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Frequently Asked Questions (FAQs) About License Renewal Inspection Procedure (IP) 71003, "Post-Approval Site Inspection for License Renewal"

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General Questions About IP-71003 and Post-Approval Site Inspection for License Renewal
Questions About Inspection Results
Questions About Other Licensing Areas

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1.Questions About IP-71003 and Post-Approval Site Inspection for License Renewal

Why is the NRC conducting the so-called "commitments inspections" under IP-71003?
Are they motivated by a safety issue or other matter?

The post-approval site inspections are part of the license renewal inspection program, which the NRC has implemented to ensure compliance and assess performance, in relation to Title 10, Part 54, of the Code of Federal Regulations (10 CFR Part 54), "Requirements for Renewal of Operating Licenses for Nuclear Power Plants." These requirements specify how power reactor licensees are to demonstrate that they are managing the effects of aging. As such, IP-71003 is primarily a part of the programs conducted under NRC Inspection Manual Chapter (IMC) 2516, "Policy and Guidance for the License Renewal Inspection Programs," and the related inspections are also referenced as an "infrequent activity" in Appendix C to IMC 2515, "Light-Water Reactor Inspection Program — Operations Phase."

There is a clear safety objective related to monitoring passive components and their intended safety-related functions within the scope of the License Renewal Rule [10 CFR 54.4(a)(1)]. In addition, 10 CFR 54.4(a)(2) includes the requirement to monitor nonsafety-related components that have the potential to affect safety-related equipment. Other components within scope of the License Renewal Rule also have a clear regulatory basis related to the intended function, such as station blackout power [10 CFR 54.4(a)(3)]. For example, the failure of passive components could be a common-mode failure for certain safety systems.

Also, public confidence and trust in the license renewal process hinges on the NRC's confirmation that the licensee's commitments have been completed. The fulfillment of these commitments is important because it forms the basis for the agency's determination of reasonable assurance that that the effects of aging will be managed throughout the period of extended operation (PEO), such that the plant's structures, systems, and components (SSCs) will continue to perform their intended functions in accordance with the current licensing basis (CLB). The agency has extensively reviewed the monitoring of passive components, as documented in license renewal applications (LRAs), subsequent application amendments or supplements, and responses to "requests for additional information" from the NRC's Office of Nuclear Reactor Regulation (NRR). That review revealed "open" aspects as reflected in commitments. In addition, the NRC based the license renewal process (to a certain extent) on the premise of demonstrated monitoring of passive components. For example, new aging management programs (AMPs) were described and found to be acceptable, but several implementing procedures remained to be completed. Thus, the essential basis for a renewed license is the staff's determination of reasonable assurance, based on inspections of AMP reviews and time-limited aging analyses (TLAAs).

Is the IP-71003 review an inspection or an audit, as if NRR was conducting an onsite application review?

The IP-71003 review is an inspection, in the sense that the staff compares the licensee's activities against standards (commitments) or requirements (license conditions). Inspection results are processed and documented using processes that are as similar as possible to those established for the Reactor Oversight Process (ROP). The related assessment or effectiveness review depends on the inspection phase during which an issue was identified (i.e., when requirements or commitments are in effect). In the interest of safety and public confidence, obvious technical issues raised in the early phases of the inspection need to be addressed by licensees before the PEO begins. For additional detail, see the Questions About Inspection Results on this page.

Moreover, for the purposes of the NRC inspection program, Section 0030-03 of IMC 0030, "Guidance for NRC Review of Licensee Draft Documents," defines an "audit" as an activity that gathers information for the purpose of making decisions relative to future inspections or regulatory decisions. As such and as described above, the IP-71003 review is not an audit because the NRC has already rendered its decision regarding the license and the inspection merely verifies the implementation of (or readiness to implement) applicable license conditions and commitments.

How much will these inspections cost the industry in terms of hours or dollars?

The staff anticipates that the post-approval inspections will require approximately 2 weeks of onsite inspection time, involving a team of four inspectors and an inspection lead. The staff will allocate an additional week (per task) to inspection preparation, in-office review between the 2 onsite weeks, and documentation of the inspection results. In addition, the team leader will require 1 week of preparation and 2 weeks to finalize the inspection report. On that basis, the staff estimates that its implementation of IP-71003 will require approximately 28 inspector-weeks per reactor unit. For fee billing purposes, this estimate equates to approximately 1,120 hours. Some efficiency might be gained for dual-unit sites or similar units with common commitments; however, it is too soon to tell.

When will the agency publish the schedule for the IP-71003 inspections?

IP-71003 inspections that are to be completed within the first 18 months following the issuance of Revision 1 of the procedure will be scheduled in the NRC's Reactor Programs System (RPS). The NRC issued the procedure on the agency's public Web site on February 22, 2008, and it is expected to be implemented by April 2008 at the R.E. Ginna Nuclear Power Plant. In a limited way, the NRC implemented the previous version of IP-71003 at the Oyster Creek Nuclear Power Plant in the fall of 2006. Other scheduling will occur as a part of the mid-cycle reviews for the ROP during the summer of 2008.

The NRC will use a three-phased approach to scheduling:

The first phase will take place during the outage before the PEO, in order to maximize inspector observations of the actual implementation of license conditions, commitments, and AMPs.
The second phase is the team inspection during operations before the PEO, in order to ensure readiness for the PEO and allow time for the licensee to implement any necessary corrective actions.
The third phase, which may occur during operations or during the outage following the PEO, is a contingency to allow for any necessary followup on issues from the first two phases.

Also, the team inspections may occur during operations prior to the outage before the PEO, provided that the outage is very close to the PEO (in the same quarter, for example).

What ROP changes do you anticipate in terms of requirements or guidance for inspectors?
Does the NRC plan to conduct ongoing IP-71003 inspections after each plant enters its PEO?

Although the NRC has not yet determined the details, the staff does anticipate some guidance changes related to inspector awareness, in order for the ROP to embrace aging management issues. In particular, as inspectors select structures, systems, and components (SSCs) based on risk, inspection procedure guidance should make them aware of aging management issues for passive aspects supporting those SSCs. For example, in one recent instance, an inspector examined a risk-important component and questioned the adequacy of the licensee's monitoring of related passive components. The assessment process (including the documentation requirements for the inspection report) may also need to be revised to better define what is minor, more than minor, and safety-significant. Some applicable ROP topics include plant status, Maintenance Rule, work control, component design-basis inspection (CDBI), modifications, and operability determinations on degraded conditions.

Why is it so important to conduct this review before the period of extended operation?

The concept is to inspect the commitments before the PEO begins, in order to inspire greater public confidence and trust. The schedule is to support completion of the review in sufficient time for licensees to make any necessary corrections before entering the PEO (i.e., about 3 to 6 months before the PEO begins).

This can be accomplished by witnessing the implementation of some commitments during the outage before the PEO begins, with only the number of inspectors (and hours) needed to accomplish the task. For example, the staff will witness the ultrasonic thickness gauging of the drywell containment liner at the Oyster Creek Nuclear Power Plant during the outage before its PEO begins. This will be followed (also before the beginning of the PEO) by a larger team inspection, in order to more thoroughly interrogate commitments.

In the case of one plant, the staff has already been informed that the licensee will be unable to complete a specific commitment because it depends on an "owners group" methodology that has not yet been approved by the NRC. Consequently, the staff reserves the right to return after the PEO begins, in order to inspect the implementation of that commitment.

How will the NRC assess the efficacy (effectiveness) of aging management programs (AMPs)?

In a performance-oriented manner, the inspectors will use performance or implementation results, in addition to probing various aspects of those results. Normally, areas to be pursued based on results would include one or all of the 10 AMP program elements defined in the Generic Aging Lessons Learned (GALL) Report (NUREG-1801), in combination with the historical commitments made, technical adequacy of the implemented programs or procedures (including improper implementation), and review of data and information with respect to meeting the acceptance criteria. In addition, the staff may consider program results from the NRC's operating experience review, in order to assess the overall efficacy of such programs.

What is the NRC's plan regarding the timing of the inspections?

Revision 1 of IP-71003 states that the inspection program will be implemented before the PEO, and the inspection plan will indicate the duration. By contrast, the draft of Revision 1 indicated that the licensee could notify the NRC when it was ready for inspection; however, that wording has since been eliminated.

Do individual licensees still have this flexibility, or will the NRC's regional office determine the timing of the inspection?

The NRC staff has never seen a need to constrain this inspection by requiring a written notification from the licensee. Rather, the staff anticipates that the regional office and the licensee will work together to arrive at a mutually convenient time for the inspection, commensurate with the required resources, as they do for any other inspection. Nonetheless, licensees are free to send a letter (before the scheduled inspection) to declare "completion," "compliance," or "readiness to implement" (with or without exceptions), if they so desire. Such letters are more of a licensing function than an inspection function, although the staff acknowledges that the NRC might have envisioned a connection in the early days of license renewal.

If the licensee can still notify the NRC of its readiness for the inspection, what are the NRC's requirements regarding the timing of this notification? In other words, how far ahead of the PEO would the NRC accept such notification and schedule the various portions of its inspection?

To the contrary, if the licensee does not send a letter of notification, how far ahead of the PEO will the NRC's regional office schedule its inspections (other than the last outage before entry into the PEO for the outage portion of the inspection)?

With the three-phased approach to the IP-71003 inspections, the NRC staff sees no connection between the licensee's letter of readiness and the timing of the inspection. Such letters are more of a licensing function than an inspection function, although the staff acknowledges that the NRC might have envisioned a connection in the early days of license renewal.

What is the NRC's plan regarding the degree of site organization involvement in the inspection?
In other words, will the inspections be conducted in a manner similar to those associated with IP-71002 (with documentation and records reviews, as well as interviews and walkdowns with AMP owners)?

For the team inspection, the involvement of the site organization will be increased slightly over that associated with license renewal inspections conducted under IP-71002. This is because the inspectors will now seek to understand how the licensee is actually implementing the given license condition, AMP, or commitment. (By contrast, when the staff conducts license renewal inspections under IP-71002, no license conditions exist, many AMPs are mere concepts, and some programs are not yet implemented.)

2. Questions About Inspection Results

What types of commitments are enforceable or have regulatory control?

The enforceability and regulatory control of specific commitments depend on where the commitments are stated in the licensing basis for a given license. Only requirements are enforceable, and they are found in statutes and the NRC's orders, rules and regulations, and licenses. By contrast, technical specifications are license conditions, and they are enforceable as such. In addition, licenses may incorporate other documents or standards by reference, and doing so designates those documents or standards as NRC requirements, although they would not constitute requirements on their own (without being incorporated by reference in a license). For that reason, the safety evaluation reports (SERs) prepared by NRR are not enforceable unless they are specifically referenced in a license condition. Nonetheless, for some plants that have renewed their licenses, the staff identified a number of technical issues (including those related to drywell corrosion), and developed specific license conditions beyond the general conditions noted in SERs; these license conditions are enforceable, if not met.

The staff has also used two general conditions in renewed licenses:

The first dealt with the requirement [in accordance with 10 CFR 54.21(d)] to revise the updated safety analysis report (USAR) or final safety analysis report (FSAR) that the licensee submitted in its license renewal application (LRA) [as required by 10 CFR 50.71(e)(4)], after the renewed license was issued. This general condition also included a provision that, until the licensee updated its USAR or FSAR, the facilities could modify license renewal commitments using the process established in 10 CFR 50.59, "Changes, tests and experiments." If not properly completed, however, these requirements would be enforceable.
The second general condition issued with all renewed licenses largely dealt with ensuring that the licensee meets its commitments before the PEO for those issues that the NRR staff raised during its review of the LRA. If a commitment (e.g., in the list of commitments and due dates presented in an appendix to the SER) is specifically listed or referenced in the license condition, it is enforceable, if not met.

In addition, a group of commitments are specifically listed in the USAR supplements that are required by 10 CFR 54.21(d). Since USAR changes are subject to the requirements of 10 CFR 50.59, such commitments may be enforceable, if those rules are not followed in making changes. (Such commitments would be viewed as commitments under additional regulatory control.)

All other commitments (i.e., those that are neither requirements nor specifically stated in the USAR) are subject to the commitment tracking system, as noted in the Nuclear Energy Institute (NEI) guidance document, entitled "Guidelines for Managing NRC Commitment Changes" (NEI 99-04, Rev. 0), and as endorsed in Regulatory Issue Summary 2000-17, "Managing Regulatory Commitments Made by Power Reactor Licensees to the NRC Staff." For additional information, see the Questions About Other Licensing Areas on this page.

Licensees should also note that, if there is a change to a commitment that the licensee has made to the NRC and that commitment is not a requirement or in a codified process such as the UFSAR, the change requires an impacts review of intended SSC functions and/or a significant hazards review. Moreover, if the modified commitment is stated in the staff's SER, the licensee may also need provide the staff with written notification of the change.

In addition, all information presented to the NRC must be accurate in all material aspects, in accordance with 10 CFR 50.9, "Completeness and accuracy of information." If not, there may be an associated finding with a violation.

How does a performance deficiency (as defined in the ROP) relate to license renewal conditions and commitments? Does the ROP minor criterion apply?

In accordance with IMC 0612, "Power Reactor Inspection Reports," a "performance deficiency" is an issue that is the result of a licensee's failure to meet a requirement or standard, where the cause was reasonably within the licensee's ability to foresee and correct, and which should have been prevented. A performance deficiency may exist if a licensee fails to meet a self-imposed standard [such as a licensee commitment] or a standard required by regulation. Accordingly, the failure to meet a license renewal commitment would constitute a performance deficiency. If a requirement is identified, the performance deficiency would be a potential finding involving a violation. If no requirement can be identified, the standard would clearly be the commitment that is written to the agency, and the performance deficiency would be a potential finding without a violation. In all cases, a review would be conducted to classify the deficiency as "minor" or "greater than minor."

All performance deficiencies are subject to review for minor issues using the NRC's Significance Determination Process (SDP) or traditional enforcement process. This is a first-order principle of the agency's assessment process. In addition, all such issues would be subject to intra-agency review by the NRR Division of Operator Reactor Licensing (DORL) and Division of License Renewal (DLR), the Office of Enforcement (OE), the Office of the General Counsel (OGC), and the applicable regional office.

If you conduct the IP-71003 team inspection before the PEO, what kind of findings will you have, given that new programs and many modified AMPs don't go into effect until the PEO?

If some requisite program is not yet in effect, the issue may be held open during the course of the inspection until it is fully addressed by the licensee. As defined in IMC 0612, "Power Reactor Inspection Reports," the issue may eventually be left unresolved in a report pending a review to determine if it is acceptable, or constitutes a violation or deviation, when the PEOO is reached. The NRC could also use other regulatory tools if the staff believes the licensee will miss a safety-significant commitment or a number of commitments. All such matters will be subject to an intra-agency review involving the NRR Division of Operator Reactor Licensing (DORL) and Division of License Renewal (DLR), the Office of Enforcement (OE), the Office of the General Counsel (OGC), and the applicable regional office.

Can the agency give examples of the kinds of escalated issues that might arise, which the industry will need to address?

In light of the past attention to license renewal and the extensive plans for monitoring passive components, the NRC staff anticipates that such issues will be rare and exceptional. For such issues, the agency has the capability, at a moment's notice to bring together an intra-agency review involving the NRR Division of Operator Reactor Licensing (DORL) and Division of License Renewal (DLR), the Office of Enforcement (OE), the Office of the General Counsel (OGC), and the applicable regional office.

For example, if a change to a commitment uses an AMP method of detection or acceptance criteria that the staff has not yet reviewed, and the process is proven to be ineffective in fulfilling the original commitment, the change may well be a potential safety issue subject to escalated enforcement if it constitutes a violation by license condition, or if the licensee failed to follow a change process required by regulation. The change may also be a violation of 10 CFR 54.29(a), a standard for issuance of a renewed license, which includes the following requirement:

Actions have been identified and have been or will be taken with respect to the matters identified [managing the effects of aging or time-limited aging analysis]… such that there is reasonable assurance that the activities authorized by the renewed license will continue to be conducted in accordance with the [current licensing basis (CLB)], and that any changes made to the plant's CLB in order to comply with this paragraph are in accord with the [Atomic Energy Act] and the Commission's regulations.

Can the agency address a USAR commitment that screens in for a safety evaluation, as well as a commitment modification for which the NRC is required to be notified as a result of a safety evaluation or other reason, such as a change in a license condition or the due date for a commitment?

All changes to commitments stated in the USAR would be within the scope of 10 CFR 50.59, "Changes, tests and experiments," subject to further screening and/or a safety evaluation. Any change to a license condition (including those referenced in license conditions) also need to be approved by the NRC, in accordance with the license amendment process established in 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit."

How will the agency assess significance of performance deficiencies for license renewal conditions and commitments not met, given that probabilistic risk assessments (PRAs) don't seem applicable?

The NRC staff plans to adhere, as close as possible, to existing ROP processes. Several first-order ROP principles still apply:

Performance deficiencies will need to meet the definition provided in IMC 0612, "Power Reactor Inspection Reports." For additional information, see the Questions About Inspection Results on this page.
All performance deficiencies will be reviewed to classify the deficiency as "minor" or "greater than minor." For additional information, see the Questions About Inspection Results on this page.
If a performance deficiency cannot be addressed through the NRC's Significance Determination Process and it is not subject to traditional enforcement, the issue is subject to NRC management review. The supplements to the NRC's Enforcement Policy can be used to determine the severity level of any violations and, as such, they may be used for the management review along with any risk-informed insights. In addition, the agency has the capability, at a moment's notice to bring together an intra-agency review involving the NRR Division of Operator Reactor Licensing (DORL) and Division of License Renewal (DLR), the Office of Enforcement (OE), the Office of the General Counsel (OGC), and the applicable regional office.

In the past, failure to meet commitments has invoked a regulatory tool called notices of deviation (NODs); however, since the institution of the ROP, the agency, for the most part, has not been issuing NODs for power reactors, and inspectors view most deviations as minor. Is the agency resurrecting the deviation process?

The NOD is a regulatory tool that is rarely used and subject to careful scrutiny by the NRC's Office of Enforcement (OE) and the Office of the General Counsel (OGC). It has its roots in the construction program of the 1960s and 1970s. Now, most deviations from commitments can be processed as findings (with no violation) or performance deficiencies within the context of significance.

Safety evaluation reports (SERs) document the NRR review of the draft USAR supplements to be issued after the renewed license. Will the inspectors be reviewing those supplements again and questioning the judgment of the NRR reviews?

The inspectors will not question USAR or FSAR updates that are modeled according to to what was deemed acceptable in the SER. Rather, they will verify that the USAR update occurred in substantial agreement with what was accepted in the staff's review of the license renewal application.

Will the inspector be reviewing time-limited aging analyses (TLAAs)?

In general, the inspectors will not review TLAAs, unless a license condition or commitment needs to be verified. Rather, the inspectors will consider inspections that support a TLAA, such as the inspection of the torus at Nine Mile Point Unit 1 (NMP1). In addition, the inspectors may rely on technical advice from NRR.

Are there any documentation requirements that the NRC sees as being unique to these inspections
(compared to the review audits and inspections associated with a license renewal application)?

Among the unique features of the IP-71003 inspections, final approved documentation will be expected for all inspection items; this will include reports indicating the results of fully implemented AMPs, including proof of monitoring and trending. The inspectors should be able to conclude, overall, that the renewed license (including all new provisions) is woven into the fabric of day-to-day plant operations. Although not required, having packages ready on site could promote the efficiency of the inspection; such packages should show the connection between commitments or license conditions and implementation through programs and procedures, along with selected implementation results.

How will the NRC's regional offices conduct the inspection for a dual-unit site?
For example, for a two-unit site where all commitments have been completed
(regardless of whether the two units have different commitments),
could one inspection be conducted for both units for portions other than the outage inspection?

For the most part, each unit will have its own outage inspection. For the non-outage team inspection(s), however, the number of inspections (i.e., 1 or 2), team size, and duration will depend on the commonality of the unit designs and AMPs for the two units, and could also be influenced by the dates when each unit enters its PEO and the time between each unit's pre-PEO outage and the start of its PEO.

For example, for a dual-unit site, where both units are of the same design vintage and similar age, we would expect few (if any) unit-specific AMPs, and most (if not all) AMPs would be implemented for the lead unit. For this example, it might be reasonable to perform a single commitments inspection for both units, but this might also entail a spot check of selected commitment items when the second unit approaches its PEO. The greater the differences in design, plant age, and uniqueness of unit-specific AMPs, the more likely that two separate inspections will need to be performed.

What is the NRC's plan regarding the scope of inspection review for newly identified structures, systems, and components (SSCs), and for SSCs removed from AMPs?

The inspectors will identify several most-risk-significant SSCs based on input from the site's probabilistic risk assessment (PRA), and will inspect those samples for SSCs that have been added or removed. Such SSCs may also be identified using other means, such as the periodic reports required by 10 CFR 50.59, "Changes, tests and experiments."

Can the NRC address the requirements for implementation of a program prior to entry into the PEO:

As an example, a specific commitment may say, "Implement an XYZ Inspection Program, consistent with industry initiatives," for which the committed due date is the date of entry into the PEO. What will the NRC require from the licensee relative to that commitment?
When the NRC staff conducts its inspection before the PEO, what criteria will be used to determine whether an AMP has been adequately implemented, when the AMP has activities that are required to be performed during the PEO?
What about one-time-only inspection program AMPs; does the staff's expectation change?

(a & b) For those AMPs that encompass periodic, recurring, or repetitive activities, the NRC would consider an AMP implemented (i.e., ready, but not completed) before the PEO, when the following conditions are satisfied:

All new program documents, instructions, or procedures necessary to perform the activities have been written, approved, and authorized for site usage.
All existing documents, instructions, or procedures necessary to perform the activities have been revised, and the revisions have been approved and authorized for site usage.
The scheduling database (e.g., for preventive maintenance, surveillance, or recurring tasks) has been updated with the AMP tasks, with an appropriate due date, grace period, and recurring task frequency. Recurring frequencies should be reasonable and not deferred in order to avoid potential problems.
The activities/tasks and documents/instructions are identified as a license renewal commitment, and are controlled by the licensee's regulatory commitment tracking program.
In accordance with 10 CFR 54.37(a), the information and documentation required by, or otherwise necessary to document compliance with, the License Renewal Rule must be maintained in an auditable and retrievable form. Therefore, there should be an auditable link between a commitment and the various activities that implement the commitment.

(c) For those AMPs that encompass one-time-only activities, the NRC would expect the licensee to complete those one-time-only activities before entering the PEO. Any exceptions would apply to commitments that specifically state that the activities will be performed during the PEO. Of course, depending on the timing of the commitments inspections, some one-time-only activities (whether due before or during the PEO), may not have been performed.

An AMP that encompasses one-time-only activities would be considered implemented (i.e., ready, but not completed), when the conditions listed above are satisfied (as described for AMPs that encompass periodic, recurring, or repetitive activities), with the exception that no recurring task frequency would be needed.

(a, b, c) Other exceptions to the conditions listed above will be handled on a case-by-case basis, as necessary. However, the existence of many exceptions, in a large number of AMPs, could raise concerns about a licensee's readiness to enter the PEO.

Overall, the licensing basis for the content of AMPs should conform with Branch Technical Position RLSB-1, "Aging Management Review — Generic," as specified in Section A.1 of Appendix A to Revision 1 of NUREG-1800, "Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants" (SRP-LR), and (more specifically) the 10 elements of an AMP for license renewal, as defined in Table A.1-1 of the SRP-LR. In addition, exceptions should have identified in the licensee's license renewal application, and noted as acceptable in the staff's safety evaluation report (SER). The inspectors will not question the adequacy of such reviews, but still have a responsibility to address obvious technical problems in this area, which should result in interaction between the inspection staff and NRR staff.

Can you provide more detail and examples to clarify the NRC's expectation that lessons learned regarding inspection resources are to be anticipated, identified, and tracked?

This expectation is intended for NRC staff. However, the industry would be expected to address lessons learned as part of AMP corrective action program elements and the problem/condition reporting process established by site-specific programs in this area.

How will the results of the inspection be documented? Will the IP-71003 reports contain more substance than those associated with IP-71002, in order to increase public confidence?^[1]

It is likely that the NRC will revise IMC 0612, "Power Reactor Inspection Reports," to meet the documentation needs of IP-71003. As with current guidance, the report will include a section to describe the scope of the inspection. This will likely include a listing of commitments that the inspectors reviewed. In addition, like the documentation for Problem Identification and Resolution inspections, the report will likely include a section regarding findings and fact-based observations on commitment status. Some timeless principles also apply. Specifically, these include ensuring that the report includes only those issues that are classified as "greater than minor," and that the agency conducts a management review of those issues that can't be addressed through the NRC's Significance Determination Process (SDP). To ensure consistency, the NRC staff will assess the need for guidance changes as issues are identified and resolved. For additional information on the classification of issues and performance deficiencies, in accordance with IMC 0612, see the Questions About Inspection Results on this page.

At a recent conference, a stakeholder commented on the vagueness of inspection reports prepared under IP-71002. In response, the NRC panelists expressed an interest in any specific examples that might be provided at a later date. Upon reviewing a few reports generated by each region, the staff noted that Region III generally provided more detailed information regarding the screening and scoping activities; however, each region was consistent in documenting the AMPs. In addition, for the most part, the regional counterparts agreed that important fact-based observations were documented, when needed, such as for issues requiring a license renewal application amendment or supplement, or when a program/procedure change was needed based on greater-than-minor inspection observations. Nonetheless, the NRC may develop an example report as guidance for the inspectors.

What will the NRC do if results of an IP-71003 inspection show that commitments were largely not fulfilled just before the end of the original license? Will the NRC suspend the renewed license until the discrepancies are resolved?

The action will be commensurate with the number, nature, and safety-significance of the issues. Toward that end, the NRC can use a multitude of regulatory tools, ranging from a management meeting to an order. Without more specific details, it is too soon to provide a more specific response, and such situations will have to be handled on a case-by-case basis.

What is the meaning of "implemented," relative to "one-time inspections" (OTIs) and other AMP activities?^[1]

If a commitment includes a requirement to perform activities before entering the PEO, the NRC expects the licensee to ensure that those activities are, in fact, performed before entering the PEO. For those AMPs that include periodic, recurring, or repetitive activities, the AMP is considered to be "implemented" when all of the following conditions are satisfied:

All new program documents, instructions, or procedures necessary to perform the activity have been written, approved, and authorized for site usage.
All existing documents, instructions, or procedures necessary to perform the activity have been revised, and the revision has been approved and authorized for site usage.
The electronic scheduling database (e.g., PM, surveillance, or recurring task database) has been updated to reflect the AMP task, with an appropriate due date, grace period, and recurring task frequency.
The activities/tasks and documents/instructions are identified as a license renewal commitment, and are controlled by the licensee's regulatory commitment tracking program.
In accordance with 10 CFR 54.37(a), the information and documentation required by, or otherwise necessary to document compliance with, the License Renewal Rule must be maintained in an auditable and retrievable form. Therefore, there should be an auditable link between a commitment and the various activities that implement that commitment.
The resources that are necessary to accomplish the activity are in place and/or available.

For additional information, see the Questions About Other Licensing Areas on this page.

3. Questions About Other Licensing Areas

What types of license renewal commitment changes require notification to the agency?

All commitments are subject to the commitment tracking system, as noted in the Nuclear Energy Institute (NEI) guidance document, entitled "Guidelines for Managing NRC Commitment Changes" (NEI 99-04, Rev. 0), and as endorsed in Regulatory Issue Summary 2000-17, "Managing Regulatory Commitments Made by Power Reactor Licensees to the NRC Staff." Figure A-1 of NEI 99-04 provides an overview of issues leading to NRC notification. Some notification may be preemptive, in terms of exploring ways to proceed, and other notifications may be necessary because the staff relied on the given commitment in the SER. In addition, if a licensee makes a change to a commitment to the NRC and the affected commitment is not a requirement or part of a codified process (such as the UFSAR), the subject guidance requires an impacts review of intended SSC functions and/or a significant hazards review.

What are the substantial aspects of an AMP that the agency is interested in knowing about
if a licensee should change something?

If a change relates to a license condition, the licensee should follow the process described in 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit." Similarly, if the change relates to a statement in the FSAR, the licensee should follow the process described in 10 CFR 50.59, "Changes, tests and experiments." In addition, if the change relates to commitments in the SER or the license renewal application, then licensee should follow the commitment tracking process, as described in the Nuclear Energy Institute (NEI) guidance document, entitled "Guidelines for Managing NRC Commitment Changes" (NEI 99-04, Rev. 0).

Do you anticipate any changes in the process defined by Title 10, Section 50.59, of the Code of Federal Regulations (10 CFR 50.59), "Changes, tests and experiments," as a result of the commitments inspections conducted under IP-71003?

Not at this time.

Does the agency still endorse the industry's commitment tracking process as reflected in NEI 99-04?

Yes, Revision 1 of IP-71003 references the Nuclear Energy Institute (NEI) guidance document, entitled "Guidelines for Managing NRC Commitment Changes" (NEI 99-04, Rev. 0).

How are licensees to notify the NRC (in writing) when activities in the license condition or USAR/UFSAR are complete and ready to be verified by inspection, as stated in the many general license conditions for license renewal?

A letter to the NRC is acceptable, with an appropriate level of detail to address the status of commitments that have been completed or are ready to be implemented with or without exceptions. Note that the IP-71003 inspections are not tied to this letter; rather, this letter is a license condition for the NRR staff to ensure proper completion of commitments and license conditions.

What is a "newly identified" SSC?

One objective of IP-71003 (Section 01.02) is to verify systems, structures, and components (SSCs) that are "newly identified" as part of 10 CFR 54.37(b), and Regulatory Issue Summary (RIS) 2007-16, Revision 1, "Implementation of the Requirements of 10 CFR 54.37(b) for Holders of Renewed Licenses," are implemented in accordance with 10 CFR Part 54. Toward that end, the guidance section of the inspection procedure includes the following note to the lead inspector, regarding the identification of newly identified SSCs:

Licensees may identify new SSCs that should be within the scope of its license renewal program at any time. These SSCs are "newly identified" pursuant to 10 CFR 54.37(b), which has been further clarified in [RIS-2007-16] as part of NRC generic communications. The NRC may also specify additional newly identified SSCs that one or more holders of renewed licenses must evaluate and include as applicable in its next FSAR update in accordance with §54.37(b)….

The intent of §54.37(b) is to capture those SSCs that, if they had been identified at the time of the license renewal application, would have been subject to [an aging management review] or evaluation as a [time-limited aging analysis]. Newly identified SSCs [that should be included in the next FSAR update required by 10 CFR 50.71(e)] are those SSCs that meet one of the two following conditions:

There is a change to the current licensing basis (CLB) that —

Impacts SSCs that were not in scope for license renewal when the license renewal application was approved, and

The SSCs would have been in the scope of license renewal based on the CLB change if §54.4(a) were applied to the SSCs.

SSCs were installed in the plant at the time of the license renewal review that in accordance with its CLB at the time, should have been in the scope of license renewal per §54.4(a) but were not identified as in scope until after the renewed license was issued.

SSCs that are plant additions or modifications installed after the renewed license is issued are not subject to the provision of §54.37(b) as per staff communication with the industry when RIS-2007-16 was issued.

What are the NRC's requirements regarding the level of detail that licensees need to include in the UFSAR Supplement to meet the requirements of 10 CFR 54.37(b) for newly identified SSCs, via the operating cycle submittal under 10 CFR 50.71(e)?^[1]

The level of detail included in the UFSAR for newly identified SSCs should be consistent with what is required by 10 CFR 54.21(a) and 10 CFR 54.21(c) in the license renewal application. For example, the licensee should include an aging management review line item that identifies the:

system, structure, or component
intended function
material
environment
aging effect and mechanism
aging management program or activity

The licensee should also include a technical justification to substantiate the adequacy of the credited aging management program or activity.

NRC Regulatory Issue Summary 2007-16, Revision 1, "Implementation of the Requirements of 10 CFR 54.37(b) for Holders of Renewed Licenses," explains why a level of detail beyond just a summary description is needed for newly identified SSCs.

What are the requirements for the content of the letter notifying the NRC that the licensee is ready for this inspection?

The NRC has no specific content requirements beyond the use of simple language, clarity of intent, and material accuracy in all aspects, in accordance with the agency's rules and regulations. Licensees should follow their plant-specific license conditions and commitments included in their renewed license.

How would the proposed scheduling change if license renewal approval is delayed — past either the original license term or the point of a scheduled outage before the start of the new license term?

The post-approval site inspection procedure (IP-71003) is encompassed within the inspection programs described in both IMC 2516, "License Renewal Inspection Program," and IMC 2515, "Light-Water Reactor Inspection Program — Operations Phase." (The NRC acknowledges that the current version of the procedure restricts the program applicability to IMC 2515, but it should also reference IMC 2516; the agency will implement this minor change in the next revision.) For the situation addressed in the question, the regional staff could invoke the infrequent operations activity of the inspection program (Reactor Oversight Process), as described in Appendix C to IMC 2515. The regional staff will consult with the NRR staff to assess the appropriate time to perform this inspection activity. It should be noted that in some cases under the IMC 2516 program, the outage before the extended period of operation is very close (in the same quarter); so the team effort during normal operations may occur before that outage. Licensees should consult with their local regional coordinator to address scheduling issues.

If a new AMP is required following one-time inspection, how will it be processed and by what group (on the regulator's side)?

The NRR staff has an extensive operating experience review group. On a routine basis (at least weekly, if not daily), they interact with regional and NRR staff related to events and inspection results along with developments within NRR. The regional staff also has an operating experience budget with resources dedicated to the effort and for interactions with the NRR staff. The need for a new AMP will most likely become the topic of a generic communication.

In the interim, the site finding the need for a new AMP should use industry-established processes for sharing operating experience, such as through the Institute of Nuclear Power Operations (INPO), and take corrective action for the site-specific issue. Corrective action is a key element of existing AMP programs, in accordance with the Generic Aging Lessons Learned (GALL) Report (NUREG-1801). Most likely, for the condition noted in this question, an AMP might be expanded, but not necessarily considered new. Reporting requirements should be reviewed to see if a report to the NRC is required, given that the licensing basis might be affected by the need for a new AMP.

Will the NRC reassess the initial consideration for including the IP-71003 inspections under the ROP, given that doing so would require changing the ROP bases to include passive components?^[1]

The NRC does not currently have any plans to consider modifying the ROP to inspect passive components on the basis of inspection activities conducted using IP-71003 to support license renewal efforts. Inspections conducted to support the license renewal effort are independent from ROP. Any changes to the ROP that are recommended on the basis of IP-71003 inspections can be addressed through the ROP feedback process. For additional information, see the General Questions About IP-71003 and Post-Approval Site Inspection for License Renewal on this page.

^[1] The indicated questions were raised during the IP-71003 Workshop, which was conducted as part of the NRC's 2008 Regulatory Information Conference (RIC).

Page Last Reviewed/Updated Wednesday, June 09, 2021