NUREG-15 68 

License Renewal 

Demonstration Program: 

NRC Observations and 

Lessons Learned 

US. Nuclear Regulatory Commission 

Office of Nuclear Reactor Regulation 

R. J. Prato, P. T. Kuo, S. E Newberry 
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1001 8-3308. 
NUREG-1568 

License Renewal 

Demonstration Program: 

NRC Observations and 

Lessons Learned 

Manuscript Completed: September 1996 

Date Published December 1996 

R. J. Prato, P. T. Kuo, S. E Newberry 

Division of Reactor Program Management 

Ofice of Nuclear Reactor Regulation 

U.S. Nuclear Regulatory Commission 

Washington, DC 20555-0001 
DISCLAIMER 

Portions of this document my be iIlegible 

in electronic image products. Images are 

produced from the best available original 

document. 

L I 
DISUAIMER 

This report was prepared as an account of work sponsod by an agency of the 

United States Government. Neither the United States Government nor any agency 

thereof, nor any of their employees, makes any warranty, express or implied, or 

assumes any legal liabiiity or responsibility for the accuracy, completeness, or usefulness of any information, apparatus, product, or process disclosed, or represents 

that its use would not infringe privately owned rights. Reference herein to any specific commercial product, process, or service by trade name, trademark, manufacturer, or otherwise does not necessarily constitute or imply its endorsement, recommendation, or favoring by the United States Government or any agency thereof. 

The views and opinions of authors expressed herein do not necessarily state or 

reflect those of the United States Government or any agency thereof. 
ABSTRACT 

Thi s report summarizes the Nuclear 

Regulatory Commi ssion staff’s observations and lessons learned from the 

five License Renewal Demonstration 

Program (LRDP) site visits performed 

by the staff from March 25, 1996, 

through August 16, 1996. The LRDP 

was a Nuclear Energy Institute (NEI) 

program intended to assess the 

effectiveness of the guidance provided by NE1 95-10, Revision 0, 

“Industry Guide1 ine for Implementing 

the Requirements of 10 CFR Part 54 - 

The License Renewal Rule,” to implement the requirements of Title 10 of 

the Code of Federa7 Regu7ations, 

Part 54 (10 CFR Part 54), “Requirements for Renewal of Operating 

Licenses for Nuclear Power Plants.” 

In general, NE1 95-10 appeared to 

contain the basic guidance needed 

for scoping, screening, identifying 

aging effects, developing aging 

management programs, and performing 

time-limited aging analyses. However, inconsistent implementation of 

this guidance in some areas was an 

indication that clarification of 

iii 

existing guidance and/or the inclusion of some new guidance may be 

needed for applicants to develop a 

license renewal program that is 

consistent with the intent of the 

rul e. 

The observations and lessons learned 

discussed in this report, as well as 

comments received from the industry 

and members of the public, will be 

used to identify additional guidance 

or changes to existing guidance 

needed to implement the requirements 

of license renewal as intended by 

10 CFR Part 54. Draft Regulatory 

Guide (DG) DG-1047, “Standard Format 

and Content for Applications to 

Renew Nucl ear Power Pl ant Operating 

Licenses,” contains the guidance 

recommended by the staff for implementing the requirements under the 

rule. This draft regulatory guide, 

when finalized, is expected to endorse NE1 95-10. In addition, 

changes as approved by the staff 

from comments provided by the public 

and industry will be added prior to 

final publication of the regulatory 

guide. 

NUREG- 15 6 8 

TABLE OF CONTENTS 

ABSTRACT ................................ iii 

EXECUTIVE SUMMARY ............................ vi1 

ABBREVIATIONS .............................. ix 

1 . INTRODUCTION ............................ 1 

1.1 Objective ........................... 1 

1.2 Description of the LRDP .................... 1 

1.3 Description of the Rule for the Renewal of Operating Licenses . 2 

1.4 Implementation ........................ 3 

2 . LESSONS LEARNED FROM THE LRDP SITE VISITS ............... 3 

2.1GeneralIssues ......................... 3 

2.1.1 Topical Reports ..................... 3 

2.1.2GSIsandUSIs ...................... 3 

2.2 Scoping Process ....................... 4 

2.2.1 Identifying Systems. Structures. and Components ..... 4 

2.2.2 Identi fyi ng System-/Structural -Level Intended Functi on . 5 

2.3 Screening Process ........................ 6 

2.3.1 Evaluation Boundaries .................. 6 

2.3.2 Identifying Structural-/Component-Level 

Intended Function .................... 6 

2.3.3 Identifying Component Passive Functions ......... 7 

2.3.4 Identifying Long-Lived Characteristics ......... 7 

2.3.5 Identifying and Listing of Structures and Components . . 8 

2.4 Aging Management Review ..................... 8 

2.4.1 Identifying Aging Effects ................ 9 

2.4.2 Use of Operating Experience ............... 9 

2.4.3 Aging Management Programs ................ 10 

2.5 Demonstration .......................... 11 

2.6 TLAA .............................. 12 

2.7 FSAR Supplement ......................... 12 

3 . CONCLUSIONS .............................. 13 

REFERENCES ................................ 14 

V NUREG-15 68 

EXECUTIVE SUHHARY 

Nuclear Energy Institute (NEI) published NE1 95-10, “Industry Guideline for Implementing the Requirements of 10 CFR Part 54 - The License Renewal Rule,” Revision 0, in 

March of 1996. NE1 95-10 is an 

industry guide1 ine for implementing 

regul atory requirements associ ated 

with the renewal of nuclear power 

plant licenses under Title 10 of the 

Code of Federal Regulations, Part 54 

(10 CFR Part 54), “Requirements for 

Renewal of Operating Licenses for 

Nuclear Power Plants.” Currently, 

the Nuclear Regulatory Commission 

(NRC) staff is involved in reviewing 

this NE1 effort with the intention 

of exercising its option to endorse 

the industry guideline. 

The License Renewal Demonstration 

Program (LRDP) was an NE1 effort 

intended to assess the effectiveness 

of the guidance provided by 

NE1 95-10, Revision 0, to implement 

the requirements of 10 CFR Part 54. 

The LRDP consisted of an NRC staff 

review of five 1 icense renewal (LR) 

programs, including a sample LR 

methodology, LR application, and 

supporting information developed by 

volunteer licensees (hereinafter , referred to as participants) from 

the guidance provided in NE1 95-10, 

Revision 0. 

The site visits were intended to be 

a review of the processes developed 

from implementing NE1 95-10 and a 

review of sample supporting materials to ensure that adequate guidance existed for potential applicants to develop the proper information in sufficient detail to allow 

the staff to make its findings. The 

LRDP site visits did not include the 

revi ew of any pl ant-speci f i c program 

for the purpose of determining its 

adequacy or acceptability in 

vii 

fulfilling the requirements of the 

rule. 

In general, the participants appeared to have performed the scoping and 

screening functions consistent with 

the guidance provided by NE1 95-10 

and the intent of the rule. However, potential improvements in the 

existing guidance under NE1 95-10, 

§ 4.1.2 and 3 4.2.1.1, that is used 

to identify intended functions and 

to assess structures and components 

passive functions have been identified. In addition, concerns associated with the listing of structures and components were observed 

during the LRDP, and indicated the 

need for additional guidance under 

NE1 95-10, Section 4. 

Although a number of good aging management processes were presented 

during the site visits, concerns 

were identified with some of the 

aging management programs presented 

by the participants during the site 

visits. In general, NE1 95-10, 

8 4.2.1, 8 4.2.1.2, and 9 4.2.1.3, 

appeared to contain the basic guidance for developing aging management 

programs but the participants’ failure to implement this guidance consistent with the intent of the, 

guideline was an indication that 

additional description and/or clarification may be needed. 

noted concern, common to all site 

visits, was the participants’ failure to provide a “demonstration” of 

the effectiveness of the aging management programs to manage the effects of aging under current licensing-basis design conditions during 

the period of extended operation. 

The content of the time-limited 

aging analyses (TLAAs) presented 

during the LRDP was generally 

The most 

NUREG-15 68 
consistent with the guidance under 

NE1 95-10, 5 5.1, and the intent of 

the rule. However, some of the 

participants indicated their intent 

to postpone of a number of TLAA 

evaluations until some time after 

submitting their LR application. 

The staff emphasized its expectation 

that TLAA eval uat i ons woul d be completed at the time of application. 

Additional guidance may be needed to 

cl airi fy th i s requi rement . 

The! si te-visi t teams observed that 

the! sample Final Safety Analysis 

Report (FSAR) supplements presented 

during the LRDP improved from site 

visit to site visit, but most of the 

samples presented did not meet the 

intent of the rule. Additional 

guidance for developing an LR FSAR 

supplement is needed to ensure consistent development of FSAR supplements that provide an adequate 

summary description of the aging 

management program. 

As a result of the LRDP, the staff 

will make recommendations to revise 

NE1 95-10 to include some additional 

descri pt i on , cl ari f i cat i on, and/or 

new guidance to address the concerns 

identified during the LRDP. 

NUEIEG-15 68 viii 
AMP 

AMR 

CLB 

FSAR 

GS I 

LR 

LRDP 

NE1 

NRC 

TLAA 

us I 

ABBREVI AT IONS 

agi ng-management program 

aging-management review 

current 1 icensing basis 

Final Safety Analysis Report 

generic safety issue 

1 i cense renewal 

License Renewal Demonstration Program 

Nuclear Energy Institute 

U.S. Nuclear Regulatory Commission 

time-limited aging analysis 

unresol ved safety issue 

ix NUREG-15 68 
1. INTRODUCTION 1.1 Object i ve 

Thi s report summarizes the observations and lessons learned from the 

site visits performed by the Nuclear 

Regul atory Commi ssi on (NRC) during 

the Nuclear Energy Institute (NEI) 

License Renewal Demonstrat ion Program (LRDP). 

LRDP was to assess the effectiveness 

of the guidance provided by 

NE1 95-10, “Industry Guideline for 

Implementing the Requirements of 

10 CFR Part 54 - The License Renewal 

Rule,” Revision 0, to implement 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.” NRC staff 

participated in this effort by performing the site visits to assess 

the implementation of NE1 95-10 by 

volunteer licensees (hereinafter 

referred to as participants) to 

determine if the participants understand the intent of the guidance and 

correctly implement that guidance 

consistent with the intent of the 

rule, and to assess the need for any 

changes to the guideline. 

The purpose of the 

During preparation of NE1 95-10, 

Revision 0, the staff and industry 

real i zed that development of final 

guidance for certain topics was best 

deferred until additional implementation experience was gained in the 

LRDP. These topics included guidance for level of detail of the 

information needed for a license 

renewal (LR) appl ication and FSAR 

supplement, application of topical 

reports, and overall level of detail 

of the guidance to develop an LR 

program consistent with the intent 

of the rule. These concerns were 

addressed by the LRDP and potential 

areas for improvement identified. 

The odservati ons ani 1 essons 1 earnel 

discussed in this report will be 

used to identify additional guidance 

and/or clarifications that need to 

be added to NE1 95-10, Revision 0, 

for an acceptible implementation of 

the LR requirements under 

10 CFR Part 54. The resulting guidance from these observations and 

1 essons 1 earned wi 11 be incorporated 

in NE1 95-10 or in the staff’s final 

version of the draft Regulatory 

Guide (RG) DG-1047, “Standard Format 

and Content for Applications to 

Renew Nucl ear Power P1 ant Operat i ng 

Licenses.” 

1.2 Description of the LRDP 

The LRDP consisted of staff reviews 

of five LR programs developed by the 

LRDP participants from the guidance 

provided in NE1 95-10, Revision 0. 

In general, the LRDP participants 

had not made a final decision to 

pursue a renewed license but participated in the LRDP to gain a better 

understanding of the LR process to 

help them in their decision. Each 

review i nvol ved a week-1 ong site 

visit, by five to six NRC staff members, to assess a participant’s 

implementation of the guidance provided by NE1 95-10 in a demonstration LR program. 

objectives for the LRDP site visits 

were as follows: (1) assess the 

extent to which the participants 

understand and correctly implement 

the guidance consistent with the 

intent of the rule; (2) assess the 

scoping, aging management review 

(AMR), and time-1 imited aging analysis (TLAA) evaluation processes and 

supporting information developed by 

the participants (based on the guidance contained in NE1 95-10) for 

documentation, control, consistency, 

and completeness with respect to the 

type of information required by the 

The NRC staff’s 

1 NUREG- 15 68 
rule; (3) assess that the LR applications, TLAA evaluations and Final 

Saflety Analysis Report (FSAR) suppleiments are of sufficient detail 

for the staff to make findings as 

required under 10 CFR 54.29; 

(4) assess the use and integration of topical reports; and (5) assess 

the material provided by the participants to identify any potential 

need for modifications to NE1 95-10. 

The scope of each participant’s 

demonstration program i ncl uded a 

sample LR methodology, an LR application and supporting information for 

approximately eight systems, two 

components per system, a minimum of 

two TLAA evaluations, and a sample 

LR FSAR supplement. 

systems, structures, components, and 

TLAAs for the LRDP was designed to 

provide a cross-section of the types 

of information expected to be seen 

in a LR application. 

The scope of 

The LRDP site visit teams reviewed 

the processes and sample materials 

developed from the guidance provided 

by NE1 95-10 to ensure that adequate 

guildance existed to develop an 

application and supporting information in sufficient detail. The site 

visit teams did not review plantspecific programs for the purpose of 

determining their adequacy or 

acceptability in fulfilling the 

requirements of the rule. 

The results of the site visits were 

documented in site-visit trip 

reports (References 1-5). The trip 

reports have been placed in the NRC 

Public Document Room. 

1.3 Description of the Rule for 

the Renewal of Operating 

Licenses 

Nucl ear power pl ant 1 i censees that 

choose to extend the operation of 

their plants beyond the initial 

licensing period of 40 years are 

required to satisfy the requirements 

delineated under 10 CFR Part 54, the 

LR rule. This rule establishes the 

criteria for the systems, structures, and components within the 

scope of LR that include: (1) safety 

related systems, structures, and 

components , (2) non-safety re1 ated 

systems, structures, and components 

whose failure could affect safetyrelated systems, structures, and 

components , and (3) those systems , structures and components that are 

relied upon to perform a function 

that satisfies the Commission regulations for fire protection 

(10 CFR 50.48), environmental qualification (10 CFR 50.49), pressurized thermal shock (10 CFR 50.61), 

anticipated transients without scram 

(10 CFR 50.62), and station blackout 

(10 CFR 50.63). 

The LR rule requires applicants to 

perform a structured AMR of structures and components that perform an 

intended function without moving 

parts or change in configuration or 

property (passive) and are not subject to replacement based on a qualified life or specified time period 

(long 1 ived) . The AMR may result in 

the development of new aging management programs for passive/long-lived 

structures and components to ensure 

their functionality during the 

period of extended operation. 

The rule also requires an applicant 

to evaluate TLAAs for systems, 

structures and components within the 

scope of the rule that involve timelimiting assumptions defined by the 

current operating term. The applicant must demonstrate that (1) the 

analyses remain valid for the period 

of extended operation, (2) the analyses have been projected to the end 

of the period of extended operation, 

or (3) the effects of aging on the 

intended functions will be 

NUREG- 15 6 8 2 
adequately managed for the period of 

extended operation. The aging management programs and 1 icensee evaluations of TLAAs will become part of 

the plant’s licensing basis, and 

will be subject to the NRC’s ongoing 

regulatory requirements. 

1.4 Imp1 ement at i on 

After publication of the amended LR 

rule in May 1995, the NRC staff and 

industry began preparing implementation guidance. In March 1996, 

NE1 95-10, Revision 0, was published. From March through August 

of 1996, the staff performed the 

five site-visit reviews for the 

LRDP. In August 1996, NRC published 

DG-1047. This draft guide proposes 

to endorse the guidance contained in 

NE1 95-10. The staff will use the 

experience gained through its observation of the plant-specific demonstrations and any information or 

comments received from members of 

the public to determine whether 

changes might be needed in NE1 95-10 

or DG-1047. 

2. LESSONS LEARNED FROM THE LRDP 

SITE VISITS 

2.1 General Issues 

2.1.1 Topical Reports 

The use of topical reports, that 

have been approved by NRC, is an 

acceptable practice for addressing 

process and technical matters consistent with 10 CFR 54.17(e). The 

use of approved topical reports is 

addressed in NE1 95-10, § 4.2.2. 

2.1.1.1 Observations 

The staff observed that some of the 

participants did not adequately 

demonstrate the site-specific 

applicability of topical reports 

used during the LRDP. 

2.1.1.2 

NE1 95- 

Lessons Learned 

0, § 4.2.2, staves tha if 

an applicant chooses to rely “on 

referenceable results of a previous 

aging management review.. .the elements of the AMR should include 

identifying and demonstrating the 

appl i cabi 1 i ty of a previous revi ew 

and then demonstrating that the 

results and conclusions are in 

effect at the plant.” In referencing a generic topical report, an 

applicant should verify the appl icability of the information within 

the report to the specific site 

being considered for a renewed license at the time of application, 

considering appropriate applicability statements made within the 

report and the staff safety evaluation report. Information comparing 

the topical report and site-specific 

characteristics such as design, materials of construction, configuration, and environment stressors, 

consistent with NE1 95-10, 5 4.2.2, 

should be discussed in the LR application. In addition, due to the 

potential for an extended period of 

time between the development of a 

topical report and the submittal of 

an LR application, the site-visit 

team concluded that the appl icants 

should have made a statement about 

any changes, or the absence of any 

changes, in plant conditions as they 

relate to the information presented 

in the report. Any “outlying” 

conditions must be evaluated on a 

plant-specific basis. The staff 

will make recommendations to add 

additional description and/or 

clarification to address the applicability of topical reports. 

2.1.2 GSIs and USIs 

Generic safety issues (GSIs) and 

unresolved safety issues (USIs) are 

to be considered for determining the 

scope of the AMR and TLAAs as dis3 NUREG- 15 6 8 
cussed in the background information 

(60 FR 22484) issued with the rule. 

NE1 95-10, 5 1.5, provides general 

guidance for considering these 

issues, without regard for the 

priority assigned to the issues 

under the NRC GSI program (Ref. 6). 

2.1<,2.1 Observations 

During a review of a participant’s 

handling of GSIs/USIs, the sitevisit team noted that those GSIs 

designated as “low priority” in the 

NRC GSI program (Ref. 6) were not 

being considered in identifying 

potential aging effects relating to 

LR. 

initiated actions to address this 

concern. 

The participants along with NE1 

In addition, the staff observed that 

participants were not discussing 

appl i cab1 e generic safety i ssues in 

their AMR and TLAA documentation. 

For example, GSI 168, “Environmental 

Qual if i cati on of El ectri cal Equipment,” was not discussed by four 

participants in TLAAs relating to 

equi pment qual i f i cation. 

2.1 I. 2.2 Lessons Learned 

NE1 95-10, 9 1.5, provides guidance 

for assessing GSIs/USIs. However, 

additional guidance appears to be 

necessary regarding the consideration of age-related GSIs. 

2.2 Scoping Process 

The scoping process for LR includes 

the identification of the system, 

structures, and components within 

the scope of LR and identifying 

their intended functions. The scoping process performed by the five 

participants typical ly i nvol ved a 

two-step process. Each participant 

first identified the scope of 

systems and structures within the 

scope of LR and their system-/struttural-level intended functions. The 

participants then identified (refer 

to ?j 2.3 of this report) the structures and components requiring AMRs 

and/or evaluation of TLAAs, and 

their structural -/component-1 eve1 

intended functions. Thi s approach 

is consistent with NE1 95-10 and the 

intent of the rule. 

2.2.1 Identifying Systems, 

Structures, and Components 

The LR scoping process presented 

during the LRDP includes the identification of the systems and structures that meet the criteria under 

10 CFR 54.4(a). 

identifying the systems and structures within the scope of LR is 

provided under NE1 95-10, § 3.1. 

The guidance for 

2.2.1.1 Observations 

The site-visit teams observed that 

the participants typically provided 

a proceduralized approach for scoping. The approaches presented by 

the participants appeared to follow 

the basic guidance under NE1 95-10, 

4 3.1 and appeared to be consistent 

with the criteria under 10 CFR 54.4. 

For those participants that implemented NE1 95-10, 4 3.1, with the 

intent to identify all plant systems 

and structures within the scope of 

LR, the site-visit teams performed a 

cursory review of their LR scoping 

efforts, and did not identify any 

obvious omissions. The site-visit 

teams also observed that the participants’ scoping processes included 

steps to evaluate safety-related 

systems, that did not meet the 10 

CFR 54.4(a)(l) criteria, under 10 

CFR 54.4(a)(2) and 54.4(a)(3) as 

described under NE1 95-10, 4 3.1.1. 

In addition, the site-visit teams 

observed that two participants 

assessed systems and structures that 

had been determined to be within the 

NUREG-1568 4 
scope of LR under 10 CFR 54.4(a)(l) 

(safety-related criteria) for 

inclusion in the scope of LR under 

10 CFR 54.4(a)(2) and 54.(a)(3) 

(nonsafety-re1 ated and specified 

Commission regulation criteria) as 

well. Because this additional 

review of safety-related systems 

under 10 CFR 54.(a)(2) and 54.(a)(3) 

was observed only during two site 

visits, some additional description 

and/or cl ari f i cat i on under 

NE1 95-10, 3 3.1, may be needed to 

meet the intent of 10 CFR 54.4. 

2.2.1.2 Lessons Learned 

Two participants included steps in 

their scoping process to evaluate 

those systems and structures, that 

met the safety-re1 ated criteria 

(10 CFR 54.4[a][l]), for inclusion 

within the scope of LR under scoping 

criteria 10 CFR 54.4(a)(2) and 

54.4(a)(3) to ensure all system-/ 

structural -1 evel intended functions 

and appropriate evaluation boundaries were identified. 

A review of the guidance under NE1 

95-10, 9 3.1, identified the guidance for assessing each system under 

each of the three scoping criteria 

in the flow-diagram, Figure 3-1. 

However, the text under NE1 95-10, 

3 3.1, does not contain a description of the review performed by the 

last two participants. The staff 

will recommend that additional 

description and/or clarification be 

added to NE1 95-10 to ensure all 

system-/structural -1 evel intended 

functions and appropriate evaluation 

boundaries are identified. 

2.2.2 Identifying System-/ 

Structural -Level Intended 

Funct i on 

The need to identify system-/struttural-level intended functions is 

delineated under 10 CFR 54.4(b). 

The guidance for identifying these 

intended functions is provided under 

NE1 95-10, 3 3.2. 

2.2.2.1 Observations 

In general, the site-visit teams 

observed that the participants appeared to have implemented the guidance for identifying system-level 

intended function that appeared to 

be consistent with NE1 95-10, 5 3.2. 

Although the site-visit reviews did 

not assess the completeness of the 

results presented, no specific concerns were noted with the intended 

functions identified by the participants, and they appeared to meet 

the intent of the rule. However, a 

site-visit team observed that one 

part i ci pant i dent i f i ed the systemlevel intended functions from multiple plant documents such as designbasis documents, training handbooks, 

scoping determination handbooks, 

etc. This approach resulted in a 

more detailed, descriptive list of 

system-/structural -1 evel intended 

functions that appeared to better 

meet the intent of the guideline. 

Some additional description and/or 

clarification may be needed to meet 

the intent of 10 CFR 54.4(b). 

2.2.2.2 Lessons Learned 

One participant used more descriptive onsite documentation to develop 

a more detailed, descriptive list of 

system-/structural -1 evel intended 

functions. From this improved list, 

the participant appeared to develop 

a more complete and descriptive list 

of the structure-/component-level 

intended functions. The staff may 

recommend that additional description and/or clarification be added 

to the existing guidance to include 

the development of a more detailed, 

descriptive list of system-/component-level intended functions. 

5 NUREG-15 68 
2.3 Screening Process 

The LR screening process described 

in NE1 95-10 includes establishing 

evaluation boundaries, determining 

the intended functions of the structures and components within the 

evaluation boundary, and identifying 

which of those structures and components need to be included in the 

AMR. In general, the screening 

methodologies presented during the 

LRDP were consistent with NE1 95-10 

and the intent of the rule with few 

exceptions as described below. 

2.3.1 Evaluation Boundaries 

NE1 95-10 describes evaluation boundaries as “those portions of the 

systems and structures that are necessary for ensuring the intended 

func:tions of the system or structure 

will be performed.” Identifying 

eval uat i on boundaries has been recognized as a basic step of the 

screening process presented under 

NE1 95-10, 5 4.1.1, for determining 

the structures and components within 

the scope of LR as intended by the 

rul e. 

2.3.1.1 Observations 

The site-visit team observed that 

all but one participant identified 

evaluation boundaries using markedup, site-approved drawings consistent with the guidance under 

NE1 95-10, 9 4.1.1. One participant 

used an alternate approach to identify the structures and components 

within the scope of LR that appeared 

to be consistent with NE1 95-10, 

§ 4.1, and the intent of the rule. 

NE1 95-10, 5 4.1.1, appeared to contain sufficient guidance for determining evaluation boundaries that 

supports the screening process 

consistent with the intent of the 

rule 

2.3.1.2 Lessons Learned 

The industry guideline allows applicants to use different approaches to 

identify the structures and components within the scope of LR and to 

meet the intent of the rule. The 

site-visit team reviewed the process 

and the structures and components 

selected by the one participant who 

did not use evaluation boundaries. 

The site-visit team verified that 

this participant’s approach and list 

of selected structures and components appeared to be consistent with 

the intended results from implementing the guidance under NE1 95-10, 

5 4.1, and the intent of the rule. 

No additional guidance appeared 

necessary for identifying evaluation 

boundaries. 

2.3.2 Identifying Structural-/ 

Component-Level Intended 

Functions 

Structural -/component-1 eve1 intended 

functions are defined under 

10 CFR 54.4(b). 

identi fyi ng these intended functions 

is provided under NE1 95-10, 

§ 4.1.2. 

The guidance for 

2.3.2.1 Observations 

The si te-vi si t teams observed that 

the structural-/component-level 

intended functions identified by the 

participants appeared to be consistent with NE1 95-10, 5 4.1.2 and the 

intent of the rule. Although the 

site-visit reviews did not assess 

the completeness of the results 

developed for the LRDP, no specific 

concerns were identified with the 

intended functions presented by the 

participants. However, as discussed 

previously, the site-visit team also 

observed that the participant that 

developed a more detailed, descriptive list of system-/structurallevel intended functions also 

NUREG-15 68 6 
devel oped a more detai 1 ed, descri ptive list of structural-/componentlevel intended functions than was 

observed during other site visits. 

This more descriptive list of structural -/component-1 evel intended functions appeared to better meet the 

intent of 10 CFR 54.4(b). Some addi ti onal description and/or cl ari f ication may be needed to meet the 

intent of 10 CFR 54.4(b). 

2.3.2.2 Lessons Learned 

The participant that developed the 

more detailed, descriptive list of 

system-/structural -1 evel intended 

functions appeared to develop a more 

complete and descriptive list of the 

structure-/component-level intended 

functions that appeared to better 

meet the intent of the rule. The 

staff may recommend that additional 

descri pt i on and/or cl ari f i cation be 

added to the existing guidance to 

include the development of a more 

complete and descriptive list of 

structural-/component-level intended 

functions. 

2.3.3 Identifying Component Passive 

Functions 

To identify a component passive function, an applicant has to determine 

if the component performs its intended function without moving parts or 

change in configuration or property 

as required under 10 CFR 54.21(a). 

The guidance for determining which 

components are passive is provided 

under NE1 95-10, 9 4.1.2. 

2.3.3.1 Observations 

The site-visit team observed that 

some component passive functions 

were not determined based on its use 

of moving parts or change in configuration or properties of the structures and components in performing 

the intended functions. Some 

additional description and/or 

clarification may be needed. 

2.3.3.2 Lessons Learned 

Although NE1 95-10 appears to contain the necessary guidance and has 

a list of active/passive structures, 

components and commodity groups in 

Appendix B, concerns with the implementation of NE1 95-10, 9 4.1.2, 

were noted during the site visits. 

The incorrect determination of component passive functions can result 

in an incorrect list of structures 

and components requiring an AMR and 

the subsequent fai 1 ure to identify 

applicable aging affects. For example, the participants considered the 

heat transfer function of a heat 

exchanger to be active. 

fer of heat is performed by heat 

exchangers without moving parts or a 

change in configuration or properties making the component passive. 

The transThe failure to recognize that a heat 

exchanger is a passive component 

with respect to the heat transfer 

function, will eliminate the need to 

consider scaling, obstructions and 

other aging effects that can effect 

the transfer of heat. The staff 

will consider recommendations to 

provide additional description and/or clarification to NE1 95-10, 

3 4.1.2, to address this concern. 

2.3.4 Identifying Long-Lived 

Characteristics 

To determine the long-lived characteristics of a component, an applicant has to determine if the component is subject to replacement based 

on a qualified life or specified 

time period as required under 10 CFR 

54.2l(a)(l)(ii). The guidance for 

determining the long-1 ived characteristics of a component is provided 

under NE1 95-10, 9 4.1.2. 

7 NUREG-15 6 8 
2.3.4.1 Observations 

The site-vi sit teams observed that 

the participants identified the 

long-1 ived characteristics of structures and components consistent with 

NE1 95-10, 5 4.1.2, without any 

noted concerns for those structures 

and components within the scope of 

the LRDP. However, the site-visit 

team did observe some inconsistenc:ies between the intent of the 

guidance under NE1 95-10, 5 4.1.2, 

and the assessment of the long-lived 

characteristics for components sometimes referred to as consumables; 

e.g., seals gaskets, and packing. 

Additional description and/or clarific:ation of NE1 95-10, !j 4.1.2, may 

be needed for these items. 

2.3.4.2 Lessons Learned 

Gask.ets, packing, and seals are 

replaced relatively frequently but 

are not replaced on the basis of 

qualified life or a specified time 

period. However, some remain in use 

for many years and others are replaced on a periodic basis or singleuse application (e.g., single crush 

of a gasket). These diverse applications make it difficult to implement the guidance under NE1 95-10, 

!j 4.1.2, that appears to work well 

in o,ther applications presented 

during the LRDP. 

sidering a recommendation that guidance be added to NE1 95-10, 9 4.1.2, 

to address such items. 

The staff is con2.3.5 Identifying and Listing of 

Structures and Components 

Upon determining the structures and 

components requiring an AMR, an 

applicant is required to identify 

and list those structures and 

components consistent with 

10 CFR 54.21(a)(l). The guidance 

for identifying and listing of 

structures and components is provided in NE1 95-10, § 4.1.2. 

2.3.5.1 Observations 

In general, the site-visit team 

observed that the participants 

interpreted 10 CFR 54.21(a)(l) to 

mean that they only needed to provide a listing of commodity groups 

to fulfill the requirement to identify and list the structures and 

components requiring an AMR. Some 

addi t i onal descri pt i on and/or cl arification may be needed under 

NE1 95-10, 5 4.2.1, to meet the 

intent of 10 CFR 54,21(a)(l). 

2.3.5.2 Lessons Learned 

The rule, 10 CFR 54.21(a)(l), states 

that an applicant is to “identify 

and list the structures and components requiring an aging management 

review. A1 though not adequately 

described under NE1 95-10, 9 4.2.1, 

the participants only provided a 

list of individual components (not 

included in any commodity groups) and/or commodity groups. 

The site-visit teams concluded that 

the participants should have provided a description of each commodity group that bounded and identified the structures and components 

intended to be included in that commodity group to fulfill the requirement for “identifying” the structuresjcomponents requiring an AMR. 

The staff may make recommendations 

to add additional description and/or 

clarification for “identifying” the 

structures and components within a 

commodity group to meet the intent 

of 10 CFR 54.21(a)(l). 

2.4 Aging Management Review 

The AMR process for LR includes 

identifying aging effects, and 

developing and/or maintaining 

NUREG-15 68 8 
programs that manage these effects 

of aging so that the structures and 

components will perform their 

intended functions under current 

licensing-basis (CLB) design conditions during the period of extended 

operation. In general, NE1 95-10, 

5 4.2.1.1 and 5 4.2.1.2 appear to 

provide the necessary guidance to 

perform an AMR consistent with 

10 CFR 54.21(a), but inconsistent 

implementation of this guidance 

indicated that additional guidance 

may be needed. 

2.4.1 Identifying Aging Effects 

The identification of aging effects 

for the structures and components 

within the scope of LR is required 

under 10 CFR 54.21(a). 

for identifying aging effects is 

described under NE1 95-10, 9 4.2.1. 

The guidance 

2.4.1.1 Observations 

In general, the site-visit teams 

observed that the aging effects 

identified by the participants to be 

“plausible” appeared to be consi stent with NE1 95-10, 5 4.2.1.1 and 

the intent of the rule. However, 

some of the aging effects that were 

determined to be “not plausible” 

were not consistent with the intent 

of the rule. Some additional guidance may be needed to correctly 

determine the aging effects appl icable to a particular structure or 

component consistent with 

10 CFR 54.21(a). 

2.4.1.2 lessons Learned 

Although the intent of the site 

visits was not to assess the completeness of the aging effects 

presented by the participants, the 

site-visit teams did observe some 

concerns with the determination of 

“not plausible” aging effects. The 

use of existing aging management 

programs (AMPs) as the basis for 

determining an aging effect as being 

“not plausible” was the most common 

concern observed with the identification of aging effects during the 

LRDP. For example, corrosion in a 

closed fluid system containing 

carbon steel pipe was determined to 

be a “not plausible” aging effect. 

This determination was based on the 

fact that corrosion of the carbon 

steel had not occurred over the 

previous 20 years of operation due 

to an existing chemistry control 

program. Using an existing AMP, 

such as chemistry control, to determine an aging effect to be “not 

plausible” is not consi stent with 

the intent of the rule. The staff 

wi 11 recommend additional descri ption and/or clarification to better 

identify aging effects. 

2.4.2 Use of Operating Experience 

The background information 

(60 FR 22467) that accompanied the 

rule discusses the use of operating 

experience appl icabl e to LR as it 

may apply to applicants being considered for a renewed license. 

NE1 95-10, 5 4.2.1.1, provides the 

guidance for considering operating 

experience during the AMR process. 

2.4.2.1 Observations 

In general, the participants used 

operating experience to help identify aging effects consistent with 

NE1 95-10, 5 4.2.1.1, but some concerns with the source documents used 

to perform the operating-experience 

revi ews were i dent i f i ed . 

Each participant reviewed various 

source documents to perform an 

operating experience review, but in 

some cases NRC generic communications were not used. Some additional guidance may be needed to 

ensure a thorough operational review 

9 NUREG-15 68 
is performed as intended by the 

rul e. 

2.41.2.2 Lessons Learned 

Because the LRDP site visits were 

not intended to assess the completeness of the participants’ results, 

the site-visit teams did not assess 

the completeness of the operatingexperience reviews performed by the 

participants. However, because NRC 

generic communications are a good 

source of aging operat i ng-h i story, 

the site-visit teams had expected 

that the participants would review 

these communications and other 

sources of industry experience in 

det,ermining aging effects. A number 

of participants did not use NRC 

generic communications as a source 

for their operating experience 

review. This raised a concern as to 

the completeness of operating-experierice reviews performed by the particnpants and the guidance provided 

under NE1 95-10, 4 4.2.1.1. 

NE][ 95-10, § 4.2.1.1, does not specify the documents or document types 

that need to be reviewed. The staff 

may recommend that additional descriiption and/or clarification be 

added to NE1 95-10, 4 4.2.1.1, to 

ensure a thorough operational review 

is performed. 

2.4.3 Aging Management Programs 

An AMR is required under 

10 CFR 54.21(a) to manage the 

effects of aging for all structures 

and components within scope of LR 

consistent with the CLB during the 

period of extended operation. The 

development of AMPs is described 

under NE1 95-10, 4 4.2.1.2. 

2.4.3.1 Observations 

In general, the participants developed agi ng-management programs 

(AMPs) that contained the basic 

elements of NE1 95-10, 9 4.2.1.2. 

However, the implementation of these 

programs sometimes produced results 

that were not consistent with the 

intent of this guidance or the rule. 

For example, the site-visit teams 

observed that some of the AMPs presented by the participants relied on 

the detection of a component failure 

to manage some aging effects. Other 

AMPs used inspection activities that 

were not documented or controlled by 

the site quality control program or 

site-approved procedures. 

In addition, the guidance for developing the level of detail for AMRs 

provided in an LR application 

appeared to be adequately described 

under NE1 95-10, 3 4.2.1.2, but 

inconsistencies in the level of 

detail observed during the LRDP was 

an indication that additional guidance may be needed. 

2.4.3.2 Lessons Learned 

A number of AMPs relied on the 

detection of a component failure to 

manage some aging effects. For 

example, one participant offered 

existing surveillance and inspection 

programs as AMPs for loss of material associated with radiationmonitoring tubing. The intent was 

to perform periodic pressurization 

of the tubing and subsequent inspection of the exterior of the tubing 

to detect interior wall thinning of 

the tubing. 

This raised the concern that the 

tubing interior wall can degrade to 

the point where it could no longer 

sustain CLB design loads before 

through-wall flaws occur and the 

condition is detected. The use of 

failure detection as a means of 

managing the effects of aging is not 

consistent with NE1 95-10, § 4.2.1. 

NUREG- 15 68 10 
Other participants used inspection 

programs that were not documented or 

controlled by the site quality control program or site-approved procedures, which is not consistent with 

NE1 95-10, 4.4. For the most 

part, this concern was based on the 

preliminary nature of the information prepared for the LRDP, but in 

some cases, credit was taken for 

routine, informal wal kdowns by plant 

personnel. A1 though the staff 

recognizes the importance of plant 

wal kdowns in identifying physical 

damage and other re1 ated probl ems, 

the use of informal walkdowns as an 

AMP was considered insufficient. 

In addition, inconsistencies were 

observed during the LRDP relating to 

i nformat i on i ncl uded i n the sampl e 

applications. Both the site-visit 

teams and the participants believed 

that there was a need for more description in LR applications and 

onsite information for new programs 

(a program not previously reviewed 

by the NRC) as compared to existing 

programs. 

The staff reviewed NE1 95-10, 

§ 4.2.1.2, and determined that 

guidance exists to address these 

concerns but will consider 

recommendations for additional descri pt i on and/or cl ari f i cat i on of 

existing guidance to address the use 

of fai 1 ure detect i on and undocumented AMPs to manage the effects of 

aging. In addition, the staff will 

recommend that additional guidance 

be considered for new and existing 

AMPs, including further guidance on 

the level of detail needed in an LR 

appl i cat i on. 

2.5 Demonstration 

Consistent with 10 CFR 54.21(a)(3), 

applicants are required to provide a 

“demonstration” 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,” for each structure and component subject to an AMR. NE1 95-10, 

§ 4.2.1.3, provides guidance for 

implementing this requirement and 

examples of “demonstrations” are 

provided in Appendix C of NE1 95-10. 

2.5.1 Observations 

Early in the LRDP, the site-visit 

teams observed that the participants 

interpreted the guideline to say 

that scoping, screening, identification of aging effects and implementing an AMP were sufficient to 

“demonstrate” reasonable assurance 

that the effects of aging will be 

managed under CLB design conditions 

during the period of extended operation. In addition, the “demonstrations” presented by the participants 

did not contain the information, in 

sufficient detail, consistent with 

guidance provided by NE1 95-10 or 

the intent of the rule. Some 

additional guidance may be needed 

for developing a “demonstration.” 

2.5.2 Lessons Learned 

Implementing the requirements for 

scopi ng , screening, identi fying 

aging effects and performing AMRs is 

not consistent with NE1 95-10, 

5 4.2.1.3, in “demonstrating” reasonable assurrance that the effects 

of aging will be managed under CLB 

design conditions during the period 

of extended operation. NE1 95-10, 

9 4.2.1.3, states that an applicant 

needs to “collect and establish 

supporting information and objective 

evidence for the aging management 

demonstration.” 

The site-visit teams commented that 

a “demonstration” for an existing 

program should include a summary of 

“objective evidence” observed from 

11 NUREG- 15 6 8 
the implementation of an AMP. The 

sitel-visit teams also commented that 

a “demonstration” for a new program 

should include a schedule, methodol ogy, acceptance criteria and corrective actions. A “demonstration” 

of the effectiveness of some new 

AMPs; may be required prior to 

approval of an application. 

NE1 95-10, 5 4.2.1.3, 4 4.4, 5 6.2 

and Appendix C does not contain 

separate guidance for a “demonstration” of a new AMP. In addition, 

the inconsistent implementation of 

the guidance contained in NE1 95-10, 

observed by the site-visit teams 

throlughout the LRDP, is an indication that additional description 

and/or clarification of the existing 

guidance is needed. The staff will 

make recommendations to address 

these concerns. 

2.6 TLAA 

The TLAA evaluations required to be 

included in an LR appl ication by 

10 CFR 54.21(c) includes all calculations and analyses as defined 

under 10 CFR 54.3. Guidance for 

preparing TLAA evaluations is provided under NE1 95-10, § 5.1. 

needed to ensure the timely submittal of TLAA evaluations. 

2.6.2 Lessons Learned 

The intent of 10 CFR 54.21(c) is for 

applicants to submit TLAA evaluations at the time of application. 

The staff emphasized its expectation 

that TLAA evaluations need to be 

completed and submitted at the time 

of application. NE1 95-10 indicates 

that there may be instances in which 

TLAAs can be deferred; however, no 

criteria are provided. The staff 

will recommend that additional guidance be added to NE1 95-10, 9 5.1.4, 

to clarify and strengthen the guidance for submitting TLAA evaluations 

at the time of application. 

2.7 FSAR Supplement 

The rule, 10 CFR 54.21(d), requires 

that a supplement to the FSAR be 

submitted at the time of application 

which provides a summary description 

of LR program and activities used to 

manage the effects of aging and the 

evaluation of TLAAs. NE1 95-10, 

3 6.2.3 and 5 6.3, contain the guidance for this requirement. 

2.7.1 Observat i ons 

2.6.1 Observations 

The content of TLAA eval uati ons presented during the site visits were 

generally consistent with the guidance under NE1 95-10, § 5.1, and the 

intent of the rule but a concern 

with the timing of TLAA evaluations 

was identified. The site-visit 

teams observed, that for the purpose 

of the LRDP, a number of the participants indicated they intended to 

defer evaluating many of the TLAAs 

until after (in some cases, many 

years) they submit their LR application which is not consistent with 

NE1 95-10 or the intent of the rule. 

Some additional guidance may be 

Although the site-visit teams observed that the sample FSAR supplements 

had improved over the LRDP, the supplements presented did not fully 

meet the requirements of 

10 CFR 54.21(d). The most notable 

deficiency was the lack of detail in 

the description of the LR programs 

and activities. In addition, the 

site-visit team noted that the guidance under NE1 95-10, 3 6.2.3 and 

3 6.3, allows applicants to submit 

descriptions that are consistent 

with the level of detail currently 

provided in some FSARs, which in 

some cases may not be consistent 

with the current NRC position on the 

NUREG-15 68 12 
information required in an FSAR. 

Additional guidance may be needed to 

address these concerns. 

2.7.2 Lessons Learned 

NE1 95-10, 5 6.3, states that “Summary descriptions of the programs 

and activities for managing the effects of aging shall be included in 

the FSAR supplement at the level of 

detail consistent with the current 

FSAR.” This guidance implies that 

the current level of description in 

the applicant’s FSAR, which may not 

include all the information required 

by 10 CFR 54.21(d), is adequate. 

The Commission recently directed 

that this issue, for LR, be coordinated with FSAR concerns observed at 

operating reactors. The staff will 

recommend that the guidance under 

NE1 95-10, 3 6.3, be revised and 

additional guidance be developed to 

provide the guidance necessary to 

develop an FSAR supplement that 

meets the intent of the rule. 

3. CONCLUSIONS 

In general, NE1 95-10, appeared to 

contain most of the guidance needed 

for scoping, screening, identifying 

aging effects, developing AMPs, and 

eval uat i ng TLAAs . However , as 

expected, the LRDP site-visit 

reviews identified the need for some 

improvements to assist applicants in 

developing LR applications and supporting documentation. 

13 

The LRDP identified the need for 

additional description and/or clarification for referencing topical 

reports, identifying intended functions, determining component passive 

functions, identifying commodity 

groups, determining aging effects, 

selecting AMPs, and providing a 

“demonstration” for AMPs. 

The LRDP also identified that additional guidance may be needed for 

assessing GSIs/USIs, determining the 

long-1 ived characteristics for consumables (e.g.; gaskets and seals), 

providing a “demonstration” for 

AMPs, and providing timely submittal 

of TLAA eval uati ons. 

Gaining experience with the level of 

detail for an LR application, onsite 

information, and an FSAR supplement 

was a key objective of the LRDP. 

The LRDP was beneficial in this 

regard and confirmed the need for 

some additional description and/or 

clarification of the guidance in 

these areas. 

The improvements and additions to 

NE1 95-10, that are needed for 

developing an LR program consistent 

with the intent of the rule, will be 

included in NE1 95-10 or the RG. In 

addition, changes as approved by the 

staff from comments provided by the 

public and industry will be added 

prior to final publication of the 

RG . 

NUREG- 15 6 8 
REFERENCES 

1. 

2. 

3. 

4. 

5. 

6. 

U.S. Nuclear Regulatory Commission, “License Renewal Demonstration 

Program Site Visit, Calvert Cliffs Nuclear Power Plant Trip Report,” 

Project No. 690, Washington D.C., April 15, 1996. 

U.S. Nuclear Regulatory Commission, “License Renewal Demonstration 

Program Site Visit, Oconee Nuclear Power Station Trip Report,” Project 

No. 690, Washington D.C., May 21, 1996. 

U.S. Nuclear Regulatory Commission, “License Renewal Demonstration 

Program Site Visit, Hatch Nuclear Power Plant Trip Report,” Project No. 

690, Washington D.C., July 9, 1996. 

U.S. Nuclear Regulatory Commission, “License Renewal Demonstration 

Program Site Visit, Point Beach Nuclear Power Station Trip Report,” 

Project No. 690, Washington D.C., July 30, 1996. 

U.S. Nuclear Regulatory Commission, “License Renewal Demonstration 

Program Site Visit, Peach Bottom Atomic Power Plant Trip Report,” 

Project No. 690, Washington D.C., September 16, 1996. 

U.S. Nuclear Regulatory Commission, “Prioritization of Generic Safety 

Issues,” NUREG-0933, June 30, 1995. 

NUREG- 15 68 14 
NRC FORM 335 US. NUCLEAR REGULATORY COMMISSION 1. REPORT NUMBER 

12-89) 

NRCM 1102, 

(Assigned by NRC. Add VOI., SUPP., Rev., 

and Addendum Numbers, if mY.1 

3201,3202 BIBLIOGRAPHIC DATA SHEET 

(See instructions on the reverse) 

2. TITLE AND SUBTITLE MURES- 1568 

Lf cense Renewal Demonstration Program: 

NRC Observations and lessons Learned 

DATE REPORT PUBLISHED 

MONTH 

December 

4. FIN OR GRANT NUMBER 

i. AUTHOR(S) 6. TYPE OF REPORT 

R.J. Prato, P.T. KUO, S.F. Newberry 7. PERIOD COVERED /Inclusive Oared 

3/% - 8/% 

. PERFoRMl.NG ORGANIZATION - NAME AND ADDRESS (If NRC, provide ~ivision, office or Region, U.S. Nuclear Regulatory Commission. and maiiingaddrerr;if conrracror. provide 

name and mailing address./ 

DRPU, NRR, U.S. Nuclear Regulatory Cotmission, Washington, DC 20555 

. SPONSORING ORGANIZATION - NAME AND ADDRESS (If NRC. type "same as above";;fcont,acror. provide NRC Division, Office or Region, U.S. Nuclear Regulatory CommisJion. 

and mailing address.1 

DRM, WRR, U.S. Nuclear Regulatory Comaission, 

Washington, DC 20555 

1. ABSTRACT /ZOO words or less) 

This repod twnmrriles the Nuclear Regulatwy Commission staff's observations and kssons learned 

from tho fk. Lkonse Renewal Demonstration Program (LRDPI site visits pwformed by the staff from 

March 28,1996. through August 16,1998. The LRDP WII a Nud..r Enefgy Institute (#El) 

program intended to assess the effectiveness of the guidance pro-vided by NE1 95-10, Revision 0, 

"Industry Guideline for Implementing the Requirements of 10 CFR Part 54 - The License Renewal 

Rule," to implement the requirements of Title 10 of the Code of Meral Regulatians. Part 54 

(10 CFR Part 541, "Requirements for Renewal of Operating Licenses for Nuclear Power Plants." 

In general, NE1 95-10, appeared to contain most of the guidance needed for scoping, screening. 

identifying aging effects, developing aging managememt programs, and evaluating time-limited 

aging analysis. However, as expected, the LRDP site-visit reviews identified the need for some 

knprovements to assist applicants in developing license renewal applications and supporting 

documentation. The improvemts and additions to NE1 95-10. that we needed for developing an 

Hcense renewal program consistent with the intent of the rule, ww1 be included in NE1 95-10 or the 

applicable fbgulatory Guide. 

2. KEY WORDS/DESCRIPTORS (List words orphrases that willassisrresearche~in locating 1hereport.J 

NE1 95-10, 1 icense renewal demonstration program, LRDP, 

1 essons 1 earned 

13. AVAILABILITY STATEMENT 

14. SECURITY CLASS1 FlCATlON 

(This Page) 

(This Report) 

15. NUMBER OF PAGES 

16. PRICE