Some of the emerging regulatory issues that need to be addressed for long term operation include:

• Potential increased requirement for safety analysis.

• Incorporating or accounting for all ongoing ageing degradation in the safety analysis.

• Resolution of a number of generic action items requiring possible modifications.

• Possible need to maintain an updated PSA.

• Evolving requirements for human factors engineering analyses.

While the codes, standards and regulations in effect at the time of plant design and construction continue to be the basis for licensing, some changes and upgrades to meet new requirements may be needed to support LTO. As the plants establish the scope for LTO, it is important for the utilities to:

• Maintain accurate records of the design basis including the modifications installed since in service (configuration management).

• Obtain a documented agreement with the regulator for the licensing basis for operation beyond design life (such as 30 years).

• Clearly identify any modification or enhancement to satisfy the licensing basis.