GNRO-2012/00105, Response to Requests for Additional Information (RAI) Set 32 Dated August 15,2012

Response to Requests for Additional Information (RAI) Set 32 Dated August 15,2012

ML12257A353
Person / Time
Site:	Grand Gulf
Issue date:	09/13/2012
From:	Mike Perito Entergy Operations
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
GNRO-2012/00105
Download: ML12257A353 (29)

Text

• Entergy

~~=. Entergy Operations, Inc.

P. O. Box 756 Port Gibson, MS 39150 Michael Perito Vice President, Operations Grand Gulf Nuclear Station Tel. (601) 437-6409 GNRO-2012/00105 September 13,2012 u.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

SUBJECT:

Response to Requests for Additional Information (RAI) Set 32 dated August 15,2012 Grand Gulf Nuclear Station, Unit 1 Docket No. 50-416 License No. NPF-29

REFERENCES:

1 NRC Letter, "Requests for Additional Information for the Review of the Grand Gulf Nuclear Station, License Renewal Application," dated August 15,2012 (GNRI-2012/00183)(ML12220A337) 2 NRC Letter, "Correction to Requests for Additional Information for the Review of the Grand Gulf Nuclear Station, License Renewal Application," dated August 21,2012 (GNRI-2012/00185)(ML12230A310)

Dear Sir or Madam:

Entergy Operations, Inc is providing, in Attachment 1, the response to the referenced Requests for Additional Information (RAI). Attachment 2 includes an updated listing of regulatory commitments for license renewal that includes revised commitment 14 required in response to an RAI in this letter.

This letter contains no new commitments. If you have any questions or require additional information, please contact Christina L. Perino at 601-437-6299.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 13th day of September, 2012.

MP/jas Attachments: (see next page)

GNRO -2012/ 00105 Page 2 of 2 Attachment( s): 1. Response to Requests for Additional Information (RAI)

2. List of Regulatory Commitments cc: with Attachments Mr. John P. Boska, Project Manager Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop 0-8-C 2 Washington, DC 20555 cc: without Attachments Mr. Elmo E. Collins, Jr.

Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 1600 East Lamar Boulevard Arlington, TX 76011-4511 U.S. Nuclear Regulatory Commission ATTN: Mr. A. Wang, NRRlDORL Mail Stop OWFN/8 G14 11555 Rockville Pike Rockville, MD 20852-2378 U.S. Nuclear Regulatory Commission ATTN: Mr. Nathaniel Ferrer NRRlDLR Mail Stop OWFN I 11 F1 11555 Rockville Pike Rockville, MD 20852-2378 NRC Senior Resident Inspector Grand Gulf Nuclear Station Port Gibson, MS 39150

Attachment 1 to GNRO-2012/00105 Response to Requests for Additional Information (RAI) to GNRO-2012/00105 Page 1 of 15 The format for the RAI responses below is as follows. The Request for Additional Information (RAI) is listed in its entirety as received from the Nuclear Regulatory Commission (NRC) with background, issue and request subparts. This is followed by the Grand Gulf Nuclear Station (GGNS) RAI response to the individual question.

RAI3.5.1.12-1 Background. NRC Information Notice (IN) 2011-20 "Concrete Degradation by Alkali-Silica Reaction (ASR)" was issued to inform industry of operating experience related to concrete degradation due to ASR. IN 2011-20 was issued on November 18, 2011, which is after the NRC received the Grand Gulf Nuclear Station (GGNS) license renewal application (LRA) on November 1,2011. IN 2011-20 states that the American Society for Testing and Materials (ASTM) updated standards, ASTM C1260 and ASTM C1293, and guidance provided in the appendices of ASTM C289 and ASTM C1293, cautions that the tests described in ASTM C227 and ASTM C289 may not accurately predict aggregate reactivity when dealing with late- or slow-expanding aggregates containing strained quartz or microcrystalline quartz.

The Generic Aging Lessons Learned (GALL) Report recommends using the XI.S2 "ASME Section XI, Subsection IWL", XI.S6 "Structures Monitoring", and XI.S7, "Regulatory Guide 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants" or the Federal Energy Regulatory Commission (FERC)/US Army Corp of Engineers dam inspections and maintenance aging management programs (AMPs) to manage cracking due to expansion from reaction with aggregates for those accessible areas of concrete structures within the scope of the respective programs. However, for inaccessible areas, further evaluation is required to determine if a plant-specific AMP is needed.

The following discussions for items with same aging-effect/mechanism "cracking due to expansion from reaction with aggregates" were provided in LRA Table 3.5.1:

LRA Table 3.5.1, item 12, states that this item is not applicable and the listed aging effects do not require management at GGNS. Nonetheless, components are included in the Containment Inservice Inspection - IWL program to verify the absence of other aging effects, such as loss of material, for components in this listing.

LRA Table 3.5.1, item 19, states that this item is not applicable and the listed aging effects do not require management at GGNS. Nonetheless, components are included in the Containment Inservice Inspection - IWL program to verify the absence of other aging effects, such as cracking, for components in this listing.

LRA Table 3.5.1, item 43, states that this item is consistent with the GALL Report. The Structures Monitoring program will manage the effects of cracking for the components in this listing.

LRA Table 3.5.1, item 50, states that this item is not applicable. Listed aging effects do not require management at GGNS. Nonetheless, components are included in the RG 1.127 and Structures Monitoring programs to verify the absence of other aging effects, such as cracking, for components in this listing.

LRA Table 3.5.1, item 54, states that cracking due to expansion due to reaction with aggregates does not require aging management for concrete for these groups of structures at GGNS, because concrete is constructed in accordance with the recommendation in ACI 318.

Nonetheless, components are included in the Structures Monitoring program.

to GNRO-2012/00105 Page 2 of 15 Issue. The GALL Report identifies cracking due to expansion from reaction with aggregates as a possible aging effect for concrete structures in any environment; and industry operating experience, communicated through IN 2011-20, has shown that tests described in ASTM C227 and ASTM C289 may not accurately predict aggregate reactivity when dealing with late- or slow-expanding aggregates containing strained quartz or microcrystalline quartz. The staff notes that LRA Section 3.5.2.2.1.8 states potential reactivity of aggregates were tested in accordance with ASTM C 289 and ASTM C 227.

It is also unclear why cracking due to expansion from reaction with late- or slow-expanding aggregates would not be an applicable aging effect at GGNS for LRA Table 3.5.1, items 12, 19, 50, and 54. but is consistent with the GALL Report for item 3.5.1-43 as stated above from the discussion column of Table 3.5-1.

Request.

a. State if operating experience for cracking due to expansion from reaction with aggregates is applicable to GGNS; and, if applicable, provide action(s) and/or program to manage this aging effect during the period of extended operation.

b. Provide the technical justification as to why the aging management review (AMR) items associated with cracking due to expansion from reaction with late- or slow-expanding aggregates are not applicable, and why this aging effect does not require aging management at GGNS.

c. If revisions to LRA Table 3.5.1, items 12, 43, and 50 are needed, ensure LRA Sections 3.5.2.2.1.8, 3.5.2.2.2.1.2, and 3.5.2.2.2.3.2 are consistent, to provide clarification in the evaluation of these sections.

RAI3.5.1.12-1 RESPONSE

a. Grand Gulf Nuclear Station (GGNS) operating experience has not identified cracking due to expansion from reaction with aggregates as an aging effect requiring management for accessible and inaccessible concrete areas of structures. Furthermore, inspections of concrete structures at GGNS which are routinely performed under the Structures Monitoring, RG 1.127 and Containment Inservice Inspection - IWL programs have shown no evidence of alkali-silica reaction (ASR) on concrete. However, as shown in LRA Table 3.5.1, concrete GGNS structures within the scope of license renewal will continue to be inspected during the period of extended operation (PEO) for any evidence of ASR. If concrete inspection results reveal cracking or any evidence of ASR, the site corrective action program requires evaluation of the condition and determination of appropriate corrective action.

b. Consistent with NUREG-1801 (GALL) (e.g., item II.A1.CP-67), an aging management program is not required if (1) as described in NUREG-1557, investigations, tests, and petrographic examinations of aggregates performed in accordance with ASTM C 295 and other ASTM reactivity tests, as required, can demonstrate that those aggregates do not adversely react within concrete, or (2) for potentially reactive aggregates, aggregate concrete reaction is not significant if it is demonstrated that the in-place concrete can perform its intended function. GGNS Class I structures and containment accessible and inaccessible concrete (walls, dome, and basemat ring girder) is designed in accordance with ACI standard AC1318, (Building Code Requirements for reinforced concrete) and GGNS concrete specification requires that the potential reactivity of aggregates be tested in accordance with ASTM C 289 and ASTM C 227. Also ASTM C 295 was used to identify elements in the aggregate, such as aggregates containing strained quartz or to GNRO-2012/001 05 Page 3 of 15 microcrystalline quartz, which may be unfavorably reactive with alkalis in cement.

Furthermore GGNS concrete structures are constructed of a dense, durable mixture of sound coarse aggregate, fine aggregate, cement, water, and admixture resulting in low permeability concrete which reduces the effects of ASR. Cement used in construction of GGNS was Portland Cement Type II, low alkali, conforming to ASTM C 150-72, Standard Specification for Portland Cement. The sum of the tricalcium silicate and tricalcium aluminate did not exceed 55 percent (in accordance with Footnote C, Table 1A on optional Chemical Requirements, ASTM C 150-72). GGNS cement does not contain more than 0.60 percent total alkali equivalent and concrete included pozzolan as an admixture. Furthermore, as discussed in part a. above, inspections of concrete at GGNS have been routinely completed with no evidence of ASR. Therefore cracking, due to expansion from reaction with late- or slow-expanding aggregates, is not an aging effect requiring management for GGNS concrete structures. Nevertheless, ongoing activities of the Structures Monitoring, RG 1.127 and Containment lnservice Inspection -

IWL programs include inspections that are capable of identifying degradation, if any, attributable to ASR.

c. A revision to the LRA is not required.

RAI 3.5.1.94-1 Background. The GALL report (item III.B1.1.TP-10) states that non-metallic vibration isolation elements exposed to air-indoor, uncontrolled or air-outdoor should be managed for reduction or loss of isolation function due to radiation hardening, temperature, humidity, and sustained vibratory loading using the ASME Section XI, Subsection IWF Program. In LRA table 3.5-1, item 94, the applicant states that age management of vibration isolation elements is not applicable because no vibration isolation elements at GGNS are in scope and subject to aging management review. The staff reviewed the applicant's Inservice lnspection-IWF Program in LRA Section B.1.24 and noted that there is an enhancement to the parameters monitored or inspected program element that states, "Elastomeric vibration elements will be monitored for cracking, loss of material, and hardening." Further, the staff reviewed LRA Section A.1.42 and noted that the Structures Monitoring Program is enhanced with inspection requirements for vibration isolators to include augmented inspections by feel or touch to detect hardening if the vibration isolation function is suspect.

Issue. The applicant's statement that there are no vibration isolation elements in scope is not consistent with the applicant's proposed enhancement to the "parameters monitored or inspected" ISI-IWF program element stated in LRA Section B.1.24 or the applicant's proposed enhancement to the Structures Monitoring program in LRA Section A.1.42 for age management of vibration isolation elements.

Request.

a. Clarify if there are vibration isolation elements at GGNS included in scope for license renewal. If not included in scope, provide justification to support that determination.

b. If vibration isolation elements will be managed as stated in the Structures Monitoring and/or Inservice Inspection-IWF Programs, confirm that the statements in the LRA accurately reflect the planned enhancements to those programs.

to GNRO-2012/001 05 Page 4 of 15 RAI 3.5.1.94-1 RESPONSE

a. There are vibration isolation elements within scope of Grand Gulf Nuclear Station (GGNS) license renewal. However, as shown in LRA line item 3.5-1 item 94, there are no non-metallic vibration isolation elements within the scope of license renewal managed by the GGNS ASME Section XI, Inservice Inspection-IWF (ISI-IWF) program.

The vibration isolation elements that are within the scope of license renewal are integral parts of structural support assemblies. Therefore, they are included in the LRA Table 2.4-4 (Bulk Commodities Subject to Aging Management Review) and Table 3.5.2-4 (Bulk Commodities) within line item "Component and piping supports" and "Component and piping supports for ASME Class 1, 2, 3 and MC." As shown in those tables, the effects of aging on structural support assemblies, which includes the vibration isolation elements, are managed by Structures Monitoring Program and ISI-IWF program.

b. As discussed in response to 'a.' above, the Structures Monitoring and ISI-IWF Program will manage the aging effects of vibration isolation elements within the scope of license renewal. Since there are no non-metallic vibration isolation elements managed by the GGNS ASME Section XI, Inservice Inspection-IWF (ISI-IWF) program, the proposed enhancement in LRA Appendix B Section B.1.24, element 3, "parameters monitored or inspected" is not required and is revised as shown below. Deletions are shown with strike-through.

8.1.24 INSERVICE INSPECTION - IWF PROGRAM Enhancements The following enhancements will be implemented prior to the period of extended operation.

to GNRO-2012/00105 Page 5 of 15 Elements Affected Enhancements

3. Parameters Monitored or The ISI-IWF Program will be enhanced to Inspected clarify that parameters monitored or inspected will include corrosion; deformation; misalignment of supports; missing, detached, or loosened support items; improper clearances of guides and stops; and improper hot or cold settings of spring supports and constant load supports. Accessible areas of sliding surfaces will be monitored for debris, dirt, or indications of excessive loss of material due to wear that could prevent or restrict sliding as intended in the design basis of the support. Elastomeric vibration isolation elements will be monitored for cracking, loss of material, and hardening.

Structural bolts will be monitored for corrosion and loss of integrity of bolted connections due to self-loosening and material conditions that can affect structural integrity. High-strength structural bolting (actual measured yield strength greater than or equal to 150 ksi or 1,034 MPa in sizes greater than 1 inch nominal diameter) susceptible to stress corrosion cracking (SCC) will be monitored for SCC.

RAI B1.14-2a 8ackground. In response to RAI 81.14-2 dated July 25,2012, the applicant described the acceptance criteria used for the GGNS containment concrete surface visual examination. The applicant also stated that the GGNS acceptance criteria used for the containment concrete surface visual examination are consistent with the quantitative acceptance criteria recommended in Chapter 5 of ACI 349.3R-02.

Issue. The staff reviewed the applicant's response of RAI 81.14-2, and noted that the detailed acceptance criteria described in RAI 81.14-2 response for the GGNS containment concrete surface is based on the quantitative limits of the second tier acceptance criteria in Subchapter 5.2.1 of ACI 349.3R-02. This does not appear to be consistent with the guidelines recommended in Chapter 5 of ACI 349.3R-02, which require further evaluation if concrete surface conditions did not meet the quantitative limits of first tier acceptance criteria in Subchapter 5.1.1. The applicant did not provide any justification for excluding the first tear evaluation criteria of the ACI 349.3R-02 for the GGNS containment concrete surface examination.

Request. Explain the reason for not using the first tier evaluation criteria as defined in Subchapter 5.1 of the ACI 349.3R-02 for the GGNS containment concrete surface examination.

to GNRO-2012/00105 Page 6 of 15 RAI 81.14-2a RESPONSE Grand Gulf Nuclear Station (GGNS) Containment Inservice Inspection- IWL containment concrete surface examination recording criteria are consistent with first tier criteria as defined in Subchapter 5.1 of ACI 349.3R-02 and include the following.

• Appearance of leaching or chemical attack to include areas of exudation, efflorescence, stalactites or stalagmites

• Abrasion or erosion degradation

• Popouts or voids 20 mm (3/4 inches) or more in diameter (or of equivalent surface area)

• Scaling 5 mm (3/16 inches) or more in depth

• Spalling 10 mm (3/8 inches) or more in depth

• Spalling 100 mm (4 ~ inches) or more in any dimension

• Excessive corrosion of embedded metallic surfaces

• Corrosion staining on the concrete surface

• Cracks 0.4 mm (0.015 inches) in maximum width, measured below any surface enhanced widening

• Excessive deflection, settlement or other physical movement The concrete surfaces that exceed the above criteria are identified for further evaluation under second tier criteria as defined in ACI 349.3R-02, subchapter 5.1, which were provided in response to RAI B.1.14-2.

RAI8.1.15-1 Background. The GGNS Containment Leak Rate Program, states that GGNS has implemented Option B for the 10 CFR Part 50, Appendix J testing and is consistent with GALL Report AMP XI.S4, "10 CFR Part 50, Appendix J." The GALL Report AMP XI.S4 "scope of program" program element states, "[t]he scope of the containment LRT program includes all containment boundary pressure-retaining components."

Issue. The GGNS Technical Specifications state, "10 CFR Part 50, Appendix J program establishes the leakage rate testing program of the containment as required by 10 CFR 50.54(0)

[conditions of licenses] and 10 CFR Part 50, Appendix J Option B as modified by approved exemptions." In addition, Section 6.2.6.3, "Primary Containment Isolation Valve Leakage Rate Tests," of the UFSAR states, "[c]ertain valves are not required to be Type C tested by Appendix J although they meet the GDC definitions of containment isolation valves." It is not clear how the applicant will manage aging effects of exempted/excluded components (valves, penetrations, and other components) from the 10 CFR Part 50, Appendix J testing for the period of extended operation.

Request. For those components (valves, penetrations, and other components) that have been exempted/excluded from the 10 CFR Part 50, Appendix J testing, identify how aging effects will be managed during the period of extended operation. Indicate which AMPs will be used to manage the aging effects for each of the exempted/excluded components, or justify why an AMP is not necessary for the period of extended operation.

to GNRO-2012/00105 Page 7 of 15 RAI 8.1.15-1 RESPONSE The components listed in the table below are exempted from 10 CFR Part 50, Appendix J testing. The components listed in the table do not meet the criteria of 10CFR50, Appendix J, for designation as containment isolation valves that are required to be Type C tested, although they are classified as containment isolation valves per General Design Criterion 55 or 56. During the period of extended operations, the aging effects on those components that have been exempted/excluded from 10 CFR Part 50, Appendix J testing are managed by the aging management program identified in the table below using the following notes.

Notes:

1. External surface of carbon steel components have no aging effects requiring management due to the temperature being greater than 212°F

2. External Surfaces Monitoring [B.1.18] manages the effects of aging on external surfaces

3. Water Chemistry Control - BWR [B.1.43] manages the effects of aging on internal surfaces

4. External surface of stainless steel component exposed to air indoor have no aging effects requiring management

5. Compressed Air Monitoring [B.1.12] manages the effects of aging on internal surfaces exposed to condensation

6. Water Chemistry Control - Closed Treated Water Systems [B.1.44] manages the effects of aging on internal surfaces

7. Internal Surfaces In Miscellaneous Piping and Ducting Components [B.1.26] manages the effects of aging on internal surfaces

8. Internal surfaces of stainless steel component exposed to air indoor have no aging effects requiring management

9. Service Water Integrity [B.1.41] manages the effects of aging on internal surfaces Component Note 821 F025A Main Steam Outboard MSIV 80dy Drain Outboard Globe Manual 2,3 821 F0258 Main Steam Outboard MSIV 80dy Drain Outboard Globe Manual 2,3 821 F025C Main Steam Outboard MSIV 80dy Drain Outboard Globe Manual 2, 3 821 F025D Main Steam Outboard MSIV 80dy Drain Outboard Globe Manual 2,3 821 F01 OA Feed Water "A" Inboard Check Process 1,3 821 F030A Feed Water "A" Outboard Globe Manual 2,3 821 F01 08 Feed Water "8" Inboard Check Process 1,3 821 F0308 Feed Water "8" Outboard Globe Manual 2,3 821 F0638 Feed Water "8" Outboard Globe Manual 2, 3 E12F004A RHR Pump "A" Suction Inboard Gate MOV 2, 3 E12F017A RHR Pump "A" Suction Relief Inboard Relief Process 2,3 E12F0048 RHR Pump "8" Suction Inboard Gate MOV 2, 3 E12F0178 RHR Pump "8" Suction Relief Inboard Relief Process 2, 3 E12F004C RHR Pump "C" Suction Inboard Gate MOV 2,3 E12F017C RHR Pump "C" Suction Relief Inboard Relief Process 2, 3 E12F439C RHR Pump "C" Suction Inboard Gate Manual 2,3 E12F440C RHR Pump "C" Suction Inboard Globe Manual 2, 3 E12F441 C RHR Pump "C" Suction Inboard Gate Manual 2, 3 E12F442C RHR Pump "C" Suction Inboard Globe Manual 2,3 to GNRO-2012/00105 Page 8 of 15 Component Note E12F002 RHR Shutdown Suction Outboard Globe Manual 2, 3 E12F300 RHR Shutdown Suction Inboard Globe Manual 2,3 E12F301 RHR Shutdown Suction Inboard Globe Manual 2,3 E12F445 RHR Shutdown Suction Outboard Globe Manual 2,3 E12F446 RHR Shutdown Suction Outboard Globe Manual 2, 3 E51 FOn Steam Supply to RCIC Turbine Outboard Globe Manual 2, 3 E12F1 07A RHR "A" to LPCI Inboard Globe Manual 2,3 E12F107B RHR "B" to LPCllnboard Globe Manual 2,3 E12F056C RHR "C" to LPCI Outboard Globe Manual 2, 3 E12F234 RHR "C" to LPCI Outboard Globe Manual 2,3 E12D003A RHR "A" Pump Test Return to Supp Pool Inboard 3,4 E12F011A RHR "A" Pump Test Return to Supp Pool Inboard Globe MOV 2,3 E12F024A RHR "A" Pump Test Return to Supp Pool Inboard Gate MOV 2, 3 E12F064A RHR "A" Pump Test Return to Supp Pool Inboard Gate MOV 2, 3 E12F227 RHR "A" Pump Test Line to Supp Pool Outboard Globe Manual 2, 3 E12F228 RHR "A" Pump Test Line to Supp Pool Inboard Globe Manual 2, 3 E12F259 RHR "A" Pump Test Line to Supp Pool Inboard Globe Manual 2,3 E12F260 RHR "A" Pump Test Line to Supp Pool Outboard Globe Manual 2, 3 E12F261 RHR "A" Pump Test Line to Supp Pool Inboard Globe Manual 2, 3 E12F262 RHR "A" Pump Test Line to Supp Pool Outboard Globe Manual 2,3 E12F290A RHR "A" Pump Test Return to Supp Pool Inboard Globe 2,3 E12F303 RHR "A" Pump Test Line to Supp Pool Outboard Globe Manual 2,3 E12F310 RHR "A" Pump Test Line to Supp Pool Outboard Globe Manual 2,3 E12F322 RHR "A" Pump Test Line to Supp Pool Inboard Globe Manual 2,3 E12F336 RHR "A" Pump Test Line to Supp Pool Inboard Globe Manual 2, 3 E12F338 RHR "A" Pump Test Line to Supp Pool Inboard Globe Manual 2,3 E12F339 RHR "A" Pump Test Line to Supp Pool Outboard Globe Manual 2,3 E12F348 RHR "A" Pump Test Line to Supp Pool Outboard Globe Manual 2, 3 E12F349 RHR "A" Pump Test Line to Supp Pool Outboard Globe Manual 2, 3 F12F430A RHR "A" Pump Test Return to Supp Pool Inboard Gate Manual 2,3 E12F431A RHR "A" Pump Test Return to Supp Pool Inboard Globe Manual 2,3 E12F432A RHR "A" Pump Test Return to Supp Pool Inboard Gate Manual 2,3 E12F433A RHR "A" Pump Test Return to Supp Pool Inboard Globe Manual 2,3 E12F434A RHR "A" Pump Test Return to Supp Pool Inboard Gate Manual 2, 3 E12F435A RHR "A" Pump Test Return to Supp Pool Inboard Globe Manual 2,3 E12F436A RHR "A" Pump Test Return to Supp Pool Inboard Gate Manual 2,3 E12F437A RHR "A" Pump Test Return to Supp Pool Inboard Globe Manual 2, 3 E12D003C RHR "C" Pump Test Return to Supp Pool Inboard 3,4 E12F021 RHR "C" Pump Test Return to Supp Pool Inboard Globe MOV 2,3 E12F064C RHR "C" Pump Test Return to Supp Pool Inboard Gate 2, 3 E12F280 RHR "C" Pump Test Line to Supp Pool Inboard Globe Manual 2,3 E12F281 RHR "C" Pump Test Line to Supp Pool Outboard Globe Manual 2,3 E12F304 RHR "C" Pump Test Line to Supp Pool Outboard Globe Manual 2,3 E12F311 RHR "C" Pump Test Line to Supp Pool Outboard Globe Manual 2, 3 E22F014 HPCS Pump Suction Relief Inboard Relief Process 2,3 E22F015 HPCS Pump Suction Inboard Gate MOV 2, 3 E22F800 HPCS Pump Suction Inboard Gate Manual 2,3 E22F801 HPCS Pump Suction Inboard Globe Manual 2,3 E22F021 HPCS Pump DischarQe to RPV Outboard Globe Manual 2, 3 E22F201 HPCS Pump Discharge to RPV Inboard Globe Manual 2,3 E22F218 HPCS Pump Discharge to RPV Inboard Globe Manual 2, 3 E22D005 HPCS Test Return Line to Supp Pool 2, 3 E22F012 HPCS Test Return Line to Supp Pool Inboard Gate 2,3 E22F023 HPCS Test Return Line to Supp Pool Inboard Globe MOV 2,3 to GNRO-2012/00105 Page 9 of 15 Component Note E22F035 HPCS Test Return Line to Supp Pool Inboard Relief Process 2,3 E22F301 HPCS Test Line to Suppression Pool Outboard Globe Manual 2, 3 E22F302 HPCS Test Line to Suppression Pool Inboard Globe Manual 2, 3 E22F303 HPCS Test Line to Suppression Pool Outboard Globe Manual 2,3 E22F304 HPCS Test Line to Suppression Pool Outboard Globe Manual 2, 3 E51 F031 RCIC Pump Suction Inboard Gate MOV 2,3 E51 F269 RCIC Pump Suction Inboard Gate Manual 2,3 E51 F270 RCIC Pump Suction Inboard Globe Manual 2,3 E51 F272 RCIC Pump Suction Inboard Gate Manual 2, 3 E51 F273 RCIC Pump Suction Inboard Globe Manual 2,3 E51 F257 RCIC Turbine Exhaust Outboard Globe Manual 2,3 E51 F258 RCIC Turbine Exhaust Outboard Globe Manual 2,3 E21 F001 LPCS Pump Suction Inboard Gate MOV 2, 3 E21 F031 LPCS Pump Suction Relief Inboard Relief Process 2,3 E21 F013 LPCS Pump Discharge to RPV Outboard Globe Manual 2, 3 E21 F200 LPCS Pump Discharge to RPV Inboard Globe Manual 2,3 E21 F207 LPCS Pump Discharge to RPV Inboard Globe Manual 2, 3 E21 D004 LPCS Test Return Line to Supp 3, 4 E21 F011 LPCS Test Return Line to Supp Pool Inboard 2, 3 E21 F012 LPCS Test Return Line to Supp Pool Inboard Globe MOV 2,3 E21 F217 LPCS Test Line to Supp Pool Inboard Globe 2,3 E21 F218 LPCS Test Line to Supp Pool Outboard Globe Manual 2, 3 E21 F221 LPCS Test Line to Supp Pool Outboard Globe Manual 2, 3 E21 F222 LPCS Test Line to Supp Pool Outboard Globe Manual 2, 3 C11 F128 CRD Pump Discharge Outboard Globe Manual 3,4 M41 F042 Containment Purge Supply Outboard Globe Manual 2, 3 M41 F051 Containment Purge Exhaust Outboard Globe Manual 2, 3 P72F167 Drywell Chill Water Supply Outboard Globe Manual 2,3 P71 F232 Plant Chilled Water Supplv Outboard Globe Manual 2,3 P71 F246 Plant Chilled Water Return Outboard Globe Manual 2, 3 M61 F009 ILRT 040 Containment Pressure Inboard Globe Manual 2, 3 P52F258 Service Air Outboard Globe Manual 4,5 P53F036 Instrument Air Outboard Globe Manual 4, 5 G33F070 RWCU to Main Condenser Outboard Globe Manual 2, 3 P42F161 Component Cooling Water Supply Outboard Globe Manual 2,6 P42F162 Component Cooling Water Return Inboard Globe Manual 2,6 E51 F019 RCIC Pmp Min Flow Line to Supp Pool Inboard Globe MOV 2,3 E51 F251 RCIC Pmp Min Flow Line to Supp Pool Inboard Globe Manual 2, 3 E51 F252 RCIC Pmp Min Flow Line to Supp Pool Outboard Globe Manual 2, 3 E12F055B RHR HX B Relief Discharge to Supp Pool Inboard Relief Process 2,3 E12F073B RHR HX B Relief Discharge to Supp Pool Inboard Globe MOV 2 2, 3 P11 F095 Condensate Make-up to Upper Cont. Pool Outboard Globe Manual 2, 3 G41 F340 FPC&CU Disch. To Upper Cont. Pool Inboard Globe Manual 2, 3 P45F275 Ret from Aux Bldg. Floor/Equip Dr. Tank Inboard Globe Manual 2, 7 P45F290 Ret from Aux Bldg. Floor/Equip Dr. Tank Outboard Globe Manual 2, 7 C41 F152 SBLC Mixing Tank (Future) Outboard Globe Manual 4,8 E61 F017 CTMT Comb Gas Control Purge Supply Outboard Globe Manual 2, 7 M41 F054 CTMT Com b Gas Control Purge Exhaust Outboard Globe Manual 2, 7 E12F011 B RHR Pump B Test Ret. Line to Supp.. Pool Inboard Globe 2,3 E12F024B RHR Pump B Test Ret. Line to Supp.. Pool Inboard Gate MOV 2,3 E12F064B RHR Pump B Test Ret. Line to Supp.. Pool Inboard Gate MOV 2, 3 E12F212 RHR Pump B Test Line to Supp Pool Inboard Globe Manual 2,3 E12F213 RHR Pump B Test Line to Supp Pool Outboard Globe Manual 2, 3 E12F249 RHR Pump B Test Line to Supp Pool Inboard Globe Manual 2,3 to GNRO-2012/00105 Page 10 of 15 Component Note E12F250 RHR Pump B Test Line to Supp Pool Outboard Globe Manual 2, 3 E12F276 RHR Pump B Test Line to Supp Pool Inboard Globe Manual 2,3 E12F277 RHR Pump B Test Line to Supp Pool Inboard Globe Manual 2,3 E12F290B RHR Pump B Test RET. Line to SuPP. Pool Inboard Globe 2,3 E12F305 RHR Pump B Test Line to Supp Pool Outboard Globe Manual 2,3 E12F312 RHR Pump B Test Line to Supp Pool Outboard Globe Manual 2, 3 E12F321 RHR Pump B Test Line to Supp Pool Inboard Globe Manual 2, 3 E12F331 RHR Pump B Test Line to Supp Pool Inboard Globe Manual 2,3 E12F334 RHR Pump B Test Line to Supp Pool Inboard Globe Manual 2, 3 E12F335 RHR Pump B Test Line to Supp Pool Inboard Globe Manual 2, 3 E12F350 RHR Pump B Test Line to Supp Pool Outboard Globe Manual 2,3 E12F351 RHR Pump B Test Line to Supp Pool Outboard Globe Manual 2,3 E12F430B RHR B Pmp Test Return Line to SuPP. Pool Inboard Gate Manual 2, 3 E12F431B RHR B Pmp Test Return Line to Supp. Pool Inboard Globe Manual 2,3 E12F432B RHR B Pmp Test Return Line to SuPP. Pool Inboard Gate Manual 2,3 E12F433B RHR B Pmp Test Return Line to Supp. Pool Inboard Globe Manual 2, 3 E12F434B RHR B Pmp Test Return Line to Supp. Pool Inboard Gate Manual 2,3 E12F435B RHR B Pmp Test Return Line to SuPP. Pool Inboard Globe Manual 2, 3 E12F436B RHR B Pmp Test Return Line to Supp. Pool Inboard Gate Manual 2,3 E12F437B RHR B Pmp Test Return Line to SuPp. Pool Inboard Globe Manual 2, 3 P11 F132 Refueling Wtr. Xfer. Pmp from Supp Pool Inboard Globe Manual 2,3 P11 F425 Refueling Wtr. Xfer. Pmp from Supp Pool Outboard Globe Manual 2,3 P53F043 Instrument Air for ADS Outboard Globe Manual 4,5 E12F018 LPCS Relief Valve Disch to Supp Pool (2") Inboard Relief Process 2, 3 E12F025C RHR C Relief vlv. Disch to Supp Pool (1") Inboard Relief Process 2,3 E12F408 Return to Suppression Pool from PASS Inboard Globe Manual 2,3 E12F409 Return to Suppression Pool from PASS Outboard Globe Manual 2,3 E12F055A RHR HX A Relief Valve Discharge to Suppression Pool Inboard Relief 2,3 Process E12F073A RHR HX A Relief Valve Discharge to Suppression Pool Inboard Globe 2, 3 MOV M61 F01 0 ILRT Drywell Pressurization Inboard Globe Manual 2,3 G33F075 Test Conn. For G33F040 Valve Inboard Globe Manual 2,3 G33F055 RWCU Return to Feed Water Outboard Globe Manual 2, 3 P60F011 Suppression Pool Clean-up Return Outboard Globe Manual 2, 3 P60F034 Suppression Pool Clean-up Return Outboard Globe Manual 2,3 G33F002 RWCU Pump Suction from Recirc Loops Outboard Globe Manual 2,3 G33F077 Test Conn. For G33F053 Valve Inboard Globe Manual 2, 3 G33F061 RWCU Pump Discharge to RWCU Hx. Outboard Globe Manual 2,3 P41 F159A Standby Service Water Supply A Outboard Globe MOV 2,9 P41F163A Standby Service Water Supply A Outboard Globe Manual 2,9 P41 F169A Standby Service Water Supply A Inboard Check Process 2,9 P41 F160A Standby Service 090 Water Return A Outboard Globe 2,9 P41 F168A' Standby Service Water Return A Inboard Globe MOV 2,9 P41 F160B Standby Service Water Return B Outboard Globe MOV 2,9 P41 F168B Standby Service Water Return B Inboard Globe MOV 2,9 P41 F159B Standby Service Water Supply B Outboard Globe MOV 2,9 P41 F163B Standby Service Water Supply B Outboard Globe Manual 2, 9 P41F169B Standby Service Water Supply B Inboard Check Process 2,9 M71 F592A Containment Pressure Inst. (Wide Range) Inboard Globe MOV 2, 7 M71 F592B CTMT Pressure Inst. (Wide RanQe) Inboard Globe MOV 2, 7 E61 F596C CTMT Hydrogen Analyzer Sample Inlet Outboard Globe MOV 2, 7 E61 F596D CTMT Hydrogen Analyzer Sample Inlet Inboard Globe MOV 2, 7 E61 F595C Drywell HydroQen Analyzer Sample Inlet Outboard Globe MOV 2, 7 to GNRO-2012/00105 Page 11 of 15 Component Note E61 F595D Drywell Hydrogen Analyzer Sample Inlet Inboard Globe MOV 2, 7 E61 F597C Drvwell HydroQen Analyzer Sample Return Outboard Globe MOV 2, 7 E61 F597D Drywell Hydrogen Analyzer Sample Return Inboard Globe MOV 2, 7 E61 F598C Containment HydroQen Analyzer Sample Return Outboard Globe MOV 2,7 E61 F598D Containment Hydrogen Analyzer Return Inboard Globe MOV 2, 7 E61 F595A Drywell H2 Analyzer Sample Inlet Outboard Globe MOV 2,7 E61 F595B Drvwell H2 Analyzer Sample Inlet Inboard Globe MOV 2, 7 E61 F597A Drywell H2 Analyzer Sample Return Outboard Globe MOV 2, 7 E61 F597B Drywell H2 Analyzer Sample Return Inboard Globe MOV 2,7 E61 F596A CTMT H2 Analyzer Sample Inlet Outboard Globe MOV 2, 7 E61 F596B CTMT H2 Analyzer Sample Inlet Inboard Globe MOV 2, 7 M61 F014 ILRT Drywell Pressure Instrument 11 OA Outboard Globe Manual 4,8 M61 F015 ILRT Drywell Pressure Instrument Inboard Globe Manual 4,8 M61 F018 ILRT Drywell Flow Instrument Outboard Globe Manual 4,8 M61 F019 ILRT Drywell Flow Instrument Inboard Globe Manual 4,8 M61 F016 ILRT CTMT Pressure Inst. Outboard Globe Manual 4,8 M61 F017 ILRT CTMT Pressure Inst. Inboard Globe Manual 4,8 E30F593A Suppression Pool Level Instrument Inboard Globe MOV 2, 3 E30F592A Suppression Pool Level Instrument Inboard Globe MOV 2,3 E30F594A Suppression Pool Level Instrument Inboard Globe MOV 2, 3 E30F591 A Suppression Pool Level Instrument Inboard Globe MOV 2, 3 E30F593B Suppression Pool Level Instrument Inboard Globe MOV 2,3 E30F592B Suppression Pool Level Instrument Inboard Globe MOV 2,3 E30F594B Suppression Pool Level Instrument Inboard Globe MOV 2, 3 E30F591 B Suppression Pool Level Instrument Inboard Globe MOV 2, 3 RAI8.1.15-2 Background. The GGNS Containment Leak Rate Program, states that GGNS has implemented Option B for the 10 CFR Part 50, Appendix J testing and is consistent with GALL Report AMP XI.S4. The GALL Report AMP XI.S4 "monitoring and trending" program element states:

Because the LRT program is repeated throughout the operating license period, the entire pressure boundary is monitored over time. The frequency of these tests depends on which option (A or B) is selected. With Option A, testing is performed on a regular fixed time interval as defined in 10 CFR Part 50, Appendix J. In the case of Option B, the interval for testing may be adjusted on the basis of acceptable performance in meeting leakage limits in prior tests.

Additional details for implementing Option B are provided in NRC RG 1.163 and NEI94-01.

Issue. The GGNS Technical Specifications, referencing the 10 CFR Part 50, Appendix J Testing Program, state that the performance characteristics of the program are implemented in accordance with Amendment 135 to the Operating License. The NRC's staff safety evaluation report for Amendment 135, dated April 6, 1998, states that the applicant does not use NRC RG 1.163, which establishes the performance criteria per GALL Report XI.S4, for "10 CFR Part 50, Appendix J Program," for implementation of Option B. There appears to be an inconsistency between the proposed AMP and the recommendations in GALL (i.e., use of guidance in NRC RG 1.163 for implementation of Option B for containment leak rate testing).

to GNRO-2012/001 05 Page 12 of 15 Request

a. For the Containment Leak Rate Program, identify the exceptions and/or enhancements needed to make the program consistent with GALL and identify whether the program should be either evaluated as:

1. Consistent with exceptions,

2. Consistent with enhancements, or

3. Consistent with exceptions and enhancements.

b. If the program is not consistent, consistent with exceptions, or consistent with enhancements with GALL, then expand the summary description of the program sufficiently, so it can be reviewed as a plant-specific program.

RAI 8.1.15-2 RESPONSE

a. The Grand Gulf Nuclear Station (GGNS) Containment Leak Rate Program is in accordance with the provisions of 10 CFR Part 50, Appendix J, Option B. GGNS procedures delineate the requirements for Types A, Band C leakage rate testing based upon the criteria in Regulatory Guide 1.163, NEI94-01, and ANSI 56.8-1994. GGNS submitted amendment request (Amendment 135) to revise the GGNS Technical Specifications to permit implementation of the containment leak rate testing provisions of 10 CFR Part 50, Appendix J, Option B. The amendment request proposed to use the guidance described in a Nuclear Regulatory Commission (NRC) Safety Evaluation Report (SER) rather than Regulatory Guide 1.163, as the method of implementing Appendix J, Option B. The NRC SER was for an exemption requested from Appendix J Option A granted to GGNS on April 26, 1995. The approval of Amendment 135 permitted GGNS to implement the containment leak rate testing provisions using Option B in lieu of Option A. The safety evaluation for Amendment 135 concluded that the amendment request was acceptable ["...that the use of the guidance of the April 26, 1995, SER is consistent with the intent of Regulatory Guide 1.163 and is therefore acceptable."] Based upon this consistency with the intent of Regulatory Guide 1.163, the GGNS Containment Leak Rate Program identified in LRA Appendix B Section B.1.15 is considered consistent with NUREG 1801 Program XI.S4 with no exceptions or enhancements.

b. The GGNS Containment Leak Rate Program is consistent as noted in response to a.

above so no additional summary description is required.

RAI8.1.22-7a Background. In addressing an error report associated with the CHECWORKS software, GGNS condition report CR201 0-00823 stated that CHECWORKS is only one of the tools used by the Flow-Accelerated Corrosion Program to determine component wear. In its initial response to the RAI for this issue, the staff requested GGNS to provide a description of other in-place processes or verification methods used by the Flow-Accelerated Corrosion Program to determine component wear that could validate or detect errors in the CHECWORKS software.

The response dated May 25, 2012, stated that the results of component inspections are the primary input used to calculate the next scheduled inspection, and that this approach provides reasonable assurance that an error in the CHECWORKS software will not prevent the GGNS Flow-Accelerated Corrosion Program from providing reasonable assurance that the intended to GNRO-2012/001 05 Page 13 of 15 function of components will be maintained. The response concluded that as more actual inspection data is acquired, the already limited reliance of CHECWORKS becomes less.

Issue. The condition report discussed above documented an error in the CHECWORKS software and the resolution of this issue stated that CHECWORKS is only one of the tools used by the Flow-Accelerated Corrosion Program to predict component wear. The response appears to state that GGNS calculates the next scheduled inspection primarily using the results of component inspections independently from CHECWORKS. It is not clear to the staff how GGNS calculates the next scheduled inspection using the results of component inspections without CHECWORKS. Further, it is not clear to staff how reliance on the component inspection results reduces the effects of the errors in CHECKWORKS. Since the condition report stated that CHECWORKS is only one of the tools used by the Flow-Accelerated Corrosion Program to determine component wear, the staff needs additional information about the other tools that are used to calculate component wear.

Request. Provide a description of the other tools (Le., any in-place process or verification method), which are used in the Flow-Accelerated Corrosion Program to determine component wear that could detect or validate errors in the CHECWORKS software. If CHECWORKS is the only prediction tool being used, then explain how the use of component inspection results reduces the effects of any errors in CHECWORKS.

RAJ B.1.22-7a RESPONSE Measurement of actual wall thickness during inspections is the primary tool used in the Flow-Accelerated Corrosion Program to determine component wear that could detect errors in the CHECWORKS software. Selection of inspection locations for an outage is based on the following factors.

• previous inspection results

• CHECWORKS susceptibility ranking

• industry and plant-specific operating experience

• components selected to calibrate CHECWORKS

• components subject to off normal flow conditions, such as caused by a leaking valve

• susceptible non-modeled small bore piping that has not been inspected For every component selected for inspection based on CHECWORKS prediction, the measured wall thickness is compared to the predicted value. The actual measured wall thickness data can be used to detect errors in the CHECWORKS software.

Decisions for component repair, replacement or re-inspection are made based on measured or apparent wear found during inspections. The process of using measured wall thickness data for determination of component wear includes the following steps.

• Initial thickness of a component is determined by ultrasonic inspection prior to the component being placed in service or in the first ultrasonic inspection during its service life. If an examination has not previously been performed on the component, the initial thickness is the nominal component wall thickness unless the initial ultrasonic inspection data identifies thickness greater than nominal thickness. In such cases, the maximum identified wall thickness within the relevant area is used as initial thickness.

to GNRO-2012/001 05 Page 14 of 15

• The projected wear rate is calculated by taking the change in wall thickness divided by the operating time between measurements or between the time the component was placed in service and the time of the measurement.

• Using the projected wear rate and the component's minimum acceptable wall thickness, the next inspection is scheduled. It is re-inspected before or during the outage immediately prior to the cycle during which it is projected to wear to the minimum acceptable wall thickness.

As can be seen from these steps, measurement of actual wall thickness is a primary contributor in predicting degradation due to flow-accelerated corrosion (FAC).

RAI8.1.43-1a Background. GALL Report AMP XI.M2, "Water Chemistry," states that the water chemistry program for boiling water reactors (BWRs) relies on monitoring and control of reactor water chemistry based on industry guidelines in the BWR Vessel and Internals Project (BWRVIP)-190.

The response to RAI B.1.43-1, dated May 25,2012, regarding the methods used to determine the effectiveness of hydrogen water chemistry (HWC) at GGNS, states that platinum loading will be verified by using an artifact that had been removed from the reactor core, because an electrochemical corrosion potential (ECP) mitigation monitoring system was not available during the last operating cycle. The response continued by stating that BWRVIP-62, Revision 1, "Technical Basis for Inspection Relief for BWR Internal Components with Hydrogen Injection,"

does not require platinum deposition measurements on coupons to demonstrate mitigation for reactors that use on-line noble chemistry (OLNC). The response also stated that the recommendations by the NRC in the safety evaluation to BWRVIP-62 were incorporated into BWRVIP-62-A, which have been incorporated into BWRVIP-62, Revision 1. The applicant further stated that continuous ECP monitoring will be installed during the spring 2012 outage, which will meet the recommendations of BWRVIP-62, Revision 1.

Issue. The NRC has not reviewed BWRVIP-62, Revision 1, and there are differences between the NRC's recommendations for verification of noble metal loading in the safety evaluation related to BWRVIP-62-A, and the guidance given in BWRVIP-62, Revision 1. Specifically, BWRVIP-62-A states that noble metal (platinum) loading shall be monitored by periodic removal of durability monitors or by removal and analysis of deposits from artifacts within the vessel. In addition, the staff noted that BWRVIP-190, states that for plants using noble metal chemical application with ECP probes, catalyst (platinum) loading on durability monitors or vessel artifacts are to be monitored to demonstrate the effective implementation of HWC. Furthermore, although BWRVIP-190 discusses OLNC, it does not address any difference for platinum deposition measurements on coupons for plants using this technique. It is not clear to the staff whether the applicant will continue to monitor noble metal loading during the period of extended operation or whether continuous ECP monitoring has been installed.

Request. Confirm that, during the period of extended operation, the Water Chemistry Control-BWR program will monitor noble metal loading by either periodic removal of durability monitors or by removal and analysis of deposits from artifacts within the vessel. If not, justify the difference with BWRVIP-190 for monitoring catalyst loading to demonstrate effective implementation of HWC. Additionally, confirm that continuous ECP monitoring has been installed.

to GNRO-2012/001 05 Page 15 of 15 RAI 8.1.43-1 a RESPONSE During the period of extended operation, GGNS will monitor noble metal loading using periodic removal of durability monitor coupons.

Installation of equipment for continuous ECP monitoring was completed during the spring 2012 refueling outage.

Attachment 2 to GNRO*2012/00105 List of Regulatory Commitments

Attachment 2 to GNRO-2012/001 05 Page 1 of 20 List of Regulatory Commitments The following table identifies those actions committed to by Entergy in this document. Additions are shown with underline and deletions with strikethrough.

RELATED IMPLEMENTATION

1. COMMITMENT SOURCE LRASECTION SCHEDULE I AUDIT ITEM 1 Implement the 115 kilovolt (KV) Inaccessible Prior to GNRO- B.1.1 Transmission Cable Program for Grand Gulf November 1, 2011/00093 Nuclear Station (GGNS) as described in License 2024 Renewal Application (LRA) Section B.1.1 2 Implement the Aboveground Metallic Tanks Prior to GNRO- B.1.2 Program for GGNS as described in LRA Section November 1, 2011/00093 B.1.2 2024 3 Enhance the Bolting Integrity Program for GGNS to Prior to GNRO- B.1.3 clarify the prohibition on use of lubricants containing November 1, 2011/00093 MoS 2 for bolting, and to specify that proper gasket 2024 compression will be visually verified following assembly.

Enhance the Bolting Integrity Program to include consideration of the guidance applicable for pressure boundary bolting in Regulatoli)' Guide (NUREG) 1339, Electric Power Research Institute (EPRI) NP-5769, and EPRI TR-104213.

Enhance the Bolting Integrity Program to include vOlumetric examination per American Society of Mechanical Engineers (ASME) Code Section IX, Table IWB-2500-1, Examination Category B-G-1, for high-strength closure bolting regardless of code classification.

Attachment 2 to GNRO-2012/001 05 Page 2 of 20 RELATED IMPLEMENTATION

1. COMMITMENT SOURCE LRASECTION SCHEDULE I AUDIT ITEM 4 Enhance the Boraflex Monitoring Program for Prior to GNRO- B.1.4j RAI GGNS to perform periodic surveillances of the November 1, 2011/00093 B.1.4-1 boraflex neutron absorbing material in the spent fuel 2024 GNRO-pool and upper containment pool at least once 2012-00077 every 5 years using Boron-10 Areal Density Gage for Evaluating Racks (BADGER) testing.

RACKLIFE analysis will continue to be performed each cycle. This analysis will include a comparison of the RACKLIFE predicted silica to the plant measured silica. This comparison will determine if adjustments to the RACKLIFE loss coefficient are merited. The analysis will include projections to the next planned RACKLIFE analysis date to ensure current Region I storage locations will not need to be reclassified as Region II storage locations in the analysis interval.

5 Implement the Buried Piping and Tanks Inspection Prior to GNRO- B.1.51 RAI Program for GGNS as described in LRA Section November 1, 2011100093 B.1.5-4a B.1.5. Soil testing will be performed at two locations 2024 GNRO-near the stainless steel condensate storage system 2012/00089 piping that is subject to aging management review.

Measured parameters will include soil resistivity, bacteria, pH, moisture, chlorides and redox potential. If the soil is determined to be corrosive then the number of inspections will be increased from one to two prior to and during the period of extended operation.

Attachment 2 to GNRO-2012/001 05 Page 3 of 20 RELATED IMPLEMENTATION

1. COMMITMENT SOURCE LRASECTION SCHEDULE I AUDIT ITEM 6 Enhance the Boiling Water Reactor (BWR) Vessel Prior to GNRO- B.1.11 Internals Program for GGNS as follows. November 1, 2011/00093 2024 (a) Evaluate the susceptibility to neutron or thermal embrittlement for reactor vessel internal components composed of CASS, X-750 alloy, precipitation-hardened (PH) martensitic stainless steel(e.g., 15-5 and 17-4 PH steel), and martensitic stainless steel (e.g., 403, 410 and 431 steel).

(b) Inspect portions of the susceptible components determined to be limiting from the standpoint of thermal aging susceptibility, neutron fluence, and cracking susceptibility (i.e., applied stress, operating temperature, and environmental conditions). The inspections will use an inspection technique capable of detecting the critical flaw size with adequate margin. The critical flaw size will be determined based on the service loading condition and service-degraded material properties. The initial inspection will be performed either prior to or within 5 years after entering the period of extended operation. If cracking is detected after the initial inspection, the frequency of re-inspection will be justified based on fracture toughness properties appropriate for the condition of the component. The sample size will be 100% of the accessible component population, excluding components that may be in compression during normal operations.

Attachment 2 to GNRO-2012/001 05 Page 4 of 20 RELATED IMPLEMENTATION

1. COMMITMENT SOURCE LRASECTION SCHEDULE I AUDIT ITEM 7 Enhance the Compressed Air Monitoring Program Prior to GNRO- 8.1.12/RAI for GGNS to apply a consideration of the guidance November 1, 2011/00093 8.1.12-1 of ASME OM-S/G-1998, Part 17; ANSI/ISA-S7.0.01- 2024 1996; EPRI NP-7079; and EPRI TR-108147 to the limits specified for air system contaminants.

Enhance the Compressed Air Monitoring Program to include periodic and opportunistic inspections of accessible internal surfaces of piping, compressors, dryers, aftercoolers, and filters to apply consideration of the guidance of ASME OM-S/G-1998, Part 17 for inspection frequency and inspection methods of these components in the following compressed air systems.

• Automatic Depressurization System (ADS) air

• Division 1 Diesel Generator Starting Air (D1DGSA)

• Division 2 Diesel Generator Starting Air (D2DGSA)

• Division 3 Diesel Generator Starting Air (D3DGSA), also known as the HPCS Diesel Generator

• Instrument Air (IA)

Attachment 2 to GNRO-2012/00105 Page 5 of 20 RELATED IMPLEMENTATION

1. COMMITMENT SOURCE LRASECTION SCHEDULE I AUDIT ITEM 8 Enhance the Diesel Fuel Monitoring Program to Prior to GNRO- 8.1.16 include a ten-year periodic cleaning and internal November 1, 2011/00093 inspection of the fire water pump diesel fuel oil 2024 tanks, the diesel fuel oil day tanks for Divisions I, II, III, and the diesel fuel oil drip tanks for Divisions I, II.

These cleanings and internal inspections will be performed at least once during the 10-year period prior to the period of extended operation and at succeeding 10-year intervals. If visual inspection is not possible, a volumetric inspection will be performed.

Enhance the Diesel Fuel Monitoring Program to include a volumetric examination of affected areas of the diesel fuel tanks if evidence of degradation is observed during visual inspection. The scope of this enhancement includes the diesel fuel oil day tanks (Divisions I, II, III), the diesel fuel oil storage tanks (Divisions I, II, III), the diesel fuel oil drip tanks (Divisions I, II), and the diesel fire pump fuel oil storage tanks, and is applicable to the inspections performed during the 1O-year period prior to the period of extended operation and at succeeding 10-year intervals.

9 Enhance the External Surfaces Monitoring Program Prior to GNRO- 8.1.18 to include instructions for monitoring of the aging November 1, 2011/00093 effects for flexible polymeric components through 2024 manual or physical manipulation of the material, including a sample size for manipulation of at least 10 percent of available surface area.

Enhance the External Surfaces Monitoring Program as follows.

1. Underground components within the scope of this program will be clearly identified in program documents.

2. Instructions will be provided for inspecting all underground components within the scope of this program during each 10-year period, beginning 10 years prior to entering the period of extended operation.

Attachment 2 to GNRO-2012/00105 Page 6 of 20 RELATED IMPLEMENTATION

1. COMMITMENT SOURCE LRASECTION SCHEDULE I AUDIT ITEM 10 Enhance the Fatigue Monitoring Program to monitor Two years prior GNRO- 8.1.19/ RAI and track all critical thermal and pressure transients to November 1, 2011/00093 8.1.19-1, for all components that have been identified to have 2024 RAI4.3-11 a fatigue Time Limited Aging Analysis (TLAA).

Enhance the Fatigue Monitoring Program to perform a review of the GGNS high energy line break analyses and the corresponding tracking of associated cumulative usage factors to ensure the GGNS program adequately manages fatigue usage for these locations.

Fatigue usage calculations that consider the effects of the reactor water environment will be developed for a set of sample reactor coolant system components. This sample set will include the locations identified in NUREG/CR-6260 and additional plant-specific component locations in the reactor coolant pressure boundary if they are found to be more limiting than those considered in NUREG/CR-6260. Fen factors will be determined using the formulae sets listed in Section 4.3.3. If necessary following this analysis, revised cycle limits will be incorporated into the Fatigue Monitoring Program documentation.

Enhance the Fatigue Monitoring Program to provide updates of the fatigue usage calculations on an as-needed basis if an allowable cycle limit is GNRO-approached, or in a case where a transient 2012/00063 definition has been changed, unanticipated new thermal events are discovered, or the geometry of components have been modified. The program revision will include providing for the consideration of the recirculation pump fatigue analysis exemption validity if cycles that were input into the exemption evaluation exceed their limits.

Attachment 2 to GNRO-2012/00105 Page 7 of 20 RELATED IMPLEMENTATION

1. COMMITMENT SOURCE LRASECTION SCHEDULE I AUDIT ITEM 11 Enhance the Fire Protection Program to require Prior to GNRO- 8.1.20/

visual inspections of the Halon/C02 fire November 1, 2011/00093 RAI8.1.20-suppression system at least once every fuel cycle to 2024 2 examine for signs of corrosion.

Enhance the Fire Protection Program to require visual inspections of fire damper framing at least once every fuel cycle to check for signs of degradation.

Enhance the Fire Protection Program to require visual inspection of concrete curbs, manways, hatches, manhole covers, hatch covers, and roof slabs at least once every fuel cycle to confirm that aging effects are not occurring.

Enhance the Fire Protection Program to require an external visual inspection of the C02 tank at least GNRO-once every fuel cycle to examine for signs of 2012/00042 corrosion.

Attachment 2 to GNRO-2012/00105 Page 8 of 20 RELATED IMPLEMENTATION

1. COMMITMENT SOURCE LRASECTION SCHEDULE I AUDIT ITEM 12 Enhance the Fire Water Program to include Prior to GNRO- B.1.21/RAI inspection of hose reels for degradation. November 1, 2011/00093 B.1.21-5, Acceptance criteria will be enhanced to verify no 2024 B.1.21-3a unacceptable degradation.

Enhance the Fire Water Program to include one of the following options.

(1 ) Wall thickness evaluations of fire protection piping using non-intrusive techniques (e.g.,

vOlumetric testing) to identify evidence of loss of material will be performed prior to the period of extended operation and at periodic intervals thereafter. Results of the initial evaluations will be used to determine the appropriate inspection interval to ensure aging effects are identified prior to loss of intended function.

OR (2) A visual inspection of the internal surface of fire protection piping will be performed upon each entry to the system for routine or GNRO-corrective maintenance. These inspections 2012/00089 will be capable of evaluating (a) wall thickness to ensure against catastrophic failure and (b) the inner diameter of the piping as it applies to the design flow of the fire protection system. Maintenance history shall be used to demonstrate that such inspections have been performed on a representative number of locations prior to the period of extended operation. A representative number is 20% of the population (defined as locations having the same material, environment, and aging effect combination) with a maximum of 25 locations. Additional inspections will performed as needed to obtain this representative sample prior to the period of extended operation. The periodicity of inspections during the period of extended operation will be determined through an engineering evaluation of the operating experience gained from the results of previous inspections of fire water piping.

Attachment 2 to GNRO-2012/001 05 Page 9 of 20 RELATED IMPLEMENTATION

1. COMMITMENT SOURCE LRASECTION SCHEDULE I AUDIT ITEM 12 Enhance the Fire Water Program to include a visual (cont.) inspection of a representative number of locations on the interior surface of below grade fire protection piping in at least one location at a frequency of at least once every 10 years during the period of extended operation. A representative number is 20% of the population (defined as locations having the same material, environment, and aging effect combination) with a maximum of 25 locations.

Acceptance criteria will be revised to verify no unacceptable degradation.

Enhance the Fire Water Program to test or replace GNRO-sprinkler heads. If testing is chosen a representative 2012-00064 sample of sprinkler heads will be tested before the end of the 50-year sprinkler head service life and at 1O-year intervals thereafter during the period of extended operation. Acceptance criteria will be no unacceptable degradation. NFPA-25 defines a representative sample of sprinklers to consist of a minimum of not less than 4 sprinklers or 1 percent of the number of sprinklers per individual sprinkler sample, whichever is greater. If replacement of the sprinkler heads is chosen, all sprinklers that have been in service for 50 years will be replaced.

Enhance the Fire Water Program to include visual inspection of spray and sprinkler system internals for evidence of degradation. Acceptance criteria will be enhanced to verify no unacceptable degradation.

13 Enhance the Flow-Accelerated Corrosion Program Prior to GNRO- 8.1.22 to revise program documentation to specify that November 1, 2011/00093 downstream components are monitored closely to 2024 mitigate any increased wear when susceptible upstream components are replaced with resistant materials, such as high Cr material.

14 Enhance the lnservice Inspection - IWF Program to Prior to GNRO- 8.1.24/ RAI address inspections of accessible sliding surfaces. November 1, 2011/00093 8.1.24-1, 2024 3.5.1.94-1

Attachment 2 to GNRO-2012/001 05 Page 10 of 20 RELATED IMPLEMENTATION

1. COMMITMENT SOURCE LRASECTION SCHEDULE I AUDIT ITEM 14 Enhance the Inservice Inspection - IWF Program to; GNRO-(cont.) clarify that parameters monitored or inspected will 2012/00105 include corrosion; deformation; misalignment of supports; missing, detached, or loosened support items; improper clearances of guides and stops; and improper hot or cold settings of spring supports and constant load supports. Accessible areas of sliding surfaces will be monitored for debris, dirt, or indications of excessive loss of material due to wear that could prevent or restrict sliding as intended in the design basis of the support. Elastomerio vibration isolation elements will be monitored for oFaoking, loss of material, and hardening. Structural bolts will be monitored for corrosion and loss of integrity of bolted connections due to self-loosening and material conditions that can affect structural integrity. High-strength structural bolting (actual measured yield strength greater than or equal to 150 ksi or 1,034 MPa in sizes greater than 1 inch nominal diameter) susceptible to stress corrosion cracking (SCC) will be monitored for SCC.

Enhance the Inservice Inspection - IWF Program to clarify that detection of aging will include:

a) Monitoring structural bolting (American Society for Testing Materials (ASTM) A-325, ASTM F1852, and ASTM A490 bolts) and anchor bolts will be monitored for loss of material, loose or missing nuts, loss of pre-load and cracking of concrete around the anchor bolts.

b) Volumetric examination comparable to that of ASME Code Section XI, Table IWB-2500-1, Examination Category B-G-1 should be performed for high strength structural bolting to detect cracking in addition to the VT-3 examination. This volumetric examination may be waived with adequate plant-specific justification.

Attachment 2 to GNRO-2012/001 05 Page 11 of 20 RELATED IMPLEMENTATION

1. COMMITMENT SOURCE LRASECTION SCHEDULE I AUDIT ITEM 14 c) Identification of component supports that GNRO-(cont.) contain high strength bolting (actual measured 2012/00055 yield greater than or equal to 150 ksi) in sizes greater than 1 inch nominal diameter. The extent of examination for support types that contain high-strength bolting will be as specified in ASME Code Section XI, Table IWF-2500-1.

GGNS will examine high-strength structural bolting on the frequency specified in ASME Code Section XI, Table IWF-2500-1.

Enhance the Inservice Inspection - IWF Program acceptance criteria to include the following as GNRO-unacceptable conditions. 2011/00093 a) Loss of material due to corrosion or wear, which reduces the load bearing capacity of the component support; b) Debris, dirt, or excessive wear that could prevent or restrict sliding of the sliding surfaces as intended in the design basis of the support; and c) Cracked or sheared bolts, including high strength bolts, and anchors.

15 Enhance the Inspection of Overhead Heavy Load Prior to GNRO- 8.1.25 and Light Load Handling Systems Program to November 1, 2011/00093 include monitoring of rails in the rail system for the 2024 aging effect "wear", and structural connections/bolting for loose or missing bolts, nuts, pins or rivets. Additionally, the program will be clarified to include visual inspection of structural components and structural bolts for loss of material due to various mechanisms and structural bolting for loss of preload due to self-loosening.

Enhance the Inspection of Overhead Heavy Load and Light Load Handling Systems Program acceptance criteria to state that any significant loss of material for structural components and structural bolts, and significant wear of rails in the rail system, is evaluated according to ASME 630.2 or other applicable industry standard in the ASME 830 series.

Attachment 2 to GNRO-2012/00105 Page 12 of 20 RELATED IMPLEMENTATION

1. COMMITMENT SOURCE LRASECTION SCHEDULE I AUDIT ITEM 16 Implement the Internal Surfaces in Miscellaneous Prior to GNRO- 8.1.26 Piping and Ducting Components Program as November 1, 2011/00093 described in LRA Section 8.1.26. 2024 17 Enhance the Masonry Wall Program to clarify that Prior to GNRO- 8.1.27/ RAI parameters monitored or inspected will include November 1, 2011/00093 8.1.27-1 monitoring gaps between the supports and masonry 2024 walls that could potentially affect wall qualification.

Enhance the Masonry Wall Program to clarify that detection of aging effects require masonry walls to be inspected every 5 years.

18 Implement the Non-EQ Cable Connections Program Prior to GNRO- 8.1.28 as described in LRA Section 8.1.28 November 1, 2011/00093 2024 19 Enhance the Non environmentally Qualified (Non- Prior to GNRO- 8.1.29 EQ) Inaccessible Power Cables (400V to 35kV) November 1, 2011/00093 Program to include low-voltage (400V to 2kV) power 2024 cables.

Enhance the Non-EQ Inaccessible Power Cables (400V to 35kV) Program to include condition-based inspections of manholes not automatically dewatered by a sump pump being performed following periods of heavy rain or potentially high water table conditions, as indicated by river level.

Enhance the Non-EQ Inaccessible Power Cables (400V to 35kV) Program to clarify that the inspections will include direct observation that cables are not wetted or submerged, that cables/splices and cable support structures are intact, and that dewatering/drainage systems (Le.,

sump pumps) and associated alarms if applicable operate properly.

20 Implement the Non-EO Instrumentation Circuits Prior to GNRO- 8.1.30 Test Review Program as described in LRA Section November 1, 2011/00093 8.1.30. 2024 21 Implement the Non-EQ Insulated Cables and Prior to GNRO- 8.1.31 Connections Program as described in LRA Section November 1, 2011/00093 8.1.31. 2024

Attachment 2 to GNRO-2012/001 05 Page 13 of 20 RELATED IMPLEMENTATION

1. COMMITMENT SOURCE LRASECTION SCHEDULE I AUDIT ITEM 22 Enhance the Oil Analysis Program to provide a Prior to GNRO- B.1.32 formalized analysis technique for particulate November 1, 2011/00093 counting. 2024 Enhance the Oil Analysis Program to include piping and components within the main generator system (N41) with an internal environment of lube oil.

23 Implement the One-Time Inspection Program as Within the 10 GNRO- B.1.33 described in LRA Section B.1.33. years prior to 2011/00093 November 1, 2024 24 Implement the One-Time Inspection - Small Bore Within the 6 GNRO- B.1.34 Piping Program as described in LRA Section years prior to 2011/00093 B.1.34. November 1, 2024 25 Enhance the Periodic Surveillance and Preventive Prior to GNRO- B.1.35 Maintenance Program to include all activities November 1, 2011/00093 described in the table provided in LRA Section 2024 B.1.35 proQram description.

26 Enhance the Protective Coating Program to include Prior to GNRO- B.1.36 parameters monitored or inspected by the program November 1, 2011/00093 per the guidance provided in ASTM D5163-08. 2024 Enhance the Protective Coating Monitoring and Maintenance Program to provide for inspection of coatings near sumps or screens associated with the Emergency Core Cooling System.

Enhance the Protective Coating Program to include acceptance criteria per ASTM D 5163-08.

27 Ensure that the additional requirements of the Prior to GNRO- B.1.38/RAI ISP(E) specified in BWRVIP-86, Revision 1, November 1, 2011/00093 B.1.38-1, including the conditions of the final NRC safety 2024 B.1.38-4 evaluation for BWRVIP-116 incorporated in GNRO-BWRVIP-86, Revision 1 will be addressed before 2012/00081 the period of extended operation.

Ensure that new f1uence projections through the GNRO-period of extended operation and the latest vessel 2012/00081 beltline ART Tables are provided to the BWRVIP prior to the period of extended operation.

Attachment 2 to GNRO-2012/001 05 Page 14 of 20 RELATED IMPLEMENTATION

1. COMMITMENT SOURCE LRASECTION SCHEDULE I AUDIT ITEM 28 Enhance the Regulatory Guide (RG) 1.127, Prior to GNRO- B.1.39 Inspection of Water-Control Structures Associated November 1, 2011/00093 With Nuclear Power Plant Program to clarify that 2024 detection of aging effects will monitor accessible structures on a frequency not to exceed 5 years consistent with the frequency for implementing the requirements of RG 1.127.

Enhance the RG 1.127, Inspection of Water-Control Structures Associated With Nuclear Power Plant Program to perform periodic sampling, testing, and analysis of ground water chemistry for pH, chlorides, and sulfates on a frequency of at least every 5 years.

Enhance the RG 1.127, Inspection of Water-Control Structures Associated With Nuclear Power Plant Program acceptance criteria to include quantitative acceptance criteria for evaluation and acceptance based on the quidance provided in ACI 349.3R.

29 Implement the Selective Leaching Program as Prior to GNRO- B.1.40 described in LRA Section B.1.40. November 1, 2011/00093 2024 30 Enhance the Structures Monitoring Program to Prior to GNRO- B.1.421 RAI clarify that the scope includes the following: November 1, 2011100093 B.1.42-3, 2024 B.1.42-5, a) In-scope structures and structural components. GNRO- 2.1-4,

• Containment Building (GGN 2) 2012/00074 3.5.1.33-2,

• Control House - Switchyard B.1.13-4a,

• Culvert No. 1 and drainage channel B.1.42-1a

• Manholes and Ductbanks

• Radioactive Waste Building Pipe Tunnel

• Auxiliary Building (GGN2)

• Turbine Building (GGN2) b) In-scope structural components GNRO-

• Anchor bolts 2012-00095

• Anchorage 1 embedments

• Base plates

• Basin debris screen and grating

• Battery racks

• Beams, columns, floor slabs and interior walls

• Cable tray and cable tray supports

• Component and piping supports

• Conduit and conduit supports

• Containment sump liner and penetrations

Attachment 2 to GNRO-2012/001 05 Page 15 of 20 RELATED IMPLEMENTATION

1. COMMITMENT SOURCE LRASECTION SCHEDULE I AUDIT ITEM

• Containment sump structures

• Control room ceiling support system 30

• Cooling tower drift eliminators (cont)

• Cooling tower fill

• CST/RWST retaining basin (wall)

• Diesel fuel tank access tunnel slab

• Drainage channel

• Drywell electrical penetration sleeves

• Drywell equipment hatch

• Drywell floor slab (concrete)

• Drywell head

• Drywell head access manway

• Drywell liner plate

• Drywell mechanical penetration sleeves

• Drywell personnel access lock

• Drywell wall (concrete)

• Ductbanks

• Electrical and instrument panels and enclosures

• Equipment pads/foundations

• Exterior walls

• Fan stack grating

• Fire proofing

• Flood curbs

• Flood retention materials (spare parts)

• Flood, pressure and specialty doors

• Floor slab

• Foundations

• HVAC duct supports

• Instrument line supports

• Instrument racks, frames and tubing trays

• Interior walls

• Main steam pipe tunnel

• Manholes

• Manways, hatches, manhole covers, and hatch covers

• Metal siding

• Missile shields

• Monorails

• Penetration sealant (flood, radiation)

• Penetration sleeves (mechanical/ electrical not penetrating primary containment boundary)

• Pipe whip restraints

• Pressure relief panels

• Reactor pedestal

• Reactor shield wall (steel portion)

Attachment 2 to GNRO-2012/00105 Page 16 of 20 RELATED IMPLEMENTATION

1. COMMITMENT SOURCE LRASECTION SCHEDULE I AUDIT ITEM

• Roof decking

• Roof hatches 30

• Roof membrane (cont)

• Roof slabs

• RPV pedestal sump liner and penetrations

• Seals and gaskets (doors, manways and hatches)

• Seismic isolation joint

• Stairway, handrail, platform, grating, decking, and ladders

• Structural bolting

• Structural steel, beams columns, and plates

• Sumps and Sump liners

• Support members: welds; bolted connections; support anchorages to building structure

• Support pedestals

• Transmission towers (see Note 1)

• Upper containment pool floor and walls

• Vents and louvers

• Weir wall liner plate Note 1: The inspections of these structures may be performed by the transmission personnel. However, the results of the inspections will be provided to the GGNS Structures Monitoring Program owner for review.

c) Clarify the term "significant degradation" to include "that could lead to loss of structural integrity".

d) Include guidance to perform periodic sampling, testing, and analysis of ground water chemistry for pH, chlorides, and sulfates on a frequency of at least every 5 years.

Enhance the Structures Monitoring Program to clarify that parameters monitored or inspected include:

a) inspection for missing nuts for structural connections.

b) monitoring sliding/bearing surfaces such as Lubrite plates for loss of material due to wear or corrosion, debris, or dirt. The program will be enhanced to include monitoring elastomeric vibration isolators and structural sealants for cracking, loss of material, and hardening.

Attachment 2 to GNRO-2012/001 05 Page 17 of 20 RELATED IMPLEMENTATION

1. COMMITMENT SOURCE LRASECTION SCHEDULE I AUDIT ITEM c) Include periodically inspecting the leak chase system associated with the upper containment pool and spent fuel pool to ensure the tell-tales are free of significant blockage. The inspection will also inspect concrete surfaces for degradation where leakage has been observed, in accordance with this Program.

30 (cont.)

Enhance the Structures Monitoring Program to clarify that detection of aging effects will: GNRO-2012/00054 a) include augmented inspections of vibration isolators by feel or touch to detect hardening if the vibration isolation function is suspect.

b) Require inspections every 5 years for structures and structural components within the scope of license renewal.

c) Require direct visual examinations when access GNRO-is sufficient for the eye to be within 24-inches of 2011/00093 the surface to be examined and at an angle of not less than 30 0 to the surface. Mirrors may be used to improve the angle of vision and accessibility in constricted areas.

d) Specify that remote visual examination may be GNRO-substituted for direct examination. For all 2012/00098 remote visual examinations, optical aids such as telescopes, borescopes, fiber optics, cameras, or other suitable instruments may be used GNRO-provided such systems have a resolution 2012/00054 capability at least equivalent to that attainable by direct visual examination.

e) Include instructions to augment the visual examinations of roof membranes, and seals and GNRO-gaskets (doors, manways, and hatches) with 2012/00054 physical manipulation of at least 10 percent of available surface area.

Enhance the Structures Monitoring Program acceptance criteria by prescribing acceptance criteria based on information provided in industry codes, standards, and guidelines including NEI 96-03, ACI 201.1 R-92, ANSI/ASCE 11-99 and ACI 349.3R-96. Industry and plant-specific operating GNRO-experience will also be considered in the 2012/00076

Attachment 2 to GNRO-2012/001 05 Page 18 of 20 RELATED IMPLEMENTATION

1. COMMITMENT SOURCE LRASECTION SCHEDULE I AUDIT ITEM development of the acceptance criteria.

GNRO-2011/00093 31 Enhance the Water Chemistry Control- Closed Prior to GNRO- 8.1.44/ RAI Treated Water Program to provide a corrosion November 1, 2011/00093 8.1.44-1, inhibitor for the engine jacket water on the engine- 2024 8.1.44-2 driven fire water pump diesel in accordance with industry guidelines and vendor recommendations.

Enhance the Water Chemistry Control - Closed Treated Water Program to provide periodic flushing of the engine jacket water and cleaning of heat exchanger tubes for the engine-driven fire water pump diesel in accordance with industry guidelines and vendor recommendations.

Enhance the Water Chemistry Control - Closed Treated Water Program to provide testing of the engine jacket water for the engine-driven fire water pump diesels at least annually.

Enhance the Water Chemistry Control - Closed Treated Water Program to revise the water GNRO-chemistry procedure for closed treated water 2012/00049 systems to align the water chemistry control parameter limits with those of EPRI 1007820.

Attachment 2 to GNRO-2012/001 05 Page 19 of 20 RELATED IMPLEMENTATION

1. COMMITMENT SOURCE LRASECTION SCHEDULE I AUDIT ITEM 31 Enhance the Water Chemistry Control- Closed (cont.) Treated Water Program to conduct inspections whenever a boundary is opened for the following systems.

• Drywell chilled water (DCW - system P72)

• Plant chilled water (PCW - system P71)

• Diesel generator cooling water subsystem for Division I and II standby diesel generators

• Diesel engine jacket water for engine-driven fire water pump

• Diesel generator cooling water subsystem for Division III (HPCS) diesel generator

• Turbine building cooling water (TBCW- system P43)

• Component cooling water (CCW - system P42)

These inspections will be conducted in accordance with applicable ASME Code requirements, industry standards, and other plant-specific inspection and personnel qualification procedures that are capable of detecting corrosion or cracking.

Attachment 2 to GNRO-2012/00105 Page 20 of 20 RELATED IMPLEMENTATION

1. COMMITMENT SOURCE LRASECTION SCHEDULE I AUDIT ITEM 31 Enhance the Water Chemistry Control - Closed (cont.) Treated Water Program to inspect a representative sample of piping and components at a frequency of once every ten years for the following systems.

• Drywell chilled water (DCW - P72)

• Plant chilled water (PCW - P71 )

• Diesel generator cooling water subsystem for Division I and II standby diesel generators

• Diesel engine jacket water for engine-driven fire water pump

• Diesel generator cooling water subsystem for Division III (HPCS) diesel generator

• Turbine building cooling water (TBCW -

P43)

• Component cooling water (CCW - P42)

Components inspected will be those with the highest likelihood of corrosion or cracking. A representative sample is 20% of the population (defined as components having the same material, environment, and aging effect combination) with a maximum of 25 components. The inspection methods will be in accordance with applicable ASME Code requirements, industry standards, or other plant specific inspection and personnel qualification procedures that ensure the capability of detecting corrosion or cracking.

32 Enhance the BWR CRD Return Line Nozzle Prior to GNRO- B.1.6 1 RAI Program to include inspection of the CRD return line November 1, 2012/00029 B.1.6-1 nozzle inconel end cap to carbon steel safe end 2024 dissimilar metal weld once prior to the period of extended operation and every 10 years thereafter.

33 Enhance the BWR Penetrations Program to include Prior to GNRO- B.1.8 1 RAI that site procedures which implement the guidelines November 1, 2012/00029 B.1.8-1 of BWRVIP-47-A will be clarified to indicate that the 2024 guidelines of BWRVIP-47-A apply without exceptions.