure that
        commited tasks are being tracked to be accomplished prior to and
        during the period of extended operation.

71002‑04 INSPECTION GUIDANCE

04.01 [General Inspection Guidance]{.underline}. This license renewal
inspection procedure will be implemented, prior to the approval of an
application for renewed license, to verify that an applicant, requesting
a renewed license under 10 CFR Part 54, meets the requirements of the
rule and has implemented license renewal programs and activities
consistent with their LRA and the safety evaluations developed by the
NRC staff. LRIs will be performed by NRC regional offices and will
include visits to the applicant=s site. The inspections will cover the
items discussed in 03.01. The inspection may include the annual LRA
update process, and unresolved open items resulting from previous
inspections or staff review of the LRA.

Inspectors should familiarize themselves with the requirements and
guidance relating to license renewal. Inspectors should familiarize
themselves with the LRA and associated safety evaluations performed by
the staff for the specific plant to be inspected. License renewal
requirements and guidance documents that should be reviewed prior to an
inspection include:

a.  10 CFR Part 54, \"Requirements for Renewal of Operating Licenses for
    Nuclear Power Plants\";

b.  The statements of consideration (SOC) published with the revision to
    the rule in the [Federal]{.underline} [Register]{.underline}, Vol.
    60, No. 88, Monday, May 8, 1995, pages 22461 to 22495;

c.  Regulatory Guide 1.188; \"Standard Format and Content for
    Applications to Renew Nuclear Power Plant Operating Licenses,\" July
    2001;

d.  NUREG-1800, AStandard Review Plan for Review of License Renewal
    Applications for Nuclear Power Plants,@ July 2001;

e.  NUREG-1801, AGeneric Aging Lessons Learned (GALL) Report,@ July
    2001;

f.  Nuclear Energy Institute 95‑10, \"Industry Guideline for
    Implementing the Requirements of 10 CFR Part 54 - The License
    Renewal Rule,\" Rev. 3, March 2001; and

g.  NRC approved Interim Staff Guidance positions relating to license
    renewal.

Throughout the license renewal inspection, the inspectors should review
the supporting documentation associated with an applicant=s license
renewal program to verify that documentation required by the rule, or
otherwise necessary to verify compliance with the rule, is being
maintained in an auditable and retrievable form consistent with the
requirements of 10 CFR 54.13 and 54.37, the applicant=s LRA, and
applicant=s approved programs and procedures.

04.02 [Specific Inspection Guidance]{.underline}

a.  [Scoping and Screening Requirements]{.underline}. The license
    renewal program must include nonsafety-related SSCs whose failure
    could prevent safety-related SSCs from accomplishing a safety
    function. These nonsafety-related SSCs are included in order to
    provide protection against safety function failure in cases where
    the safety-related structure or component is not itself impaired by
    age-related degradation but is vulnerable to failure from the
    failure of another structure or component that may be so impaired.
    Consideration of hypothetical failures that could result from system
    interdependencies that are not part of the current licensing bases
    and that have not been previously experienced is not required.

b.  [Aging Management Programs Inspection]{.underline}. As required
    under 10 CFR 54.21(a)(3), an applicant is required to demonstrate
    that the aging effects will be adequately managed so the intended
    function will be maintained consistent with the CLB for the period
    of extended operation. To fulfill this requirement an applicant must
    first identify the applicable aging effects, and the aging
    management program(s) and activities that will manage each aging
    effect.

> As part of the inspection process of AMP documentation, the site
> inspector needs to ensure that the implementation of the program is
> producing results consistent with the claims made by the applicant as
> to how the program will manage the aging effect in question. Each
> program should clearly state how the aging management program will
> manage the aging effect, and the supporting documentation, along with
> the material condition of the SSCs, must be consistent with these
> claims.
>
> Some AMPs may have an objective to monitor and trend ongoing
> degradation, and implement corrective actions prior to anticipated
> failure of a structure or component to perform its intended function
> consistent with the applicant=s CLB. During the site inspection, any
> trends identified as being less conservative with respect to the
> objectives of the AMPs in the LRA and/or applicant approved procedures
> need to be identified to NRR and included in the inspection report.

71002‑05 RESOURCE ESTIMATES

License renewal inspection activities will require approximately two
weeks of inspection time on site involving a team of four inspectors and
a team leader. An additional week will be allocated each to inspection
preparation, in-office review between two onsite weeks, and for
documentation of the inspection results. In addition, from past
experience, the team leader will need approximately 15 additional
working days to finalize the inspection report. Based on past
experience, the final follow up inspection can be accomplished by one
inspector with one preparation week, one week of inspection on site,
plus two additional weeks for documentation. Based on these estimates,
each application will require approximately 32 inspector weeks of
inspection activities prior to the approval of a renewed license.

71002‑06 REFERENCES

10 CFR Part 54, \"Requirements for Renewal of Operating Licenses for
Nuclear Power Plants\"

U.S. Nuclear Regulatory Commission, Regulatory Guide 1.188, \"Standard
Format and Content for Applications to Renew Nuclear Power Plant
Operating Licenses,\" July 2001

Nuclear Energy Institute, \"Industry Guideline for Implementing the
Requirements of 10 CFR Part 54 - The License Renewal Rule,\" NEI 95-10,
Rev. 3, March 2001

NUREG 1568, \"License Renewal Demonstration Program: NRC Observation and
Lessons Learned,\" December 1996

NUREG-1800, AStandard Review Plan for Review of License Renewal
Applications for Nuclear Power Plants,@ July 2001

NUREG-1801, AGeneric Aging Lessons Learned (GALL) Report,@ July 2001

U.S. Nuclear Regulator Commission, \"Nuclear Power Plants License
Renewal; Revisions,\" [Federal]{.underline} [Register]{.underline}, Vol.
60, No. 88, Monday, May 8, 1995, pages 22461 to 22495

U.S. Nuclear Regulator Commission, \"Standard Review Plan for the Review
of License Renewal Applications for Nuclear Power Plants,\" April 21,
2000.

END