Issue Date: 11/23/11 1 71002

NRC INSPECTION MANUAL DLR

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 planned or 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 applicant has adequate programs planned or in place to implement 

aging management for the systems, structures and components (SSCs) that require an 

aging management review, such that these SSCs will be adequately maintained consistent 

with the rule, the staff=s existing 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). Structures and Components that perform an 

intended function without moving parts or without a change in configuration, change in 

properties, or change of state. These may include SCs that are classified as inherently 

reliable under the maintenance rule, or SCs for which aging degradation is not readily 

monitored.

Long-lived Structures and Components. Structures and components that are not subject to 

replacement based on a qualified life or specified time period.

Current Licensing Basis (CLB). 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

The License Renewal Inspections (LRI) verify, on a sampling basis: 
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a. The applicant=s implementation of the scoping and screening methodology includes 

nonsafety-related structures, and components 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

a. Scoping and Screening Inspection. The scoping portion of this inspection verifies 

on a sampling basis, through onsite review and walkdown of selected areas of the 

plant, that the 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. 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. Conduct 

walkdowns in selected plant areas to assess whether the applicant identified all the 

SSCs required to be in scope. 

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. This portion of the inspection is intended 

to assess the implementation of the AMPs resulting from the applicant=s license 

renewal program, and may be performed in conjunction with the scoping and 

screening inspection. The inspection verifies that there is reasonable assurance 

that the applicant has adequately addressed all the identified passive and 

long-lived SSCs identified during the AMR. The inspection verifies, through review 

of supporting documents and a walkdown of select systems, that the effects of 

aging can be adequately managed in the period of extended operation. For 

selected SSCs within the scope of the rule the following inspection activities should 

be performed.

1. For the selected SSCs, determine from the LRA the AMPs that 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. The applicant should have addressed the 

recommendations in the GALL Report and any applicable interim staff 

guidance. 
Issue Date: 11/23/11 3 71002

2. Review the description of these AMPs from the LRA, updated final safety 

analysis report, 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 walkdowns 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 walkdown to discuss 

observations at the equipment location. The purpose of these walkdowns 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.

5. 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. 

6. It is recommended that a system be selected to perform a vertical slice 

review in order to determine if the applicant properly accounted for all 

possible environmental aging effects on that system in the LRA. The 

purpose of this selection is to assess for a single system whether the 

applicant properly identified operating experience, including historical site 

experience, regarding the effects of aging on the system and placed the 

system, structures and components for the selected system into an 

established aging management program. 

7. For previously existing AMPs, review the results of past tests and 

inspections. Verify the proposed and existing programs adequately 

demonstrate adequate scope and methodology 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. 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 
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commitments to satisfy an issue raised during the NRC review process or raised 

during a license renewal inspection. Additional inspection to review open items will 

be conducted at the option of the Regional Administrator. During this inspection,

the following 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 inspections 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 entered these items into an official plant work tracking system. 

This review is to ensure that committed 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. 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 planned or implemented license renewal programs and activities 

consistent with their LRA and existing safety evaluations developed by the NRC staff. 

Inspections will be performed by NRC regional offices and will include visits to the 

applicant=s site. 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 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 are listed in the 

References.

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.

a. Scoping and Screening Requirements. 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 impaired. Consideration of hypothetical failures that could 
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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@. 

Verify that the licensee established processes and procedures consistent with the 

NRC accepted guidance contained in Nuclear Energy Institute 95-10, "Industry 

Guideline for Implementing the Requirements of 10 CFR Part 54 – The License 

Renewal Rule," Revision 6, Appendix F, Sections 3, 4, and 5. Specifically, the 

applicant assessed: (1) nonsafety-related systems, structures and components 

within the scope of the current licensing basis, (2) nonsafety-related systems, 

structures and components directly connected to safety-related systems, structures 

and components, and (3) nonsafety-related systems, structures and components 

not directly connected to safety-related systems, structures and components, 

respectively. Conduct walkdowns in selected plant areas to assess whether the 

applicant identified all the SSCs required to be in scope. 

b. Aging Management Programs Inspection. 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 for each in-scope SSC, and the AMPs and 

activities that will manage each aging effect.

As part of the inspection process of AMP documentation, the inspector should 

verify that the implementation of the program is producing results consistent with 

the LRA. Each program should clearly state how the AMP will manage the aging 

effect. The supporting documentation, along with the material condition of the 

SSCs, must be consistent with these claims. For any AMP that has little detail or 

no specific implementation guidance (i.e., new AMPs or enhancements not yet 

implemented for existing AMPs), the inspector should discuss the plans with the 

applicant and use their best judgment since the program does not have to be in 

place until the period of extended operation. 

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. 

c. Review of Operating Experience. The problem identification and resolution 

database should have been searched, by the applicant, for a period of not less 

than 5 years prior to the date the license renewal application analysis was 

terminated (Note: many times the applicant's operating experience review is 

1 to 2 years old by the time the review team arrives onsite). This operating 

experience search should be verified by the inspector independently in two ways: 

(a) The results of the applicant’s database search will result in corrective actions 

being flagged because the corrective action used age-related keywords, 

(e.g., corrosion or cracking). Each flagged corrective action then has to be 

evaluated by the applicant for applicability to aging management. The 

inspector should then select and review a sample of flagged corrective 

actions, including both those where the applicant concluded there was an 

aging effect and those where the applicant concluded there was not an aging 

effect. 
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(b) The inspector should independently query the applicant’s problem 

identification and resolution program for selected keywords, for selected 

periods of time, to identify issues that were not included in the applicant’s 

evaluation. The inspector is not required to learn how to independently 

manipulate the applicant’s system but may ask the applicant to perform the 

search using the inspector’s keywords. 

(c) Because NEI 95-10 guidance for operational experience review states that a 

site specific search of 5 to 10 years should be sufficient, the inspector should 

choose the samples above during a period of 10 years to determine if the 

applicant's cut-off date is appropriate. The inspector should also emphasize 

known issues, when possible (e.g., containment corrosion at a BWR Mark I 

unit, buried pipe leaks, small bore piping socket weld issues, submerged 

cables, and Boral/Boraflex issues in spent fuel pool storage racks) for a 

period prior to the applicant's cut-off date. 

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, if needed, 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, Revision 1, "Standard 

Format and Content for Applications to Renew Nuclear Power Plant Operating Licenses," 

September 2005

Nuclear Energy Institute, "Industry Guideline for Implementing the Requirements of 10 CFR

Part 54 - The License Renewal Rule," NEI 95-10, Revision 6, June 2005

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,@ Revision 2, September 2005December 2010

NUREG-1801, AGeneric Aging Lessons Learned (GALL) Report,@ Volumes 1 and 2, 

Revision 2, December 2010

U.S. Nuclear Regulatory Commission, "Nuclear Power Plants License Renewal; 

Revisions," Federal Register, Vol. 60, No. 88, Monday, May 8, 1995, pages 22461 to 

22495
Issue Date: 11/23/11 7 71002

NRC approved Interim Staff Guidance positions relating to license renewal

IMC 2516, “Policy and Guidance for the License Renewal Inspection Program”

END
Issue Date: 11/23/11 Att1-1 71002

Attachment 1

Revision History for IP 71002

Commitment 

Tracking 

Number

Issue Date Description of Change Training 

Needed

Training 

Completion 

Date

Comment Resolution 

Accession Number

71002-1545 11/23/11

CN 11-038

ML11238A010

The regions determined that some 

clarification and updating of 

guidance would improve the 

procedure. Region IV

made initial changes and 

consolidated comments from the 

other regional offices into the 

attached draft.

No n/a 71002-1545 earlier 

version has 

responses.