ML070440127

License Renewal Application, Amendment 5

ML070440127
Person / Time
Site:	FitzPatrick
Issue date:	02/01/2007
From:	Peter Dietrich Entergy Nuclear Northeast, Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
JAEP-07-0019
Download: ML070440127 (36)

Text

Entergy Entergy Nuclear Northeast Entergy Nuclear Operations, Inc.James A. Fitzpatrick NPP P.O. Box 110 Lycoming, NY 13093 Tel 315 349 6024 Fax 315 349 6480 February 01, 2007 JAFP-07-0019 Pete Dietrich Site Vice President

-JAF U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001

REFERENCES:

1. Letter, Entergy to USNRC, "James A. FitzPatrick Nuclear Power Plant, Docket No. 50-333, License No. DPR-59, License Renewal Application," JAFP-06-0109, dated July 31, 2006 2. Letter, Entergy to USNRC, "License Renewal Application for James A.FitzPatrick Nuclear Power Plant (TAC No. MD2667)," JAFP-06-0167, dated December 6, 2006

SUBJECT:

Entergy Nuclear Operations, Inc.James A. FitzPatrick Nuclear Power Plant Docket No. 50-333, License No. DPR-59 License Renewal Application, Amendment 5

Dear Sir or Madam:

On July 31, 2006, Entergy Nuclear Operations, Inc. submitted the License Renewal Application (LRA) for the James A. FitzPatrick Nuclear Power Plant (JAFNPP) as indicated by Reference

1. The LRA Aging Management Program (AMP) audit was conducted the week of November 13, 2006 and the LRA Aging Management Review (AMR) audit was conducted the week of December 11, 2006. Based on the results of these audits, .Regulatory Commitments, the LRA, and previous RAI responses provided to the NRC in Reference 2 required revision.

Attachments 1, 2, and 3 provide the information, respectively.

Should you have any questions concerning this submittal, please contact Mr. Jim Costedio at (315) 349-6358.I declare under penalty of perjury that the foregoing is true and correct. Executed on the I day of February, 2007.Sincerely, C.~ A~ c- -. '-PETE DIETRICH SITE VICE PRESIDENT PD/cf A42y February 01, 2007 JAFP-07-0019 Page 2 of 2 Attachments 1, 2, and 3 cc: Mr. N.B. (Tommy) Le, Senior Project Manager License Renewal Branch B Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop 0-11-F1 Washington, DC 20555 Mr. Samuel J. Collins, Administrator Region I U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 NRC Resident Inspector U. S. Nuclear Regulatory Commission James A. FitzPatrick Nuclear Power Plant P.O. Box 136 Lycoming, NY 13093 Mr. John P. Boska, Project Manager Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop O-8-C2 Washington, DC 20555 Mr. Paul Eddy New York State Department of Public Service 3 Empire State Plaza, 1 0 th Floor Albany, NY 12223 Mr. Peter R. Smith, President NYSERDA 17 Columbia Circle Albany, NY 12203-6399 JAFP-07-0019 Docket No. 50-333 Attachment 1 James A. FitzPatrick Nuclear Power Plant License Renewal Application

-Amendment 5 JAFNPP License Renewal Commitment List, Revision 1 JAFNPP Revised List of Regulatory Commitments The following table identifies those actions committed to by Entergy in this document.

Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments.

1. COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION NO. /COMMENTS 1 Implement the Buried Piping and Tanks Inspection October 17, 2014 JAFP-06-0109 A.2.1.1 Program as described in LRA Section B.1.1. B.1.1 2 Enhance the BWR CRD Return Line Nozzle Program to October 17, 2014 JAFP-06-0109 A.2.1.2 examine the CRDRL nozzle-to-vessel weld and the B.1.2 CRDRL nozzle inside radius section per Section XI Table IWB-2500-1 Category B-D Items B3.90 and B3.100.3 Enhance the Diesel Fuel Monitoring Program to include October 17, 2014 JAFP-06-0109 A.2.1.9 periodic draining, cleaning, visual inspections, and B.1.9 ultrasonic measurement of the bottom surfaces of the fire pump diesel fuel oil tanks, EDG day tanks, and EDG fuel oil storage tanks to ensure that significant degradation is not occurring.

Enhance the Diesel Fuel Monitoring Program to specify acceptance criteria for UT measurements of diesel generator fuel storage tanks within the scope of this I program.4 Enhance the External Surfaces Monitoring Program October 17, 2014 JAFP-06-0109 A.2.1.11 guidance documents to include periodic inspections of B.1.11 systems in scope and subject to aging management review for license renewal in accordance with 10 CFR-54.4(a)(1) and (a)(3). Inspections shall include areas surrounding the subject systems to identify hazards to those systems. Inspections of nearby systems that could impact the subject systems will include SSCs that are in scope and subject to aging management review for license renewal in accordance with 10 CFR 54.4(a)(2).

5 Enhance the Fire Protection Program to inspect fire October 17, 2014 JAFP-06-0109 A.2.1.13 barrier walls, ceilings, and floors at least once every B.1.13.1 refueling outage. Inspection results will be acceptable if there are no visual indications of degradation such as cracks, holes, spalling, or gouges.Enhance the Fire Protection Program to inspect at least One seal of each type every 24 months. I Attachment 1 Page 1 of 5 JAFP-07-0019 COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION NO. I COMMENTS 6 Enhance the Fire Water Program to include inspection of October 17, 2014 JAFP-06-0109 A.2.1.14 hose reels for corrosion.

Acceptance criteria will be B.1.13.2 enhanced to verify no significant corrosion.

Enhance Fire Water Program to include visual inspection of spray and sprinkler system internals for evidence of corrosion.

Acceptance criteria will be enhanced to verify no significant corrosion.

Enhance Fire Water Program to include that a sample of sprinkler heads will be inspected using guidance of NFPA 25 (2002 Edition) Section 5.3.1.1.1.

NFPA 25 also contains guidance to repeat sampling every 10 years after initial field service testing.Enhance Fire Water Program to include that wall thickness evaluations of fire water piping will be performed on system components using non-intrusive techniques to identify evidence of loss of material due to corrosion.

These inspections will be performed before the end of the current operating term and at intervals thereafter during the period of extended operation.

Results of the initial evaluations will be used to determine the appropriate inspection interval to ensure aging effects are identified prior to loss of intended function.7 Implement the Heat Exchanger Monitoring Program as October 17, 2014 JAFP-06-0109 A.2.1.16 described in LRA Section B.1.15. B.1.15 8 Implement the Metal-Enclosed Bus Inspection Program October 17, 2014 JAFP-06-0109 A.2.1.19 as described in LRA Section B.1.17. B.1.17 9 Implement the Non-EQ Instrumentation Circuits Review October 17, 2014 JAFP-06-0109 A.2.1.20 Program as described in LRA Section B.1.18. B.1.18 10 Implement the Non-EQ Insulated Cables and October 17, 2014 JAFP-06-0109 A.2.1.21 Connections Program as described in LRA Section B.1.19 B.1.19: 11 Enhance the Oil Analysis Program to periodically sample October 17, 2014 JAFP-06-0109 A.2.1.22 lubricating oil and the insulating oil in the underground B.1.20 oil-filled cable, the security generator, and the fire pump diesel.Enhance the Oil Analysis Program to include viscosity and neutralization number determination of oil samples from components that do not have regular oil changes.Enhance the Oil Analysis Program to include particulate and water content for oil replaced periodically.

12 Implement the One-Time Inspection Program as Will be JAFP-06-0109 A.2.1.23 described in LRA Section B.1.21. implemented within the 10 years prior to B.1.21 October 17, 2014 13 Enhance the Periodic Surveillance and Preventive October 17, 2014 JAFP-06-0109 A.2.1.24 Maintenance Program as necessary to assure that the B.1.22 effects of aging will be managed in accordance with JAF-RPT-05-LRD02.

Attachment 1 Page 2 of 5 JAFP-07-0019 COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION NO. I COMMENTS 14 Enhance the Reactor Vessel Surveillance Program to October 17, 2014 JAFP-06-0109 A.2.1.26 include the data analysis, acceptance criteria, and B.1.24 corrective actions described in LRA Section B.1.24.15 Implement the Selective Leaching Program in October 17, 2014 JAFP-06-0109 A.2.1.27 accordance with the program as described in LRA B. 1.25 / Audit Section B.1.25. Item 443 & 445 16 Enhance the Structures Monitoring Program procedure October 17, 2014 JAFP-06-0109 A.2.1.30 to: B.1.27.2/* specify that manholes, duct banks, underground Audit Item 203 fuel oil tank foundations, manway seals and &287 gaskets, hatch seals and gaskets, underwater concrete in the intake structure, and crane rails and girders are included in the program.* include guidance for performing structural examinations of elastomers and rubber components to identify cracking and change in material properties." include guidance for performing periodic inspections to confirm the absence of aging effects for lubrite surfaces in the torus radial beam seats and for lubrite surfaces in the torus support saddles." perform an engineering evaluation on a periodic basis (at least once every five years) of Audit Item 201.groundwater samples to assess aggressiveness (pH < 5.5, chloride > 500 ppm and Sulfate >1500) of groundwater to concrete.* inspect any inaccessible concrete areas that may be exposed by excavation for any reason, Audit Item 201 or any inaccessible area where observed conditions in accessible areas, which are exposed to-the same environment, show that significant concrete degradation is occurring.

17 Implement the Thermal Aging and Neutron Irradiation October 17, 2014 JAFP-06-0109 A.2.1.31 Embrittlement of Cast Austenitic Stainless Steel (CASS) B.1.28 Program as described in LRA Section B.1.28.18 Enhance the Water Chemistry Control -Auxiliary October 17, 2014 JAFP-06-0109 A.2.1.32 Systems Program to include guidance for sampling the B.1.29.1 control room and relay room chilled water, decay heat removal cooling water, and the security generator jacket I cooling water.19 Enhance the Bolting Integrity Program to include October 17, 2014 JAFP-06-0109 A.2.1.35 guidance from EPRI NP-5769 and EPRI TR-104213.

B.1.30 Enhance the Bolting Integrity Program to clarify that actual yield strength is used in selecting materials for low susceptibility to SCC and to clarify the prohibition on use I of lubricants containing MoS2 for bolting.Attachment 1 Page 3 of 5 JAFP-07-0019

1. COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION NO. /COMMENTS 20 At least 2 years prior to entering the'period of extended October 17, 2012 JAFP-06-0167 4.3.3/Audit operation, for the locations identified in NUREG/CR-6260 Item 317 for BWRs of the JAFNPP vintage, JAFNPP will implement one or more of the following:

(1) Refine the fatigue analyses to determine valid CUFs less than 1 when accounting for the effects of reactor water environment.

This includes applying the appropriate Fen factors to valid CUFs determined in accordance with one of the following.

1. For locations, including NUREG/CR-6260 locations, with existing fatigue analysis valid for the period of extended operation, use the existing CUF to determine the environmentally adjusted CUF.2. More limiting JAFNPP-specific locations with a valid CUF may be added in addition to the NUREG/CR-6260 locations.

3. Representative CUF values from other plants, adjusted to or enveloping the JAFNPP plant specific external loads may be used if demonstrated applicable to JAFNPP.4. An analysis using the NRC-approved ASME code 2001 edition up to and including 2003 addendum, may be performed to determine a valid CUF.The determination of Fen will account for operating time Audit Item 485 with normal water chemistry and operating time with &487 hydrogen water chemistry.

(2) Manage the effects of aging due to fatigue at the affected locations by an inspection program that has been reviewed and approved by the NRC (e.g., periodic non-destructive examination of the affected locations at inspection intervals to be determined by a method acceptable to the NRC).(3) Repair or replace the affected locations before exceeding a CUF of 1.0.Should JAFNPP select the option to manage environmentally assisted fatigue during the period of extended operation, details of the aging management program such as scope, qualification, method, and frequency will be submitted to the NRC at least 2 years prior to the period of extended operation.

21 Enhance the BWR Vessel Internals Program to perform October 17, 2014 JAFP-06-0167 A.2.1.7 and inspections of the core plate rim hold down bolts in B.1.7/Audit accordance with ASME Section XI Table IWB-2500-1, Item 252 Examination Category B-N-2 or in accordance with a future NRC-approved revision of BWRVIP-25 that provides a feasible method of inspection.

22 Enhance the BWR Vessel Internals Program to ensure the effects of aging on the steam dryer are managed in October 17, 2014 JAFP-06-0167 A.2.1.7 and accordance with the guidelines of BWRVIP-139 as B.1 .7/Audit approved by the NRC and accepted by the BWRVIP Item 245 Executive Committee.

Attachment 1 Page 4 of 5 JAFP-07-0019 COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION NO./COMMENTS 23 Appendix A.2.2.7 Core Plate is revised to add that JAFNPP will perform one of the following:

October 17, 2012 JAFP-07-0019 A.2.2.7 Audit Item 483 1. Install core plate wedges prior to the period of extended operation, or, 2. Complete a plant-specific analysis to determine acceptance criteria for continued inspection of core plate rim hold down bolting in accordance with BWRVIP-25 and submit the inspection plan to the NRC two years prior to the period of extended operation for NRC review and approval, or 3. Perform inspection of core plate rim hold down bolts in accordance with ASME Code Section XI or in accordance with an NRC-approved version of BWRVIP-25.24 Implement the Bolted Connections Program as described October 17, 2014 JAFP-07-0019 A.2.1.36 in LRA Section B.1.31.B.1.31 Audit item 296 Attachment 1 Page 5 of 5 JAFP-07-0019 JAFP-07-0019 Docket No. 50-333 Attachment 2 James A. FitzPatrick Nuclear Power Plant License Renewal Application

-Amendment 5 JAFNPP License Renewal Application Changes FITZPATRICK License Renewal Application Changes The following information supplements the previously submitted License Renewal Application:

Audit Item 52/361/363/376:

LRA Appendix B.1.1, Buried Piping and Tanks Inspection Program Add: "If an inspection did not occur, a focused inspection will be performed prior to the period of extended operation." to the Program Description.

Audit Item 57: LRA Section A.2. 1.1, Buried Piping and Tanks Inspection Program Add: "This program will be implemented prior to the period of extended operation." Audit Item 69: LRA Appendix A.2.1.9, Diesel Fuel Monitoring Program Add: "This program will be enhanced to include periodic draining, cleaning, and ultrasonic measurement of the bottom surfaces of the fire pump diesel fuel oil tanks, EDG day tanks, and EDG fuel oil storage tanks. Also, this program will be enhanced to specify acceptance criteria for UT measurements of diesel fuel storage tanks included in this program. These enhancements will be implemented prior to the period of extended operation." Audit Item 83: LRA Appendix A.2.1.23, One-Time Inspection Program Add: "This program will be implemented within the ten years prior to the period of extended operation." Audit Item 90: LRA Appendix A.2.1.24, Periodic Surveillance and Preventative Maintenance Program Add: "This program will be enhanced as necessary to assure that the effects of aging will be managed such that applicable components will continue to perform their intended functions consistent with the current licensing basis. These enhancements will be implemented prior to the period of extended operation." Audit Item 94: Appendix B.1.2, BWR CRD Return Line Nozzle Revise: The enhancement description concerning inspection of Category B-D items is changed from "B3.10 and B3.20" to "B3.90 and B3.100".Audit Item 97/98: Appendix B.1.3, BWR Feedwater Nozzle The phrase "removed all identified feedwater blend radii flaws," is deleted from the Program Description section.Audit Item 115: Appendix B.1.5, BWR Stress Corrosion Cracking Revise: The operating experience section is revised to state as follows: "Ultrasonic examination of four recirculation nozzle safe-end welds, one jet pump instrumentation nozzle safe-end weld and two piping welds (Note that N8-SE-1 and N8-SE-3 welds are piping welds despite nomenclature), seven recirculation system piping welds, and five RHR system piping welds ....." Attachment 2 Page 1 of 23 JAFP-07-0019 FITZPATRICK License Renewal Application Changes Audit Item 143/146/150/153/154:

LRA Appendix B. 1.29.1, Water Chemistry Control -Auxiliary Systems Delete: The following table;Attributes Affected Enhancement

1. Scope of Program Guidance for sampling the control room and 2. Preventive Actions relay room chilled water, decay heat removal 3. Parameters Monitored/Inspected cooling water, and the security generator 6. Acceptance Criteria jacket cooling water will be added to the Water Chemistry Control -Auxiliary Systems Program procedures.

Add: The following table;Attributes Affected Enhancement

1. Scope of Program Guidance for sampling and analysis of the control room and relay room chilled water, decay heat removal cooling water, and the security generator jacket cooling water will be added to the Water Chemistry Control -Auxiliary Systems Program procedures.

Industry recommendations and One-Time Inspection Program results will be considered in determining the parameters to be sampled and the analytical techniques to be used.3. Parameters Monitored/Inspected Guidance for monitoring to control the concentration of corrosive impurities (such as chlorides, sulfates, and dissolved oxygen) to mitigate degradation of structural materials will be developed for control room and relay room chilled, water, decay heat removal cooling water, and security generator jacket cooling water and will be addedý to the Water Chemistry Control -Auxiliary Systems Program procedures.

Industry recommendations and One-Time Inspection Program results will be considered in determining the specific parameters to be sampled.6. Acceptance Criteria Industry standards such as EPRI guidelines along with manufacturer's recommendations will be used to establish the appropriate acceptance criteria for control room and relay room chilled water, decay heat removal cooling water, and security generator jacket cooling water, and these criteria will be added to the Water Chemistry Control -Auxiliary_ Systems Program procedures.

Attachment 2 Page 2 of 23 JAFP-07-0019 FITZPATRICK License Renewal Application Changes Audit Item 145: LRA Appendix B.1.21, One-Time Inspection Program Add: "Combinations of nondestructive examinations (including VT-i-, ultrasonic, and surface techniques) will be performed by qualified personnel following procedures that are consistent with Section XI of ASME B&PV Code and 10CFR50, Appendix B." to the Program Description section.Audit Item 178: LRA Appendix A.2.1.11, External Surfaces Monitoring Add: "The program guidance documents will be enhanced to include periodic inspections of systems in scope and subject to aging management review in accordance with 10 CFR 54.4(a)(1) and (a)(3). Inspections shall include areas surrounding the subject systems to identify hazards to those systems. Inspections of nearby systems that could impact the subject systems will include SSCs that are in scope and subject to aging management review in accordance with 10 CFR 54.4(a)(2).

These enhancements will be implemented prior to the period of extended operation." Audit Item 186: LRA Appendix A.2.1.16, Heat Exchanger Monitoring Program Add: "This program will be implemented prior to the period of extended operation." Audit Item 201: LRA Appendix B.1.27.2, Structures Monitoring The following enhancements are added;Attributes Affected Enhancements Attrbute Afecte Enanceent 4. Detection of Aging Effects Guidance to perform an engineering evaluation of groundwater samples to assess aggressiveness of groundwater to concrete on a periodic basis (at least once every five years) will be added to the Structures Monitoring Program. JAFNPP will obtain samples from a well that is most representative of the ground water surrounding below-grade site structures.

Samples will be monitored for sulfates, pH and chlorides.

4. Detection of Aging Effects Guidance will be added to the Structures Monitoring Program to inspect any inaccessible concrete areas that may be exposed by excavation for any reason.JAFNPP will also inspect inaccessible concrete areas in environments where observed conditions in accessible areas exposed to the same environment indicate that significant concrete degradation is occurring.

Attachment 2 Page 3 of 23 JAFP-07-0019 FITZPATRICK License Renewal Application Changes Audit Item 245: LRA Appendix A.2.1.7 and Appendix B.1.7, BWR Vessel Internals Program Add: "In addition to the scope described in NUREG-1801, JAFNPP Scope also includes the steam dryer: BWRVIP-139 and GE SIL 644 Rev 1 provide guidelines for inspection and evaluation.

JAFNPP follows BWRVIP-139 and GE SIL 644 Rev 1 guidelines." to A.2.1.7 and to B.1.7 Program Description section.Audit Item 252/352/353:

LRA Appendix A.2.1.7 and Appendix B.1.7, BWR Vessel Internals Program Add/Revise: "JAFNPP will perform inspections of the core plate rim hold down bolts in accordance with ASME Section Xl Table IWB-2500-1, Examination Category B-N-2 or in accordance with a future NRC-approved revision of BWRVIP-25 that provides a feasible method of inspection." is added to A.2.1.7 and replaces the existing text in the first table item in the Exceptions to NUREG-1801 section of B.1.7.Audit Item 257: LRA Section B.1.7, BWR Vessel Internals Delete: The following exception and associated exception note 2.1. Scope of Program Jet Pump Assembly 4. Detection of Aging Effects Inspections for inaccessible welds, beam (UT), and scheduled inspections of high ranked welds have been deferred, but the deferrals are technically justified 2 2. Welds at TS-1, TS-3 and TS-4 are inaccessible for inspection.

There is no inspection technique developed to inspect the thermal sleeve welds. However, the BWRVIP/EPRI NDE Center has new plans to develop an inspection capability.

The BWRVIP is also pursuing analyses which may reduce or alleviate inspection of the TS-1 through.TS-4 welds. Inspection is recommended when techniques or accessibility becomes available.

Also, there are other welds mainly along the diffuser lower section where coverage is low due to interference from core shroud gussets, tierods, and others. The BWRVIP is also pursuing an analysis to reduce or alleviate inspection of the adapter welds. A technical justification for inspecting inaccessible jet pump welds, and the deferral of beam UT inspection has been prepared per BWRVIP-94 guidelines.

Finally, several high priority ranked welds in JP-1,2,3, 4, 19 and 20 previously scheduled for inspection in R016, were deferred to R017 (one cycle deferral) with technical justification.

Audit Item 260: LRA Section B.1.13.2 Fire Water System Program Revise the exception to the Fire Water System program related to annual gasket inspections to state: "Gaskets are not subject to aging management review since they are periodically inspected, tested and replaced 3." Revise exception note 3 to state "Gaskets are replaced based on performance or condition monitoring and are excluded from aging management review per Table 2.1-3 of NUREG-1800 Rev. 1".Attachment 2 Page 4 of 23 JAFP-07-0019 FITZPATRICK License Renewal Application Changes Audit Item 262: LRA Section B.1.13.2 Fire Water System Program Revise exception note 2 to state "Fire hoses are replaced based on performance or condition monitoring and are excluded from aging management review per Table 2.1-3 of NUREG-1800 Rev. 1 ".Audit Item 264: LRA Appendix A.2.1.14, Fire Water System Program Add: "This program will be enhanced to include inspection of hose reels for corrosion.

The acceptance criteria will be enhanced to verify no unacceptable signs of degradation.

For sprinkler systems, this program will be enhanced to include visual inspection of spray and sprinkler system internals for evidence of corrosion.

Acceptance criteria will be enhanced for these inspections to verify no unacceptable signs of degradation.

A sample of sprinkler heads will be inspected using guidance of NFPA 25 (2002 Edition) Section 5.3.1.1.1.

This program will be enhanced to include wall thickness evaluations of fire protection piping using non-intrusive techniques (e.g., volumetric testing) to identify evidence of loss of material due to corrosion.

These enhancements will be implemented prior to the period of extended operation." Audit Item 266: LRA Appendix B.1.20, Oil Analysis Program Delete: "an exception and" from the NUREG-1801 Consistency section.Replace: All verbage, including exception table, in the Exceptions to NUREG-1801 section with"None".Audit Item 268: LRA Appendix B.1.13.1, Fire Protection Program Add: "The program also includes plant C02 fire suppression system valve position checks and operational tests, C02 storage tank level- and pressure checks, system functional checks, and external surface inspections." to the Program Description.

Add: "and one exception' to the Consistency with NUREG-1 801 section.Revise: "None" is deleted in the Exceptions to NUREG-1801 section and an exception is added to state (changes in bold): The Fire Protection Program at JAFNPP is consistent with the program described in NUREG-1801,Section XI.M26, Fire Protection, with the following exception.

Attributes-Affected Exception 4. Detection of Aging Effects The six-month periodicity listed in NUREG-1801 for the full C02 system functional test will be performed on a 24-month basis in accordance with the plants current licensing basis.Attachment 2 Page 5 of 23 JAFP-07-0019 FITZPATRICK License Renewal Application Changes Audit Item 271: LRA Appendix A.2.1.13, Fire Protection Program Add: "This program will be enhanced to inspect fire barrier walls, ceilings, and floors at least once every refueling outage. Inspection results will be acceptable if there are no visual indications of degradation such as cracks, holes, spalling, or gouges. This program will be enhanced to inspect at least one randomly selected seal of each type every 24 months. These enhancements will be implemented prior to the period of extended operation." Audit Item 279 / 397: LRA Appendix B.1.21, One-Time Inspection Program Add: "Internal surfaces of components exposed to lube oil" implemented by "One-time inspection activity will verify the effectiveness of the oil analysis program by confirming that unacceptable cracking, loss of material, and fouling is not occurring." to the Proqram Description section table of activities.

Additionally, in each of the following locations; LRA Section 3.2.2.2.3, Item 4, Loss of Material due to Pitting and Crevice Corrosion LRA Section 3.2.2.2.4, Item 1, Reduction of Heat Transfer due to Fouling LRA Section 3.2.2.2.8, Item 3, Loss of Material due to General, Pitting, and Crevice Corrosion LRA Section 3.3.2.2.7, Item 1, Loss of Material due to General, Pitting, and Crevice Corrosion LRA Section 3.3.2.2.9, Item 2, Loss of Material due to General, Pitting, Crevice, LRA Section LRA Section LRA Section LRA Section LRA Section LRA Section Microbiologically-Influenced Corrosion and Fouling 3.3.2.2.10, Item 4, Loss of Material due to Pitting and Crevice Corrosion 3.3.2.2.12, Item 2, Loss of Material due to Pitting, Crevice, and Microbiologically-Influenced Corrosion 3.4.2.2.2, Item 2, Loss of Material Due to General, Pitting, and Crevice Corrosion 3.4.2.2.5, Item 2, Loss of Material due to General, Pitting, Crevice, and Microbiologically-Influenced Corrosion 3.4.2.2.7, Item 3, Loss of Material due to Pitting and Crevice Corrosion 3.4.2.2.8, Loss of Material due to Pitting, Crevice, and Microbiologically-Influenced Corrosion Delete: "During the past five years, many visual inspections of components containing lubricating oil have been performed during corrective and preventive maintenance activities.

The visual inspections of these components would identify degraded conditions such as fouling, corrosion or cracking that could be attributed to an ineffective Oil Analysis Program. These past inspections at JAFNPP serve in lieu of a one-time inspection to provide confirmation of the effectiveness of the Oil Analysis Program." And replace with;"One-time Inspection Program activities will be utilized to confirm the effectiveness of the Oil Analysis Program." Audit Item 287: LRA Section 3.5.2.2.2.1.8, Lock Up Due to Wear for Lubrite Radial Beam Seats in BWR Drywell and Other Sliding Support Surfaces Delete: "and ISI-IWF Programs" from item 8 of section 3.5.2.2.2.1.

Attachment 2 Page 6 of 23 JAFP-07-0019 FITZPATRICK License Renewal Application Changes Item 287 continued LRA Appendix B.1.16.2, Inservice Inspection Delete: "No aging effects requiring management are identified for lubrite sliding supports.However, the ISI Program will confirm the absence of aging effects for the period of extended operation." from item 4 of Evaluation section.Replace: All verbage, including table, in Enhancements section with "None".Audit Item 290: LRA Table 3.5.2-1, Reactor Building and Primary Containment Delete: Table 3.5.2-1 Structure and/or Component or Commodity line items "inner refueling bellows" and Table 2.4-1 Component line item "inner refueling bellows".Audit Item 292: LRA Table 3.5.2-4, Bulk Commodities Revise: Table 3.5.2-4, Structure and/or Component or Commodity line item Seals and Gaskets, Note "A" replaces Note "E".Audit Item 296: LRA section 3.6-1 JAFNPP will have a one-time inspection program that will inspect or test a representative sample of bolted cable connections.

The one-time inspection program will verify that there are no aging effects for bolted cable connections that require management during the period of extended operation.

Revise LRA Section 3.6, Appendix A and B as Follows: LRA Section 3.6.2.1, Aging Effects Requiring Management, is revised to add and delete the following: " loosening of bolted connections" thermal-4 cYcling and ohmnic heaatingq LRA Section 3.6.2.1, Aging Management Programs, is revised to add the following AMP:* Bolted Cable Connections Program LRA Table 3.6.1, Item 3.6.1-13, is revised as shown below (strike-outs deleted, underlined text added).Attachment 2 Page 7 of 23 JAFP-07-0019 FITZPATRICK License Renewal Application Changes Item Component Aging Effect / AMP Further Discussion Number Mechanism Evaluation Recommended 3.6.1-13 Cable Loosening of bolted Electrical Cable No NUIREG_ 1801 aging efeGt i Connections connections due to Connections Not not applicable to JF.NPP.metallic thermal cycling, ohmic Subject To 10 CAblo connections outcido of parts heating, electrical CFR 50.49 actiV, deies are taped- o transients, vibration, Environmental siloo..Vo.d.

for prOtco.chemical contamination, Qualification Operating eXporincG with corrosion, and oxidation Requirements m.tallic par-t of .lectrical (abWo connoctionr a;t JAF=NPP in-dicatePd-no aging effectr JAFNPP is providing a plant specific program (Bolted Cable Connections Program) as an alternate to the NUREG-1801, XI.E6 program.LRA Table 3.6.2-1 is revised as shown below (strike-outs deleted, underlined text added).Componen Intended Material Environment AERM AMP NUREG- Table 1 Notes Type Function 1801, Item Vol.2 Item Cable Conducts Various Heat, moisture, Noee Nene VIA-1 3.6.1-13 , Connection, electricity metals used or radiation (LP-12)(metallic for electrical and air Loosening of Bolted Cable E 601 parts) connections Bolted Connections Connections Proam Notes for Table 3.6.2-1 601 -Based on the NEI/NRC meeting on November 30, 2006 to discuss the NUREG-1801, XI.E6 program, JAFNPP will implement a one-time inspection program prior to the period of extended operation to verify the absence of aging effects requiring management.

LRA Appendix A is revised to add the following:

A.2.1.36, BOLTED CABLE CONNECTIONS PROGRAM The Bolted Cable Connections Program will focus on the metallic parts of the cable connections.

This sampling program provides a one-time inspection to verify that the loosening of bolted connections due to thermal cycling, ohmic heating, electrical transients, vibration, chemical contamination, corrosion, and oxidation is not an aging issue that requires a periodic aging management program. A representative sample of the electrical cable connection population subject to aging management review will be inspected or tested. Connections covered under the EQ program, or connections inspected or tested as part of a preventative maintenance program are excluded from aging management review.The factors considered for sample selection will be application (medium and low voltage), circuit loading (high loading), and location (high temperature, high humidity, vibration, etc.).The technical basis for the sample selection will be documented.

This program will be implemented prior to the period of extended operation.

Attachment 2 Page 8 of 23 JAFP-07-0019 FITZPATRICK License Renewal Application Changes LRA Appendix B is revised to add the following:

B.1.31, BOLTED CABLE CONNECTIONS PROGRAM Program Description Cable connections are used to connect cable conductors to other cables or electrical devices. Connections associated with cables within the scope of license renewal are considered for this program. The most common types of connections used in nuclear power plants are splices (butt or bolted), crimp-type ring lugs, connectors, and terminal blocks. Most connections involve insulating material and metallic parts. This program for electrical cable connections (metallic parts) accounts for loosening of bolted connections due to thermal cycling, ohmic heating, electrical transients, vibration, chemical contamination, corrosion, and oxidation.

This program does not apply to the high-voltage switchyard connections.

NUREG-1801, XI.E4, "Metal Enclosed Bus," manages the aging effects for the connections associated with metal enclosed bus. XI.E4 manages the aging effects from thermal cycling, ohmic heating, electrical transients, vibration, chemical contamination, corrosion, and.oxidation on the metallic parts of metal enclosed bus (MEB) connections.

Therefore, MEB connections are not included in this program.Circuits exposed to appreciable ohmic or ambient heating during operation may experience loosening related to repeated cycling of connected loads or cycling of the ambient temperature environment.

Bolted connectors, splices, and terminal blocks may loosen if subjected to significant thermally induced stress and cycling.The design of these connections will account for the stresses associated with ohmic heating, thermal cycling,, and dissimilar metal connections.

Therefore, these stressors/mechanisms should not be a significant aging issue. However, confirmation of the lack of aging effects will be required.This sampling program provides for one-time inspections that will be completed prior to the period of extended operation.

The factors considered for sample selection are application (medium and low voltage), circuit loading (high loading), and location (high temperature, high humidity, vibration, etc.). The technical basis for the sample selection will be documented.

If an unacceptable condition or situation is identified in the selected sample, the corrective action program will be used to evaluate the condition and determine appropriate corrective action.None of the connections in this program are subject to the environmental qualification requirements of 10 CFR 50.49. This plant-specific aging management program has been developed as an alternate to NUREG-1801, XI.E6, to provide additional assurance that electrical cable connections will perform their intended function for the period of extended operation.

Attachment 2 Page 9 of 23 JAFP-07-0019 FITZPATRICK License Renewal Application Changes Evaluation and Technical Basis 1. Scope of Program: Non-EQ connections associated with cables in scope of license renewal are part of this program. This program does not include the high-voltage

(> 35kV)switchyard connections.

In-scope connections are evaluated for applicability of this program. The criteria for including connections in the program are that the connection is a bolted connection and is not covered under the EQ program or an existing preventive maintenance program.2. Preventive Actions: This one-time inspection program is a condition monitoring program;therefore, no actions are taken as part of this program to prevent or mitigate aging degradation.

3. Parameters Monitored/Inspected:

This program will focus on the metallic parts of the cable connections.

The one-time inspection verifies that the loosening.

of bolted connections due to thermal cycling, ohmic heating, electrical transients, vibration, chemical contamination, corrosion, and oxidation is not an aging effect that requires a periodic aging management program.4. Detection of Aging Effects: A representative sample of electrical connections within the scope of license renewal and subject to aging management review will be inspected or tested prior to the period of extended operation to verify there are no aging effects requiring.

management during the period of extended operation.

The factors considered for sample selection will be application (medium and low voltage), circuit loading (high loading), and location (high temperature, high humidity, vibration, etc.). The technical basis for the sample selection will be documented.

Inspection methods may include thermography, contact resistance testing, or other appropriate methods including visual inspection based on plant configuration and industry guidance.

The one-time inspection provides additional confirmation to support industry operating experience that shows electrical connections have not experienced a high degree of failures, and that existing installation and maintenance practices are effective.

5. Monitoring and Trending:

Trending actions are not included as part of this program because this is one-time inspection program.6. Acceptance Criteria:

The acceptance criteria for each inspection/surveillance are defined by the specific type of inspection or test performed for the specific type of cable connection.

Acceptance criteria ensure that the intended functions of the cable connections can be maintained consistent with the current licensing basis.7. Corrective Actions: If the inspection or test acceptance criteria are not met, the corrective action program will be used to perform an evaluation that will consider extent of condition, the indications of aging effects, and possible changes to the one-time inspection program such as increased frequency and sample size. As discussed in the appendix to NUREG-1801, the requirements of 10 CFR Part 50, Appendix B, are acceptable to address the corrective actions. The JAFNPP Corrective Action Program, which is implemented in accordance with requirements of 10 CFR Part 50, Appendix B, applies to the Bolted Cable Connections Program.8. Confirmation Process: This attribute is discussed in Section B.0.3.Attachment 2 Page 10 of 23 JAFP-07-0019 FITZPATRICK License Renewal Application Changes 9. Administrative Controls:

This attribute is discussed in Section B.O.3.10. Operating Experience:

Operating experience has shown that loosening of connections and corrosion of connections could be a problem without proper installation and maintenance activities.

Industry operating experience supports performing this one-time inspection program in lieu of a periodic testing program. This one-time inspection program will verify that installation and maintenance activities are effective.

The Bolted Cable Connections Program is a new program. Plant and industry operating experience was considered when this program was developed.

Industry operating experience that forms the basis for the program is described in the operating experience element of the NUREG-1801 Section XI.E6 program description.

Plant-specific operating experience is consistent with the operating experience in the NUREG-1801 XI.E6 program description.

Conclusion The Bolted Cable Connections Program will be effective for managing aging effects since it will incorporate proven monitoring techniques, acceptance criteria, corrective actions, and administrative controls.

The Bolted Cable Connections Program will provide reasonable assurance that applicable cable connections will continue to perform their intended function consistent with the current licensing basis for the period of extended operation.

Audit Item 297: LRA Section 3.6.2.2.3, Loss of Material due to Wind Induced Abrasion and Fatigue, Loss of Conductor Strength due to Corrosion, and Increased Resistance of Connection due to Oxidation or Loss of Pre-load Revise: "Connection surface oxidation for aluminum switchyard bus is not applicable since switchyard bus connections requiring AMR are welded connections.

For ambient environmental conditions at JAFNPP, no aging effects have been identified that could cause a loss of intended function for the period of extended operation.

Vibration is not applicable since flexible connectors connect switchyard bus." is replaced by: "Connection surface oxidation and loosening of bolted connections for aluminum switchyard bus is not applicable since the switchyard bus connections requiring AMR are welded connections.

However, the flexible conductors, which are welded to the switchyard bus, are bolted to the other switchyard components.

These switchyard component connections are also included in the infrared PM of the 115 kV switchyard, which verifies the effectiveness of the, connection design and installation, practices.

The infrared PM is performed at least once every year. The flexible conductors were not considered part of the switchyard bus in the application, but these flexible conductors are added to the switchyard bus commodity for completeness.

For environmental conditions at JAFNPP, no significant aging has been identified that could cause a loss of intended function for the period of extended operation.

Vibration is not applicable since flexible connectors connect switchyard bus to active components." Audit Item 302: LRA Table 3.6.2-1, Electrical Components Revise: The environment for Structure and/or Component or Commodity line items "Electrical cables and connections not subject to 10 CFR 50.49 EQ requirements" and "Electrical cables not subject to 10 CFR 50.49 EQ requirements used in instrumentation circuits" is changed from"heat or radiation or air" to "heat, radiation, or moisture and air." Attachment 2 Page 11 of 23 JAFP-07-0019 FITZPATRICK License Renewal Application Changes Audit Item 317: LRA Section 4.3.4, Effects of Reactor Water Environment on Fatigue Life Delete: "Prior to entering the period of extended operation, for each location that may exceed a CUF of 1.0 when considering environmental effects, JAFNPP will implement one or more of the following:

(1) further refinement of the fatigue analyses to lower the predicted CUFs to less than 1.0 using an NRC-approved method;(2) management of fatigue at the affected locations by an inspection program that has been reviewed and approved by the NRC (e.g., periodic non-destructive examination of the affected locations at inspection intervals to be determined by a method acceptable to the NRC);(3) repair or replacement of the affected locations.

Should JAFNPP select the option to manage environmental-assisted fatigue during the period of extended operation, details of the aging management program such as scope, qualification, method, and frequency will be submitted to the NRC prior to the period of extended operation.

And replace with: "At least 2 years prior to entering the period of extended operation, for the locations identified in NUREG/CR-6260 for BWRs of the JAFNPP vintage, JAFNPP will implement one or more of the following:

(1) Refine the fatigue analyses to determine valid CUFs less than 1 when accounting for the effects of reactor water environment.

This includes applying the appropriate Fen factors to valid CUFs determined in accordance with one of the following.

1. For locations, including NUREG/CR-6260 locations, with existing fatigue analysis valid for the period of extended operation, use the existing CUF to determine the environmentally adjusted CUF.2. More limiting JAFNPP-specific locations with a valid CUF may be added in addition to the NUREG/CR-6260 locations.

3. Representative CUF values from other plants, adjusted to or enveloping the JAFNPP plant specific external loads may be used if demonstrated applicable to JAFNPP.4. An analysis using the NRC-approved ASME code 2001 edition up to and including 2003 addendum, may be performed to determine a valid CUF.The determination of Fen will account for operating time with normal water chemistry and operating time with hydrogen water chemistry.

(2) Manage the effects of aging due to fatigue at the affected locations by an inspection program that has been reviewed and approved by the NRC (e.g., periodic non-destructive examination of the affected locations at inspection intervals to be determined by a method acceptable to the NRC).Attachment 2 Page 12 of 23 JAFP-07-0019 FITZPATRICK License Renewal Application Changes (3) Repair or replace the affected locations before exceeding a CUF of 1.0.Should JAFNPP select the option to manage environmentally assisted fatigue during the period of extended operation, details of the aging management program such as scope, qualification, method, and frequency will be submitted to the NRC at least 2 years prior to the period of extended operation." Audit Item 333: LRA Table 3.1.1, Reactor Coolant System, NUREG-1801 Vol. 1 and LRA Table 3.1.2-2, Reactor Vessel Internals Revise: As shown {additions in bold italics}Table 3.1.1 line item;3.1.1-47 Stainless steel and nickel alloy reactor vessel internals exposed to reactor coolant Loss of material due to pitting and crevice corrosion Inservice Inspection (IWB, IWC, and IWD), and Water Chemistry No Loss of material in stainless steel and nickel-alloy components of the reactor vessel internals is managed by the Water Chemistry Control -BWR Program. The One-Time Inspection Program will verify the effectiveness of the Water Chemistry Control Program to manage loss of, material.

Management of loss of material using the Water Chemistry Program augmented by the One-Time Inspection Program is consistent with other items of this table, including 3.1.1-14 and 3.1.1-15.JAFNPP performs all the inspections required by the ASME Section XI Inservice Inspection Program, but this program is not. credited for managing loss of material because it does not specifically inspect many of the reactor vessel internals components.

JAFNPP credits the BWR Vessel Internals Program which incorporates the requirements of ASME Section XI, the approved BWRVIP documents, and other approved industry documents such as vendor letters and NUREGs.Attachment 2 Page 13 of 23 JAFP-07-0019 FITZPATRICK License Renewal Application Changes Table 3.1.2-2 Reactor Vessel Internals Component Intended Material Environment Aging Effect Aging Management NUREG-1801 Table 1 Notes Type Function Requiring Program Vol. 2 Item Item Management Control rod guide tubes Support for Stainless Treated water Loss of material Water Chemistry Control IV.B1-15 (RP- 3.1.1-47 E, 107-Tubes

• CRD Criterion teel > 140'F (int) -BWR 26)thermal sleeves (a)(1) BWR Vessel Internals equipment Control rod guide tubes Support for tainless Treated water Cracking BWR Vessel Internals IV.B1-8 (R-104) 3.1.1-43 D-Tubes -CRD Criterion steel > 140°F (int) Water Chemistry Control thermal sleeves (a)(1) -BWR equipment Control rod guide tubes Support for CASS Treated water Loss of material Water Chemistry Control IV.B1-15 (RP- 3.1.1-47 E, 107-Bases Criterion

> 140°F (int) -BWR 26)(a)(1) BWR Vessel Internals equipment Control rod guide tubes Support for CASS Treated water Cracking BWR Vessel Internals IV.B1-8 (R-104) 3.1.1-43 D-Bases Criterion

> 140°F (int) Water Chemistry Control (a)(1) -BWR equipment Control rod guide tubes Support for CASS Treated water Reduction of Thermal Aging and IV.B1-9 (R-103) 3.1.1-51 A-Bases Criterion

> 482°F and fracture Neutron Irradiation (a)(1) neutron fluence toughness Embrittlement of Cast equipment Austenitic Stainless Steel (CASS)Core spray lines F Flow Stainless Treated water Loss of material Water Chemistry Control IV.B1-15(RP-3.1.1-47 E, 107 Brackets, piping, distribution steel > 140°F (int) -BWR 26)spargers, t-boxes, t- BWR Vessel Internals box and upper elbow gussets

• Downcomer repair clamshell sleeve -U-bolt and clamp bolts Core spray lines

• Flow Stainless reated water -racking " BWR Vessel Internals IV.B1-7 (R-99) .1.1-44 B Brackets, piping, distribution steel 140OF (int) ater Chemistry Control Attachment 2 Page 14 of 23 JAFP-07-0019 FITZPATRICK License Renewal Application Changes Table 3.1.2-2 Reactor Vessel Internals Component Intended Material Environment Aging Effect Aging Management NUREG-1801 Table I Notes Type Function Requiring Program Vol. 2 Item Item Management spargers, t-boxes, t- BWR box and upper elbow gussets

• Downcomer repair clamshell sleeve -U-bolt and clamp bolts Core support .Support for Stainless Treated water Loss of material Water Chemistry Control IV.B1-15 (RP- 3.1.1-47 E, 107 Alignment pins, bar, Criterion steel > 140°F (int) -BWR 26)eyebolt, pipe, plates (a)(1) BWR Vessel Internals equipment Core support* Support for Stainless Treated water Cracking BWR Vessel Internals IV.B1-6 (R-93) 3.1.1-44 B Alignment pins, bar, Criterion steel > 140°F (int) Water Chemistry Control eyebolt, pipe, plates (a)(1) -BWR equipment Core support rim bolts Support for Stainless Treated water Cracking BWR Vessel Internals IV.B1-6 (R-93) 3.1.1-44 B Criterion steel > 140°F (int) Water Chemistry Control (a)(1) BWR equipment Core support rim bolts Support for Stainless Treated water Loss of material Water Chemistry Control IV.B1-15 3.1.1-47 E, 107 Criterion steel > 140°F (int) -BWR (a)(1) BWR Vessel Internals equipment Core support rim bolts Support for Stainless Treated water Loss of preload TLAA -loss of preload H Criterion steel > 140°F (int)(a)(1)equipment Fuel support pieces ° Support for CASS Treated water Loss of material Water Chemistry Control IV.B1-15 (RP- 3.1.1-47 E, 107 Orificed supports Criterion

> 140°F (int) BWR 26)(a)(1) BWR Vessel Internals equipment I Fuel support pieces .Support for ASS reated water Cracking BWR Vessel Internals IV.B1-6 (R-93) 3.1.1-44 0D Orificed supports Criterion 140°F (int) ,/Vater Chemistry Control Attachment 2 Page 15 of 23 JAFP-07-0019 FITZPATRICK License Renewal Application Changes Table 3.1.2-2 Reactor Vessel Internals Component Intended Material Environment Aging Effect Aging Management NUREG-1801 Table I Notes Type Function Requiring Program Vol. 2 Item Item______________

________ ______ _________

Management

____ __(a)(1) -BWR equipment Fuel support pieces .Support for CASS Treated water Reduction of Thermal Aging and IV.B1-9 (R-103) 3.1.1-51 A Orificed supports Criterion

> 482°F and racture Neutron Irradiation (a)(1) neutron fluence toughness Embrittlement of Cast equipment ,ustenitic Stainless Steel (CASS)Fuel support pieces

• Support for Stainless Treated water Loss of material Water Chemistry Control IV.B1-15 (RP- 3.1.1-47 E, 107 Peripheral supports Criterion steel > 140°F (int) -BWR 26)(a)(1) BWR Vessel Internals equipment Fuel support pieces .Support for Stainless Treated water Cracking BWR Vessel Internals IV.B1-6 (R-93) 3.1.1-44 D Peripheral supports Criterion steel > 140°F (int) Water Chemistry Control (a)(1) -BWR equipment Incore flux monitors ° Pressure Stainless Treated water Loss of material Water Chemistry Control IV.B1-15 (RP- 3.1.1-47 E, 107 Dry tubes °LPRM boundary steel > 140°F (int) -BWR 26)BWR Vessel Internals Incore flux monitors ° Pressure Stainless Treated water Cracking BWR Vessel Internals IV.B1-10 (R- 3.1.1-44 B Dry tubes °LPRM boundary steel > 140°F (int) Water Chemistry Control 105)-BWR Incore flux monitors ° Pressure Stainless Air-indoor (ext) None None IV.E-2 (RP-04) 3.1.1-86 A Dry tubes °LPRM boundary steel Incore flux monitors ° Pressure Stainless Treated water Loss of material Water Chemistry Control IV.B1-15 (RP- 3.1.1-47 E, 107 Guide tubes boundary steel > 140.°F (int) -BWR 26)BWR Vessel Internals Incore flux monitors -Pressure Stainless Treated water Cracking BWR Vessel Internals IV.B1-10 (R- 3.1.1-44 B Guide tubes boundary steel > 140°F (int) Water Chemistry Control 105)-BWR Jet pump assemblies

• Floodable tainless Treated water Loss of material Water Chemistry Control IV.B1-15 (RP- 3.1.1-47 E, 107 Riser pipe, riser I IS I III Attachment 2 Page 16 of 23 JAFP-07-0019 FITZPATRICK License Renewal Application Changes Table 3.1.2-2 Reactor Vessel Internals Component Intended Material Environment Aging Effect Aging Management NUREG-1801 Table 1 Notes Type Function Requiring Program Vol. 2 Item Item Management elbow, riser braces volume steel > 140°F (int) -BWR 26)-Hold down bolts BWR Vessel Internals-Mixer barrels-Restrainer bracket wedge assemblies

• Diffuser shell, tailpipes and adapter (top piece)Jet pump assemblies

• Floodable Stainless Treated water Cracking -TLAA- Metal Fatigue IV.B1-14 (R-53) 3.1.1-5 A Riser pipe, riser volume steel > 140°F (int) atigue (diffuser elbow, riser braces adapter)-Hold down bolts-Mixer barrels-Restrainer bracket wedge assemblies-Diffuser shell, tailpipes and adapter (top piece)Jet pump assemblies Floodable Stainless Treated water Cracking BWR Vessel Internals IV.B1-13 (R- 3.1.1-44 B-Riser pipe, riser volume steel > 140°F (int) ater Chemistry Control 100)elbow, riser braces -BWR-Hold down bolts-Mixer barrels-Restrainer bracket wedge assemblies-Diffuser shell, tailpipes and adapter (top piece)Jet pump assemblies Floodable Nickel- Treated water Loss of material Water Chemistry Control IV.B1 -15 (RP- 3.1.1-47 E, 107*Holddown beams volume based alloy > 140'F (int) BWR 26)-Diffuser adapter BWR Vessel Internals (bottom piece)Jet pump assemblies Floodable Nickel- Treated water racking BWR Vessel Internals IV.B1-13 (R- .1.1-44 B*Holddown beams

• volume based alloy 140°F (int) Tater Chemistry Control 100) r Attachment 2 Page 17 of 23 JAFP-07-0019 FITZPATRICK License Renewal Application Changes TablA 3.1.2-2 R~ctor V~~l lntArnal~Component Intended Material Environment Aging Effect Aging Management NUREG-1801 Table I Notes Type -Function Requiring Program Vol. 2 Item Item Management Diffuser adapter -BWR (bottom piece)Jet pump castings Floodable CASS Treated water Loss of material Water Chemistry Control IV.B1-15 (RP- 3.1.1-47 E, 107-Transition piece volume > 140°F (int) -BWR 26)-Inlet elbow/ nozzle BWR Vessel Internals-Mixer adapter-Restrainer bracket-Diffuser collar Jet pump castings Floodable CASS Treated water Cracking BWR Vessel Internals IV.B1-13 (R- 3.1.1-44 B Transition piece -Inlet volume > 140'F (int) Water Chemistry Control 100)elbow/ nozzle -Mixer -BWR adapter -Restrainer bracket -Diffuser collar Jet pump castings Floodable CASS Treated water Reduction of Thermal Aging and IV.B1-11 (R- 3.1.1-51 C-Transition piece volume > 482 0 F and fracture Neutron Irradiation 101)-Inlet elbow/ nozzle

• neutron fluence toughness Embrittlement of Cast Mixer adapter ,ustenitic Stainless Steel-Restrainer bracket (CASS)-Diffuser collar Shroud -Upper, Support for Stainless Treated water Loss of material Water Chemistry Control IV.B1-15 (RP- 3.1.1-47 E, 107 central, and lower Criterion steel > 140°F (int) -BWR 26)sections, and bolting (a)(1) BWR Vessel Internals equipment Floodable volume Shroud -Upper, Support for Stainless Treated water Cracking BWR Vessel Internals IV.B1-1 (R-92) 3.1.1-44 B central, and lower Criterion steel > 140OF (int) Water Chemistry Control sections, and bolting (a)(1) BWR equipment Floodable volume Attachment 2 Page 18 of 23 JAFP-07-0019 FITZPATRICK License Renewal Application Changes Table 3.1.2-2 Reactor Vessel Internals Component Intended Material Environment Aging Effect Aging Management NUREG-1801 Table I Notes Type Function Requiring Program Vol. 2 Item Item Management Shroud stabilizers Support for tainless Treated water Loss of material Water Chemistry Control IV.B1-15 (RP- 3.1.1-47 E, 107-Radial restraints -Tie Criterion teel > 140OF (int) -BWR 26)rod assemblies (a)(1) BWR Vessel Internals-Brackets equipment Shroud stabilizers Support for tainless Treated water Cracking -TLAA- Metal Fatigue IV.B1-14 (R-53) 3.1.1-5 A-Radial restraints -Tie Criterion teel > 140°F (int) fatigue rod assemblies (a)(1)-Brackets equipment Shroud stabilizers Support for tainless Treated water Cracking BWR Vessel Internals IV.B1-1 (R-92) 3.1.1-44 B-Radial restraints -Tie Criterion steel > 140°F (int) Water Chemistry Control rod assemblies (a)(1) -BWR-Brackets equipment Shroud support .Ring, Support for Nickel- Treated water Loss of material Water Chemistry Control IV.B1-15 (RP- 3.1.1-47 E, 107 cylinder, gussets, Criterion based alloy > 140OF (int) -BWR 26)bolting, and manway (a)(1) BWR Vessel Internals covers equipment Floodable volume Shroud support -Ring, Support for Nickel- Treated water Cracking-TLAA- Metal Fatigue IV.B1-14 (R-53) 3.1.1-5 A cylinder, gussets, Criterion based alloy > 140'F (int) fatigue bolting, and manway (a)(1)covers equipment Floodable volume Shroud support -Ring,. Support for Nickel- Treated water Cracking BWR Vessel Internals IV.B1-2 (R-96) 3.1.1-44 B E cylinder, gussets, Criterion based alloy > 140OF (int) Water Chemistry Control IV.B1-5 (R-94) 3.1.1-49 bolting, and manway (a)(1) BWR covers equipment Floodable volume Steam dryers Structural Stainless reated water racking BWR Vessel Internals IV.B1-16 (RP- 3.1.1-29 E integrity steel 140°F (int) __-_18)Attachment 2 Page 19 of 23 JAFP-07-0019 FITZPATRICK License Renewal Application Changes Table 3.1.2-2 Reactor Vessel Internals Component Intended Material Environment Aging Effect Aging Management NUREG-1801 Table 1 Notes Type Function Requiring Program Vol. 2 Item Item Management Top guide assembly Support for Stainless Treated water Loss of material Water Chemistry Control IV.B1-15 (RP- 3.1.1-47 E, 107 Criterion steel > 140'F (int) -BWR 26)(a)(1) BWR Vessel Internals equipment Top guide assembly Support for Stainless Treated water Cracking BWR Vessel Internals IV.B1-17 (R-98) 3.1.1-44 B Criterion steel > 140°F (int) Water Chemistry Control (a)(1) BWR equipment Attachment 2 Page 20 of 23 JAFP-07-0019 FITZPATRICK License Renewal Application Changes Audit Item 360: LRA Table 3.1.2-3, Reactor Coolant System Pressure Boundary Delete: Line item for Component Type "Thermal sleeves" from Table 3.1.2-3.Audit Item 365: LRA Table 3.2.1, Engineered Safety Features, NUREG-1801, Vol. 1 Delete: "not applicable" from the discussion column of line item 3.2.1-24.Audit Item 374: LRA Section 3.3.2.2.3, Cracking Due to Stress Corrosion Cracking Revise: In section 3.3.2.2.3, "This item is not applicable to JAFNPP." is replaced by"However, the PSPM program will verify the absence of cracking in the stainless steel exhaust components." Audit Item 377: LRA Table 3.3.1, Auxiliary Systems, NUREG-1801, Vol. 1 Delete: "not applicable" from the discussion column of AMR line item 3.3.1-45.Audit Item 379: LRA Table 3.3.2-14-41, Emergency Diesel Generator Revise: In the line items for Component Types compressor housing, piping, and valve body that compare to GALL line item 3.3.1-71, "One-Time Inspection" program is changed to"Periodic Surveillance and Preventive Maintenance" program.Audit Item 403/409: LRA Appendix B.13.1, Fire Protection Add: The following enhancement (addition in bold).Attributes Affected Enhancements

4. Detection of Aging Effects The Fire Protection Program will be enhanced to include periodic inspection of diesel-driven fire pump exhaust system components.

These inspections will identify cracking through the use of visual or other NDE techniques Audit Item 406: LRA Table 3.3.2-7, Heating, Ventilation and Air Conditioning Revise: In the line item for heat exchanger (tubes) / Copper alloy / Gas (ext) / Loss of material -wear, "Periodic Surveillance and Preventive Maintenance" program is changed to"Heat Exchanger Monitoring" program.Audit Item 447: LRA Appendix B.1.23, Reactor Head Closure Studs Add: To Exception Note 1 add "This is applicable to the current (third) ISI interval which is based on the ASME Section Xl Code 1989 version. The code of record for the fourth interval (2001 Edition / 2003 Addenda) has deleted the requirements for surface exams." Attachment 2 Page 21 of 23 JAFP-07-0019 FITZPATRICK License Renewal Application Changes Audit Item 460: LRA Appendix B. 1.13.2, Fire Water System Revise: 1 st two enhancements to read as follows (changes in bold);Attributes Affected Enhancements

3. Parameters Monitored/

Procedures will be enhanced to include Inspected inspection of hose reels for corrosion.

6. Acceptance Criteria Acceptance criteria will be enhanced to verify no unacceptable signs of degradation.

3. Parameters Monitored/

Procedures for sprinkler systems will be Inspected enhanced to include visual inspection of 6. Acceptance Criteria spray and sprinkler system internals for evidence of corrosion.

Acceptance criteria will be enhanced to verify no unacceptable signs of degradation.

Audit Item 465: LRA Appendix B.1.17, Metal-Enclosed Bus Delete: "where applicable" in last sentence of the 2 nd paragraph of Program Description section.Audit Item 471: LRA Appendix B Revise: Delete the sentence that includes the words "is comparable to NUREG-1801

........in each of the programs where applicable and replace it or add wording that the program is"new" or "existing" as specified in the table below for each Program Description section.From LRA Table B-i: Buried Piping and Tanks Inspection Program B.1.1 new BWR CRD Return Line Nozzle Program B.1.2 existing BWR Feedwater Nozzle Program B.1.3 existing BWR Penetrations Program B. 1.4 existing BWR Stress Corrosion Cracking Program B.1.5 existing BWR Vessel ID Attachment Welds Program B.1.6 existing BWR Vessel Internals Program B.1.7 existing Containment Leak Rate Program B.1.8 existing Diesel Fuel Monitoring Program B.1.9 existing Environmental Qualification. (EQ) of Electric Components Program B. 1.10 existing External Surfaces Monitoring Program B. 1.11 existing Fatigue Monitoring Program B.1.12- existing Fire Protection

-Fire Protection Program B.1.13.1 existing, Fire Protection

-Fire Water System Program B. 1.13.2 existing: Flow-Accelerated Corrosion Program B. 1.14 existing Heat Exchanger Monitoring Program B. 1.15 new Inservice Inspection

-Containment Inservice Inspection (CII) Program B.1.16.1 existing Inservice Inspection

-Inservice Inspection (ISI) Program B.1.16.2 existing Metal-Enclosed Bus Inspection Program B.1.17 new Non-EQ Instrumentation Circuits Test Review Program B.1.18 new Attachment 2 Page 22 of 23 JAFP-07-0019 FITZPATRICK License Renewal Application Changes Non-EQ Insulated Cables and Connections Program B.1.19 new.Oil Analysis Program B.1.20 existing One-Time Inspection Program B.1.21 new Periodic Surveillance and Preventive Maintenance Program B.1.22 existing Reactor Head Closure Studs Program B.1.23 existing Reactor Vessel Surveillance Program B.1.24 existing Selective Leaching Program B.1.25 new Service Water Integrity-Program B.1.26 existing Structures Monitoring

-Masonry Wall Program B.1.27.1 existing Structures Monitoring

-Structures Monitoring Pr6gram B. 1.27:2 existing Thermal Aging and Neutron Irradiation Embrittlement of Cast Austenitic B.1.28 new Stainless Steel (CASS) Program Water Chemistry Control -Auxiliary Systems Program B.1.29.1 existing.Water Chemistry Control -BWR Program B.11.29.2 existing Water Chemistry Control -Closed Cooling Water Program B.1.29.3 existing.Bolting Integrity Program B.1.30 existing Audit Item 483: LRA Section A.2.2.7, Core Plate Appendix A.2.2.7 will be revised as follows: Add: "There are three options for Core Plate hold down bolts.1. Install core plate wedges prior to the period of extended operation, or 2. Complete a plant-specific analysis to determine acceptance criteria for continued inspection of core plate rim hold down bolting in accordance with BWRVIP-25 and submit the inspection plan to the NRC two years prior to the period of extended operation for NRC review and approval, or 3. Perform inspection of core plate rim hold down bolts in accordance with ASME Code Section XI or in accordance with an NRC-approved version of BWRVIP-25." Attachment 2 Page 23 of 23 JAFP-07-0019 JAFP-07-0019 Docket No. 50-333 Attachment 3 James A. FitzPatrick Nuclear Power Plant License Renewal Application

-Amendment 5 Updated RAI Responses RAI B.1.16.2-1 RAI 3.6.2-1 RAI B.1.16.2-1 The "scope of program" attribute for AMP B.1.16.2 states that the program implements applicable requirements of ASME Section Xl, Subsections IWA, IWB, IWC, IWD and IWF, and other requirements specified in 10 CFR 50.55a with NRC approved relief requests.The staff notes that there is no regulatory basis to include previously granted inservice inspection (ISI) relief requests within the scope of a license renewal application because the NRC's approval of the relief requests does not extend beyond the scope of the current operating period and because these requests are not subject to processing under the requirements of 10 CFR Part 54. The same holds true for alternative programs that have previously been granted on applicable ASME Section XI inservice testing (IST) requirements.

The staff therefore requests that the applicant either amend the LRA to delete any and all references to relief requests for ASME ISI or IST requirements or amend the LRA to provide a commitment that any new or renewed relief requests that are sought for during the period of extended operation will be processed through the NRC's 10 CFR 50.55a relief request provisions after the operating license for the facility has been renewed.RAI B.1.16.2-1 Response.The revised response to RAI B.1.16.2-1 below supersedes the response in Attachment 1 of LRA Amendment 1.RAI B.1.16.2-1 Revised Response Since ASME code relief requests have their own process under 10 CFR 50.55a, reference to relief requests in the LRA is unnecessary.

The following change is made to the LRA to remove reference to relief requests:

Section B.1.16.2, page B-58, first paragraph in Scope of Program is revised as shown below (strike-outs deleted).The ISI Program manages cracking, loss of material, and reduction of fracture toughness of reactor coolant system piping, components, and supports.

The program implements applicable requirements of ASME Section XI, Subsections IWA, IWB, IWC, IWD and IWF, and other requirements specified in 10 CFR 50.55a with appr.Vo.d NRC , ltrn.atives and relicf ..qu.e.Every 10 years the ISI Program is updated to the latest ASME Section XI code edition and addendum approved by the NRC in 10 CFR 50.55a. Any necessary relief requests will be pursued as required at that time.Attachment 3 Page 1 of 3 JAFP-07-0019 James A. FitzPatrick Oil-Filled Cable System RAI 3.6.2-1 In JAFNPP LRA Table 3.6.2-1, the applicant states that 115 KV oil-filled cable (passive electrical for station blackout) has no aging effect requiring management for meeting the component's electrical intended function.

The staff requests the applicant to provide a technical justification of why an AMP is not required or provide a plant-specific AMP that contains the required ten elements to manage the aging effects due to aging mechanisms such as insulation degradation, moisture intrusion, elevated operating temperature, and galvanic corrosion.

In addition, explain what periodic tests are planned prior to and during the extended period of operation.

RAI 3.6.2-1 Response The revised response to RAI 3.6.2-1 below supersedes the response in Attachment 1 of LRA Amendment 1.RAI 3.6.2-1 Revised Response The underground oil-filled cable environment is constant temperature soil, ambient temperature, and moisture.

The underground oil-filled cables are 350 MCM hollow core copper, oil with impregnated paper / copper wall / intercalated with paper tape / copper bearing lead wall and a polyethylene protective jacket. The underground oil-filled cables use a lead sheath to prevent effects of moisture on the cables. This cable is designed with a thick layer of lead over the cable insulation and an overall jacket over the lead and insulation.

Lead sheath cables are designed for submergence for extended periods.Operating experience was reviewed by searching JAF condition reports and interviewing knowledgeable plant staff. No failures were identified.

This is consistent with the industry operating experience for this type of cable system.The mechanisms

/ stressor identified in this question are not an issue for this type of cable. A lead-sheathed cable is not susceptible to moisture intrusion.

There are no significant environment issues associated with degradation of the paper insulation.

This is supported by plant and industry OE. Elevated operating temperature is not an issue since the cables are designed for the load and do not operate in an area of elevated temperatures.

There are no dissimilar metal connections, so galvanic corrosion is not an issue. Since the cable is lead-sheathed, the insulation material is protected from moisture The JAF oil-filled cable does not have any aging effects that require management.

However, the oil-filled cable system will be included in the Periodic Surveillance and Preventive Maintenance Program as described in Appendix B.1.22, to verify the absence of aging effects that require management.

A preventive maintenance procedure will provide the maintenance activities for the oil-filled cable system that are described in the vendor maintenance requirements.

This program under PSPM will ensure that the oil-filled cable system will be able to perform its intended function into the period of extended operation.

Attachment 3 Page 2 of 3 JAFP-07-0019 LRA Section 3.6.2.1, Aging Management Programs, is revised to add the following AMP:* Periodic Surveillance and Preventive Maintenance Program LRA Table 3.6.2-1 is revised as shown below (strike-outs deleted, underlined text added).Component Type Intended Material Environment AERM AMP NUREG- Table Notes Function 1801, 1 Vol.2 Item Item Oil-filled cable Pressure Carbon Mineral oil Loss of Oil analysis J system -MECH boundary steel, (internal) material External (passive stainless Outdoor surfaces mechanical for steel, weather monitoring SBO recovery) copper (external) alloy, glass Oil-filled cable -Conducts Insulation i an None Periodic J, ELEC (passive electricity material-velte e-- Surveillance 602 electrical for SBC varIeuS and Preventive recovery)

Organic Outdor Maintenance polymer weather polymers ~Soil______________

_____Notes for Table 3.6.2-1 602 -Based on vendor information this transmission cable is not subject to water treeing, since it is designed for continuously wet conditions.

Industry and plant operating experience has not provided any information on failures of this type of cable. The only portion of the cables exposed to the environments (outdoor weather and soil) is the okolene (black polyethylene) outer jacket, which is over the lead sheath and serves as an anti-corrosion and moisture protection.

These environments do not affect the oil impregnated paper insulation.

Attachment 3 Page 3 of 3 JAFP-07-0019