L-13-160, Reply to Request for Additional Information for the Review of the License Renewal Application and License Renewal Application Amendment No. 40

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Reply to Request for Additional Information for the Review of the License Renewal Application and License Renewal Application Amendment No. 40
ML13114A254
Person / Time
Site: Davis Besse Cleveland Electric icon.png
Issue date: 04/19/2013
From: Lieb R
FirstEnergy Nuclear Operating Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
L-13-160, TAC ME4640
Download: ML13114A254 (57)
v • d • e


Text

FENOC- 5501 North State Route 2 Oak Harbor,Ohio 43449 FirstEnergyNuclear Operating Company Raymond A. Lieb 419-321-7676 Vice President,Nuclear Fax: 419-321-7582 April 19, 2013 L-13-160 10 CFR 54 ATTN: Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555-0001

SUBJECT:

Davis-Besse Nuclear Power Station, Unit No. 1 Docket No. 50-346, License Number NPF-3 Reply to Request for Additional Information for the Review of the Davis-Besse Nuclear Power Station, Unit No. 1, License Renewal Application (TAC No. ME4640) and License Renewal Application Amendment No. 40 By letter dated August 27, 2010 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML102450565), FirstEnergy Nuclear Operating Company (FENOC) submitted an application pursuant to Title 10 of the Code of Federal Regulations, Part 54 for renewal of Operating License NPF-3 for the Davis-Besse Nuclear Power Station, Unit No. 1 (Davis-Besse). By letter dated March 26, 2013 (ML13051A056), the Nuclear Regulatory Commission (NRC) requested additional information to complete its review of the License Renewal Application (LRA).

The Attachment provides the FENOC reply to the NRC request for additional information. The NRC request is shown in bold text followed by the FENOC response.

The Enclosure provides Amendment No. 40 to the Davis-Besse LRA.

45 Af '0

Davis-Besse Nuclear Power Station, Unit No. 1 L-1 3-160 Page 2 There are no regulatory commitments contained in this letter. If there are any questions or if additional information is required, please contact Mr. Clifford I. Custer, Fleet License Renewal Project Manager, at 724-682-7139.

I declare under penalty of perjury that the foregoing is true and correct. Executed on April 4/___, 2013.

Sincerely, Raym A. Lieb

Attachment:

Reply to Request for Additional Information for the Review of the Davis-Besse Nuclear Power Station, Unit No. 1 (Davis-Besse), License Renewal Application (LRA), Section A.1

Enclosure:

Amendment No. 40 to the Davis-Besse License Renewal Application cc: NRC DLR Project Manager NRC Region III Administrator cc: w/o Attachment or Enclosure NRC DLR Director NRR DORL Project Manager NRC Resident Inspector Utility Radiological Safety Board

Attachment L-1 3-160 Reply to Request for Additional Information for the Review of the Davis-Besse Nuclear Power Station, Unit No. 1 (Davis-Besse),

License Renewal Application (LRA),

Section A. 1 Page 1 of 3 Question RAI A.1-1

Background:

By letter dated August 27, 2010, FirstEnergy Nuclear Operating Company (FENOC) submitted an application pursuant to Title 10 of the Code of Federal Regulations Part 54 for renewal of Operating License NPF-3 for the Davis-Besse Nuclear Power Station. The staff of the U.S. Nuclear Regulatory Commission (NRC or the staff) is reviewing this application in accordance with the guidance in NUREG-1800, "Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants." By letter dated July 31, 2012, the NRC provided the "Safety Evaluation Report with Open Items related to the License Renewal of the Davis-Besse Nuclear Power Station" (SER), and requested that FENOC review the SER and provide comments to the NRC staff. By letter dated September 14, 2012, FENOC provided its comments.

During the review of the Davis-Besse license renewal application (LRA) by the U.S. Nuclear Regulatory Commission (NRC) staff, FENOC made commitments related to aging management programs to manage the aging effects of structures and components prior to the period of extended operation. The list of these commitments, as well as the implementation schedules and the sources for each commitment, was included as Table A-1 in Appendix A to the SER with Open Items.

In Section 1.7, "Summary of Proposed License Conditions," of the SER with Open Items, the staff stated that following its review of the LRA, including subsequent information and clarifications provided by the applicant, the staff identified proposed license conditions. The first license condition requires the information in the updated safety analysis report (USAR) supplement, submitted pursuant to 10 CFR 54.21(d), as revised during the license renewal application review process, be made a part of the USAR. The second license condition in part states that the activities listed in Appendix A of the SER and the applicant's USAR supplement be completed no later than October 22, 2016 (i.e., 6 months prior to the period of extended operation).

The NRC plans to revise the second proposed license condition regarding the USAR supplement, which describes certain programs to be implemented and activities to be completed prior to the period of extended operation (PEO). Under the license condition, FENOC will be required to implement those new programs

Attachment L-1 3-160 Page 2 of 3 and enhancements to existing programs no later than 6 months prior to the PEO.

In addition, the license condition will state that FENOC shall complete those inspection or testing activities as noted in certain commitments by 6 months prior to the PEO or the end of the last refueling outage prior to the PEO, whichever occurs later.

Therefore, the license condition will be revised to state:

The USAR supplement submitted pursuant to 10 CFR 54.21(d), as revised during the license renewal application review process, and as supplemented by Appendix A of NUREG [XXXX], "Safety Evaluation Report Related to the License Renewal of Davis-Besse Nuclear Power Station" dated [Month Year], describes certain programs to be implemented and activities to be completed prior to the period of extended operation.

a. The licensee shall implement those new programs and enhancements to existing programs no later than 6 months prior to PEO.
b. The licensee shall complete those inspection and testing activities, as noted in Commitment Nos. x through xx of Appendix A of NUREG XXXX, by the 6-month date prior to PEO or the end of the last refueling outage prior to the PEO, whichever occurs later.

The licensee shall notify the NRC in writing within 30 days after having accomplished item (a) above and include the status of those activities that have been or remain to be completed in item (b) above.

Issue:

As proposed in the Davis-Besse LRA Table A-1, the implementation schedule for some commitments may conflict with the implementation schedule intended by the generic license condition.

Request:

1. Identify those commitments to implement new programs and enhancements to existing programs. Indicate the expected date for completing the implementation of each of these programs and enhancements.
2. Identify those commitments to complete inspection or testing activities prior to the PEO. Indicate the expected dates for the completion of each of these inspection and testing activities.

Attachment L-13-160 Page 3 of 3 RESPONSE RAI A.1-1

1. The following license renewal future commitments to implement new programs and' enhance existing programs are revised to change the completion dates from "April 22, 2017," to "prior to October 22, 2016":

Commitments 1-14, 16-21, 25, 27-32, 34, 40, 45-47, and 49

2. The following license renewal future commitments to complete inspection and testing activities are revised to change the completion dates from "April 22, 2017," to "prior to October 22, 2016":

Commitments 22-24, 38, 41, 43, 44, and 48 Additionally, for consistency with the commitment date revisions in response to Requests 1 and 2 above, Commitment 33, Phase 1, Action 2 is revised to change the completion date from "prior to December 31, 2016" to "prior to October 22, 2016".

However, the [multiple] activities in Commitment 33 are not "inspection or testing activities", so Commitment 33 was not included in the list of commitments revised in response to Request 2, above, and therefore should not be included in the list of commitments in the license condition.

See the Enclosure to this letter for the revision to the Davis-Besse LRA.

Enclosure A Davis-Besse Nuclear Power Station, Unit No. 1 (Davis-Besse)

Letter L-1 3-160 Amendment No. 40 to the Davis-Besse License Renewal Application Page 1 of 52 License Renewal Application Sections Affected Table A-1 The Enclosure identifies the change to the License Renewal Application (LRA) by Affected LRA Section, LRA Page No., and Affected Paragraph and Sentence. The count for the affected paragraph, sentence, bullet, etc. starts at the beginning of the affected Section or at the top of the affected page, as appropriate. Below each section the reason for the change is identified, and the sentence affected is printed in italics with deleted text lined-ou and added text underlined..

Enclosure A L-13-160 Page 2 of 52 Affected LRA Section LRA Paqe No. Affected ParaqraDh and Sentence Table A-1 Pages A-55 41 of 49 Commitments thru A-69 Implementation Schedule, Source and Related LRA Section No./ Comments columns In response to RAI A.1-1, 41 of 49 Commitments in LRA Table A-I, "Davis-Besse License Renewal Commitments,"

reprinted in its entirety, below, are revised to change the "Implementation Schedule", as follows:

Table A-I Davis-Besse License Renewal Commitments Im Related LRA Item Commitment Implementation Source Section No./

Number Schedule Comments Enhance the Aboveground Steel Tanks Inspection Program to: Priorto LRA A.1.2

  • Include a volumetric examination of tank bottoms to detect A and B.2.2 evidence of loss of material due to crevice, general, or pitting October 22 2016and corrosion, or to confirm a lack thereof. Establish the examination technique, the inspection locations, and the acceptance criteria FENOC Responses to for the examination of the tank bottoms. Require that Letters NRC RAls unacceptable ihspection results be entered into the FENOC L-11-153 B.2.2-1 from Corrective Action Program. The volumetric examination of the and NRC Letter tank bottoms will be performed within five years after entering L-13-160 dated the period of extended operation. Additional opportunistic tank April 20, 2011, bottom inspections will be performed whenever the tanks are and drained. A.1-1 from

Enclosure A L-13-160 Page 3 of 52 Table A-1 Davis-Besse License Renewal Commitments Related LRA Item Commitment Implementation Source Section No./

Number Schedule Comment NRC Letter dated March 26. 2013 2 Implement the Boral Monitoring Program as described in LRA Priorto LRA A.1.5' Section B.2.5. Ap22*, 20 adB27 October22, 2016 and FENOC Response to Letter NRC RAI L-13-160 A. 1-1 from NRC Letter dated March 26. 2013 3 Enhance the Buried Piping and Tanks Inspection Program to: ApMPriorto LRA A.1.7 Add 1) bolting for buried Fire Protection System piping and 2) "'o" 22-,22,20!-7 and B.2.7 SytmOctober 22, 2016 the emergency diesel fuel oil storage tanks (DB-T1 53-1, DB- and T1 53-2) to the scope of the program. FENOC Responses to Letters_ NRCRAIs_

0 Conduct annual ground potential surveys of the cathodic protection system using the acceptance criteria listed in L-11-153 B.2.7-1 from and NRC Letter NACE RP0285 2002 and NACE SP0169-2007. Monitor cathodic protection voltage and current monthly to determine L-13-160 dated the effectiveness of cathodic protection systems and, thereby, Apr120, 2011d the effectiveness of corrosion mitigation. Trend voltage,A

Enclosure A L-13-160 Page 4 of 52 Table A-1 Davis-Besse License Renewal Commitments Item Commitment Im Implementation Source Related LRA Section No./

Number Schedule Cmet Comments current, and ground potential readings and evaluate for and adverse changes. A. 1-1 from

  • Require that the activity of the jockey fire pump or equivalent NRC Letter parameter be monitored on at least a monthly interval, dated Conduct a flow test by the end of the next refueling outage when March 26, 2013 unexplained changes in jockey pump activity are observed.

a Require that the directed buried pipe inspection locations be selected based on risk.

  • Require that the minimum number of buried in-scope piping inspections during the 30-40, 40-50, and 50-60 year operating period is one steel safety-related piping segment and one steel piping segment containing hazardous material. Perform the directed buried steel pipe and tank inspections each ten year interval based upon the following table. Each inspection will have a minimum of 10 feet of piping inspected.

Preventive # of inspections of safety # of Hazmat inspections Actions related piping or tanks or % of pipe length A 1 (Note 2) 1 (Note 2)

B 1 2%

C 4 5%

D 8 10%

Note 1: Preventive actions are categorized as follows:

A. - Cathodic protection, in accordance with

Enclosure A L-13-160 Page 5 of 52 Table A-1 Davis-Besse License Renewal Commitments Item Number Commitment Implementation Sheme Source TRelated LRA Section No.1 Comments NACE SP0169-2007 or NACE RP0285-2002, was installed for at least 5 years prior to entering the period of extended operation and was operational for 90% of the time during that 5 years or cathodic protection was operational for 90% of the time since the last inspection conducted under this program.

B. - Cathodic protection, in accordance with NACE SP0169-2007 or NACE RP0285-2002, was installed for less than 5 years prior to entering the period of extended operation or was operational for less than 90% of the time during that 5 years or cathodic inspection was operational for less than 90% of the time since the last inspection conducted under this program C. - Protective coatings are in place and no mechanical.

coating damage due to the backfill, but cathodic protection is not provided or not in accordance with criteria A or B and the period of extended operation has not been entered.

D. - Criteria of A, B, and C not met.

Note 2: Only one inspection is required for piping which is both safety-related and contains hazardous material.

Require that the EDG Fuel Oil Storage Tanks (DB-T153-1 and DB-T1 53-2) be inspected prior to entering the period of extended operation. The inspection will be either a visual

Enclosure A L-1 3-160 Page 6 of 52 Table A-I Davis-Besse License Renewal Commitments Item Number Commitmenttion Commitment Implementation Source TRelated LRA Section No./

Comments inspection of at least 25% of each tank and include at least some portion of the tank top and bottom or, an internal inspection consisting of UT measurements with at least one measurement per square foot of the surface of the tanks.

These inspections are not required if it is demonstrated that the tanks are cathodically protected in accordance with NACE SP0169-2007 or NACE RP0285-2002.

Require that a visual and volumetric inspection of the underground piping within the borated water piping trench will be performed during each 10-year period beginning no sooner than 10 years prior to the entry into the period of extended operation.

Require that if adverse indications are detected, additional buried in-scope piping inspections be performed in order to provide reasonable assurance of the integrity of buried piping.

Base the selection of components to be examined on previous examination results, trending, risk ranking, and areas of cathodic protection failures or gaps, if applicable. Continue additional sampling until reasonable assurance of the integrity of buried piping is provided.

Require that an inspection of buried Fire Protection System bolting will be performed when the bolting becomes accessible during opportunistic or focused inspections.

Enclosure A L-13-160 Page 7 of 52 TableA-1 Davis-Besse License Renewal Commitments Related LRA Item Commitment Implementation Source Section No./

Number Schedule Comments Require that the inspections of buried piping be conducted using visual (VT-3 or equivalent) inspection methods. Excavation shall be a minimum of 10 linear feet of piping, with all surfaces of the pipe exposed.

4 Implement the Collection, Drainage, and Treatment Components Priorto LRA A.1.9 Inspection Program as described in LRA Section B.2.9. ApF# 22--, ,,.7 October 22, 2016 and FENOC Response to Letter NRC .RAI L-13-160 A.1-1 from NRC Letter

  • dated March 26. 2013 5 Implement the Electrical Cable Connections Not Subject to Priorto LRA A.1.11 10 CFR 50.49 Environmental Qualification Requirements Inspection Ap,, 22-,:20 and B.2.11 as described in LRA Section B.2.11. October22, 2016 Enhance the Electrical Cable Connections Not Subject to and 10 CFR 50.49 Environmental Qualification Requirements FENOC Responses to Inspection to: Letters NRC RAIs L-11-134 *3.6-3 Letter from and NRC
  • Include high voltage connections to confirm the absence of aging effects for metallic electrical connections. L-13-160 dated

Enclosure A L-13-160 Page 8 of 52 Table A-1 Davis-Besse License Renewal Commitments I

Implementation Related LRA Item Number Commitment Schedule Source Section No./

Comments April 5, 2011, and A. 1-1 from NRC Letter dated March 26. 2013 6 Implement the Electrical Cables and Connections Not Subject to Priorto LRA A.1.12 10 CFR 50.49 Environmental Qualification Requirements Program Ap,!and B.2.12 as described in LRA Section B.2.12. October22, 2016 and FENOC Response to Letter NRC RAI L-13-160 A. 1-1 from NRC Letter dated March 26. 2013

Enclosure A L-1 3-160 Page 9 of 52 Table A-1 Davis-Besse License Renewal Commitments 1mo 1Related LRA Item' Iter Number Commitment j Implementation Schedule 1m Source _ oimet Section No./

Comments 7 Implement the Electrical Cables and Connections Not Subject to: Priorto LRA A.1.13 10 CFR 50.49 Environmental Qualification Requirements Used in Aril 2Z nd B.2.13 Instrumentation Circuits Program as described in LRA Section October 22, 2016 B.2.13. and FENOC Response to Letter NRC RAI L-13-160 A. 1-1 from NRC Letter dated March 26, 2013 8 Enhance the External Surfaces Monitoring Program to: Priorto LRA A.1.15

...... and B.2,15 October22, 2016 do not have Maintenance Rule intended functions to the scope and of the program. FENOC Responses to

  • Perform opportunistic inspections of surfaces that are Letters NRC RAes_

inaccessible or not readily visible during normal plant operations L-11-153, 3.3.2.2.5-1 and L-11-166, B.2.2-2 from or refueling outages, such as surfaces that are insulated.

Surfaces that are accessible will be inspected at a frequency not L-11-238 NRC Letter to exceed one refueling cycle. and dated 0 Perform, in conjunction with the Inspection of Internal Surfaces L-13-160 April 20, 2011, in Miscellaneous Piping and Ducting Program, inspection and 3.3.2-2 from surveillance of elastomers and polymers exposed to air-indoor NRC Letter uncontrolled or air-outdoor environments, but not replaced on a

Enclosure A L-1 3-160 Page 10 of 52 Table A-1 Davis-Besse License Renewal Commitments Item Implementation Related LRA NumberCommitment Sceue Source Section No./

Number Schedule *Comments set frequency or interval (i.e., are long-lived), for evidence of dated cracking and change in material properties (hardening and loss May 2, 2011, of strength) and loss of material due to wear. Specify 3.3.2.2.5-2 from acceptance criteria of no unacceptable visual indications of NRC.Letter cracks or discoloration that would lead to loss of function prior to dated the next inspection, and of no hardening as evidenced by a loss July 12, 2011, of suppleness during manipulation.

Perform inspection of the control room emergency ventilation Supplemental system air-cooled condensing unit cooling coil tubes and fins RAI OIN-352 from and the station blackout diesel generator radiator tubes and fins for visible evidence of external surface conditions that could IP-71002 result in a reduction in heat transfer. Specify acceptance criteria Inspection, of no unacceptable visual indications of fouling (build up of dirt or other foreign material) that would lead to loss of function prior and to the next scheduled inspection. A. 1-1 from NRC Letter

  • Manage cracking of copper alloys with greater than 15 percent dated zinc and stainless steel components exposed to an outdoor air March 26, 2013 environment through plant system inspections and walkdowns for evidence of leakage. Specify acceptance criteria of no unacceptable visual indications of cracks that would lead to loss of function prior to the next scheduled inspection.
  • Include inspection parameters and acceptance criteria for polymers, elastomers and metallic components as applicable in system inspection and walkdown documentation. Retain system

Enclosure A L-1 3-160 Page 11 of 52 Table A-1 Davis-Besse License Renewal Commitments Related LRA Item Commitment Implementation Source Section No./

Number Schedule Comments inspection and walkdown documentation in plant records.

9 Enhance the Fatigue Monitoring Program to: Priorto LRA A.1.16 Provide for updates of the fatigue usage calculations on an as Octobrand B.2.16 needed basis if an allowable cycle limit is approached. When October 22. 2016 and the number of accrued cycles is within 75% of the allowable cycle limit for. any transient, a condition report will be generated. FENOC Responses to For any transient whose cycles are projected to exceed the Letters NRC RAIs allowable cycle limit by the end of the next plant operating cycle L-11-166 B.2.16-3, (Davis-Besse operating cycles are normally two years in and B.2.16-4 duration), the program will require an update of the fatigue L-13-160 and usage calculation for the affected component(s). B.2.16-5 from Establish an acceptance criterion for maintaining the cumulative NRC Letter fatigue usage below the Code design limit of 1.0 through the dated period of extended operation, including environmental effects April 20, 2011, where applicable and' A. 1-1 from NRC Letter dated March 26, 2013 10 Enhance the Fire Water Program to: Priorto LRA A.1.18

  • Perform periodic ultrasonic testing for wall thickness of Oor 22, 2017 and B.2.18 representative above-ground water suppression piping that is October 22. 2016

Enclosure A L-13-160 Page 12 of 52 Table A-1 Davis-Besse License Renewal Commitments Item Commitment Implementation Source Section No,/

Number Schedule comments Comments not periodically flow tested but contains, or has contained, and stagnant water. The ultrasonic testing will be performed prior to the period of extended operation and at appropriate intervals FENOC Response to thereafter, based on engineering evaluation of the initial results. Letter NRC RAI L-13-160 A. 1-1 from Perform at least one opportunistic or focused visual inspection NRC Letter of the internal surface of buried fire water piping and of similar dated above-ground fire water piping, within the five-year period prior March 26, 2013 to the period of extended operation, to confirm whether conditions on the internal surface of above-ground fire water piping can be extrapolated to be indicative of conditions on the internal surface of buried fire water piping.

Perform representative sprinkler head sampling (laboratory field service testing) or replacement prior to 50 years in-service (installed), and at 10-year intervals thereafter, in accordance with NFPA 25, or until there are no untested sprinkler heads that will see 50 years of service through the end of the period of extended operation.

Perform opportunistic fire water supply and water-based suppression system internal inspections each time a fire water supply or water-based suppression system (including fire pumps) is breached for repair or maintenance. These internal, visual inspections must be demonstrated to be: 1) representative of water supply and water-based suppression locations, 2) performed on a reasonable basis (frequency), and

Enclosure A L-1 3-160 Page 13 of 52 Table A-1 Davis-Besse License Renewal Commitments Item Commitment Implementation Impledue.tto Source Related LRA Section No./

Numer Number jSchedule Comments

3) capable of evaluating wall thickness and flow capability. If the internal inspections cannot be completed of a representative sample, then ultrasonic testing inspections will be used to complete the representative sample.

11 Implement the Inaccessible Power Cables Not Subject to Priorto LRA A. 1.21 10 CFR 50.49 Environmental Qualification Requirements Program ,,r4 ,,and 13.2.21 as described in LRA Section B.2.21. October 22, 2016 Enhance the Inaccessible Power Cables Not Subject to and 10 CFR 50.49 Environmental Qualification Requirements FENOC Responses to Program to: Letters NRC RAIs L-11-134 and B.2.21-1 and B.2.21-3 from

  • Include inaccessible underground lower service voltage cables (400VAC to 2kV). L-13-160 NRC Letter 0 Not use 'significant voltage' (defined as being subjected to dated system voltage for more than twenty-five percent of the time) as April 5, 2011, a criterion for inclusion into the program. and Include inspection of electrical manholes which contain power A. 1-1 from cables within the scope of the program. NRC Letter dated Inspect electrical manholes at least once per year. The March 26, 2013 frequency of inspections for accumulated water will be established and adjusted based on plant-specific inspection results. Also, manhole inspections will be performed in response to event-driven occurrences (e.g., heavy rain or flooding).

Enclosure A L-1 3-160 Page 14 of 52 Table A-1 Davis-Besse License Renewal Commitments Item Commitment Implementation Source Section LRA Related No./

Number Schedule Cmet Comments

  • Include a requirement in preventive maintenance activities PM 4297, PM 4294, PM 8025, and PM 4296 to generate a condition report in cases where in scope inaccessible non-EQ power cable manhole inspection identifies submerged cables.

Although the Inaccessible Power Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Program is a new program, preventive maintenance activities exist for inspection of water accumulation in the manholes associated with the in scope inaccessible non-EQ power cables.

Perform cable testing on a frequency of at least every 6 years.

Testing will be evaluated for more frequent performance based on test results and operating experience.

12 Enhance the Masonry Wall Inspection to: Priorto LRA A.1.27 0 Include and list the structures within the scope of license "" 22-,..... and B.2.27 renewal that credit the program for aging management. October 22. 2016 and 0 Add an action to follow the documentation requirement of FENOC Responses to 10 CFR 54.37, including submittal of records of structural Letters NRC RAIs L-11-153 B.2.39-5 from evaluations to records management.

  • Specify that for each masonry wall, the extent of observed and NRC Letter masonry cracking or degradation of steel edge supports or L-13-160 dated bracing is evaluated to ensure that the current evaluation basis April 5, 2011, is still valid. Corrective action is required ifthe extent of masonry and

Enclosure A L-13-160 Page 15 of 52 Table A-1 Davis-Besse License Renewal Commitments Related LRA Item Commitment Implementation Source Section No./

Number Schedule Comments cracking or steel degradation is sufficient to invalidate the A. 1-1 from evaluation basis. An option is to develop a new evaluation basis NRC Letter that accounts for the degraded condition of the wall dated (i.e., acceptance by further evaluation). March 26, 2013 Specify that for the masonry walls within the scope of license renewal, inspections will be conducted at least once every five years, with provisions for more frequent inspections in areas where significant loss of material or cracking is observed to ensure there is no loss of intended function between inspections.

Enclosure A L-1 3-160 Page 16 of 52 Table A-1 Davis-Besse License Renewal Commitments Related LRA Item Commitment Implementation Source Section No./

Number Schedule Cmet Comments 13 Implement the One-Time Inspection as described in LRA Section Priorto LRA A.1.30 B.2.30. Enhance the One-Time Inspection to: ApR 22, and B.2.30

  • Include enhanced visual (EVT-1 or equivalent) or surface October 22, 2016 and examination (magnetic particle, liquid penetrant), or volumetric (RT or UT) inspections to detect and characterize cracking due FENOC Responses to to cyclic loading of the stainless steel makeup pump casings Letters NRC RAIs (DB-P37-1 and 2) of the Makeup and Purification System. The L-11-153, 3.3.2.2.4.3-1 one-time inspections will provide verification of the absence of L-11-166, from cracking due to cyclic loading. L-11-218, NRC Letter L-11-237, dated L-11-252 May 2, 2011, and L-13-160 Supplemental Question -

Makeup Pump Casing Inspections, and A.1-1 from NRC Letter dated March 26. 2013

Enclosure A L-1 3-160 Page 17 of 52 Table A-1 Davis-Besse License Renewal Commitments Item Numer Commitment Implementation Impleduentto SRelated Section LRA Source No./

Number Schedule Cmet Comments 14 Implement the PWR Reactor Vessel Internals Program as described Priorto LRA A.1.32 in LRA Section B.2.32. Aprand B.2.32 October22, 2016 and FENOC Response to Letter NRC RAI L-13-160 A. 1-1 from NRC Letter dated March 26. 2013 15 In association with the PWR Reactor Vessel Internals Program, a Prior to LRA A.1.32 plant-specific inspection plan for ensuring the implementation of April 22, 2015

  • MRP-227 program guidelines, as amended by the safety evaluation and B.2.32 for MRP-227, and Davis-Besse's responses to the plant-specific and action items, as identified in Section 4.2 of the safety evaluation for FENOC Response to MRP-227, will be submitted for NRC review and approval. Letter NRC RAI
  • NOTE: The inspection plan will be submitted no later than two L-1 1-252 B.2.32-1 from years after issuance of the renewed operating license or two years NRC Letter prior to the beginning of the period of extended operation dated (April 22, 2015), whichever is earlier. July 11,2011 16 Enhance the Reactor Head Closure Studs Program as follows: Priorto LRA A.1.34
  • Select an alternate stable lubricant that is compatible with the "'*" 22, October 22, 2016 and B.2.34

Enclosure A L-1 3-160 Page 18 of 52 Table A-1 Davis-Besse License Renewal Commitments Related LRA Commitment Implementation Source Section No.!

ScheduleCommen

______en-s fastener material and the environment. A specific precaution and against the use of compounds containing sulfur (sulfide),

including molybdenum disulfide (MoS 2), as a lubricant for the FENOC Responses to reactor head closure stud assemblies will be included in the Letters NRC RAIs program. L-11-218 B.2.34-1 from and NRC Letter

  • Preclude the future use of replacement closure stud bolting L-13-160 dated fabricated from material with actual measured yield strength June 20, 2011, greater than or equal to 150 ksi except for use of the existing spare reactor head closure stud bolting. and A.1-1 from NRC Letter dated March 26, 2013 17 Enhance the Reactor Vessel Surveillance Program as follows: Priorto LRA A.1.35 The Capsule Insertion and Withdrawal Schedule for Octbe22-, and B.2.35 Davis-Besse will be revised to schedule testing of the TE1-C October 22. 2016 and capsule.

FENOC Response to Letter NRC RAI L-13-160 A. 1-1 from NRC Letter dated March 26, 2013

Enclosure A L-1 3-160 Page 19 of 52 Table A-1 Davis-Besse License Renewal Commitments Numer Schleduenain, Related LRA Item Commitment Implementation Source Section No./

_u e _ _ Comments 18 Implement the Selective Leaching Inspection as described in LRA Priorto LRA A. 1.36 Section B.2.36. ApF#I22-,-204-7 and B.2.36 October 22, 2016 and FENOC Response to Letter NRC RAI L-13-160 A. 1-1 from NRC Letter dated March 26. 2013 19 Implement the Small Bore Class 1 Piping Inspection as described in Completed within LRA A.1.37 LRA Section B.2.37. the six year and B.2.37 periodprior to April 22, ,27 and October22, 2016 FENOC Responses to Letters NRC RAI L-11-153 B.2.37-2 from and NRC Letter L-13-160 dated April 20, 2011, and A. 1-1 from NRC Letter

Enclosure A L-1 3-160 Page 20 of 52 Table A-1 Davis-Besse License Renewal Commitments Item IRelated LRA Number. Commitment Implementation Source Section No./

Number Schedule Comments dated March 26. 2013 20 Enhance the Structures Monitoring Program to: Priorto LRA A.1.39

  • Include and list the structures within the scope of license and B.2.39 renewal that credit the program for aging management. October22, 2016 a.2 and
  • Include aging effect terminology (e.g., loss of material, cracking, FENOC Responses to change in material properties, and loss of form). Letters NRC RAIs
  • List ACI 349.3R and ANSI/ASCE 11-90 as references and L-I1-153, B.2.39-4, indicate that they provide guidance for the selection of L-11-237, B.2.39-5, parameters monitored or inspected. L-11-292, B.2.39-6 L-11-317, and L-12-455, B.2.39-7
  • Clarify that a "structural component" for inspection includes each from L-13-037 of the component types identified within the scope of license renewal as requiring aging management. and NRC Letter
  • Require the responsible engineer to review site raw water pH, L-13-160 dated chlorides, and sulfates test results prior to the inspection to take April 5, 2011, into account the raw water chemistry for any unusual trends B.2.39-11 and during the period of extended operation. Raw water chemistry 3.5.2.3.12-4 data shall be collected at least once every five years. Data from collection dates shall be staggered from year to year (summer- NRC Letter winter-summer) to account for seasonal variation. dated Perform an inspection for loss of material for carbon steel July 21, 2011, structural components subject to aggressive groundwater. Supplemental

Enclosure A L-1 3-160 Page 21 of 52 Table A-1 Davis-Besse License Renewal Commitments Item Related LRA Commitment Implementation Source Section No./

Number Schedule Comments Require the use of the FENOC Corrective Action Program for RAI B.2.39-11 identified concrete or steel degradation. from telecon

  • Specify that, upon notification that a below-grade structural wall held with the or other in-scope concrete or metal structural component will NRC on become accessible through excavation, a follow-up action is September 13, initiated to the responsible engineer to inspect the exposed 2011, surfaces for age-related degradation. Such inspections will Supplemental include concrete examination using acceptance criteria from RAI OIN-380 NUREG-1801, XI.S6, Program element 6. Degradation found from Region III that exceeds the acceptance criteria will be trended and IP-71002 processed through the FENOC Corrective Action Program. Inspection,
  • List ACI 349.3R, ANSI/ASCE 11-90, and EPRI Report 1007933 B.2.4-1a from as references and indicate that they provide guidance for NRC Letter detection of aging effects. dated
  • Add an action to follow the documentation requirement of November 14, 201Z 10 CFR 54.37, including submittal of records of structural evaluations to records management. B.2. 43-3a
  • Add sufficient acceptance criteria and critical parameters to from trigger an increased level of inspection and initiation of NRC Letter corrective action. Indicate that ACI 349.3R provides acceptable dated guidelines which will be considered in developing acceptance January4, criteria for concrete structural elements, steel liners, joints, and 2013L waterproofing membranes. The acceptance criteria for visual

_and

Enclosure A L-13-160 Page 22 of 52 Table A-1 Davis-Besse License Renewal Commitments

-e Related LRA Itemb Commitment Implementation Source Section No./

Comments inspection of coatings on in-scope concrete structures will be in A. 1-1 from accordance with ACI 349.3R. Plant specific quantitative NRC Letter degradation limits, similar to the three-tier hierarchy acceptance dated criteria from Chapter 5 of ACI 349.3R, will be developed and March 26, 2013 added to the inspection procedure. The Structures Monitoring Program procedure will also be enhanced to reflect the "Periodic Evaluation" criteria defined in chapter 3.3 of ACI 349.3R. The Structures Monitoring Program procedure will include the "prioritization process" to develop a representative sample of areas to inspect in accordance with ACI 349.3R.

Require that personnel performing the structural inspections meet qualifications that are commensurate with ACI 349.3R, "Evaluation of Existing Nuclear Safety-Related Concrete Structures," Chapter 7, "Qualifications of Evaluation Team."

The program procedure will be enhanced by specifying that, for the structures within the scope of license renewal, inspections will be conducted at least once every five years.

  • Conduct a baseline inspection of the structures within the scope of license renewal prior to entering the period of extended operation.
  • Require optical aids, scaling technologies, mechanical lifts, ladders or scaffolding for tall structures or difficult to reach areas of structures to allow visual inspections that meet the guidelines

Enclosure A L-13-160 Page 23 of 52 Table A-1 Davis-Besse License Renewal Commitments Related LRA Item Commitment Implementation Number Numbe Schedule Source SchduleComments Section No.

_ I ___

of Chapter 5 of ACI 349.3R. Select the areas to be inspected in accordance with the guidelines of Chapter 5 of ACI 349.3R to reflect the "Periodic Evaluation" criteria defined in Chapter 3.3 of ACI 349.3R. Include the "prioritization process" in the selection methodology to develop a representative sample of areas to inspect in accordance with ACI 349.3R.

" Monitor elastomeric vibration isolators and structural sealants for cracking, loss of material and hardening.

" Supplement visual inspection of elastomeric vibration isolation elements by feel to detect hardening if the vibration isolation function is suspect.

  • Identify that:

o Loose bolts and nuts and cracked high strength bolts are not acceptable unless accepted by engineering evaluation;

" Structural sealants are acceptable if the observed loss of material, cracking, and hardening will not result in loss of sealing; and,

.o Elastomeric vibration isolation elements are acceptable if there is no loss of material, cracking, or hardening that could lead to the reduction or loss of isolation function.

" Require that high strength (i.e., ASTM A540 Grade B23) structural bolting materials with an actual measured yield

Enclosure A L-1 3-160 Page 24 of 52 Table A-1 Davis-Besse License Renewal Commitments Item Nurber Commitment I

Schedule j Source Related LRA Section No./

Comments strength greater than or equal to 150 kilo-pounds per square inch (ksi) and greater than 1 inch in nominal diameter are monitored for stress corrosion cracking (SCC). Perform periodic visual inspections of susceptible ASTM A540 bolting to identify locations where A540 bolting may be exposed to a potentially corrosive environment for SCC. Complete the initial visual inspections prior to entering the period of extended operation, and perform recurring inspections at an interval not to exceed five years. Perform volumetric examination (i.e., ultrasonic testing) on a sampling basis of bolting exposed to a corrosive environment, as determined by engineering evaluation, to a depth of at least 12 inches.

  • Require that personnel performing ultrasonic testing (UT) examinations of structural bolting have a current ASME Code Section Xl, Appendix VIII, Supplement 8 endorsement.

" Revise the applicable structural bolting specifications to prevent future use of A540 bolting with measured yield strength equal to or exceeding 150 ksi.

21 Enhance the Water Control Structures Inspection to: Priorto A.1.40

and

  • Include parameters monitored and inspected for water control Responses to structures, including the Service Water Discharge Structure, in

Enclosure A L-1 3-160 Page 25 of 52 Table A-1 Davis-Besse License Renewal Commitments 1pi 1Related LRA Commitment Implementation Source Section No./

Comments accordance with applicable inspection elements listed in

  • Letters NRC RAIs Section C.2 of Regulatory Guide 1.127 Revision 1. Descriptions L-11-153, B.2.39-6 from of concrete conditions will conform with the appendix to the L-11-292 NRC Letter American Concrete Institute (ACI) publication, ACl 201. The use and dated of photographs for comparison of previous and present L-13-160 April 5, 2011, conditions will be included as a part of the inspection program. . Rd

" Specify that water control structure periodic inspections are to Supplemental be performed at least once every five years. RAI OIN-379 from Region Ill

  • Add an action to follow the documentation requirement of IP-71002 10 CFR 54.37, including submittal of records of structural Inspection, evaluations to records management.

and

" Add sufficient acceptance criteria and critical parameters to A. 1-1 from trigger an increased level of inspection and initiation of NRC Letter corrective action. Indicate that ACI 349.3R provides acceptable dated guidelines which will be considered in developing acceptance March 26, 2013 criteria for water control structures. Plant-specific quantitative degradation limits, similar to the three-tier hierarchy acceptance criteria from Chapter 5 of ACI 349.3R, will be developed and added to the inspection procedure. The Structures Monitoring Program procedure will also be enhanced to reflect the "Periodic Evaluation" criteria defined in chapter 3.3 of ACI 349.3R. The Structures Monitoring Program procedure will include the "prioritization process" to develop a representative sample of areas to inspect in accordance with ACI 349.3R.

Enclosure A L-1 3-160 Page 26 of 52 Table A-1 Davis-Besse License Renewal Commitments Item Implement ation Related LRA Itumbr Commitment Impeme Source Section No./

Number Schedule Comments 0 Conduct a baseline inspection of the structures within the scope of license renewal prior to entering the period of extended operation.

a Require that loose bolts and nuts, cracked high strength bolts, and degradation of piles and sheeting (sheet pilings) are accepted by engineering evaluation or subject to corrective actions. Engineering evaluation will be documented and based on codes, specifications and standards such as American Institute of Steel Construction (AISC) specifications, Structural Engineering Institute / American Society of Civil Engineers (SEI/ASCE) 11, and codes, specifications or standards referenced in the Davis-Besse current licensing basis.

22 Enclose or otherwise protect the safety-related station ventilation Priorto AlA N/A radiation monitors located in the Turbine Building such that leakage Ar4 22,,2 FENOC Resonseto and spray from surrounding piping systems does not adversely October22, 2016 Letter NRC RAI impact the intended function of the radiation monitors. L-13-160 A. 1-1 from NRC Letter dated March 26, 2013 23 In association with the TLAA for effects of environmentally assisted Priorto LRA A.2.3.4.2 fatigue of the high pressure injection (HPI) nozzle safe end including Apr4i 22, 20iA7 the associated Alloy 82/182 weld (weld that connects the safe end October22, 2016 to the nozzle), replace the HPI nozzle safe end including the and

Enclosure A L-1 3-160 Page 27 of 52 Table A-1 Davis-Besse License Renewal Commitments Related LRA Item ImplementationRead A Iter Number Commitment Sheme Schedule Source Section CmetNo./

Comments associated Alloy 82/182 weld for all four HPI nozzles prior to the FENOC Responses to period of extended operation. Apply the Fatigue Monitoring Program Letters NRC RAIs to evaluate the environmental effects and manage cumulative L-11-107, 4.7.4-1 from fatigue damage for the replacement high pressure injection (HPI) L-11-203, NRC Letter nozzle safe ends and associated welds. L-11-334 dated and April 15, 2011, L-13-160 4.3-18 from NRC Letter dated June 17, 2011, and 4.7.4-1 from NRC Letter dated October 11, 2011, and A.1-1 from NRC Letter dated March 26. 2013

Enclosure A L-1 3-160 Page 28 of 52 Table A-1 Davis-Besse License Renewal Commitments Related LRA ItembCommitment Implementation Source Number Schedule Section No./

Comments 24 Apply the elements of corrective actions, confirmation process, and Priorto LRA A.1 administrative controls in the Quality Assurance Program Manual to Ap, ,22, 2-1-7a the credited aging management programs and activities for safety- October22, 2016 an related and nonsafety-related structures and components FENOC Responses to determined to require aging management for the period of extended Letters NRC RAI 3.0 operation. L-11-166 from and NRC Letter L-13-160 dated May 2, 2011, and A. 1-1 from NRC Letter dated March 26. 2013 25 Enhance the Steam Generator Tube Integrity Program to: Priorto LRA A.1.38

  • Include gross visual inspection of the steam generator tube to "coe 22....... and B.2.38 tubesheet welds coupled with eddy-current inspection (i.e., and bobbin coil or rotating coil examinations) of the tubes to monitor for cracking and degradation of the tube-to-tubesheet welds FENOC Responses to (Alloy 600). Schedule the gross visual inspection of the tube-to- Letters NRC RAI tubesheet welds concurrent with eddy-current inspection of the L-12-001 3.1.2.2.16-3 steam generator tubes that are scheduled in accordance with and from Davis-Besse Technical Specification 5.5.8 such that 100% of L-13-160 NRC Letter the tube-to-tubesheet welds (includes both the hot leg and cold dated

Enclosure A L-13-160 Page 29 of 52 Table A-1 Davis-Besse License Renewal Commitments Related LRA Item Commitment Implementation Source Section No./

Number Schedule Comments leg welds) are inspected at sequential periods of 60 effective full December 27, power months. Perform the gross visual inspection of the tube to 2011, tubesheet welds through remote-visual examination using a and.

manipulator camera to obtain a straight-on view of the weld with A.1-1 from a visual acuity sufficient to detect evidence of degradation. NRC Letter Perform the gross visual inspections using personnel who are dated qualified for American Society of Mechanical Engineers (ASME) March 26, 2013 code visual examination (i.e., are certified VT-1 or VT-3 examiners) and are knowledgeable in the type of tube-to-tubesheet welds being examined (i.e., fillet welds). Define the acceptance criteria for the gross visual inspections and the eddy-current inspections as no indication of cracking or relevant conditions of degradation.

26 Obtain and evaluate for degradation a concrete core bore from two Prior to FENOC Responses to representative inaccessible concrete components of an in-scope December 31, Letters NRC RAIs structure subjected to aggressive groundwater prior to entering the 2014 L-1 1-153, B.2.39-3 from period of extended operation. Based on the results of the initial core L-1 1-237 NRC Letter bore sample, evaluate the need for collection and evaluation of and dated representative concrete core bore samples at additional locations L-1 1-292 April 5, 2011, that may be identified during the period of extended operation as B.2.39-11 from having aggressive groundwater infiltration. Select additional core NRC Letter bore sample locations based on the duration of observed dated aggressive groundwater infiltration. Document identified concrete or July 21, 2011, steel degradation in the FENOC Corrective Action Program.

I I_ I and

Enclosure A L-1 3-160 Page 30 of 52 Table A-1 Davis-Besse License Renewal Commitments

. Related LRA Item Number Commitment Implementation Source SourcedNle Section No./

Comments Supplemental RAI B.2.39-11 from telecon held with the NRC on September 13, 2011 27 DBNPS Surveillance Test Procedure DB-PF-03009, Revision 06, Priorto FENOC Responses to "Containment Vessel and Shielding Building Visual Inspection," Ap,#-22*,2 ,1,7 Letters NRC RAIs Subsection 2.1.2, shall be enhanced to state, "Personnel who October 22, 2016 L-11-134 B.2.1-1 from perform general visual examinations of the exterior surface of the and NRC Letter Containment Vessel and the interior and exterior surfaces of the L-13-160 dated Shield Building shall meet the requirements for a general visual April 5, 2011, examiner in accordance with Nuclear Operating Procedure and NOP-CC-5708, "Written Practice for the Qualification and A. 1-1 from Certification of Nondestructive Examination Personnel." These NRC Letter individuals shall be knowledgeable of the types of conditions which dated may be expected to be identified during the examinations." March 26, 2013 28 Enhance the Fuel Oil Chemistry Program to: Priorto LRA A.1.20 Require that internal surfaces of emergency diesel generator "" ......... and B.2.20 fuel oil storage tanks and day tanks, diesel oil storage tank, October22. 2016 and diesel fire pump day tank, and station blackout diesel generator day tank are periodically drained (at least once every 10 years) FENOC Responses to

Enclosure A L-13-160 Page 31 of 52 Table A-1 Davis-Besse License Renewal Commitments Related LRA Item Commitment Implementation Source Section No./

Number Schedule Comments for cleaning and are visually inspected to detect potential Letters NRC RAIs degradation. If degradation is identified in a diesel fuel tank by L-11-134, B.2.20-1 and Visual inspections, a volumetric inspection is performed. L-11-238 B.2.20-2 from an__d L-13-160 NRC Letter dated Require that biological activity be monitored and trended at least quarterly. April 5, 2011, Cand Supplemental RAI OIN-368 from NRC Region Ill IP-71002 Inspection, and A.1-1 from NRC Letter dated March 26, 2013

Enclosure A L-13-160 Page 32 of 52 Table A-1 Davis-Besse License Renewal Commitments Related LRA Item Commitment Implementation Source Section No./

Number Schedule Comments 29 Enhance the Cranes and Hoists Inspection Program to: Priorto LRA A.1.10

  • Include visual inspections for loose bolts and missing or loose A"'# 22,...... and B.2.10 nuts in crane, monorail and hoist inspection procedures at the October22 2016and same frequency as inspections of rails and structural components. FENOC Responses to Letters NRC RAIs

.L-11-153 B.2.10-2 from and NRC Letter L-13-160 dated April 20, 2011L and A.1-1 from NRC Letter dated March 26. 2013

Enclosure A L-13-160 Page 33 of 52 Table A-1 Davis-Besse License Renewal Commitments Related LRA Item Commitment Implementation Source Section No./

Number Schedule Cmet Comments 30 Enhance the Leak Chase Monitoring Program to: Priorto LRA A.1.25 Include acceptance criteria Inclde citeia such ccetane that measurement uchtha mesurmen of leakage ofleaage ".Apr.22,2 October 22. 2016 and adB22 B.2.25 from any monitoring line exceeding 15 ml/min will be and and documented in the Corrective Action Program for evaluation potential corrective actions. Evaluation will include consideration FENOC Responses to of more frequent monitoring. Letters NRC RAIs L-11-153, B.2.25-5 from Analyze collected leak chase drainage for pH monthly and for L-11-238 NRC Letter iron every six months. The initial acceptance criteria will be 7.0 and dated to 8.0 for pH. The results for iron will be monitored and trended L-13-160 April 5, 2011, to insure that there is no indication of corrosion of the reinforcing bars in the walls or floor of the pool and pits. An acceptance criterion for the iron analyses will be developed after three years B.2.25-7 and of measurements. Analyses that exceed the limits will be B.2.39-10 from documented in the Corrective Action Program. NRC Letter dated Perform the leak chase inspection and cleaning recurring July 21, 2011, preventive maintenance (PM) activity every 18 months.

and Inspect once per year for leakage migrating through the A. 1-1 from accessible outside walls and floor (from the ceiling side) of the NRC Letter pool and pits. Document the inspection results and retain in dated plant records. Indication of leakage through the walls will be March 26, 2013 documented in the Corrective Action Program.

Enclosure A L-1 3-160 Page 34 of 52 Table A-1 Davis-Besse License Renewal Commitments Item Implementation Related Item Commitment Source Section LRA No./

Number Schedule Comments

- 31 Incorporate reference to and the preventative actions of the Priorto FENOC Responses to Research Council for Structural Connections "Specification for Apr, ,22*,)20-7 Letters NRC RAIs Structural Joints Using ASTM A325 or A490 Bolts" into the October22, 2016 L-1 1-153 B.2.39-8 from Davis-Besse specifications and implementing procedures that and NRC Letter address Davis-Besse structural bolting within the scope of L-13-160 dated license renewal. April 5, 2011, and A. 1-1 from NRC Letter dated March 26. 2013 32 Enhance the Closed Cooling Water Chemistry program to: Priorto LRA A.1.8

  • Document the results of periodic inspections of opportunity, Ocoe 22.-201 and B.2.8 performed when components are opened for maintenance, and repair, or surveillance.

FENOC Responses to

  • Ensure that a representative sample of piping and components Letters NRC RAIs will be inspected on a 10-year interval, with the first inspection L-11-153, B.2.8-1 from taking place prior to entering the period of extended operation. L- 11-354 NRC Letter
  • Ensure that component cooling water radiochemistry is sampled and dated on a weekly interval to verify the integrity of the letdown coolers L-13-160 April 20, 2011, and seal return coolers.

Supplemental

Enclosure A L-1 3-160 Page 35 of 52 Table A-1 Davis-Besse License Renewal Commitments e IRelated LRA Item Commitment Implementation Source Section No./

Number ScheduleComments

_____________________ _____________________________ m _____________Comm ents_____

RAI 2.3.3.18-4 from telecom held with the NRC on November 9, 2011, and A. 1-1 from NRC Letter dated March 26, 2013 33 Phase 1 Phase 1: FENOC Responses to Perform the following actions to reduce or mitigate the refueling Action I prior to Letters NRC RAIs canal leaks inside containment: December 31, L- 11-252 B.2.39-9 from

1. Select and implement a leak detection method to locate the 2014 and NRC Letter leakage area. L-13-160 dated July 27, 2011,
2. Evaluate temporary and permanent repair methods to stop Action 2 priorto or significantly reduce the leakage, and implement a DecoMbo 31-, and repair plan. October22, A. I-1 from 2016 NRC Letter dated Phase 2 March 26, 2013 Perform the following actions to evaluate the impact of refueling canal leaks on concrete and reinforcing steel structures.

Enclosure A L-13-160 Page 36 of 52 Table A-1 Davis-Besse License Renewal Commitments Related LRA Item Commitment Implementation Source Section Number Schedule CmetNo./

Comments Discontinue core bores, testing and reinforcing steel inspections Phase 2:

when indications of refueling canal leakage are no longer present: Action 1 prior to

1. Perform a core bore in the south wall of the east-west December 31, section of the core flood pipe tunnel. 2014
a. Assess borated water degradation of the concrete by testing the core bore sample for compressive strength and by petrographic examination, and Action 2 prior to evaluate the results. December 31,
b. Conduct a visual examination of the concrete and 2023 reinforcing steel to identify aging effects (e.g.,

concrete degradation or steel corrosion). Enter identified aging effects into the FENOC Corrective Action 3 -

Action Program and evaluate in accordance with the Ongoing requirements of the current licensing basis Maintenance Rule Program.

2. If leakage from the refueling canal has not been eliminated or resumes by the beginning of the period of extended operation, then evaluate the concrete structures in a manner similar to the way that they were evaluated under Phase 2, Action 1. However, use acceptance criteria from the American Concrete Institute (ACI) Report 349.3R for the evaluation.
3. If leakage from the refueling canal has not been eliminated or resumes during the period of extended operation, then

Enclosure A L-1 3-160 Page 37 of 52 Table A-1 Davis-Besse License Renewal Commitments Item Commitment Implementation Source Related Section LRA No./

Number Schedule Cmet Comments evaluate the concrete structures again in a manner similar to the way that they were evaluated under Phase 2, Action 2.

Perform evaluations every ten years until the end of the period of extended operation.

34 Enhance the Bolting Integrity Program to: Priorto LRA A. 1.4 Select an alternate stable lubricant that is compatible with the O 2 and B.2.4 fastener material and the environment. A specific precaution Octobera22 2016 a against the use of compounds containing sulfur (sulfide),

including molybdenum disulfide (MoS 2 ), as a lubricant will be FENOC Responses to included in the program. Letters NRC RAIs L-11-153 B.2.4-3 from and NRC Letter L-13-160 dated April 20, 2011, and A. 1-1 from NRC Letter dated March 26, 2013 35 Perform the following actions for each of two examinations (Phase 1 Phase 1 prior to FENOC Response to and Phase 2) of the Containment Vessel in the sand pocket region: December 31, Letter NRC RAI

Enclosure A L-13-160 Page 38 of 52 Table A-1 Davis-Besse License Renewal Commitments Item Implementation Related LRA Commitment Source Section No./

Number Schedule Comments previously-identified groundwater in-leakage, and July 21, 2011 o Examine the vessel at a minimum of three vertical grid locations at 12 inches nominal horizontal spacing at each area. Examine the Containment Vessel at a minimum of Phase 2 prior to three elevations: 2025 31, December existing grout-to-1.. approximately 3 inches below the vessel interface in the sand pocket region;

2. at the existing grout-to-vessel interface level in the sand pocket region; and,
3. approximately 3 inches above the existing grout-to-vessel interface in the sand pocket region.

" Compare the ultrasonic test (UT) thickness readings to minimum ASME Code vessel thickness requirements and to the results obtained during previous UT examinations of the Containment Vessel. Determine the need for maintenance or repair of the Containment Vessel based on the results and evaluation of the examinations.

  • Document the results of each of the two examinations in the work order system. Document and evaluate adverse conditions in accordance with the FENOC Corrective Action Program for an evaluation of potential degradation of the steel Containment Vessel thickness over the longer term.

Enclosure A L-13-160 Page 39 of 52 Table A-1 Davis-Besse License Renewal Commitments Item Number IImplementation Commitment Sheme Source Related LRA Section No./

Comments

.36 Perform the following actions related to the Containment Vessel Ongoing FENOC Response to sand pocket region each refueling outage: Letters NRC RAI Li11-252 and B.2.22-5 from NRC Letter

  • Perform visual inspection of 100 percent of the accessible areas LIn1-354 dated of the wetted outer surface of the Containment Vessel in the sand pocket region. July 21, 2011
  • Perform visual inspection of accessible dry areas of the outer and surface of the Containment Vessel in the sand pocket region Supplemental and the areas above the grout-to-steel interface up to RAI B.2.22-5 Elevation 566 feet + 3 inches, - 1 inch. from telecons
  • Perform visual inspection for deterioration (e.g., missing or held with the damaged grout) of accessible grout and the containment NRC on exterior moisture barrier in the sand pocket area. October 5 and November 14, SPerform opportunistic visual inspections of inaccessible areas of 2011 the Containment Vessel in the sand pocket region when such areas are made accessible.

Perform opportunistic visual inspections for deterioration (e.g.,

missing or damaged grout) of inaccessible grout in the sand pocket region when such areas are made accessible.

Inaccessible grout is the grout below the normally-exposed surface of the grout in the sand pocket area.

Address issues of pitting or microbiologically-influenced corrosion (MIC), and degraded grout, moisture barrier or sealant

Enclosure A L-1 3-160 Page 40 of 52 Table A-1 Davis-Besse License Renewal Commitments Item Implementation Related LRA Number Commitment Schedule Source Section No./

Comments identified during the inspections using the FENOC Corrective Action Program.

Sample the water in the sand pocket region when sufficient volumes are available. The number of sampled water volumes will be determined by the number of water volumes observed and the size of those water volumes. Analyze the sample(s) for pH, chlorides, iron and sulfates. Treat or wash (or a combination thereof) the sand pocket area to reduce measured chloride concentrations to less than 250 parts per million (ppm) if the concentration of chlorides in a sample exceeds 250 ppm.

Note: Water samples may be taken at different times during each outage. Engineering judgment may be used to determine the priority of the chemical analyses to be performed if sufficient water is not available in a given sample for all analyses.

Enclosure A L-13-160 Page 41 of 52 Table A-1 Davis-Besse License Renewal Commitments Item Commitment Implementation Source Section LRA Related No./

Number Schedule Cmet Comments 37 Perform and evaluate core bores of the ECCS Pump Room No. 1 Phase 1 prior to FENOC Responses to wall and the Room 109 ceiling. December 31, Letters NRC RAIs 204L-1 1-153 B.2.39-2 from NRC Letter

  • The core bores will be deep enough to expose reinforcing bar in 2014 and the wall and ceiling. The core samples from the core bores will L-1 1-238 dated be examined for signs of corrosion or chemical effects of boric and April 5,d2011 acid on the concrete or reinforcing bars. The examination will include a petrographic examination. The reinforcing steel that and will be exposed for a visual inspection will have corrosion Phase 2 prior to B.2.39-10 from products collected for testing. Degradation identified from the December 31, NRC Letter samples will be entered into the FENOC Corrective Action 2020 dated Program. The core bores will be performed in areas where July 21, 2011 leakage has been observed in the past.
  • The first set of core bores will be performed prior to the end of 2014 (Phase 1).
  • The second set of core bores will be performed prior to the end of 2020 (Phase 2).
  • Further core bores will be conducted, if warranted, based on the evaluation of the results of the inspection and testing of the core bores orif spent fuel pool leakage through the wall or ceiling recurs after the second set of core bores is performed. If spent fuel pool leakage through another wall or ceiling is identified, then core bores will be performed in a manner similar to that stated for the ECCS Pump Room No. 1 wall and the Room 109 ceiling.

Enclosure A L-1 3-160 Page 42 of 52 Table A-1 Davis-Besse License Renewal Commitments Item Implementation Related LRA Number Commitment Schedule Source Section No./

Comments 38 Evaluate the concrete cracking observed on the underside of the Priorto FENOC Responses to spent fuel pool for necessary repairs. Ap, -247

,22), Letters NRC RAIs Note: A core bore of the Room 109 ceiling will be performed by the October 22, 2016 L-11-153, B.2.39-2 from end of 2014 (see license renewal commitment 37). Degradation and N dated identified from the samples will be entered into the FENOC Ln.__1d0 Ated Corrective Action Program. The condition of the concrete and the L-13-160 April 5, 2011, reinforcing steel will be evaluated at that time to assist in &Rd determining what repairs, if any, need to be made to the underside B.2.39-10 from of the spent fuel pool concrete. The criterion for determining the NRC Letter need to repair the cracking will be the continued capability of the dated structures to perform their intended functions during the period of July 21, 2011, extended operation. and A. 1-1 from NRC Letter dated March 26. 2013

Enclosure A L-1 3-160 Page 43 of 52 Table A-1 Davis-Besse License Renewal Commitments

  • Related LRA Item Commitment Implementation Sectio No.

Number ComtetSchedule Source Section No./

Comments 39 Address the potential for borated water degradation of the steel Phase 1 prior to FENOC Responses to containment vessel through the following actions: December 31, Letters NRC RAIs

  • Access the inside surface of the embedded steel containment. A 2014 1-153 L-1and B.2.22-2 from NRC Letter dated core bore will be completed by the end of 2014 (Phase 1). If and 1-3 and necessary, a second core bore will be completed by the end of Phase 2 prior to April 5, 2011, 2020 (Phase 2). Ifthere is evidence of the presence of borated December 31, And water in contact with the steel containment vessel, conduct D.2.62020 fmand non-destructive testing (NDT) to determine what effect, if any, B.2.22-6 from the borated water has had on the steel containment vessel. NRC Letter Based on the results of NDT, perform a study to determine the dated effect through the period of extended operation of any identified July 27, 2011 loss of thickness in the steel containment due to exposure to borated water.

Enclosure A L-1 3-160 Page 44 of 52 Table A-1 Davis-Besse License Renewal Commitments Related LRA Item Commitment Implementation Source Section No./

Number Schedule Cmet Comments 40 Implement the Inspection of Internal Surfaces in Miscellaneous Priorto LRA A.1.41 Piping and Ducting Program as described in LRA Section B.2.41. Ap 22, 207.2.41 October22, 2016 and FENOC Responses to Letters NRC RAIs L-11-153 3.3.2.2.5-1 and and 3.3.2.71-2 from L-13-160 NRC Letter dated April 20, 2011, and A. 1-1 from NRC Letter dated March 26, 2013

Enclosure A L-1 3-160 Page 45 of 52 Table A-1 Davis-Besse License Renewal Commitments Related LRA Iter Number Commitment Implementation Schedule Source EEU Section CmetNo./

Comments 41 Establish a preventive maintenance task to periodically replace the Priorto FENOC Response to flexible connections exposed to fuel oil in the Fuel Oil System. Ap, ,,22,-27 Letters NRC RAIs October22, 2016 L-11-166 3.3.2.3.12-2 and from L-13-160 NRC Letter dated May 2, 2011, and A. 1-1 from NRC Letter dated March 26, 2013 42 Enhance the Fatigue Monitoring Program to: Prior to LRA A.1.16 Evaluate additional plant-specific component locations in the April 22, 2016 and B.2.16 reactor coolant pressure boundary that may be more limiting and than those considered in NUREG/CR-6260. This evaluation will include identification of the most limiting fatigue location FENOC Response to exposed to reactor coolant for each material type (i.e., CS, LAS, Letter NRC RAI SS, and NBA) and that each bounding material/location will be L-1 1-166 B.2.16-2 from evaluated for the effects of the reactor coolant environment on NRC Letter fatigue usage. Nickel based alloy items will be evaluated using dated NUREG/CR-6909. Submit the evaluation to the NRC one year April 20, 2011 prior to the period of extended operation.

Enclosure A L-13-160 Page 46 of 52 Table A-1 Davis-Besse License Renewal Commitments Item IImplementation Related LRA Commitment ImSource Section No./

Number Schedule Comments 43 Ensure that the current station operating experience review process Priorto FENOC Responses to includes future reviews of plant-specific and industry operating Aprt! 22-,207 Letters NRC RAIs experience to confirm the effectiveness of the License Renewal October22, 2016 L-11-188 B. 1.4-1 from aging management programs, to determine the need for programs and NRC Letter to be enhanced, or indicate a need to develop new aging L-13-160 dated management programs. May 19, 2011, and A.1-1 from NRC Letter dated March 26, 2013

Enclosure A L-13-160 Page 47 of 52 Table A-1 Davis-Besse License Renewal Commitments Item Nmer Number Commitment 1Implementation ISheme Shdl Source Related LRA Section No./

Comments 44 Cathodically protect the EDG fuel oil storage tanks (DB-T1 53-1 and Priorto FENOC Responses to DB-T153-2) and the in-scope fuel oil and Service Water buried Apr,-

22ý-0,47, Letters NRC RAIs piping in accordance with NACE SP0169-2007 or October22, 2016 L-11-203, B.2.7-1 from NACE RP0285-2002. L-11-218 NRC Letter and dated L-13-160 April 20, 2011, as modified per telecon with the NRC held on June 7, 2011, and A. 1-1 from NRC Letter dated March 26. 2013

Enclosure A L-13-160 Page 48 of 52 Table A-1 Davis-Besse License Renewal Commitments CImplementation Related LRA Item Number Number Commitment Iledlen Schedule n Source Section Cmet No./

Comments 45 Implement the Nuclear Safety-Related Coatings Program as Priorto FENOC A.1..42 described in LRA Section B.2.42. April 22,-2017 Letters B.2.42 October 22, 2016 L-11-203, L-11-218 and and Responses to L-13-160 NRC RAIs XI.S8-1 from NRC Letter dated April 5, 2011, and A.1-1 from NRC Letter dated March 26, 2013

Enclosure A L-1 3-160 Page 49 of 52 Table A-1 Davis-Besse License Renewal Commitments Item Item TRelated LRAA Impleme ntationRead Commitment S dSource Section No./

rSchedule Comments 46 Implement the Shield Building Monitoring Program as described in Priorto LRA A.1.43 LRA Section B.2.43. Aarn, 20-7 .2.43 October22, 2016 and FENOC Responses to Letters NRC RAIs L-12-028 B.2.16-2 from and NRC Letter L-13-160 dated December 2 7, 2012, and A. 1-1 from NRC Letter dated March 26. 2013

Enclosure A L-13-160 Page 50 of 52 Table A-1 Davis-Besse License Renewal Commitments Item Commitment Implementation Source 1Related Section LRA No./

Number Schedule Comments 47 Enhance the Inservice Inspection (ISI) Program - IWE to: Priorto LRA A.1.22 Include surface examinations to monitor for cracking of Ocoe 22, 2 and B.2.22 containment stainless steel penetration sleeves, dissimilar metal October22. 2016 and welds, bellows, and steel components that are subject to cyclic loading but have no current licensing basis fatigue analysis. FENOC Responses to The inspection sample size will include 10 percent of the Letters NRC RAIs containment penetration population that are subject to cyclic L-11-238, B.2.22-7 from loading but have no current licensing basis fatigue analysis. L-11-292 NRC Letter Penetrations included in the inspection sample will be scheduled and dated for examination in each 10-year ISI interval that occurs during L-13-160 July 21, 2011, the period of extended operation. Should fatigue analyses be aWd performed in the future for the subject containment penetrations, Supplemental the surface examinations will no longer be required. RAI B.2.22-7 from NRC telecons held on September 13 and 16, 2011, and A.1-1 from NRC Letter dated March 26, 2013

Enclosure A L-13-160 Page 51 of 52 Table A-1 Davis-Besse License Renewal Commitments Related LRA Number Commitment Implementation Source Section No./

Number___ .. Schedule Comments Cmet 48 Complete an investigation and needed repairs or modification of the Priorto FENOC Responses to degraded portion of the safety-related intake canal embankment. Ap,,*2* 2,0--7 Letters NRC RAIs October 22, 2016 L-11-238 B.2.40-2 from and NRC Letter L-13-160 dated July 21, 2011, and A. 1-1 from NRC Letter dated March 26. 2013

Enclosure A L-13-160 Page 52 of 52 Table A-1 Davis-Besse License Renewal Commitments Item Implementation Related LRA Number Commitment Schedule Source Section No./

Comments 49 Enhance the Nickel-Alloy Management Program to: Priorto FENOC A. 1.28

  • Provide for inspection of dissimilar metal butt welds in "pr"

...... etters B.2.28 accordance with the requirements of ASME Code Case October22, 2016 L- 11-238 and and N-770-1, "Alternative Examination Requirements and Acceptance Standards for Class 1 PWR Piping and Vessel L-13-160 Responses to Nozzle Butt Welds Fabricated with UNS N06082 or UNS NRC RAIs W86182 Weld Filler Material With or Without Application of B.2.28-1 from Listed Mitigation Activities,Section XI, Division 1," as NRC Letter modified by the Code of Federal Regulations, dated 10 CFR 50.55a(g)(6)(ii)(F). July 27, 2011, and A. 1-1 from NRC Letter dated March 26, 2013

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