HNP-06-136, License Renewal - Resolution of Confirmatory Items and License Renewal Application Amendment 7

License Renewal - Resolution of Confirmatory Items and License Renewal Application Amendment 7

ML081200755
Person / Time
Site:	Harris
Issue date:	04/23/2008
From:	Burton C Progress Energy Carolinas
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
HNP-06-136, HNP-08-029
Download: ML081200755 (19)

Text

C Progress Energy SERIAL: HNP-08-029 10 CFR 54 APR 2 3 '2008 U. S. Nuclear Regulatory Commission ATTENTION: Document Control Desk Washington, DC 20555

Subject:

SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. I DOCKET NO. 50-400 / LICENSE NO. NPF-63 LICENSE RENEWAL - RESOLUTION OF CONFIRMATORY ITEMS AND LICENSE RENEWAL APPLICATION AMENDMENT 7

References:

1. Letter from Cornelius J. Gannon to the U. S. Nuclear Regulatory Commission (Serial: HNP-06-136), "Application for Renewal of Operating License," dated November 14, 2006

2. Letter from P. T. Kuo (NRC) to Robert J. Duncan II, "Safety Evaluation Report with Open Items Related to the License Renewal of the Shearon Harris Nuclear Power Plant, Unit 1," dated March 18, 2008 Ladies and Gentlemen:

On November 14, 2006, Carolina Power & Light Company, doing businress as Progress Energy Carolinas, Inc. (PEC), requested the renewal of the operating license for the Shearon Harris Nuclear Power Plant, Unit No. 1, also known as the Harris Nuclear Plant (HNP), to extend the term of its operating license an additional 20 years beyond the current expiration date.

By letter dated March 18, 2008, the Nuclear Regulatory Commission (NRC) issued the Safety Evaluation Report with Open Items Related to the License Renewal of the Shearon Harris Nuclear Power Plant, Unit 1. Section 1.5 of the report identified one Open Item (01),

and Section 1.6 of the report identified two Confirmatory Items (CIs) for which resolution had been achieved but formal submittal of the resolution remained to be done. This letter submits the information to close the CIs and requests an extension of the deadline to submit the information for closure of the 01 until June 30, 2008.

In support of closure of the CIs, revisions to the information submitted in the HNP License Renewal Application (LRA) are required. Also, resolution of the CIs requires changes to the HNP License Renewal Commitments.

Progress Energy Carolinas, Inc.

Harris Nuclear Plant P. 0. Box 165 New Hill, NC 27562

,A 12 (ýý

Document Control Desk HNP-08-029 / Page 2 Therefore, this letter contains three enclosures. Enclosure 1 provides the information required to resolve the CIs. Enclosure 2 is a table that identifies the changes to the LRA; the changes constitute LRA Amendment 7. Enclosure 3 is the list of HNP regulatory commitments supporting License Renewal modified to reflect the information provided in. Any actions, other than those identified in Enclosure 3, should be considered intended or planned actions; they are included for informational purposes but are not considered to be regulatory commitments.

Please refer any questions regarding this submittal to Mr. Roger Stewart, Supervisor -

License Renewal, at (843) 857-5375.

I declare, under penalty of perjury, that the foregoing is true and correct (Executed on APR 2 3 2008

)"

Sincerely, Christopher L. Burton Director - Site Operations Harris Nuclear Plant CLB/mhf

Enclosures:

1. Resolution of License Renewal Confirmatory Items

2. Amendment 7 Changes to the License Renewal Application

3. HNP License Renewal Commitments, Revision 5 cc:

Mr. P. B. O'Bryan (NRC Senior Resident Inspector, HNP)

Ms. B. 0. Hall (Section Chief, N.C. DENR)

Mr. M. L. Heath (NRC License Renewal Project Manager, HNP)

Ms. M. G. Vaaler (NRC Project Manager, HNP)

Mr. V. M. McCree (NRC Acting Regional Administrator, Region II)

HNP-08-029 Page 1 of 4 Resolution of License Renewal Confirmatory Items

Background

On November 14, 2006, Carolina Power & Light Compa~ny, doing business as Progress Energy Carolinas, Inc. (PEC), submitted a License Renewal Application (LRA) and requested renewal of the operating license for the Shearon Harris Nuclear Power Plant, Unit No. 1, also known as the Harris Nuclear Plant (FINP), to extend the term of its operating license an additional 20 years beyond the current expiration date.

By letter dated March 18, 2008, the Nuclear Regulatory Commission (NRC) issued the Safety Evaluation Report (SER) with Open Items Related to the License Renewal of the Shearon Harris Nuclear Power Plant, Unit 1. Section 1.6 of the SER identified two Confirmatory Items (CIs) for which resolution had been achieved but formal submittal of the resolution remained to be done.

The requisite information to close the CIs is provided below.

Confirmatory Item 3.4-1 (SER Section 3.4 - Steam and Power Conversion Systems)

In LRA Section 3.4, the applicant has credited its External Surfaces Monitoring Program, in conjunction with the program enhancement in LRA Commitment No. 18, to manage changes in materials and cracking for elastomeric piping, piping components and piping elements, as well as thermoplastic piping, piping components and piping elements.

The staff has determined that this enhancement in Commitment No. 18: (1) does not specifically reference elastomeric or thermoplastic materials, (2) is made on a matter that is not specifically addressed within the scope of GALL AMP XI.M36, "External Surfaces Monitoring," and (3) does not provide any provision that the specific inspection method and acceptance criteria for future inspections of elastomeric and thermoplastic components under the External Surfaces Monitoring Program would be submitted for NRC review and approval. The staff raised these issues in a RAI letter dated January 7, 2008.

The staff reviewed the applicant's responses dated January 17, 2008 and found that the responses did not address all elastomeric and thermoplastic components. The staff was not satisfied with the applicant's response. The staff discussed the issue with the applicant on a conference call and it was agreed that the elastomeric and thermoplastic (with the exception of the condensate storage tank diaphram) components will be placed in a Preventive Maintenance Program with periodic replacement. The condensate storage tank diaphram will be added to the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program. The applicant agreed to provide this in a docketed correspondence. This is CI 3.4-1.

HNP-08-029 Page 2 of 4 Response to Confirmatory Item 3.4-1 With the exception of the Condensate Storage Tank (CST) diaphragm, addressed separately below, HNP will re-evaluate the elastomeric and thermoplastic components addressed in the Request for Additional Information (RAI) response letter, to the NRC (Serial: HNP-08-001),

dated January 17, 2008, (specifically, the components addressed in the responses to RAls 3.4-2, 3.4-3, 3.4-4, 3.4-5, 3.4-7, and 3.4-8) as short-lived consumables. Screening of consumables is identified in HNP LRA Section 2.1.2.1 and is based on guidance in NUREG-1800, "Standard Review Plan for the Review of License Renewal Applications for Nuclear Power Plants," Rev. 1, Table 2.1-3, and in NEI 95-10, "Industry Guideline for Implementing the Requirements of 10 CFR Part 54 - The License Renewal Rule," Rev. 6, Table 4.1-2. As short-lived, the subject components will be periodically replaced. Since the subject components will be periodically replaced, they do not require aging management review. The replacement frequency will be based on the guidance in HNP's Preventive Maintenance (PM) Program. The PM program guidance for determining the frequency of a PM activity uses established PM basis documents, requirements determined from Technical Specifications, the FSAR, vendor recommendations, equipment history, site and industry operating experience, and requirements developed under other specific engineering and site programs.

Therefore, HNP makes the following commitment. (Note that RAI 3.4-8 addresses the thermoplastic diaphragm in the CST and thermoplastic tubing in the Secondary Sampling System. The tubing in the Secondary Sampling System is also addressed in RAI 3.4-3, and the CST diaphragm is addressed separately below. Therefore, the scope of the following commitment includes the components addressed in RAIs 3.4-2, 3.4-3, 3.4-4, 3.4-5, and 3.4-7.)

Prior to entering the period of extended operation, HNP will replace the subject elastomeric and thermoplastic components referenced in RAIs 3.4-2, 3.4-3, 3.4-4, 3.4-5, and 3.4-7 and add them to the Preventive Maintenance Program. HNP will perform an evaluation to determine the frequency of periodic replacement of the components during the period of extended operation based on the guidance in the HNP Preventive Maintenance Program.

The Condensate Storage Tank diaphragm is subject to periodic inspection every fifth refueling outage. This component was replaced in 1994 and was inspected most recently in 2006 and found to be in good condition. Since this component is already periodically inspected, HNP will add the inspection to the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program.

Based on the above information, an LRA amendment is required.

HINP-08-029 Page 3 of 4 Confirmatory Item 4.3 (SER Section 4.3 - Metal Fatigue)

The staff requested the applicant to clarify the apparent discrepancy with two different CUF values for the pressurizer lower head. The staff reviewed the applicant's response dated January 17, 2008, and found that the applicant clarified how the design basis transients for the HNP surge line, charging nozzle, and pressurizer lower head and surge nozzle were redefined based on changes that were made to the plant design. The applicant also stated that, although the plant operational transients had been redefined, the design specification had not been updated. The staff position is that an ASME design report should follow the design specification and that if design conditions change, an updated design specification should reflect the change(s).

Also, the staff requests that FSAR supplement Section A. 1.2.2.10 be updated to reflect that the applicant is crediting its Reactor Coolant Pressure Boundary Metal Fatigue Program as the basis for accepting its TLAA on environmentally-assisted metal fatigue, as assessed relative to the HNP surge line, charging nozzle, and pressurizer lower head and surge nozzle, in accordance with 10 CFR 54.21 (c)(1)(iii), in that the effects of aging will be managed for the period of extended operation.

The staff discussed the issue with the applicant on a teleconference and it was agreed that the applicant will add a new commitment to update, prior to the period of extended operation, the piping design specifications to reflect design basis transients and provide an FSAR supplement to address the HNP surge line, charging nozzle, and pressurizer lower head and surge nozzle, in accordance with 10 CFR 54.21(c)(1)(iii). This is CI 4.3.

Response to Confirmatory Item 4.3 The responses to this confirmatory item can be divided into two parts:

1. Add a commitment to update the design specification for the operational transients, and

2. Amend the LRA to revise FSAR Supplement Subsection A. 1.2.2. 10 for the HNP surge line, charging nozzle, and pressurizer lower head and surge nozzle to include a statement that they will be managed in accordance with 10 CFR 54.21 (c)(1)(iii).

Part I The operational transients that were redefined are discussed in the response to NRC Audit Question LRA 4.3.3-5 (Follow-up), which is contained in HNP letter to the NRC (Serial: HNP-08-001), "License Renewal Application - Amendment 6 and Responses to Requests for Additional Information related to aging Management Reviews and Time-Limited Aging Analyses," dated January 17, 2008. A commitment to update the piping design specification will be added to the HNP LR Commitments. The commitment will state that, prior to the period of extended operation, HNP will update the piping design, specification to reflect the current design basis operational transients used in the Time-Limited Aging Analyses for the reactor coolant pressure boundary.

HNP-08-029 Page 4 of 4 Part 2 The following paragraph will be added to the end of FSAR Supplement Subsection A. 1.2.2.2.10 as described in the HNP letter to the NRC (Serial: HNP-07-119)," License Renewal Application, Amendment 2: Changes Resulting from Responses to Site Audit Questions Regarding Time-Limited Aging Analyses," dated August 31, 2007:

The Reactor Vessel Shell and Lower Head and Reactor Vessel Inlet and Outlet Nozzles are addressed in A. 1.2.2.1 and their analyses has been projected through the period of extended operation using 10 CFR 54.21(c)(1) method (ii). Reactor Coolant Pressure Boundary Piping (ASME Class 1) components are addressed in A. 1.2.2.7. For these components, the effects of fatigue will be managed for the period of extended operation in accordance with 10 CFR 54.21 (c)(1)(iii). The pressurizer lower head and surge nozzle are addressed in A. 1.2.2.6 and the effects of fatigue will be managed for the period of extended operation in accordance with 10 CFR 54.21 (c)(1)(iii).

Based on the above information, an LRA amendment is required.

HNP-08-029 Page 1 of 2 Amendment 7 Changes to the License Renewal Application Source of License Renewal Application (LRA) Amendment 7 Changes Change Resolution of Confirmatory Item 3.4-1 Revise LRA Subsection 3.4.2.1.3 for the Main Sfeam Supply System, on Page 3.4-6, to delete the materials "Elastomers" and "PVC or Thermoplastics," the Environment "Radiation (Ultraviolet),"

and the Aging Effect Requiring Management "Change in Material Properties."

Revise LRA Subsection 3.4.2.1.6 for the Feedwater System, on Pages 3.4-8 and 3.4-9, to delete the material "Elastomers," the Aging Effect Requiring Management "Change in Material Properties," and the Aging Management Program "External Surfaces Monitoring Program."

Revise LRA Subsection 3.4.2.1.11 for the Secondary Sampling System, on Page 3.4-13, to delete the material "Thermoplastic," the Environments "Air/Gas Wetted" and "!'Radiation (Ultraviolet),"

and the Aging Effect Requiring Management "Change in Material Properties."

Revise LRA Table 3.4.2-3, on Page 3.4-44, by deleting the aging management review (AMR) line items for "Elastomers" and "PVC or Thermoplastics."

Revise LRA Table 3.4.2-6, on Page 3.4-53, by deleting the AMR line items for "Elastomers."

Revise LRA Table 3.4.2-11, on Page 3.4-72, by deleting the AMR line, items for "Thermoplastic."

Delete Plant-Specific Notes 404 and 405 on LRA Page 3.4-76.

Delete Plant-Specific Notes 408 and 411 on LRA Page 3.4-77.

The above changes are the basis for Commitment #36.

Revise LRA Subsection 3.4.2.1.10 for the Condensate Storage System,, on Page 3.4-12, to add the Aging Effects Requiring Management of "Cracking" and "Change in Material Properties," and to add the Aging Management Program "Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program."

Revise LRA Table 3.4.2-10, on Page 3.4-67, for the material "Thermoplastic" in both the Treated Water (Inside) environment and in the Air/Gas (Wetted) (Outside) environment, as follows:

Aging Effect Requiring Aging Management NUREG-1801

'ýTable N

Management Program Volume 2 Item Item______

Change in Material Properties due to Various Degradation Mechanisms Cracking due to Various Degradation Mechanisms Inspection of Internal Surfaces in Miscel-laneous Piping and Ducting Components J, 407

HNP-08-029 Page 2 of 2 Source of Chanige License Renewal Application (LRA) Amendment 7 Changes Resolution of Confirmatory Item 4.3 Revise LRA Appendix A, Subsection A. 1.1 by adding the following paragragh:

Prior to the period of extended operation, HNP will update the piping design specification to reflect the current design basis operational transients used in the Time-Limited Aging Analyses for the reactor coolant pressure boundary.

Also, revise LRA Appendix A, Subsection A. 1.2.2.2.10 entitled "Environmentally-Assisted Fatigue Analysis" by adding the following paragragh to the end of the subsection:

The Reactor Vessel Shell and Lower Head and Reactor Vessel Inlet and Outlet Nozzles are addressed in A. 1.2.2.1 and their analyses has been projected through the period of extended operation using 10 CFR 54.21 (c)(1) method (ii). Reactor Coolant Pressure" Boundary Piping (ASME Class 1) components are addressed in A. 1.2.2.7.

For these components, the effects of fatigue will be managed for the period of extended operation in accordance with 10 CFR 54.21(c)(l)(iii). The pressurizer lower head and surge nozzle are addressed in A. 1.2.2.6 and the effects of fatigue will be managed for the period of extended operation in accordance with 10 CFR 54.2 l(c)(1)(iii).

14NP-08-029 Page 1 of 11 In accordance with the guidance ofNUREG-1801, Rev. 1, regarding aging management of reactor vessel internals components, HNP will:

(1) participate in the industry programs for investigating and managing aging effects on reactor internals (such as Westinghouse Owner's Group and Electric Power Research Institute materials programs),

(2) evaluate and implement the results of the industry programs as applicable to the reactor internals, and (3) upon completion of these programs, 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.

As stated in the commitment Meacwor veSSet ientrnaIs Aging Management Activities LRA Section A. 1.1 2

In accordance with the guidance ofNUREG-1801, Rev. 1, regarding A. 1.1 As stated in the Primary Water Stress aging management of nickel alloy and nickel-clad components commitment Corrosion Cracking of susceptible to primary water stress corrosion cracking, HNP will Nickel Alloys comply with applicable NRC Orders and will implement: (1) applicable Bulletins and Generic Letters, and (2) staff-accepted LRA Section A. 1.1 industry guidelines.

3 Program inspections are performed as augmented inspections in the A. 1.1.5 Prior to the period of Nickel-Alloy Penetration HNP Inservice Inspection (ISI) Program. The ISI Program extended operation Nozzles Welded to the administrative controls will be enhanced to specifically identify the Upper Reactor Vessel requirements of NRC Order EA-03-009.

Closure Heads of Pressurized Water Reactors Program LRA Section B.2.5 4

The Thermal Aging and Neutron Irradiation Embrittlement of Cast A. 1.1.6 Prior to the period of Thermal Aging and Austenitic Stainless Steel (CASS) Program is a new program to be extended operation Neutron Irradiation implemented.

Embrittlement of Cast Austenitic Stainless Steel (CASS) Program LRA Section B.2.6

HNP-08-029 Page 2 of 11 The Program will be enhanced to provide a consolidated exclusion bases document (i.e., a FAC susceptibility analysis). The exclusion bases document will include an evaluation of the Steam Generator Feedwater Nozzles to determine their susceptibility to FAC.

rI1u1 LU LIIX pr Iuu uI extended operation i iL, rIUW-IALL.WUIdLVU Corrosion (FAC)

Program LRA Section B.2.7 6

A precautionary note will be added to plant bolting guidelines to A. 1.1.8 Prior to the period of Bolting Integrity prohibit the use of molybdenum disulfide lubricants, extended operation Program LRA Section B.2.8 7

The Program implementing procedure will be enhanced to include a A. 1.1.9 Prior to the period of Steam Generator Tube description of the instructions for implementing corrective actions if extended operation Integrity Program tube plugs or secondary-side components (e.g., tube supports) are found to be degraded.

LRA Section B.2.9 8

The Program will be enhanced to: 1) include measurements of actual A. 1.1.12 Prior to the period of Boraflex Monitoring boron areal density using in-situ techniques, 2) include neutron extended operation, Program attenuation testing ("blackness testing"), to determine gap formation in unless an approved Boraflex panels, and 3) include the use of the EPRI RACKLIFE analysis exists that LRA Section B.2.12 predictive code or its equivalent, eliminates credit for the Boraflex in the BWR fuel racks 9

The Program will be enhanced to: (1) include in the Program all cranes A. 1.1.13 Prior to the period of Inspection of Overhead within the scope of License Renewal; (2) require the responsible extended operation Heavy Load and Light engineer to be notified of unsatisfactory crane inspection res-ults; Load Handling Systems (3) specify an annual inspection frequency for the Fuel Cask Handling Program Crane, Fuel Handling Bridge Crane, and Fuel handling Building Auxiliary Crane, and every refuel cycle for the Polar Crane, Jib LRA Section B.2.13; Cranes, and Reactor Cavity Manipulator Crane, and (4) include a Response to Audit requirement to inspect for bent or damaged members, loose Question B.2.13 -JW-0 1 bolts/components, broken welds, abnormal wear of rails, and corrosion (other than minor surface corrosion) of steel members and connections. I

HNP-08-029 Page 3 of 11 I ne program will be enhanced to: (1) include inspection criteria as described in NUREG-1801 for penetration seals, (2) provide specific procedural guidance for inspecting fire barrier walls, ceilings and floors, (3) include a visual inspection of the diesel-driven fire pump fuel oil supply piping for signs of leakage, and (4) include minimum qualification requirements for inspectors performing inspections required by this Program.

Prior to the period ot extended operation LRA Section B.2.14 11 The Program will be revised to: (1) incorporate a requirement to perform one or a combination of the following two activities:

(a) Perform non-intrusive baseline pipe thickness measurements at various locations, prior to the expiration of current license and trended through the period of extended operation. The plant-specific inspection intervals will be determined by engineering evaluation performed after each inspection of the fire protection piping to detect degradation prior to the loss of intended function, or (b) Perform flow testing meeting the general flow requirements (intent) of NFPA 25, (2) either replace the sprinkler heads prior to reaching their 50-year service life or revise site procedures to perform field service testing, by a recognized testing laboratory, of representative samples from one or more sample areas, and (3) for in-scope spray nozzles, either (a) add a requirement to perform flow testing to ensure proper spray pattern or (b) add a modification to prevent blockage from external sources.

A. 1.1.15 Prior to the period of extended operation Fire Water System Program LRA Section B.2.15 Commitment (1)(b) and the option of using a combination of (1)(a) and (*)(b) were added in the response to Audit Question B.2.15-PB-01 Commitment (3) was added per Audit Question 3.3.1-70-MK-01

HNP-08-029 Page 4 of 11 Program administrative controls will be enhanced to: (1) add requirements to enter an item into the corrective action program whenever an administrative value or control limit for parameters relevant to this program are exceeded or water is drained from a fuel oil tank in the scope of this program; (2) establish administrative values for fuel oil chemistry parameters relating to corrosion; (3) require Diesel Fuel Oil System chemistry controls to include semiannual monitoring and trending of water and sediment and particulates from an appropriate sample point for the day tanks and semiannual monitoring and trending of biological growth in the main storage tanks; (4) require Security Power System fuel oil chemistry controls to include semiannual monitoring and trending of biological growth in the fuel oil in the buried storage tank and periodic inspecting of the internal surfaces of the buried storage tank and the aboveground day tank or require UT or other NDE of the tanks if inspection proves inadequate or indeterminate; (5) require Site Fire Protection System fuel oil chemistry controls for the Diesel Driven Fire Pump fuel oil storage tank to include quarterly monitoring and trending of particulates and semiannual monitoring and trending of biological growth, to check and remove water quarterly, to periodically inspect the tank or require UT or other NDE of the tank if inspection proves inadequate or indeterminate; and to revise chemistry sampling procedures to address positive results for biological growth including as oneoption the use of biocides; and (6) verify the condition of the Diesel Fuel Oil Storage Tank Building Tank Liners by means of bottom thickness measurements under the One Time Inspection Program. Day tank sampling for water, sediment, and particulate contamination is considered to be confirmatory of components outside the main storage tanks, and its frequency may be adjusted based on site operating experience.

Frior to tne period oi extended operation ruei uli cnemistry Program LRA Section B.2.16, Response to Audit Question B.2.16-MK-12 I

HNP-08-029 Page 5 of 11 HA~RRIS NU CLEAR PElANT LICE'.NSE.RENE.WA.I, COMMITMENTS, RE~iNI,()-5 F..NAL............

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IP o!R The Program will be enhanced to: (1) include a provision that tested A. 1.1.17 Prior to the period of Reactor Vessel and untested specimens from all capsules pulled from the reactor extended operation Surveillance Program vessel must be kept in storage to permit future reconstitution use, and that the identity, traceability, and recovery of the capsule specimens LRA Section B.2.17, shall be maintained throughout testing and storage, (2) include a RAI-B.2.17 provision that withdrawal of the next capsule (i.e., Capsule W) will occur during Refueling Outage 16, at which time the capsule fluence is projected to be equivalent to the 60-year maximum vessel fluence of 6.8x10' 9 n/cm2 in accordance with ASTM E 185-82, (3) include a provision that analysis of Capsule W be used to evaluate neutron exposure for remaining Capsules Y and Z, as required by 10 CFR 50 Appendix H. The withdrawal schedule for one of the remaining capsules will be adjusted, based on the analysis of Capsule W, so that the capsule fluence will not exceed twice the 60-year maximum vessel fluence in accordance with ASTM E 185-82. The neutron exposure and withdrawal schedule for the last capsule will be optimized to provide meaningful metallurgical data. If the last capsule is projected to significantly exceed a meaningful fluence value, it will either be relocated to a lower flux position or withdrawn for possible testing or re-insertion. Capsules Y and Z and archived test specimens available for reconstitution will be available for the monitoring of neutron exposure if additional license renewals are sought, and (4) include a provision that, if future plant operations exceed the limitations in Section 1.3 of Regulatory Guide 1.99, Revision 2, or the applicable bounds, e.g., cold leg operating temperature and neutron fluence, as applied to the surveillance capsules, the impact of these plant operation changes on the extent of reactor vessel embrittlement will be evaluated, and the NRC will be notified.

14 The One-Time Inspection Program is a new program to be A. 1.1.18 Prior to the period of One-Time Inspection implemented.

extended operation Program I LRA Section B.2.18

HNP-08-029 Page 6 of 11 The Selective Lea implemented prior to me perioa or extended operation Selective Leaching of Materials Program LRA Section B.2.19 16 The Buried Piping and Tanks Inspection Program is a new program to A. 1.1.20 Prior to the period of Buried Piping and Tanks be implemented.

extended operation Inspection Program LRA Section B.2.20 17 The One-Time Inspection of ASME Code Class 1 Small-Bore Piping A. 1.1.21 Prior to the period of One-Time Inspection of Program is a new program to be implemented.

extended operation ASME Code Class 1 Small-Bore Piping Program LRA Section B.2.21 18 The program will be enhanced to: (1) include a specific list of systems A. 1.1.22 Prior to the period of External Surfaces managed by the program for License Renewal, (2) provide specific extended operation Monitoring Program guidance for insulated/jacketed pipe and piping components to identify signs of leakage and provide criteria for determining whether the LRA Section B.2.22 insulation/jacket should be removed to inspect for corrosion, (3) provide inspection criteria for components not readily accessible during plant operations or refueling outages, (4) provide specific guidance for visual inspections of elastomers for cracking, chafing, or changes in material properties due to wear, and (5) incorporate a checklist for evaluating inspection findings, with qualified dispositions.

19 The Program will be enhanced: (1) to require an evaluation of historic A. 1.1.23 Prior to the period of Flux Thimble Tube plant-specific test data in order to ensure that conservative wear rates extended operation Inspection Program are used so that a loss of intended function will not occur, (2) to provide guidance for treatment of flux thimbles that could not be LRA Section B.2.23 inspected due to restriction, defect or other reason, and (3) to require test results and evaluations be formally documented as QA records.

• A

HNP-08-029 Page 7 of 11 i ne inspection or internal burtaces in Miscellaneous t'iping and Ducting Components Program is a new program to be implemented.

A.. 1.24 Frior to the period ot extended operation Inspection ot Internal Surfaces in Miscellaneous Piping and Ducting Components Program LRA Section B.2.24 21 The Program will be enhanced as follows: (1) a review and revision of A. 1.1.25 Prior to the period of Lubricating Oil Analysis work documents and analysis requirements will be performed to ensure extended operation Program that the used oil from appropriate component types in the scope of License Renewal is analyzed to determine particle count and moisture, LRA Section B.2.25 and if oil is not changed in accordance with the manufacturer's recommendation, then additional analyses for viscosity, neutralization number, and flash point will be performed. This activity will ensure that used oil is visually checked for water; and (2) the program administrative controls will be enhanced to include a requirement to perform ferrography or elemental analysis to identify wear particles or products of corrosion when particle count exceeds an established level or when considered appropriate.

22 The Program implementing procedure will be enhanced to: (1) include A. 1.1.26 Prior to the period of ASME Section XI, additional recordable conditions, (2) include moisture barrier and extended operation Subsection IWE applicable aging effects, (3) include pressure retaining bolting and Program aging effects, and (4) include a discussion of augmented examinations.

LRA Section B.2.26 23 The Program will be enhanced to describe in the implementing A. 1.1.29 Prior to the period of 10 CFR Part 50, procedures the evaluation and corrective actions to be taken when extended operation Appendix J Program leakage rates do not meet their specified acceptance criteria.

LRA Section B.2.29 24 Program administrative controls will be enhanced to identify the A. 1.1.30 Prior to the period of Masonry Wall Program structures that have masonry walls in the scope of License Renewal.

extended operation LRA Section B.2.30

HNP-08-029 Page 8 of 11 The Program implementing procedures will be enhanced to:

(1) identify the License Renewal structures and systems that credit the program for aging management, (2) require notification of the responsible engineer when below-grade concrete is exposed so an inspection may be performed prior to backfilling, (3) require periodic groundwater chemistry monitoring including consideration for potential seasonal variations., (4) define the term "structures of a system" in the system walkdown procedure and specify the condition monitoring parameters that apply to "structures of a system,"

(5) include the corporate structures monitoring procedure as a reference in the plant implementing procedures and specify that forms from the corporate procedure be used for inspections, (6) identify additional civil/structural commodities and associated inspection attributes required for License Renewal, and (7) require inspection of inaccessible surfaces of reinforced concrete pipe when exposed by removal of backfill.

A. 1..J I rrior to me periou o0 extended operation 3tructures ivionnoring Program LRA Section B.2.31 26 The Program will be enhanced to: (1) require an evaluation of any A.1.1.32 Prior to the period of RG 1.127, Inspection of concrete deficiencies in accordance with the acceptance criteria extended operation Water-Control Structures provided in the corporate inspection procedure, (2) require initiation of Associated with Nuclear a Nuclear Condition Report (NCR) for degraded plant conditions and Power Plants Program require, as a minimum, the initiation of an NCR for any condition that constitutes an "unacceptable" condition based on the acceptance LRA Section B.2.32 criteria specified, and (3) require documentation of a visual inspection

-of the miscellaneous steel at the Main Dam and Spillway-.

27 The Electrical Cables and Connections Not Subject to 10 CFR 50.49 A.1.1.33 Prior to the period of Electrical Cables and Environmental Qualification Requirements Program is a new program extended operation Connections Not Subject to be implemented.

to 10 CFR 50.49 Environmental Qualification Requirements Program LRA Section B.2.33

HNP-08-029 Page 9 of 11 The Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Used in Instrumentation Circuits Program is a new program to be implemented.

Prior to the period of extended operation Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Used in Instrumentation Circuits Program LRA Section B.2.34 29 The Inaccessible Medium Voltage Cables Not Subject to 10 CFR A. 1.1.35 Prior to the period of Inaccessible Medium ----

50.49 Environmental Qualification Requirements Program is a new extended operation Voltage Cables Not program to be implemented.

Subject to 10 CFR 50.49 Environmental Qualification Requirements Program LRA Section B.2.35 30 The Metal Enclosed Bus Program is a new program to be A. 1.1.36 Prior to the period of Metal Enclosed Bus implemented.

extended operation Program LRA Section B.2.36 31 The Electrical Cable Connections Not Subject to 10 CFR 50.49 A.1.1.37 Prior to the period of Electrical Cable Environmental Qualification Requirements Program is a ne-w-program extended operation Connections Not Subject to be implemented.

to 10 CFR 50.49 Environmental Qualification Requirements Program LRA Section B.2.37

HNP-08-029 Page 10 of 11 The Program will be enhanced to: (1) expand the program scope to include an evaluation of selected RCPB components beyond the reactor pressure vessel (including auxiliary system components such as the pressurizer lower head, pressurizer surge line, and CVCS piping and heat exchanger), and to include the NUREG/CR-6260 locations analyzed for environmental effects, (2) provide preventive actions to include, prior to a monitored location exceeding a cumulative usage factor limit of 1.0, evaluation of operational changes to reduce the number or severity of future transients, (3) include a provision to utilize online fatigue analysis software for the periodic updating (not to exceed once every 18 months) of cumulative usage, (4) describe the acceptance criteria for maintaining fatigue usage below the design limit, and (5) address corrective actions, to be implemented through the Corrective Action Program, for components that have exceeded alarm limits, with options to include a revised fatigue analysis or repair or replacement of the component and for piping systems that have exceeded their cyclic alarm limit to require a review of the pertinent design calculations to determine if any additional locations should be designated as pnostulated high energy line breaks.

Prior to the period of extended operation rWUIrL

'..IoulIILt rr-Boundary (RCPB)

Fatigue Monitoring Program LRA Section B.3.1, Response to Audibt.

Questions B.3..1-R-H-01, B.3.1-RH-05, and4-u).

4.7.4-1 (Follow7up);,,'

33 The Low Temperature Overpressure (LTOP) setpoint analysis will be A. 1.2.1.4 After capsule fast TLAA - Low recalculated following removal of one of the remaining surveillance neutron exposure temperature Over-capsules from the reactor vessel, comparable to the Pressure Limits end of the period of extended operation LRA Section 4.2.5 34 The Oil-Filled Cable Testing Program is a new program tobe A.1.1.40 Prior to the period of Oil-Filled Cable Testing implemented.

extended operation Program LRA Section B.2.38, Response to Audit Question LRA-3.6.2-1 -RM-02

HNP-08-029 Page 11 of 11 When the EPRI MRP methodology described in MRP-140, "Materials Reliability Program: Leak-Before-Break Evaluation for PWR Alloy 82/182 Welds," has been reviewed and approved by the NRC, HNP will review its plant-specific calculation for conformance to the endorsed approach.

/-AS SLaLeu in me commitment I LI*-,1 - Ledt'-JeIU[e-Break evaluation for Alloy 82/182 Welds LRA Section 4.3.4, Response to Audit Question LRA 4.3.4-1 36 HNP will replace the subject elastomeric and thermoplastic A.1.1 Prior to the period of Section 3.4 AMR Tables components referenced in RAIs 3.4-2, 3.4-3, 3.4-4, 3.4-5, and 3.4-7 extended operation for Main Steam Supply, and add them to the Preventive Maintenance Program. HNP will Feedwater, and perform an evaluation to determine the frequency of periodic Secondary Sampling replacement of the components during the period of extended Systems operation based on the guidance in the HNP Preventive Maintenance Program.

Response to Confirmatory Item 3.4-1 37 HNP will update the piping design specification to reflect the current A. 1.1 Prior to the period of, Table 4.3-3 60-year design basis operational transients used in the Time-Limited Aging extended operation Environmentally-Analyses for the reactor coolant pressure boundary.

Adjusted CUF Values Response to Confirmatory Item 4.3