NL-08-021, License Renewal Application Amendment 2

License Renewal Application Amendment 2

ML080290659
Person / Time
Site:	Indian Point
Issue date:	01/22/2008
From:	Dacimo F Entergy Corp, Entergy Nuclear Northeast
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NL-08-021
Download: ML080290659 (27)

Text

r Enteraqy Nuclear Northeast Indian Point Energy Center 450 Broadway, GSB P~EnterWgv

-

P.O. Box 249 Buchanan, NY 10511-0249 Tel (914) 788-2055 Fred Dacimo Vice President License Renewal January 22, 2008 Re: Indian Point Units 2 & 3 Docket Nos. 50-247 & 50-286 NL-08-021 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

SUBJECT:

Entergy Nuclear Operations Inc.

Indian Point Nuclear Generating Unit Nos. 2 & 3 Docket Nos. 50-247 and 50-286 License Renewal Application Amendment 2

REFERENCES:

1. Entergy Letter dated April 23, 2007, F. R. Dacimo to Document Control Desk, "License Renewal Application" (NL-07-039)

2. Entergy Letter dated April 23, 2007, F. R. Dacimo to Document Control Desk, "License Renewal Application Boundary Drawings" (NL-07-040)

3. Entergy Letter dated April 23, 2007, F. R. Dacimo to Document Control Desk, "License Renewal Application Environmental Report References" (NL-07-041)

Dear Sir or Madam:

In the referenced letters, Entergy Nuclear Operations, Inc. (Entergy) applied for renewal of the Indian Point Energy Center operating licenses for Unit 2 and 3.

Based on discussions during license renewal audits, clarification to the LRA is provided in . This information clarifies the relationship between Commitment 33 regarding environmentally assisted fatigue and the Fatigue Monitoring Program described in LRA Section B.1.12. The Fatigue Monitoring Program includes the actions identified in Commitment 33 to address the evaluation of the effects of environmentally assisted fatigue in accordance with 10 CFR 54.21(c)(1)(iii). The revised Regulatory Commitment List is provided in Attachment 2.

If you have any questions, or require additional information, please contact Mr. Robert Walpole at 914-734-6710.

N 9-9

NL-08-021 Docket Nos. 50-247 & 50-286 Page 2 of 3 I declare under penalty of perjury that the foregoing is true and correct. Executed on Sincerely, Fred R. Dacimo /e t Vice President License Renewal

NL-08-021 Docket Nos. 50-247 & 50-286 Page 3 of 3 Attachments:

1.Fatigue Monitoring Program Clarification

2. Regulatory Commitment List, Revision 3 cc: Mr. Samuel J. Collins, Regional Administrator, NRC Region I Mr. Kenneth Chang, NRC Branch Chief, Engineering Review Branch I Mr. Bo M. Pham, NRC Environmental Project Manager Mr. John Boska, NRR Senior Project Manager Mr. Paul Eddy, New York State Department of Public Service NRC Resident Inspector's Office Mr. Paul D. Tonko, President, New York State Energy, Research, & Development Authority

ATTACHMENT 1 TO NL-08-021 Fatigue Monitoring Program Clarification ENTERGY NUCLEAR OPERATIONS, INC.

INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 & 3 DOCKET NOS. 50-247 AND 50-286

NL-08-021 Attachment I Docket Nos. 50-247 & 50-286 Page 1 of 6 License Renewal Application Amendment 2 Fatigue Monitoring Program Clarification LRA and commitment list revisions are provided below. (underline - added, strikethrough -

deleted)

LRA Table 4.1-1, List of IP2 TLAA and Resolution, line item titled "Effects of reactor water environment on fatigue life", is revised as follows.

Effects of reactor water environment A^"" .....e.... i....a'; 4.3.3 on fatigue life 10 CFR 54.21*(*)(1)(i)

OR Aging effect managed 10 CFR 54.21(c)(1)(iii)

LRA Table 4.1-2, List of IP3 TLAA and Resolution, line item titled "Effects of reactor water environment on fatigue life", is revised as follows.

Effects of reactor water environment Analyses remain valid 4.3.3 on fatigue life 10 CFR 54.21(G)(1)(4)

-OR Aging effect managed 10 CFR 54.21(c)(1)(iii)

LRA Section 4.3.3, paragraph 10 is revised as follows.

At least 2 years prior to entering the period of extended operation, for the locations identified in LRA Table 4.3-13 (IP2) and LRA Table 4.3-14 ( 6260 for'estighoeu%-

,3)NURE4GICR PWRs of the IPEG vintage, under the Fatigue Monitoring Program IPEC will implement one or more of the following.

(1) Consistent with the Fatigue Monitoring Program, Detection of Aging Effects, update the fatigue usage calculations using Rrefined the fatigue analyses to determine valid CUFs less than 1.0 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.

For locations in LRA Table 4.3-13 (IP2) and LRA Table 4.3-14 (IP3)iarluding NUIREGICR 6260 locations, with existing fatigue analysis valid for the period of

NL-08-021 Attachment I Docket Nos. 50-247 & 50-286 Page 2 of 6 extended operation, use the existing CUF to determine the enVironmentally adjusted P-.UF--.

More limiting IPEC Additional plant-specific locations with a valid CUF may be added-in addition to the NUREGICR 6260 locationsevaluated. In particular, the pressurizer lower shell will be reviewed to ensure the surge nozzle remains the limiting component.

Representative CUF values from other plants, adjusted to or enveloping the IPEC plant-specific external loads may be used if demonstrated applicable to IPEC.

An analysis using an NRC-approved version of the ASME code or NRC-approved alternative (e.g., NRC-approved code case) may be performed to determine a valid CUF.

(-2) due " faiu at t tee dlfoa led t*ogngby an in.pection l,,,,+,ns programn that has been reviewed and approved by the NRC (e.g., period*G non-destructive examination of the affecated locations at inspe~r'ion-itep~als to be determnined by a mnethod acceptable to the NRC).

(32_) Consistent with the Fatigue Monitoring Program, Corrective Actions, Rrepair or replace the affected locations before exceeding a CUF of 1.0.

Should !PEG se!lGt the option to manage the aging effects due to enVironmental assisted fatigue during the peried of extended operation, details of the aging management-PregFa sucsh as scope, qualificsation, mnethod, and frequency Will -Sbe s.b.ied to the NRC at least 2 years prior to the period of extended operation.

Depending on the option chosen, whicoh may Yayby compenent, this TLAA.will be projected through the period of extended operation per IGOCFR54 *21 (c)(1)(ii) or-tlhe effects of environmentally assisted fatigue will be managed per 10CFR54.21(c)(1)(iii).

LRA Section A.2.1.11, Fatigue Monitoring Program, is revised as follows.

The Fatigue Monitoring Program is an existing program that tracks the number of critical thermal and pressure transients for selected reactor coolant system components. The program ensures the validity of analyses that explicitly analyzed a specified number of fatigue transients by assuring that the actual effective number of transients does not exceed the analyzed number of transients. The program provides for update of the fatigue usage calculations to maintain a CUF of < 1.0 for the period of extended operation. For the locations identified in Section A.2.2.2.3, updated calculations will account for the effects of the reactor water environment. These calculation updates are governed by Entergy's 10 CFR 50 Appendix B Quality Assurance (QA) program and include design input verification and independent reviews ensuring that valid assumptions, transients, cycles, external loadings, analysis methods, and environmental fatigue life correction factors will be used in

NL-08-021 Attachment I Docket Nos. 50-247 & 50-286 Page 3 of 6 the fatigque analyses. The program requires corrective actions including repair or replacement of affected components before fatigue usage calculations determine the CUF exceeds 1.0. Specific corrective actions are implemented in accordance with the IPEC corrective action program. Repair or replacement of the affected component(s), if necessary, will be in accordance with established plant procedures governing repair and replacement activities. These established procedures are governed by Entergy's 10 CFR 50 Appendix B QA pro-gram and meet the applicable repair or replacement requirements of the ASME Code Section Xl.

LRA Section A.2.2.2.3, Environmental Effects on Fatigue, is revised as follows.

The effects of reactor water environment on fatigue were evaluated for license renewal.

Projected cumulative usage factors (CUFs) were calculated for the limiting locations identified-in-based on NUREG/CR-6260. The identified IP2 locations are those listed in the license renewal application, Table 4.3-13. For the locsations with CU, s less, than 1.0, the 64.24(G)(1)(ii).Several locations may exceed a CUF of 1.0 with consideration of environmental effects during the period of extended operation. The Fatigue Monitorinq Pro-gram requires that Aat least two years prior to entering the period of extended operation, the site will implement one or more of the following-(1) Consistent with the Fatigue Monitoring Program, Detection of Aging Effects, update the fatigue usage calculations using Rrefined thefatigue analyses to determine valid CUFs less than 1.0 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.

For locations, includinRg UREGi/R 6260 lecation&, with existing fatigue analysis valid for the period of extended operation, use the existing CUF to d.et*tin, the enironmentally adjusted CUF.

in addition to the NUREGICR 6260 locsations, moro lirniting~dditlional 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.

Representative CUF values from other plants, adjusted to or enveloping the plant-specific external loads may be used if demonstrated applicable.

An analysis using an NRC-approved version of the ASME code or 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 "f"e'ted le*ations by an in.pe.ti*;

program that has been reviewed and approved by the NRG (e~g., perindi-nen-n

NL-08-021 Attachment I Docket Nos. 50-247 & 50-286 Page 4 of 6 deetrUetive examination of the affected locations at inspeotion"--intefals- te-be-determnined by a mnethod acceptable to the NRC).

(32) Consistent with the Fatigue Monitoring Program, Corrective Actions, Rrepair or replace the affected locations before exceeding a CUF of 1.0.

Should !PEG celect the option to manage the aging effecsts due to enVironmental assisted fatigue during the period of extended operation, details of the aging management-pFOgFa such as sopc, qualification, mnethod, and frequenc will be-submitted to the NRC at least 2 yearc prior to the period of extended operation.

LRA Section A.3.1.11, Fatigue Monitoring Program, is revised as follows.

The Fatigue Monitoring Program is an existing program that tracks the number of critical thermal and pressure transients for selected reactor coolant system components. The program ensures the validity of analyses that explicitly analyzed a specified number of fatigue transients by assuring that the actual effective number of transients does not exceed the analyzed number of transients. The program provides for update of the fatigue usage calculations to maintain a CUF of < 1.0 for the period of extended operation. For the locations identified in Section A.3.2.2.3, updated calculations will account for the effects of the reactor water environment. These calculation updates are governed by Entergy's 10 CFR 50 Appendix B Quality Assurance (QA) program and include design input verification and independent reviews ensuring that valid assumptions, transients, cycles, external loadings, analysis methods, and environmental fatigue life correction factors will be used in the fatigue analyses. The program requires corrective actions including repair or replacement of affected components before fatigue usage calculations determine the CUF exceeds 1.0. Specific corrective actions are implemented in accordance with the IPEC corrective action program. Repair or replacement of the affected component(s), if necessary, will be in accordance with established plant procedures governing repair and replacement activities. These established procedures are governed by Enteray's 10 CFR 50 Appendix B QA program and meet the applicable repair or replacement requirements of the ASME Code Section X1.

LRA Section A.3.2.2.3, Environmental Effects on Fatigue, is revised as follows.

The effects of reactor water environment on fatigue were evaluated for license renewal.

Projected cumulative usage factors (CUFs) were calculated for the limiting locations idenfifldir based on NUREG/CR-6260. The identified IP3 locations are those listed in the license renewal application, Table 4.3-14. For the lcsations With CU.s less than 1.0, the TLAA. has been projected through the period of extended oporation per 10 CFR 5424(o)(4)(ii). Several locations may exceed a CUF of 1.0 with consideration of environmental effects during the period of extended operation. The Fatigue Monitoring Program requires that Aat least two years prior to entering the period of extended operation, for the lwoations identified in NUREGICR 6260 fOr Westingh WR6of this vintage the site will implement one or more of the following:

NL-08-021 Attachment I Docket Nos. 50-247 & 50-286 Page 5 of 6 (1) Consistent with the Fatigue Monitoring Program, Detection of Aging Effects, update the fatigue usage calculation using R-refined the fatigue analyses to determine valid CUFs less than 1.0 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.

For locations, including NUREGICR 6260 lcatins-,; with existing fatigue analysis valid for the period of extended operation, use the existing CUF to dcteRmine the environmentally adjsed GUF.

in addition to the NUREGCR 6260 loc"ationsmo... limitingAdditional 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.

Representative CUF values from other plants, adjusted to or enveloping the plant-specific external loads may be used if demonstrated applicable.

An analysis using an NRC-approved version of the ASME code or 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 affectcd locations by an inspection program that has been reviewed and approved by the NRC (e.g., pe*i9dic non destructive examination of the affected locations at insperstion intewals to--be detenrmined by a method acceptable to the NRC).

(3) Consistent with the Fatigue Monitoring Program, Corrective Actions, Rrepair or replace the affected locations before exceeding a CUF of 1.0.

Should !PEG select the option to manage the aging effects due to environmnental assisted fatigue during the period of extended operation, details ofthe agn aagement-PFOgFa such as scope, qualification, method, and frequency will be submttd16d to the NRC at least 2 years prorF to the period of extended operation-.

LRA Section B.1.12, Fatigue Monitoring, Program Description, is revised as follows.

The Fatigue Monitoring Program is an existing program that tracks the number of critical thermal and pressure transients for selected reactor coolant system components. The program ensures the validity of analyses that explicitly analyzed a specified number of fatigue transients by assuring that the actual effective number of transients does not exceed the analyzed number of transients.

The pro-gram provides for update of the fatigue usage calculations to maintain a CUF of <

1.0 for the period of extended operation. For the locations identified in LRA Table 4.3-13 (1P2) and LRA Table 4.3-14 (IP3), updated calculations will account for the effects of the reactor water environment. These calculation updates are governed by Enter-gy's 10 CFR 50 Appendix B Quality Assurance (QA) program and include design input verification and

NL-08-021 Attachment I Docket Nos. 50-247 & 50-286 Page 6 of 6 independent reviews ensuring that valid assumptions, transients, cycles, external loadings, analysis methods, and environmental fatigue life correction factors will be used in the fatigue analyses.

The analysis methods for determination of stresses and fatigue usage will be in accordance with an NRC endorsed Edition of the American Society of Mechanical Engineers (ASME)

Boiler and Pressure Vessel Code,Section III Rules for Construction of Nuclear Power Plant Components Division 1 Subsection NB, Class 1 Components, Sub articles NB-3200 or NB-3600 as applicable to the specific component. IPEC will utilize design transients from IPEC Design Specifications to bound all operational transients. The numbers of cycles used for evaluation will be based on the design number of cycles and actual IPEC cycle counts proiected out to the end of the license renewal period (60 years).

Environmental effects on fatigue usage will be assessed using methodology consistent with the Generic Aging Lessons Learned Report, NUREG-1 801, Rev. 1, (GALL) that states: "The sample of critical components can be evaluated by applying environmental life correction factors to the existing ASME Code fatigue analyses. Formulae for calculating the environmental life correction factors are contained in NUREG/CR-6583 for carbon and low-alloy steels and in NUREG/CR-5704 for austenitic stainless steels."

The Fatigue Monitoring Program tracks actual plant transients and evaluates these against the design transients. Cycle counts show no limits are expected to be approached for the current license term. The Fatigue Monitoring Program will ensure that the numbers of transient cycles experienced by the plant remain within the analyzed numbers of cycles and hence, the component CUFs remain below the values calculated in the design basis fatigue evaluations. If ongoing monitoring indicates the potential for a condition outside that analyzed above, IPEC may perform further reanalysis of the identified configuration using established configuration management processes as described above.

The program requires corrective actions including repair or replacement of affected components before fatigue usage calculations determine the CUF exceeds 1.0. Specific corrective actions are implemented in accordance with the IPEC corrective action program. Repair or replacement of the affected component(s), if necessary, will be in accordance with established plant procedures governing repair and replacement activities. These established procedures are governed by Entergy's 10 CFR 50 Appendix B QA program and meet the applicable repair or replacement requirements

ATTACHMENT 2 TO NL-08-021 Regulatory Commitment List, Revision 3 ENTERGY NUCLEAR OPERATIONS, INC.

INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 & 3 DOCKET NOS. 50-247 AND 50-286

NL-08-021 Attachment 2 Docket Nos. 50-247 & 50-286 Page lof 16 List of Regulatory Commitments Rev. 3 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 SOURCE RELATED SCHEDULE LRA SECTION I AUDIT ITEM Enhance the Aboveground Steel Tanks Program for P2: NL-07-039 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, 2013 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: NL-07-039 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 2013 B.1.2 prohibition on use of lubricants containing MoS 2 for 1P3: NL-07-153 Audit Items bolting. December 12, 201,241, The Bolting Integrity Program manages loss of 2015 270

_ preload and loss of material for all external bolting.

3 Implement the Buried Piping and Tanks Inspection P2: NL-07-039 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 NL-07-153 Audit Item This new program will be implemented consistent with IP3: 173 the corresponding program described in NUREG- December 12, 1801 Section XI.M34, Buried Piping and Tanks 2015 Inspection.

NL-08-021 Attachment 2 Docket Nos. 50-247 & 50-286 Page 2 of 16 COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION I AUDIT ITEM eP2: NL-07-039 A.2.1.8 4 Enhance the Diesel Fuel Monitoring Program to of the IP2 GT-1 gas September 28, A.3.1.8 include cleaning and inspection IP3 EDG fuel oil 013 B.1.9 turbine fuel oil storage tanks, IP2 and NL-07-153 Audit items N 7P3: 128, 129, day tanks, IP2 SBO/Appendix R diesel generator fuel 132 oil day tank, and IP3 Appendix R fuel oil storage tank December 12, D015 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/l. 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 program.

Enhance the Diesel Fuel Monitoring Program to direct samples be taken near the tank bottom and include direction to remove water when detected.

Enhance the Diesel Fuel Monitoring Program to direct the addition of chemicals including biocide when the presence of biological activity is confirmed.

NL-08-021 Attachment 2 Docket Nos. 50-247 & 50-286 Page 3 of 16

1. COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION I AUDIT ITEM 1P2: NL-07-039 A.2.1.10 5 Enhance the External Surfaces Monitoring Program September 28, A.3.1.10 for IP2 and IP3 to include periodic inspections of 2013 B.1.11 systems in scope and subject to aging management review for license renewal in accordance with 10 CFR IP3:

54.4(a)(1) and (a)(3). Inspections shall include areas December 12, surrounding the subject systems to identify hazards to 015 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).

1P2: NL-07-039 A.2.1.11 6 Enhance the Fatigue Monitoring Program for IP2 to September 28, A.3.1.11 monitor steady state cycles and feedwater cycles or 013 B.1.12, perform an evaluation to determine monitoring is not Audit Item required. Review the number of allowed events and 164 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.

NL-08-021 Attachment 2 Docket Nos. 50-247 & 50-286 Page 4 of 16 COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION I AUDIT ITEM IP2: NL-07-039 A.2.1.12 7 Enhance the Fire Protection Program to inspect September 28, A.3.1.12 external surfaces of the IP3 RCP oil collection 2013 B.1.13 systems for loss of material each refueling cycle.

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.

NL-08-021 Attachment 2 Docket Nos. 50-247 & 50-286 Page 5 of 16 COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION I_ IjI/I IAUDIT ITEM IP2: NL-07-039 A.2.1.13 8 Enhance the Fire Water Program to include inspection A.3.1.13 September 28, of IP2 and IP3 hose reels for evidence of corrosion. B.1.14 2013 Acceptance criteria will be revised to verify no NL-07-153 Audit Items unacceptable signs of degradation. IP3: 105, 106 Enhance the Fire Water Program to replace all or test December 12, NL-08-014 a sample of IP2 and IP3 sprinkler heads required for 2015 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 foam based fire suppression tanks.

Acceptance criteria will be enhanced to verify no siqnificant corrosion.

NL-08-021 Attachment 2 Docket Nos. 50-247 & 50-286 Page 6 of 16 COMMITMENT IMPLEMENTATION SOURCE I RELATED SCHEDULE LRA SECTION I 4I AUDIT ITEM IP2: NL-07-039 A.2.1.15 9 Enhance the Flux Thimble Tube Inspection Program September 28, A.3.1.15 for IP2 and IP3 to implement comparisons to wear 2013 B.1.16 rates identified in WCAP-12866. Include provisions to compare data to the previous performances and IP3:

perform evaluations regarding change to test December 12, frequency and scope. 2015 Enhance the Flux Thimble Tube Inspection Program for IP2 and IP3 to specify the acceptance criteria as outlined in WCAP-12866 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.

NL-08-021 Attachment 2 Docket Nos. 50-247 & 50-286 Page 7 of 16 COMMITMENT IMPLEMENTATIONI SOURCE RELATED SCHEDULE LRA SECTION I I I /IAUDIT ITEM 10 Enhance the Heat Exchanger Monitoring Program for IP2: NL-07-039 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.t17, NL-07-153 Audit Item

" Safety injection pump lube oil heat exchangers IP3: 52 0 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

• Charging pump crankcase oil coolers

• 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 siqns of degradation.

NL-08-021 Attachment 2 Docket Nos. 50-247 & 50-286 Page 8 of 16

1. COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION I AUDIT ITEM 11 Enhance the ISI Program for IP2 and IP3 to provide IP2: NL-07-039 A.2.1.17 periodic visual inspections to confirm the absence of September 28, A.3.1.17 aging effects for lubrite sliding supports used in the agingurieNL-07-153 013 B.1.18 Audit item NP3: 59 steam generator and reactor coolant pump support systems. December 12, 2015 12 Enhance the Masonry Wall Program for IP2 and IP3 IP2: NL-07-039 A.2.1.18 to specify that the IP1 intake structure is included in September 28, A.3.1.18 2013 8.1.19 the program.

IP3:

December 12, 2015 Enhance the Metal-Enclosed Bus Inspection Program IP2: NL-07-039 A.2.1.19 13 September 28, A.3.1.19 to add IP2 480V bus associated with substation A to the scope of bus inspected. 013 B.1.20 NL-07-153 Audit Item Enhance the Metal-Enclosed Bus Inspection Program 1P3: 124 for IP2 and IP3 to visually inspect the external surface December 12, Audit Item of MEB enclosure assemblies for loss of material at 2015 133 least once every 10 years. The first inspection will occur prior to the period of extended operation and the acceptance criterion will be no significant loss of material.

Enhance the Metal-Enclosed Bus Inspection Program for 1P2 and 1P3 to inspect bolted connections at least once every five years if performed visually or at least once every ten years using quantitative measurements such as thermography or contact resistance measurements. The first inspection will occur prior to the period of extended operation.

The plant will process a change to applicable site procedure to remove the reference to "re-torquing" connections for phase bus maintenance and bolted connection maintenance.

Implement the Non-EQ Bolted Cable Connections 1P2: NL-07-039 A.2.1.21 14 Program for IP2 and IP3 as described in LRA Section eptember 28, A.3.1.21 B.1.22. 2013 B.1.22 IP3:

December 12, 2015

NL-08-021 Attachment 2 Docket Nos. 50-247 & 50-286 Page 9 of 16

1. COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION I AUDIT ITEM 15 Implement the Non-EQ Inaccessible Medium-Voltage IP2: NL-07-039 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 NL-07-153 Audit item This new program will be implemented consistent with IP3: 173 the corresponding program described in NUREG- December 12, 1801 Section XI.E3, Inaccessible Medium-Voltage 2015 Cables Not Subject To 10 CFR 50.49 Environmental Qualification Requirements.

16 Implement the Non-EQ Instrumentation Circuits Test IP2: NL-07-039 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 NL-07-153 Audit item This new program will be implemented consistent with 1P3: 173 the corresponding program described in NUREG- December 12, 1801 Section XI.E2, Electrical Cables and 2015 Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Used in Instrumentation Circuits.

17 Implement the Non-EQ Insulated Cables and IP2: NL-07-039 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 NL-07-153 Audit item This new program will be implemented consistent with IP3: 173 the corresponding program described in NUREG- December 12, 1801 Section XI.E1, Electrical Cables and 2015 Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements.

NL-08-021 Attachment 2 Docket Nos. 50-247 & 50-286 Page 10 of 16

1. COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION I AUDIT ITEM 18 Enhance the Oil Analysis Program for IP2 to sample IP2: NL-07-039 A.2.1.25 and analyze lubricating oil used in the SBO/Appendix September 28, A.3.1.25 R diesel generator consistent with oil analysis for 2013 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.

19 Implement the One-Time Inspection Program for IP2 IP2: NL-07-039 A.2.1.26 and IP3 as described in LRA Section B.1.27. September 28, A.3.1.26 2.013 B.1.27 This new program will be implemented consistent with NL-07-153 Audit item the corresponding program described in NUREG- IP3: 173 1801,Section XI.M32, One-Time Inspection. December 12, 2015 20 Implement the One-Time Inspection - Small Bore 1P2: NL-07-039 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 NL-07-153 Audit item This new program will be implemented consistent with lP3: 173 the corresponding program described in NUREG- December 12, 1801,Section XI.M35, One-Time Inspection of ASME 2015 Code Class I Small-Bore Piping.

21 Enhance the Periodic Surveillance and Preventive IP2: NL-07-039 A.2.1.28 Maintenance Program for IP2 and IP3 as necessary eptember 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 2015 1 operation.

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1. COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION IAUDIT

/ ITEM 22 Enhance the Reactor Vessel Surveillance Program for IP2: NL-07-039 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 1P3:

through the end of the period of extended operation. 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 I vessel are maintained in storage.

23 Implement the Selective Leaching Program for IP2 IP2: NL-07-039 A.2.1.32 and IP3 as described in LRA Section B.1.33. September 28, A.3.1.32 2013 B.1.33 This new program will be implemented consistent with NL-07-153 Audit item the corresponding program described in NUREG- 1P3: 173 1801,Section XI.M33 Selective Leaching of Materials. December 12, 2015 24 Enhance the Steam Generator Integrity Program for IP2: NL-07-039 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 2013 B.1.35 operational assessment performed for the prior IP3:

operating cycle with differences evaluated. De December r112, 2015 25 Enhance the Structures Monitoring Program to IP2: NL-07-039 A.2.1.35 explicitly specify that the following structures are September 28, A.3.1.35 included in the program. 2013 B.1.36

" Appendix R diesel generator foundation (IP3) NL-07-153

" Appendix R diesel generator fuel oil tank vault IP3: Audit item (IP3) December 12, 86

• Appendix R diesel generator switchgear and 2015 enclosure (IP3) Audit item

• city water storage tank foundation 88

• condensate storage tanks foundation (IP3) Audit Item

• containment access facility and annex (IP3) 87

• 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 (IP2)

• new station security building (IP2)

NL-08-021 Attachment 2 Docket Nos. 50-247 & 50-286 Page 12 of 16 COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION I /IAUDIT ITEM

• 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 (including their anchorages) 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

" 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.

NL-08-021 Attachment 2 Docket Nos. 50-247 & 50-286 Page 13 of 16 COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION I AUDIT ITEM 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). IPEC will obtain samples from at least 5 wells that are representative of the ground water surrounding below-grade site structures.

Samples will be monitored for sulfates, pH and chlorides.

Enhance the Structures Monitoring Program for IP2 and IP3 to perform inspection of normally submerged concrete portions of the intake structures at least once every 5 years.

26 Implement the Thermal Aging Embrittlement of Cast IP2: NL-07-039 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. 2013 B.1.37 NL-07-153 Audit item This new program will be implemented consistent with IP3: 173 the corresponding program described in NUREG- December 12, 1801,Section XI.M12, Thermal Aging Embrittlement 2015 of Cast Austenitic Stainless Steel (CASS) Program.

27 Implement the Thermal Aging and Neutron Irradiation IP2: NL-07-039 A.2.1.37 Embrittlement of Cast Austenitic Stainless Steel September 28, A.3.1.37 (CASS) Program for IP2 and IP3 as described in LRA 2013 B.1.38 Section B.1.38. NL-07-153 Audit item IP3: 173 This new program will be implemented consistent with December 12, the corresponding program described in NUREG- 2015 1801 Section XI.M13, Thermal Aging and Neutron Embrittlement of Cast Austenitic Stainless Steel (CASS) Program.

28 Enhance the Water Chemistry Control - Closed IP2: NL-07-039 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.

NL-08-021 Attachment 2 Docket Nos. 50-247 & 50-286 Page 14 of 16 COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION I AUDIT ITEM 29 Enhance the Water Chemistry Control - Primary and IP2: NL-07-039 A.2.1.40 Secondary Program for IP2 to test sulfates monthly in September 28, B.1.41 013 the RWST with a limit of <1 50 ppb.

30 For aging management of the reactor vessel internals, 1P2: NL-07-039 A.2.1.41 IPEC will (1) participate in the industry programs for September 28, A.3.1.41 011 investigating and managing aging effects on reactor internals; (2) evaluate and implement the results of the industry programs as applicable to the reactor P3:

D)ecember 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.

IP2: NL-07-039 A.2.2.1.2 31 Additional P-T curves will be submitted as required 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 2013 4.2.3 Surveillance Program. IP3:

December 12, 2015 32 As required by 10 CFR 50.61 (b)(4), IP3 will submit a IP3: NL-07-039 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.

NL-08-021 Attachment 2 Docket Nos. 50-247 & 50-286 Page 15 of 16 COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LLRA SECTION I AUDIT ITEM 33 At least 2 years prior to entering the period of IP2: NL-07-039 A.2.2.2.3 extended operation, for the locations identified in LRA September 28, A.3.2.2.3 Table 4.3-13 (IP2) and LRA Table 4.3-14 (IP3), under 2011 4.3.3 the Fatigue Monitoring Program, IP2 and IP3 will NL-07-153 Audit item implement one or more of the following: IP3: 146 December 12, NL-08-021 (1) Consistent with the Fatigue Monitoring Program, 2013 Detection of Aging Effects, update the fatigue usage calculations using Rrefined the fatigue analyses to determine valid CUFs less than 1.0 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 in LRA Table 4.3-13 (IP2) and LRA Table 4.3-14 (1P3) including NUREG!CR 6260 le.ati*n,, with existing fatigue analysis valid for the period of extended operation, use the existing CUF.-te determine thc eirnntally adijusted CU.F-.

2. Inadditin to the NUREGICR 6260 locations,' mFAe kiiting Additional 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 ifdemonstrated applicable to IPEC.

4. An analysis using an NRC-approved version of the ASME code or NRC-approved alternative (e.g., NRC-approved code case) may be performed to determine a valid CUF.

(2)Manage the offects of aging due to fatigue at th affected locations by an inspection prgram that has been roviewed and approved by the NRC (e.g., peFrodi c.no deStructive examination of the affected locations-at i~sperstieR intewals to be determnined by a mnethod accGeptable to the NRC).

(3) (2)Consistent with the Fatigue Monitoring Pro-gram, Corrective Actions, Rrepair or replace the affected locations before exceeding a CUF of 1.0.

Should WIE* select the option to manage the aging effects due to Mental Bnviroassisted fatigue during the period of extended operation, details of the ag-n mangemnent program such as scope, qualification, mrethod, and frequency will hp izwhmniftfcI in thp WIRC :;t IP:;Q 2 ix:;c j - nrinr w r-.-

ie Re ~n-ueri aRa4 Ai texnded eacrfilfl-.

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1. COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION

/IAUDIT ITEM 34 IP2 SBO /Appendix R diesel generator will be April 30, 2008 NL-07-078 2.1.1.3.5 installed and operational by April 30, 2008. This committed change to the facility meets the requirements of 10 CFR 50.59(c)(1) and, therefore, a license amendment pursuant to 10 CFR 50.90 is not required.