ML040200988

App. a - Commitment Listing Table

ML040200988
Person / Time
Site:	Robinson
Issue date:	01/20/2004
From:	Mitra S Office of Nuclear Reactor Regulation
To:	Moyer J Carolina Power & Light Co
Mitra, SK, NRR/DRIP/RLEP, 415-2783
Shared Package
ML040200981	List: ML040200983 ML040200984 ML040200985 ML040200986 ML040200987 ML040200988 ML040200989 ML040200990 ML040200991
References
Download: ML040200988 (24)

Text

Appendix A: Commitment Listing During the review of the RNP LRA by the NRC staff, the applicant made commitments to provide aging management programs (AMPs) to manage aging effects of structures and components (SCs) prior to the period of extended operation. The following table lists these commitments, along with the implementation schedule and the source of the commitment.

ITEM COMMITMENT UPDATED IMPLEMENTA- SOURCE NUMBER FINAL SAFETY TION ANALYSIS SCHEDULE REPORT (UFSAR)

SUPPLEMENT LOCATION

1. Quality Quality Assurance Program. Existing program is credited. A.3.1 Assurance See note below.

Program

2. 10 CFR Upon issuance of the renewed license, guidance will be A.3.1 Following Request for 54.37(b) incorporated into administrative control procedures that issuance of Additional Require- manage the RNP configuration control process to ensure renewed license Information ments that the requirements of 10 CFR 54.37(b) are met. (RAI) 2.1.1-2 A-1

3. NUREG- Prior to the period of extended operation, a statement will A.3.1 Prior to the RAI B.1-1 1801 GALL be incorporated into the UFSAR Supplement description of period of Report the programs to document consistency of RNP AMP with extended programs defined in NUREG-1801, Generic Aging operation Lessons Learned (GALL) Report. For RNP programs that are consistent with NUREG-1801, the program description will be revised to state This program is consistent with the corresponding program described in the GALL Report.

4. ASME ASME Section XI, Subsection IWB, IWC, and IWD A.3.1.1 Section XI, Program. Existing program is credited. No changes Subsection required. See note below.

IWB, IWC, and IWD Program

5. Water Water Chemistry Program. Existing program is credited. A.3.1.2 Chemistry No changes required. See note below.

Program

6. Reactor Reactor Head Closure Studs Program. Existing program is A.3.1.3 Head credited. No changes required. See note below.

Closure Studs Program

7. Steam Steam Generator Tube Integrity Program. Existing A.3.1.4 Generator program is credited. No changes required. See note below.

Tube Integrity Program A-2

8. Closed- Closed-Cycle Cooling Water System Program. Existing A.3.1.5 Cycle program is credited. No changes required. See note below.

Cooling Water System Program

9. ASME ASME Section XI, Subsection IWF Program. Existing A.3.1.6 Section XI, program is credited. No changes required. See note below.

Subsection IWF Program

10. 10 CFR 50, Appendix J Program. Existing program is A.3.1.7 10 CFR 50, credited. See note below.

Appendix J Program

11. Flux Flux Thimble Eddy Current Inspection Program. Existing A.3.1.8 Thimble program is credited. See note below.

Eddy Current Inspection Program

12. Fire The Fire Protection Program will be enhanced to note that A.3.1.9 Prior to the LRA, Protection concrete surface inspections performed under structures period of Appendix B, Program monitoring procedures are credited for inspection of fire extended Section B.3.1 barrier walls, ceilings, and floors. operation A-3

13. Boric The scope of the Boric Acid Corrosion Program will be A.3.1.10 Prior to the LRA, Acid expanded to (1) ensure that the mechanical, structural, and period of Appendix B, Corrosion electrical components in scope for license renewal are extended Section B.3.2 Program addressed and (2) identify additional areas in which operation components are susceptible to exposure from boric acid.

14. Flow- The Flow-Accelerated Corrosion Program will be modified A.3.1.11 Prior to the LRA, Acceler- to (1) include additional components potentially susceptible period of Appendix B, ated to flow-accelerated corrosion and/or erosion, and (2) clarify extended Section B.3.3 Corrosion when condition reports shall be initiated. operation Program

15. Bolting The following will be implemented: (1) administrative A.3.1.12 Prior to the LRA, Integrity controls for bolting will be modified to prohibit the use of period of Appendix B, Program MoS2 compounds in high-strength bolting applications, and extended Section B.3.4 (2) an inspection and evaluation will be performed on operation high-strength bolting used on one motor-operated valve to determine susceptibility for cracking.

16. Open- An activity will be scheduled in the site Preventive A.3.1.13 Prior to the LRA, Cycle Maintenance Program to replace cooling coils in the period of Appendix B, Cooling emergency core cooling system room coolers on a extended Section B.3.5 Water prescribed frequency. operation System Program A-4

17. Administrative controls for inspection of overhead heavy A.3.1.14 Prior to the LRA, Inspection load and light load handling will be enhanced to (1) include period of Appendix B, of requirements for inspecting the turbine gantry crane in extended Section B.3.6 Overhead addition to the other cranes that require inspection, (2) operation Heavy Load note that cranes are to be inspected using the attribute RAI B.3.6-2 and Light inspection checklist for structures, and (3) revise the Load attribute inspection checklist for structures to include GALL Handling terminology such as wear.

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18. Fire The Fire Water System Program will be modified to A.3.1.15 As noted in the LRA, Water includeFire Protection Sprinkler Systems commitment Appendix B, System (1) For sprinkler heads in service for 50 years, either Section B.3.7 Program sprinkler head replacement or sampling/field service testing of heads in accordance with National Fire CP&L letter to Protection Association (NFPA) 25 requirements based on NRC, RNP-the inservice date of the affected systems, and (2) prior to RA/02-0159:

the period of extended operation, either full flow testing of Supplement to portions of fire protection wet pipe sprinkler systems Application for through the system cross mains, which are not routinely Renewal of subject to flow, at the greatest flow and pressure allowed Operating by the design of the systems or, alternatively, inspections License, dated or ultrasonic (UT) testing of a representative sample of October 23, these systems. Results from initial tests or inspections, 2002 reflecting 40 years of service, will be used to determine the scope and subsequent test/inspection intervals. The intervals are not expected to exceed 10 years.

Fire Protection Suppression Piping Prior to the period of extended operation, UT examination on a representative sampling of the above ground fire protection piping normally containing water will be performed. Each sampling will include different sections of piping. Alternatively, internal inspections may be conducted on a representative sampling of these piping systems. Results from initial tests or inspections, reflecting 40 years of service, will be used to determine the scope and subsequent test/inspection intervals. The intervals are not expected to exceed 10 years.

Halon/Carbon Dioxide Fire Suppression Systems The NRC staff guidance with respect to halon/carbon dioxide fire suppression systems will be implemented prior to the period of extended operation. The guidance is documented in a letter from C. Grimes (NRC) to A. Nelson A-6

of Concerned Scientists) Proposed Staff Guidance on Aging Management of Fire Protection Systems for License Renewal, January 28, 2002.

19. Buried A review will be performed to ascertain the need to update, A.3.1.16 Prior to the LRA, Piping and as necessary, administrative controls for the Buried Piping period of Appendix B, Tanks and Tanks Surveillance Program to ensure consistency extended Section B.3.8 Surveil- with National Association of Corrosion Engineers (NACE) operation lance Standard RP-0169-96 regarding acceptance criteria for the Program cathodic protection system, and additional leak testing provisions for underground piping will be incorporated.

20. Above Administrative controls for the Above Ground Carbon Steel A.3.1.17 Prior to the LRA, Ground Tanks Program will be revised to indicate that the external period of Appendix B, Carbon surfaces of the fuel oil tanks are to be inspected extended Section B.3.9 Steel Tanks periodically and to incorporate corrective action operation Program requirements.

21. Fuel Oil Administrative controls for the Fuel Oil Chemistry Program A.3.1.18 Prior to the LRA, Chemistry will be enhanced to (1) improve sampling and de-watering period of Appendix B, Program of selected storage tanks, (2) formalize existing practices extended Section B.3.10 for periodically draining and filling the diesel fuel oil storage operation tank, (3) formalize bacteria testing for fuel oil samples from various tanks, and (4) incorporate quarterly trending of fuel oil chemistry parameters.

A-7

22. Reactor Reactor Vessel Surveillance Program administrative A.3.1.19 Prior to the LRA, Vessel controls will be revised to require surveillance test samples period of Appendix B, Surveil- to be stored in lieu of optional disposal. extended Section B.3.11 lance operation Program

23. Buried The Buried Piping and Tanks Inspection Program will be A.3.1.20 Prior to the LRA, Piping and enhanced to (1) require that an appropriate as-found pipe period of Appendix B, Tanks coating and material condition inspection is performed extended Section B.3.12 Inspection whenever buried piping within the scope of this program is operation Program exposed, (2) add precautions to ensure backfill with material that is free of gravel or other sharp or hard material that can damage the coating, (3) require that the coating inspection be performed by qualified personnel to assess its condition, and (4) require that a coating engineer assist in evaluation of any coating degradation noted during the inspection.

24. ASME ASME Boiler & Pressure Vessel Code,Section XI, A.3.1.21 Prior to the LRA,Section XI, Subsection IWE Program administrative controls will be period of Appendix B, Subsection enhanced to (1) specify the requirements for conducting extended Section B.3.13 IWE reexaminations, and (2) document that repairs meet the operation Program specified acceptance standards.

A-8

25. ASME ASME Boiler & Pressure Vessel Code,Section XI, A.3.1.22 Prior to the LRA,Section XI, Subsection IWL Program enhancements will be made to period of Appendix B, Subsection require supervisors to notify civil/structural design extended Section B.3.14 IWL engineering of the location and extent of proposed operation Program excavations of foundation concrete, to require inspection of CP&L letter to below-grade concrete when excavated for any reason to NRC, RNP-monitor for potential effects and to inspect above-grade RA/02-0159:

accessible concrete, and include trending requirements for Supplement to structures based on aggressive ground water. Application for Renewal of Operating License, dated October 23, 2002 Confirmatory Item 3.5-1 A-9

26. Structures Monitoring Program administrative controls will A.3.1.23 Prior to the LRA, Structures be enhanced to (1) include buildings and structures and period of Appendix B, Monitoring associated acceptance criteria in scope for license renewal extended Section B.3.15 Program but outside the scope of the Maintenance Rule, (2) identify operation interfaces between structures monitoring inspections of CP&L letter to concrete surfaces and the Fire Protection Program NRC, RNP-requirements for barriers, (3) state clearly the boundary RA/02-0159:

definition between systems and structures, (4) revise Supplement to administrative controls to provide inspection criteria for Application for portions of systems covered by structures monitoring and Renewal of require corrective action(s) to be initiated for unacceptable Operating inspection attributes, (5) expand system walkdown License, dated inspection criteria to include observation of adjacent October 23, components, (6) inspect above-grade accessible concrete, 2002 and (7) revise personnel responsibilities to include providing assistance in evaluating structural deficiencies when requested by the responsible engineer, inspecting excavated concrete to monitor for potential aging effects, and notifying civil/structural design engineering of the location and extent of proposed excavations, and (8) include trending requirements for structures based on aggressive ground water and lake water.

Confirmatory Item 3.5-1 A-10

27. Dam To enhance the Dam Inspection Program, the system A.3.1.24 Prior to the LRA, Inspection monitoring administrative controls will be revised to period of Appendix B, Program (1) identify the Recommended Guidelines for Safety extended Section B.3.16 Inspection of Dams as the required management program operation document for the dam, (2) require the responsible system CP&L letter to engineer to review the inspection report and initiate NRC, RNP-corrective actions for any unacceptable attributes, RA/02-0159:

(3) include Recommended Guidelines for Safety Supplement to Inspections of Dams as the applicable inspection Application for guidance in the inspection procedure for RNP, (4) inspect Renewal of above-grade accessible concrete, (5) inspect submerged Operating spillway concrete on a frequency not to exceed (10) ten License, dated years and (6) include trending requirements for structures October 23, based on aggressive ground water and lake water.. 2002 Confirmatory Item 3.5-1

28. Systems Monitoring Program administrative controls will be A.3.1.25 Prior to the LRA, Systems enhanced to (1) include aging effects identified in the aging period of Appendix B, Monitoring management reviews (AMRs), (2) identify inspection extended Section B.3.17 Program criteria in checklist form, (3) include guidance for operation inspecting connected piping/components, (4) require that RAI B.3.17-1 the extent of degradation be recorded and that appropriate corrective action(s) be taken, (5) add a section specifically addressing corrective actions, and (6) ensure Loss of Material due to Wear is specifically included as an aging effect/mechanism identified in the system walkdown checklist.

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29. Preventive Maintenance Program administrative controls A.3.1.26 Prior to the LRA, Preventive will be enhanced to (1) include aging effects/mechanisms period of Appendix B, Main- identified in the AMRs and (2) incorporate specific aging extended Section B.3.18 tenance management activities identified in the AMRs into the operation Program program.

30. Metal The Fatigue Monitoring Program load/unload transient limit A.3.1.27 Prior to the LRA, Fatigue of will be reduced to provide the margin needed for period of Appendix B, Reactor consideration of reactor water environmental effects. extended Section B.3.19 Coolant operation Pressure Boundary (Fatigue Monitoring Program)

A-12

31. Nickel- The Nickel-Alloy Nozzles and Penetrations Program is a A.3.1.28 As noted in the LRA, Alloy new program that will incorporate the following: commitment Appendix B, Nozzles (1) evaluations of indications will be performed under the Section B.4.1 and ASME Boiler & Pressure Vessel Code,Section XI Penetra- program, (2) corrective actions for augmented inspections RAI B.4.1-1 tions will be performed in accordance with repair and Program replacement procedures equivalent to those requirements RNP-RA/03-in ASME Boiler & Pressure Vessel Code,Section XI, (3) 0154 RNP will maintain its involvement in industry initiatives and will systematically assess for implementation applicable programmatic enhancements, that are agreed upon between the NRC and the nuclear power industry to monitor for, detect, evaluate, and correct cracking in the vessel head penetration (VHP) nozzles, specifically as the actions relate to ensuring the integrity of VHP nozzles in the RNP upper reactor vessel head during the extended period of operation, and (4) RNP will submit, for review and approval, its inspection plan for the Nickel-Alloy Nozzles and Penetrations Program, as it will be implemented from the applicants participation in industry initiatives, prior to July 31, 2009.

Revised commitment A-13

32. Thermal The Thermal Aging Embrittlement and Cast Austenitic A.3.1.29 Prior to the LRA, Aging Stainless Steel (CASS) Program is a new program applied period of Appendix B, Embrittle- to CASS components within Class 1 boundaries of the extended Section B.4.2 ment and reactor coolant system and connected systems where operation Cast operating temperature exceeds the threshold criterion.

Austenitic Stainless Steel (CASS)

Program A-14

33. The Pressurized Water Reactor (PWR) Vessel Internals A.3.1.30 As noted in the LRA, Pressurized Program is a new program that will incorporate the commitment Appendix B, Water following(1) RNP will continue to participate in industry Section B.4.3 Reactor programs to investigate aging effects and determine the Vessel appropriate AMP activities to address baffle and former RAI B.4.3-2 Internals assembly issues, and to address change in dimensions Program due to void swelling, (2) as Westinghouse Owners Group and Electric Power Research Institute MRP research projects are completed, RNP will evaluate the results and factor them into the PWR Vessel Internals Program as appropriate, and (3) RNP will implement an augmented inspection during the license renewal term. Augmented inspections, based on required program enhancements resulting from industry programs, will become part of the ASME Boiler & Pressure Vessel Code,Section XI program. Corrective actions for augmented inspections will be developed using repair and replacement procedures equivalent to those requirements in ASME Boiler &

Pressure Vessel Code,Section XI. RNP will submit, for review and approval, its inspection plan for the PWR Vessel Internals Program, as it will be implemented from the applicants participation in industry initiatives, 24 months prior to the augmented inspection.

A-15

34. One- One-Time Inspection Program activities consist of A.3.1.31 Prior to the LRA, Time inspections of the following. period of Appendix B, Inspection (1) The AMP determined that an inspection of CCW heat extended Section B.4.4 Program exchanger tubing would be prudent to assure that operation potential degradation due to erosion was managed. RAI 3.5.1-1 (2) Miscellaneous piping in steam and power conversion systems protected by the Water Chemistry Program will RAI B.3.10-6 be inspected. The One-Time Inspection Program will be used to select representative inspection locations.

(3) The small bore reactor coolant system and connected piping will be inspected to verify effectiveness of the Water Chemistry Program. Components to be examined will be selected based on accessibility, exposure levels, nondestructive examination (NDE) techniques, and locations identified in NRC Information Notice 97-46.

(4) Emergency diesel generator exhaust silencers. Open Item (5) Certain inaccessible areas of the containment liner 2.3.1.6-1 plate and containment structure moisture barrier are required to be inspected to determine their material condition.

(6) The diesel fire pump fuel oil tank.

(7) Steam Generator feed ring/J-nozzles.

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35. The Selective Leaching of Materials Program is a new A.3.1.32 Prior to the LRA, Selective program to determine the properties of selected period of Appendix B, Leaching of components that may be susceptible to selective leaching. extended Section B.4.5 Materials The program will ascertain whether loss of material is operation Program occurring and whether the process will affect the ability of the components to perform their intended function for the period of extended operation.

36. Non- The Non-Environmentally Qualified Insulated Cables and A.3.1.33 As noted in the LRA, Environ- Connections Program is a new program and involves commitment Appendix B, mentally inspecting accessible power and instrument and control Section B.4.6 Qualified cables at least once every 10 years. The technical basis Prior to the Insulated for selecting a sample of cables to be inspected will be period of RAI 3.6.1-2 Cables and defined prior to the period of extended operation. The extended Connec- sample locations will consider the location of cables inside operation B4.6-3 tions and outside containment, as well as any known adverse Program localized environments. Confirmatory Item 3.6.2.3.1.2-1 A-17

37. Aging The Aging Management Program for Non-EQ Electrical A.3.1.34 As noted in the RAI 3.6.1-2 Manage- Cables Used in Instrumentation Circuits is a new program commitment ment that uses calibration or surveillance testing programs to RAI B.4.6-3 Program for identify the potential existence of aging degradation of Prior to the Non-EQ cables. This program applies to the cables used in period of Electrical containment high-range radiation monitoring extended Cables instrumentation circuits. The program has a 10-year operation Used in frequency.

Instru-mentation Circuits

38. Aging The Aging Management Program for Neutron Flux A.3.1.35 As noted in the RAI 3.6.1-2 Manage- Instrumentation Circuits is a new program that will employ commitment ment insulation resistance or other testing to identify the RAI B.4.6.-3 Program for potential existence of aging degradation of cables in Prior to the Neutron neutron monitoring circuits. The program has a 10-year period of Flux Instru- frequency. extended mentation operation Circuits A-18

39. Aging The Aging Management Program for Fuse Holders is a A.3.1.36 As noted in the RAI 2.5.2-1 Manage- new program applicable to fuse holders located outside of commitment ment active devices. The program utilizes thermography or Program for other appropriate test methods to identify the potential Prior to the Fuse existence of aging degradation. The program has a 10- period of Holders year frequency. extended operation

40. Aging The Aging Management Program for Bus Duct is a new A.3.1.37 As noted in the RAI 2.5.2-2 Manage- program for inspecting bus duct for signs of cracks, commitment ment corrosion, foreign debris, excessive dust buildup or Program for discoloration which may indicate overheating, loosening of Prior to the Bus Duct bolted connections, or water intrusion. The program period of applies to the iso-phase bus duct as well as to all extended nonsegregated 4.16 kV and 480 V bus duct within the operation scope of license renewal. The program has a 10-year frequency.

41. Environ- Credit is taken for existing Environmental Qualification A.3.1.38 As noted in the RAI 4.4-2 mental (EQ) of Electric Equipment activities. EQ is an ongoing commitment Quali- program. EQ packages are undergoing revision to RAI 4.4.1-2 fication of incorporate increased radiation values resulting from Electric power uprate and will be updated prior to the end of the Equipment current license term.

Program A-19

42. Time- Time-Limited Aging Analysis (TLAA) - Reactor Vessel A.3.2.1 Limited Neutron Embrittlement. Existing program is credited. See Aging note below.

Analysis (TLAA) -

Reactor Vessel Neutron Embrittle-ment A-20

43. TLAA - Based upon the most recent fatigue analysis performed to A.3.2.2 As noted in the LRA, Metal date for the three auxiliary feedwater (AFW)-to-feedwater commitment Section 4.3 Fatigue (FW) line connections downstream of the steam-driven pump, transient limits have been reduced in the RNP RAI 4.3-2 Fatigue Monitoring Program. These reduced limits are based upon inputs used in the analysis and are more RAI 4.3-7 conservative than the original limits. The reduced limits will remain in effect until the connections are further analyzed, RAI 4.3-10 repaired, or replaced to assure the connections remain within their design basis through the period of extended operation.

Based upon the fatigue analyses performed to consider environmentally assisted fatigue, the load/unload transient limit has been reduced in the RNP Fatigue Monitoring Program. The reduced limits are based upon inputs used in the analyses and will remain in effect permanently unless the components are reanalyzed. The reduced time limit is not expected to be approached through the period of extended operation, because the original limit was established at a high value to account for load following, which is not necessary at RNP.

Further action is required for management of environmental fatigue of the surge line for the period of extended operation. Therefore, fatigue of the surge line will be managed using one or more of the following options.

1. Further refinement of the fatigue analyses to maintain the EAF-adjusted CUF below 1.0.

2. Repair of the affected locations.

3. Replacement of the affected locations.

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reviewed and approved by the NRC. This includes periodic surface and volumetric examinations of the limiting locations at inspection intervals to be determined by a method accepted by the NRC. If this option is selected, the scope, qualification, method, and frequency will be provided to the NRC for review and approval prior to the period of extended operation.

44. TLAA - In accordance with the requirements of the Environmental A.3.2.3 As noted in the LRA, Sections Environ- Qualification Program, any component that is not qualified commitment 4.4 and mental through the period of extended operation will be 4.4.1.3 Quali- refurbished or replaced prior to exceeding its qualified life.

fication Prior to the period of extended operation, certain motor-operated valve actuators will either be reevaluated to demonstrate acceptable wear-cycle qualifications or they will be replaced.

A-22

45. TLAA - To provide additional assurance of the tendons design A.3.2.4 As noted in RAI 4.5-2 Contain- capacity, testing (at integrated leak rate test pressure) commitment ment similar to the Structural Integrity Test performed in 1992 Tendon will be scheduled to coincide with Appendix J containment Loss of integrated leak rate testing conducted during the period of Prestress extended operation (required frequency in accordance with 10 CFR 50, Appendix J). The monitoring criteria for these tests will be limited to deformations and cracking associated with the vertical prestressed tendons, and will not include radial monitoring. Guidelines for performing the IWL examinations for these tests will include additional emphasis on looking for a pattern of horizontal cracks, and additional cracking in the discontinuity areas.

46. TLAA - Information from the response to RAI 4.5-1 will be A.3.2.4 Prior to the RAI 4.5-3 Contain- incorporated into Section 3.8.1.4.7 of the UFSAR. This will period of ment include initial average prestressing force, losses, and final extended Tendon average prestressing force at 50 and 60 years as operation Loss of discussed in the response to RAI 4.5-1. This commitment Prestress supersedes the proposed changes shown on LRA Page A-6 for UFSAR Section 3.8.1.4.7.

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47. TLAA - Prior to the period of extended operation, the Boraflex A.3.2.8 Prior to the LRA, Section Aging of Monitoring Program will be modified to (1) include neutron period of 4.6.4 Boraflex in attenuation testing, called blackness testing, to determine extended Spent Fuel gap formation in Boraflex panels; (2) include trending the operation RNP-RA/03-Pool results for silica levels by using the EPRI RACKLIFE 0154 predictive code or equivalent, and (3) include measurements of boron areal density by techniques such as the BADGER device, RNP has requested, by letter dated May 28, 2003, Serial: RNP-RA/03-0038, an amendment to the Technical Specifications to eliminate the need to credit Boraflex neutron absorbing material for reactivity control. The Boraflex Monitoring Program will be eliminated upon NRC approval of this amendment or upon implementation of another option(such as re-racking the spent fuel pool) which eliminates the need to credit Boraflex for reactivity control.

Revised commitment NOTE: Not listed in this table. Consistent with guidance provided by letter from Pao-Tsin Kuo (NRC) to Alan Nelson (NEI) and David Lochbaum (Union of Concerned Scientists), CONSOLIDATED LIST OF COMMITMENTS FOR LICENSE RENEWAL, dated December 16, 2002.

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