**NRC INSPECTION MANUAL** RLEP

MANUAL CHAPTER 2516

POLICY AND GUIDANCE FOR THE

LICENSE RENEWAL INSPECTION PROGRAMS

2516‑01 PURPOSE

The purpose of MC 2516 is to document policy and guidance for review and
inspection activities associated with the License Renewal Inspection
Program (LRIP). The LRIP is the process used by Nuclear Regulatory
Commission (NRC) staff, region, and consultants to verify the accuracy
of the aging management programs and activities associated with an
applicant=s request for a renewed license for a commercial nuclear power
plant beyond the initial licensing period under Title 10 of the Code of
Federal Regulation, (10 CFR) Part 54.

2516‑02 POLICY AND OBJECTIVES

02.01 The basic policies, excerpted from the Statements of Consideration
of the License Renewal Rule, and objectives used in the development and
implementation of the LRIP are as follows:

a.  The NRC exists to assure that the public health and safety, the
    common defense and security, and the environment are protected.

b.  With respect to license renewal of a commercial nuclear power plant,
    the NRC has established the following two basic principles:

    1.  The first principle of license renewal is that with the
        exception of age-related degradation and possibly a few other
        issues related to safety only during extended operation of
        nuclear power plants, the existing regulatory process is
        adequate to ensure that the licensing bases of all currently
        operating plants provide and maintain an acceptable level of
        safety so that operation will not be inimical to public health
        and safety or common defense and security.

    2.  The second and equally important principle of license renewal
        holds that the plant-specific licensing basis must be maintained
        during the renewal term in the same manner and to the same
        extent as during the original licensing term. This would be
        accomplished, in part, through a program of age-related
        degradation management.

c.  An applicant for license renewal should rely on the plant\'s current
    licensing basis (CLB), actual plant-specific experience,
    industry-wide operating experience, as appropriate, and existing
    engineering evaluations to determine those systems, structures, and
    components that are the initial focus of the license renewal review.

d.  The detrimental effects of aging affecting passive structures and
    components are less apparent than the detrimental effects of aging
    affecting structures and components that perform their intended
    functions with moving parts or a change in configuration or
    properties (active structures and components). Therefore, the aging
    management review of passive structures and components is needed to
    provide reasonable assurance that their intended functions are
    maintained consistent with the CLB during the period of extended
    operation.

e.  For the purpose of license renewal, an applicant can generically
    exclude, from its integrated plant assessment, the aging management
    review of the following: (1) active structures and components,
    and (2) structures and components that are replaced, based on
    qualified life or specified time period, when the replacement
    frequency is less than 40 years (Ashort-lived@). In addition, some
    components are both active and passive. Components that are passive,
    or both active and passive, must be included within the scope of
    components requiring an aging management review based on the
    intended function(s) that is performed without moving parts or
    change in configuration or properties.

f.  Postulated failures that could result from system interdependencies
    that are not part of the CLB and that have not been previously
    experienced, need not be considered as part of a license renewal
    application (LRA). However, for some license renewal applicants,
    postulated failures that are part of the CLB may require
    consideration of more than the first level support systems.

02.02 The objectives of the LRIP are as follows:

a.  The LRIP will provide the guidance for the inspection of license
    renewal programs, documentation, and activities necessary for the
    staff to make a finding that an applicant=s LRA, aging management
    programs (AMPs), implementation activities, and on-site
    documentation provide reasonable assurance that the effects of aging
    will be effectively managed consistent with the CLB during the
    period of extended operation.

b.  The LRIP will also provide the guidance for assessing the adequacy
    of implemented AMPs to effectively manage the effects of aging,
    consistent with the licensee=s CLB, after the renewed license is
    issued.

2516‑03 DEFINITIONS

[Current licensing basis]{.underline} is the set of NRC requirements
applicable to a specific plant and a licensee\'s written regulatory
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. The CLB includes the NRC
regulations contained in 10 CFR Parts 2, 19, 20, 21, 26, 30, 40, 50, 51,
54, 55, 70, 72, 73, 100 and appendices thereto; orders; license
conditions; exemptions; and technical specifications. It also includes
the plant‑specific design-basis information defined in 10 CFR 50.2 as
documented in the most recent final safety analysis report (FSAR) as
required by 10 CFR 50.71; and the licensee\'s commitments remaining in
effect that were made in docketed licensing correspondence such as
licensee responses to NRC bulletins, generic letters, and enforcement
actions, as well as licensee commitments documented in NRC safety
evaluations or licensee event reports.

[Regulatory Commitment]{.underline} is an explicit statement made by a
licensee (or applicant) to take a specific action agreed to or
volunteered by a licensee, and that has been submitted in writing on the
docket to the Commission.

[Integrated Plant Assessment (IPA)]{.underline} is a licensee assessment
that demonstrates that a nuclear power plant facility\'s structures and
components requiring aging management review in accordance with
\'54.21(a) for license renewal have been identified and that the effects
of aging on the functionality of such structures and components will be
managed to maintain the CLB such that there is an acceptable level of
safety during the period of extended operation.

[Nuclear power plant]{.underline} means a nuclear power facility of a
type described in 10 CFR 50.21(b) or 50.22.

2516‑04 RESPONSIBILITIES AND AUTHORITIES

04.01 Director of Nuclear Reactor Regulation (NRR) is responsible for
approving and issuing the renewed license for a period beyond the
current licensing term.

04.02 Regional Administrators (RAs) are responsible for the following:

a.  Managing and supervising the implementation of license renewal
    inspection programs and activities at their respective regions.

b.  Making recommendations for the approval/disapproval of a request for
    a renewed license by an applicant from their region, on the basis of
    the inspection results.

04.03 The Responsible Regional Division Director or designee is
responsible for the approval of license renewal inspection plans within
its region.

04.04 Division of Regulatory Improvement Programs (DRIP), NRR is
responsible for the following:

a.  Overall development and implementation of staff programs and
    activities associated with 10 CFR Part 54.

b.  Coordination of the staff=s final recommendation for the
    approval/disapproval of a request for a renewed license.

c.  Ensuring adequate training is developed and made available to NRR
    staff and regions.

04.05 License Renewal and Environmental Impacts Program (RLEP), NRR is
responsible for the following:

a.  Development and control of the license renewal Standard Review Plan
    (SRP-LR), Regulatory Guides, and LRIP.

b.  Coordination of LRA reviews.

c.  Technical and inspection support for the review and inspection of
    license renewal applicants= programs and activities.

d.  Development of an adequate training program for NRC license renewal
    activities.

2516-05 GENERAL POLICIES

05.01 [Authority]{.underline}. NRR is assigned the responsibility to
establish the foundation on which the reactor inspection program is
structured, and to confer on the regions the authority to inspect
activities over which the NRC has jurisdiction. For the purpose of
license renewal, NRR/DRIP, will be responsible for the development and
oversight of the LRIP, while the regions will be responsible for the
implementation of the LRIP. Any follow-up and future inspection needs
relating to license renewal after the renewed license is granted will be
integrated into the Reactor Oversight Program under Manual Chapter (MC)
2515. The responsibility for these inspections will be maintained by the
regions.

05.02 [Applicant Responsibility]{.underline}. It is emphasized that it
is the applicant\'s responsibility to maintain and operate the facility
safely and in compliance with the CLB and regulatory requirements. NRC
inspections are not designed to duplicate or substitute for an
applicant\'s management controls established as a part of its quality
verification system.

05.03 [Communications]{.underline}. In implementing the inspection
program set forth by this manual chapter, frequent communications
between RLEP, the regions and other offices within the NRC are
encouraged. An inspection plan, based on the requirements of IP 71002
and subject to the approval of the responsible Regional Division
Director or designee, will be developed early in the inspection process
by the inspection team leader for each applicant with assistance from
RLEP. The region will implement this plan with assistance from RLEP and
other supporting organizations.

2516‑06 LICENSE RENEWAL INSPECTION PROGRAM

06.01 [Purpose]{.underline}. The fundamental task of the LRIP is to
ensure that there is reasonable assurance that the effects of aging will
be managed consistent with the CLB during the period of extended
operation. The program objectives derived from that task are as follows:

a.  To provide a basis for recommending issuance or denial of a renewed
    license.

b.  To identify weaknesses within an applicant=s overall license renewal
    program or an individual AMP that fail to provide reasonable
    assurance that the applicable aging effects will be adequately
    managed during the period of extended operation.

c.  To determine the status of compliance with 10 CFR Part 54 and other
    areas relating to maintaining and operating the plant such that the
    continued operation beyond the current licensing term will not be
    inimical to the public health and safety.

06.02 [Independent Inspection Policy]{.underline}. These inspections
should be conducted in accordance with inspection procedure IP 71002.
However, it is not possible to anticipate all the unique circumstances
that might be encountered during the course of a particular inspection
and, therefore, individual inspectors are expected to exercise
initiative in conducting inspections based on their expertise and
experience to assure that all the inspection objectives are met.

If in the course of conducting an inspection, current potential safety
concerns or compliance issues outside the scope of the procedure being
executed are identified, the concerns should be pursued to the extent
necessary to understand the issue and then they will be turned over to
the Senior Resident Inspector for further follow-up inspection.

06.03 [License Renewal Review Program]{.underline}. The license renewal
review program consists of an LRA review and site inspections. The LRA
review is primarily a headquarters review performed by NRR to ensure
that the applicant meets the technical and regulatory requirements of
the rule, and to verify that the format and content of the application
meet the requirements of the rule. The regional staff and inspection
team members will become familiar with the LRA in preparation for
inspections to provide operational and performance input in the
application review, to assess the applicant=s commitments against their
past performance and experience, and in preparation to provide a
regional recommendation to grant or deny approval for the applicant=s
request for a renewed license.

06.04 [Site-Inspections]{.underline}. The site inspections are
assessments of an applicant=s implementation of and compliance with 10
CFR Part 54 requirements. All inspection teams will be led by the
regions and any NRR supporting staff will be detailed to the region for
the period of time necessary to prepare, inspect, and document
inspection activities. The site inspections will be performed by a team
inspection in the areas of the scoping and screening activities,
observation of the condition of plant equipment, and implementation of
the aging management programs and review of associated documentation. By
observing the current condition of plant equipment in the scope of
license renewal, inspectors may identify the effects of aging not
previously recognized. Such observations allow the inspectors to
evaluate the success of previously implemented plant programs which are
being credited for license renewal AMPs. The site-inspection activities
will be performed using IP 71002 ALicense Renewal Inspections.@

06.05 [Post Renewal Site-Inspections]{.underline}. Site inspections of
AMP implementation conducted after the approval of the renewed license
will be conducted in accordance with IP 71003 APost-Approval Site
Inspection for License Renewal.@ These inspections will verify the
licensee=s continued compliance with 10 CFR Part 50 and implementation
of commitments related to the LRA.

06.06 [Inspection Documentation]{.underline}. Inspections will be
documented with inspection reports sent to the applicant and made
publicly available in ADAMS. Attachments to IMC 2516 provide guidance on
the preparation of documents related to the site inspection. Attachment
1, ARegion Notification of Plant Readiness For License Renewal,@
provides a region with guidance on how to prepare its overall evaluation
of inspection activities performed on an applicant for license renewal.
Attachment 2, ASample License Renewal Inspection Letter,@ is a sample
letter of an overall evaluation of the inspection completion. The
results of site team inspections will provide major input for the staff
and regional recommendations to grant or deny an applicant=s request for
a renewed license.

END

Attachments:

1\. Region Notification of Plant Readiness for License Renewal

2\. Sample License Renewal Inspection Letter

Attachment 1

REGION NOTIFICATION OF PLANT READINESS FOR LICENSE RENEWAL

OBJECTIVES

-   Provide a status of the license renewal inspection program and
    findings.

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-   Provide a summary status of the applicant=s license renewal program
    compliance with 10 CFR Part 54.

NOTIFICATION

Approximately 30 days before the scheduled issuance of a renewed
license, the regional office will provide an overall evaluation of
inspection activities to assess the applicant=s readiness for
relicensing for an extended period of operation. The evaluation will be
transmitted by memorandum to the Office Director, Office of Nuclear
Reactor Regulation (NRR). It will include the region\'s evaluation as to
whether or not the applicant has adequately documented and implemented
license renewal programs and activities consistent with the rule such
that there is reasonable assurance that the effects of aging will be
managed consistent with the current licensing basis (CLB) throughout the
period of extended operation. This evaluation will be based on sample
inspections of the applicant=s scoping, screening, and aging management
programs and activities relating to license renewal to verify, with
reasonable assurance, that these programs and activities have been
implemented effectively and the associated procedures and records have
been documented consistent with the rule, and site approved programs and
procedures.

The status report will address the following areas, as appropriate:

a.  [Inspection Program]{.underline}. Review the status of inspections
    required by IP 71002 and identify all outstanding inspection items
    and the reason(s) for their incompleteness.

b.  [Other Items]{.underline}. Identify any other items relative to the
    applicant=s readiness to operate for the period of extended
    operation requested by the applicant.

ATTACHMENT 2

SAMPLE LICENSE RENEWAL INSPECTION LETTER

MEMORANDUM TO: James E. Dyer, Director

Office of Nuclear Reactor Regulation

FROM: Luis A. Reyes, Regional Administrator

SUBJECT: V. C. SUMMER LICENSE RENEWAL APPLICATION

South Carolina Electric & Gas Company (SCE&G), by letter dated August 6,
2002, requested license renewal of V. C. Summer Nuclear Station in
accordance with Title 10 of the Code of Federal Regulations Part 54 (10
CFR 54). We have completed inspections at Summer in accordance with the
guidance contained in Inspection Manual Chapter 2516 and Inspection
Procedure 71002, closely coordinating with the Office of Nuclear Reactor
Regulation (NRR) to confirm the scope and timing of the inspections. The
inspections verified that SCE&G implemented the scoping and screening
methodology and established aging management programs in conformance
with the descriptions contained in SCE&G\'s application for license
renewal. Sampling inspections verified, with reasonable assurance, the
acceptability of the existing and planned aging management programs. The
inspections also verified the documentation used to support the
application to be in an auditable and retrievable form. The inspections
also reviewed license renewal corrective actions for issues raised by
the NRC. Details of the scope of our inspections and results are
contained in Inspection Reports 50-395/2003-07 dated June 13, 2003,
2003-08 dated September 29, 2003, and 2003-09 dated December 11, 2003.

We have determined that SCE&G programs and activities related to the
license renewal of Summer have been or will be completed in substantial
agreement with docketed commitments and regulatory requirements prior to
the date of expiration of the current 40 year operating license. SCE&G
demonstrated the capability to manage the effects of aging during the
period of extended operation. We, therefore, conclude that there is
reasonable assurance that SCE&G=s aging management programs provide an
adequate foundation for renewing the license for Summer for an
additional twenty years.

Should you have any questions concerning this letter, please contact me
at (404) 562-4410.

Docket No. 50-395

License No. NPF-12