ML071210512
| ML071210512 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 04/23/2007 |
| From: | Dacimo F Entergy Nuclear Indian Point 2, Entergy Nuclear Indian Point 3 |
| To: | Document Control Desk, NRC/NRR/ADRO |
| References | |
| NL-07-039 | |
| Download: ML071210512 (17) | |
Text
Indian Point Energy Center 450 Broadway, GSB P.O. Box 249 Enter Buchanan, N.Y. 10511-0249 Tel (914) 734-6700 Fred Dacimo Site Vice President Administration April 23, 2007 Re: Indian Point Units No. 2 & 3 Docket Nos. 50-247, 50-286 NL-07-039 Document Control Desk U.S. Nuclear Regulatory Commission Mail Stop O-P1-17 Washington, DC 20555-0001
Subject:
Indian Point Energy Center Docket No. (Unit 2) 50-247 (License No. DPR-26)
Docket No. (Unit 3) 50-286 (License No. DPR-64)
Dear Sir or Madam:
Pursuant to 10 CFR 51 and 10 CFR 54, Entergy Nuclear Operations, Inc. (ENO) hereby applies for renewal of the operating license for the Indian Point Energy Center Units 2 and 3 (IPEC) to extend the licenses for an additional 20 years beyond the current expiration date.
With renewal, the IP2 operating license would be extended from midnight on September 28, 2013 to midnight on September 28, 2033 and IP3 operating license would be extended from midnight on December 12, 2015 to midnight on December 12, 2035.
The enclosed License Renewal Application and related Appendices contain the information required by 10 CFR 54 for the contents of an application.
As required by 10 CFR 54.21(b), current licensing basis changes which have a material effect on the content of this application, including the FSAR Supplement (Appendix A), will be identified at least annually while the application is under NRC review and at least three months prior to the scheduled completion of the NRC review.
This application is submitted in accordance with 10 CFR 2 Subpart A, 10 CFR 50.4, and 10 CFR 50.30. ENO hereby submits the original (plus 80 CDs) of the application pursuant to 10 CFR50.4(b), 10 CFR 51.55(a), and 10 CFR 54.17(a).
Commitments contained in this application are summarized in the attachment.
Should you have any questions concerning this submittal, please contact Mr. T.R. Jones, Acting Manager of Licensing at (914) 734-6670.
-Ad2- '
Docket Nos. 50-247, 50-286 NL-07-039 Page 2 of 3 I declare under penalty of perjury that the foregoing is true and correct. Executed on the 23rd day of April, 2007 lc Iy, Fred Dacimo Site Vice President
Attachment:
Enclosures:
List of Regulatory Commitments License Renewal Application Appendix A Updated Final Safety Analysis Report Supplement Appendix B Aging Management Programs and Activities Appendix C Not Used Appendix D Technical Specifications Changes Appendix E Environmental Report cc: see next page
Docket Nos. 50-247, 50-286 NL-07-039 Page 3 of 3 cc: with Attachment and Enclosures Mr. John P. Boska, Project Manager Plant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mail Stop O-8-C2 Washington, DC 20555 cc: without Attachment and Enclosures Mr. Samuel J. Collins Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406-1415 Resident Inspector's Office U.S. Nuclear Regulatory Commission Indian Point Energy Center 450 Broadway Buchanan, NY 10511 Mr. Paul Eddy New York State Department of Public Service 3 Empire State Plaza, 10 th Floor Albany, NY 12223-1350 Mr. Peter R. Smith, President New York State Energy, Research, and Development Authority 17 Columbia Circle Albany, NY 12203-6399 cc:
(INTERNAL USE ONLY)
Mr. F. G. Burford (M-ECH-521)
Mr. J. T. Herron (K-WPO-12A)
Mr. M. Kansler (M-ECH-61)
Mr. 0. Limpias (K-WPO-1 ID)
Mr. M. Balduzzi (K-WPO-12A)
Mr. J. DeRoy (M-ECH-579)
Mr. W. Dennis (K-WPO-12A)
Mr. J. McCann (K-WPO-12C)
Mr. G. G. Young (N-GSB-45)
Mr. M. D. Stroud (N-GSB-45)
Corporate File (3)
ATTACHMENT to NL-07-039 List of Regulatory Commitments ENTERGY NUCLEAR OPERATIONS, INC.
INDIAN POINT UNIT 2 AND 3 NUCLEAR POWER PLANTS DOCKET NOS. 50-247 AND 50-286
Docket Nos. 50-247, 50-286 NL-07-039 Page 1 of 13 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.
COMMITMENT IMPLEMENTATION Related SCHEDULE LRA Section 1
Enhance the Aboveground Steel Tanks Program for lP2:
A.2.1.1 IP2 and IP3 to perform thickness measurements of September 28, A.3.1.1 the bottom surfaces of the condensate storage tanks, 013 B.1.1 city water tank, and fire water tanks once during the IP3:
first ten years of the period of extended operation.
December 12, Enhance the Aboveground Steel Tanks Program for 2015 IP2 and IP3 to require trending of thickness measurements when material loss is detected.
2 Enhance the Bolting Integrity Program for IP2 and IP3 IP2:
A.2.1.2 to clarify that actual yield strength is used in selecting September 28, A.3.1.2 materials for low susceptibility to SCC and clarify the 013 B.1.2 prohibition on use of lubricants containing MoS 2 for IP3:
bolting.
December 12, 2015 3
Implement the Buried Piping and Tanks Inspection IP2:
A.2.1.5 Program for IP2 and IP3 as described in LRA Section September 28, A.3.1.5 B.1.6.
2013 B.1.6 IP3:
December 12, 1_ _
1_2015 1
Docket Nos. 50-247, 50-286 NL-07-039 Page 2 of 13 COMMITMENT IMPLEMENTATION1 Related I
SCHEDULE LRA Section 4
Enhance the Diesel Fuel Monitoring Program to include cleaning and inspection of the IP2 GT-1 gas turbine fuel oil storage tanks, IP2 and IP3 EDG fuel oil day tanks, IP2 SBO/Appendix R diesel generator fuel oil day tank, and IP3 Appendix R fuel oil storage tank and day tank once every ten years.
Enhance the Diesel Fuel Monitoring Program to include quarterly sampling and analysis of the IP2 SBO/Appendix R diesel generator fuel oil day tank, IP2 security diesel fuel oil day tank, and IP3 Appendix R fuel oil storage tank. Particulates, water and sediment checks will be performed on the samples.
Filterable solids acceptance criterion will be less than or equal to 10mg/I. Water and sediment acceptance criterion will be less than or equal to 0.05%.
Enhance the Diesel Fuel Monitoring Program to include thickness measurement of the bottom surface of the following tanks once every ten years. IP2: EDG fuel oil storage tanks, EDG fuel oil day tanks, SBO/Appendix R diesel generator fuel oil day tank, GT-1 gas turbine fuel oil storage tanks, and diesel fire pump fuel oil storage tank; IP3: EDG fuel oil day tanks, Appendix R fuel oil storage tank, and diesel fire pump fuel oil storage tank.
Enhance the Diesel Fuel Monitoring Program to change the analysis for water and particulates to a quarterly frequency for the following tanks. IP2: GT-1 gas turbine fuel oil storage tanks and diesel fire pump fuel oil storage tank; IP3: Appendix R fuel oil day tank and diesel fire pump fuel oil storage tank.
Enhance the Diesel Fuel Monitoring Program to specify acceptance criteria for thickness measurements of the fuel oil storage tanks within the scope of the proqram.
I P2:
September 28, 2013 IP3:
December 12, 2015 A.2.1.8 A.3.1.8 B.1.9
+
I I
5 Enhance the External Surfaces Monitoring Program for IP2 and IP3 to include periodic inspections of 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).
I P2:
September 28, 2013 I P3:
December 12, 2015 A.2.1.10 A.3.1.10 B.1.11
Docket Nos. 50-247, 50-286 NL-07-039 Page 3 of 13 COMMITMENT IMPLEMENTATION Related SCHEDULE LRA Section 6
Enhance the Fatigue Monitoring Program for IP2 to 1P2:
A.2.1.11 monitor steady state cycles and feedwater cycles or September 28, A.3.1.11 2013B.
1.12 perform an evaluation to determine monitoring is not 013 required. Review the number of allowed events and resolve discrepancies between reference documents and monitoring procedures.
Enhance the Fatigue Monitoring Program for IP3 to IP3:
include all the transients identified. Assure all fatigue December 12, analysis transients are included with the lowest 2015 limiting numbers. Update the number of design transients accumulated to date.
7 Enhance the Fire Protection Program to inspect IP2:
A.2.1.12 external surfaces of the IP3 RCP oil collection September 28, A.3.1.12 systems for loss of material each refueling cycle.
013 B.1.13 Enhance the Fire Protection Program to explicitly IP3:
state that the IP2 and IP3 diesel fire pump engine December 12, sub-systems (including the fuel supply line) shall be 2015 observed while the pump is running. Acceptance criteria will be revised to verify that the diesel engine does not exhibit signs of degradation while running; such as fuel oil, lube oil, coolant, or exhaust gas leakage.
Enhance the Fire Protection Program to specify that the IP2 and IP3 diesel fire pump engine carbon steel exhaust components are inspected for evidence of corrosion and cracking at least once each operating cycle.
Enhance the Fire Protection Program for IP3 to visually inspect the cable spreading room, 480V switchgear room, and EDG room CO 2 fire suppression system for signs of degradation, such as corrosion and mechanical damage at least once every six months.
Docket Nos. 50-247, 50-286 NL-07-039 Page 4 of 13 COMMITMENT IMPLEMENTATIONI Related I
SCHEDULE LRA Section 8
Enhance the Fire Water Program to include inspection of IP2 and IP3 hose reels for evidence of corrosion.
Acceptance criteria will be revised to verify no unacceptable signs of degradation.
Enhance the Fire Water Program to inspect a sample of IP2 and IP3 sprinkler heads required for 10 CFR 50.48 using guidance of NFPA 25 (2002 edition),
Section 5.3.1.1.1 before the end of the 50-year sprinkler head service life and at 10-year intervals thereafter during the extended period of operation to ensure that signs of degradation, such as corrosion, are detected in a timely manner.
Enhance the Fire Water Program to perform wall thickness evaluations of IP2 and IP3 fire protection piping on system components using non-intrusive techniques (e.g., volumetric testing) 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.
Enhance the Fire Water Program to inspect the internal surface of the IP3 foam based fire suppression tanks. Acceptance criteria will be enhanced to verify no si.qnificant corrosion.
I P2:
September 28, 2013 IP3:
December 12, 2015 A.2.1.13 A.3.1.13 B. 1.14
Docket Nos. 50-247, 50-286 NL-07-039 Page 5 of 13 COMMITMENT IMPLEMENTATION1 Related I_
ISCHEDULE LRA Section 9
Enhance the Flux Thimble Tube Inspection Program for IP2 and IP3 to implement comparisons to wear rates identified in WCAP-12866. Include provisions to compare data to the previous performances and perform evaluations regarding change to test frequency and scope.
Enhance the Flux Thimble Tube Inspection Program for IP2 and IP3 to specify the acceptance criteria as outlined in WCAP-1 2866 or other plant-specific values based on evaluation of previous test results.
Enhance the Flux Thimble Tube Inspection Program for IP2 and IP3 to direct evaluation and performance of corrective actions based on tubes that exceed or are projected to exceed the acceptance criteria. Also stipulate that flux thimble tubes that cannot be inspected over the tube length and cannot be shown by analysis to be satisfactory for continued service, must be removed from service to ensure the integrity of the reactor coolant system pressure boundary.
IP2:
September 28, 2013 IP3:
December 12, 2015 A.2.1.15 A. 3.1.15 B.1.16
Docket Nos. 50-247, 50-286 NL-07-039 Page 6 of 13 COMMITMENT IMPLEMENTATION1 Related I
I SCHEDULE LRA Section 10 Enhance the Heat Exchanger Monitoring Program for IP2:
A.2.1.16 IP2 and IP3 to include the following heat exchangers September 28, A.3.1.16 in the scope of the program.
2013 B.1.17 Safety injection pump lube oil heat exchangers IP3:
RHR heat exchangers December 12, 2015 RHR pump seal coolers Non-regenerative heat exchangers Charging pump seal water heat exchangers Charging pump fluid drive coolers Instrument air heat exchangers (IP3 only)
" Spent fuel pit heat exchangers
" Secondary system steam generator sample coolers Waste gas compressor heat exchangers SBO/Appendix R diesel jacket water heat exchanger (IP2 only)
Enhance the Heat Exchanger Monitoring Program for IP2 and IP3 to perform visual inspection on heat exchangers where non-destructive examination, such as eddy current inspection, is not possible due to heat exchanger design limitations.
Enhance the Heat Exchanger Monitoring Program for IP2 and IP3 to include consideration of material-environment combinations when determining sample population of heat exchangers.
Enhance the Heat Exchanger Monitoring Program for IP2 and IP3 to establish minimum tube wall thickness for the new heat exchangers identified in the scope of the program. Establish acceptance criteria for heat exchangers visually inspected to include no unacceptable signs of degradation.
w w
I~~P2:
A211 11 Enhance the ISI Program for IP2 and IP3 to provide A.2.1.17 periodic inspections to confirm the absence of aging September 28, A.3.1.17 peidcisetos013 B. 1.18 effects for lubrite sliding supports used in the steam generator and reactor coolant pump support systems.
IP3:
December 12, 12015
Docket Nos. 50-247, 50-286 NL-07-039 Page 7 of 13 COMMITMENT IMPLEMENTATION Related SCHEDULE LRA Section 12 Enhance the Masonry Wall Program for IP2 and IP3 IP2:
A.2.1.18 to specify that the IP1 intake structure is included in September 28, A.3.1.18 the program.
013 B.1.19 1 P3:
December 12, 2015 13 Enhance the Metal-Enclosed Bus Inspection Program IP2:
A.2.1.19 to add IP2 480V bus associated with substation A to September 28, A.3.1.19 the scope of bus inspected.
2013 B.1.20 Enhance the Metal-Enclosed Bus Inspection Program IP3:
for IP2 and IP3 to visually inspect the external surface December 12, of MEB enclosure assemblies for loss of material at 2015 least once every 10 years. The acceptance criterion will be no significant loss of material.
Enhance the Metal-Enclosed Bus Inspection Program for IP2 and IP3 to inspect bolted connections visually at least once every five years or at least once every ten years using thermography.
14 Implement the Non-EQ Bolted Cable Connections 1P2:
A.2.1.21 Program for IP2 and IP3 as described in LRA Section September 28, A.3.1.21 B.1.22.
2013 B.1.22 IP3:
December 12, 2015 15 Implement the Non-EQ Inaccessible Medium-Voltage IP2:
A.2.1.22 Cable Program for IP2 and IP3 as described in LRA September 28, A.3.1.22 Section B.1.23.
2013 B.1.23 I P3:
December 12, 2015 16 Implement the Non-EQ Instrumentation Circuits Test IP2:
A.2.1.23 Review Program for IP2 and IP3 as described in LRA September 28, A.3.1.23 Section B.1.24.
2013 B.1.24 IP3:
December 12, 2015
Docket Nos. 50-247, 50-286 NL-07-039 Page 8 of 13 COMMITMENT IMPLEMENTATION Related SCHEDULE LRA Section 17 Implement the Non-EQ Insulated Cables and IP2:
A.2.1.24 Connections Program for IP2 and IP3 as described in September 28, A.3.1.24 LRA Section B.1.25.
2013 B.1.25 I P3:
December 12, 2015 IP2:
A.2.1.25 18 Enhance the Oil Analysis Program for IP2 to sample IP2:
and analyze lubricating oil used in the SBO/Appendix September 28, A.3.1.25 R diesel generator consistent with oil analysis for 013 B.1.26 other site diesel generators.
IP3:
Enhance the Oil Analysis Program for IP2 and IP3 to December 12, sample and analyze generator seal oil and turbine 2015 hydraulic control oil.
Enhance the Oil Analysis Program for IP2 and IP3 to formalize preliminary oil screening for water and particulates and laboratory analyses including defined acceptance criteria for all components included in the scope of this program. The program will specify corrective actions in the event acceptance criteria are not met.
Enhance the Oil Analysis Program for IP2 and IP3 to formalize trending of preliminary oil screening results as well as data provided from independent laboratories.
Docket Nos. 50-247, 50-286 NL-07-039 Page 9 of 13 COMMITMENT IMPLEMENTATION Related SCHEDULE LRA Section 19 Implement the One-Time Inspection Program for IP2 IP2:
A.2.1.26 and IP3 as described in LRA Section B.1.27.
September 28, A.3.1.26 2013 B.1.27 IP3:
December 12, 2015 20 Implement the One-Time Inspection - Small Bore lP2:
A.2.1.27 Piping Program for IP2 and IP3 as described in LRA September 28, A.3.1.27 Section B.1.28.
2013 B.1.28 IP3:
December 12, 2015 21 Enhance the Periodic Surveillance and Preventive IP2:
A.2.1.28 Maintenance Program for IP2 and IP3 as necessary September 28, A.3.1.28 2013 B.1.29 to assure that the effects of aging will be managed such that applicable components will continue to perform their intended functions consistent with the DP e1 current licensing basis through the period of extended De r1 operation.
2015 22 Enhance the Reactor Vessel Surveillance Program for IP2:
A.2.1.31 IP2 and IP3 revising the specimen capsule withdrawal September 28, A.3.1.31 schedules to draw and test a standby capsule to 013 B.1.32 cover the peak reactor vessel fluence expected I
through the end of the period of extended operation.
DP3 e
December 12, Enhance the Reactor Vessel Surveillance Program for 2015 IP2 and IP3 to require that tested and untested specimens from all capsules pulled from the reactor vessel are maintained in storage.
IP2:
A.2.1.32 23 Implement the Selective Leaching Program for IP2 Spt r
A.2.1.32 and IP3 as described in LRA Section B.1.33.
September 28, A.3.1.32 2013 B. 1. 33 1P3:
December 12, 2015 24 Enhance the Steam Generator Integrity Program for IP2:
A.2.1.34 IP2 and IP3 to require that the results of the condition September 28, A.3.1.34 monitoring assessment are compared to the operational assessment performed for the prior IP3:
operating cycle with differences evaluated.
December 12, 2015 25 Enhance the Structures Monitoring Program to IP2:
A.2.1.35 explicitly specify that the following structures are September 28, A.3.1.35
Docket Nos. 50-247, 50-286 NL-07-039 Page 10 of 13 COMMITMENT IMPLEMENTATIONJ Related I
I SCHEDULE LRA Section included in the program.
Appendix R diesel generator foundation (IP3)
Appendix R diesel generator fuel oil tank vault (IP3)
Appendix R diesel generator switchgear and enclosure (IP3) city water storage tank foundation condensate storage tanks foundation (IP3) containment access facility and annex (IP3) discharge canal (IP2/3) emergency lighting poles and foundations (IP2/3) fire pumphouse (IP2) fire protection pumphouse (IP3) fire water storage tank foundations (IP2/3) gas turbine 1 fuel storage tank foundation maintenance and outage building-elevated passageway (I P2) new station security building (IP2) nuclear service building (IP1) primary water storage tank foundation (IP3) refueling water storage tank foundation (IP3) security access and office building (IP3) service water pipe chase (IP2/3) service water valve pit (IP3) superheater stack transformer/switchyard support structures (IP2) waste holdup tank pits (IP2/3)
Enhance the Structures Monitoring Program for IP2 and IP3 to clarify that in addition to structural steel and concrete, the following commodities are inspected for each structure as applicable.
cable trays and supports concrete portion of reactor vessel supports conduits and supports cranes, rails and girders equipment pads and foundations fire proofing (pyrocrete)
- HVAC duct supports
- jib cranes
- manholes and duct banks
- manways, hatches and hatch covers
- monorails
- new fuel storage racks 2013 B.1.36 P3:
December 12, 2015
Docket Nos. 50-247, 50-286 NL-07-039 Page 11 of 13 COMMITMENT TIMPLEMENTATIONI Related I_
ISCHEDULE LRA Section 0
sumps, sump screens, strainers and flow barriers Enhance the Structures Monitoring Program for IP2 and IP3 to inspect inaccessible concrete areas that are exposed by excavation for any reason. IP2 and IP3 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.
Enhance the Structures Monitoring Program for IP2 and IP3 to perform inspections of elastomers (seals, gaskets, seismic joint filler, and roof elastomers) to identify cracking and change in material properties and for inspection of aluminum vents and louvers to identify loss of material.
Enhance the Structures Monitoring Program for IP2 and IP3 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). IP2 and IP3 will obtain samples from a well that is representative of the ground water surrounding below-grade site structures.
Samples will be monitored for sulfates, pH and chlorides.
26 Implement the Thermal Aging Embrittlement of Cast IP2:
A.2.1.36 Austenitic Stainless Steel (CASS) Program for IP2 September 28, A.3.1.36 and IP3 as described in LRA Section B.1.37.
013 B.1.37 I P3:
December 12, 2015 27 Implement the Thermal Aging and Neutron Irradiation IP2:
A.2.1.37 Embrittlement of Cast Austenitic Stainless Steel September 28, A.3.1.37 2013B.1
.38 (CASS) Program for IP2 and IP3 as described in LRA 013 Section B.1.38.
I P3:
December 12, 12015
Docket Nos. 50-247, 50-286 NL-07-039 Page 12 of 13 COMMITMENT IMPLEMENTATION Related SCHEDULE LRA Section 28 Enhance the Water Chemistry Control - Closed IP2:
A.2.1.39 Cooling Water Program to maintain water chemistry of September 28, A.3.1.39 the IP2 SBO/Appendix R diesel generator cooling 2013 B.1.40 system per EPRI guidelines.
IP3:
Enhance the Water Chemistry Control - Closed December 12, Cooling Water Program to maintain the IP2 and IP3 2015 security generator cooling water system pH within I limits specified by EPRI guidelines.
29 Enhance the Water Chemistry Control - Primary and IP2:
A.2.1.40 Secondary Program for IP2 to test sulfates monthly in September 28, B.1.41 the RWST with a limit of <150 ppb.
013 30 For aging management of the reactor vessel internals, P2:
A.2.1.41 IPEC will (1) participate in the industry programs for
' September 28, A.3.1.41 investigating and managing aging effects on reactor 011 internals; (2) evaluate and implement the results of lP3:
the industry programs as applicable to the reactor December 12, internals; and (3) upon completion of these programs, 2013 but not less than 24 months before entering the period of extended operation, submit an inspection plan for reactor internals to the NRC for review and approval.
31 Additional P-T curves will be submitted as required IP2:
A.2.2.1.2 per 10 CFR 50, Appendix G prior to the period of September 28, A.3.2.1.2 extended operation as part of the Reactor Vessel 013 4.2.3 Surveillance Program.
I P3:
December 12, 2015 32 As required by 10 CFR 50.61(b)(4), IP3 will submit a IP3:
A.3.2.1.4 plant-specific safety analysis for plate B2803-3 to the December 12, 4.2.5 NRC three years prior to reaching the RTPTS 2015 screening criterion. Alternatively, the site may choose to implement the revised PTS (10 CFR 50.61) rule when approved, which would permit use of Regulatory Guide 1.99, Revision 3.
Docket Nos. 50-247, 50-286 NL-07-039 Page 13 of 13 COMMITMENT IMPLEMENTATION Related I
I SCHEDULE LRA Section 33 At least 2 years prior to entering the period of extended operation, for the locations identified in NUREG/CR-6260 for PWRs of the IPEC vintage, IP2 and IP3 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. In addition to the NUREG/CR-6260 locations, more limiting plant-specific locations with a valid CUF may be evaluated. In particular, the pressurizer lower shell will be reviewed to ensure the surge nozzle remains the limiting component..
- 3. Representative CUF values from other plants, adjusted to or enveloping the IPEC plant specific external loads may be used if demonstrated applicable to IPEC.
- 4. An analysis using an NRC-approved version of the ASME code of NRC-approved alternative (e.g., NRC-approved code case) may be performed to determine a valid CUF.
(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 IPEC select the option to manage the aging effects due to 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 at least 2 years prior to the period of extended operation.
I P2:
September 28, 2013 1P3:
December 12, 2015 Option 2 I P2:
September 28, 2011 IP3:
December 12, 2013 A.2.2.2.3 A.3.2.2.3 4.3.3