Nuclear Regulatory Commission (NRC) guidance for Subsequent License Renewal (SLR) applicants is provided in the NUREG-2191. Specifically, Section X.M1 of the NUREG-2191 includes guidance for aging management programs (AMP) which has two aspects related to fatigue analyses, one that verifies the continued acceptability of existing analyses through cycle counting and the other that provides periodically updated evaluations of the fatigue analyses to demonstrate that they continue to meet the appropriate limits. In addition, the NUREG-2191 provides requirements to account for reactor water environment by deriving cumulative fatigue usage (CUF) including environmental effects (CUFen) in component fatigue analyses for a set of sample critical components for the plant outlined in NUREG/CR-6260. Furthermore each applicant is required to determine plant-specific component locations in the reactor coolant pressure boundary that may be more limiting than those considered in NUREG/CR–6260. This paper presents a methodology to identify plant-specific primary equipment component locations that are potentially more limiting than the locations identified in NUREG/CR-6260, through a detailed review and ranking of the analyses of record (AORs) for a plant. The ranking approach implemented in this methodology assesses the level of technical rigor required to derive the CUF values and provides a means to appropriately compare CUF values within the same transient section. This paper also illustrates how this methodology was applied for a recent license renewal application.

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