ML102310325

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Entergy Nuclear Operations Inc. (Indian Point Nuclear Generating Units 1 & 2), Notification of Entergy'S Submittal Regarding Completion of Commitment 33 for Indian Point Units 2 & 3
ML102310325
Person / Time
Site: Indian Point  Entergy icon.png
Issue date: 08/10/2010
From: Bessette P, Sutton K
Entergy Nuclear Operations, Morgan, Morgan, Lewis & Bockius, LLP
To: Lathrop K, Lawrence Mcdade, Richard Wardwell
Atomic Safety and Licensing Board Panel
SECY RAS
References
50-247-LR, 50-286-LR, RAS E-391
Download: ML102310325 (31)
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Text

Morgan, Lewis & Bockius LLP 1111' Pennsylvania Avenue, NW Washington, DC 20004 Morgan Lewis COUNSELORS Tel: 202.739.3000 AT LAW Fax: 202.739.3001 DOCKETED www.morganlewis.com USNRC August 11, 2010 (8:30a.m.)

Kathryn M. Sutton Partner OFFICE OF SECRETARY 202.739.5738 RULEMAKINGS AND ksutton@morganlewis.com ADJUDICATIONS STAFF Paul M. Bessette Partnfer .

202.739.5796 pbessette @morgan lewiscom August 10 2010 Lawrence G. McDade, Chairman Dr. Richard E. Wardwell Dr. Kaye D. Lathrop Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Docket: Entergy Nuclear Operations,Inc. (Indian Point Nuclear Generating Units 2 and 3), Docket Nos. 50-247-LR and 50-286-LR f

RE: Notification of Entergy's Submittal Regarding Completion of Commitment 33 for Indian Point Units 2 and 3

Dear Administrative Judges:

Entergy Nuclear Operations, Inc. ("Entergy") is providing this notice to the Atomic Safety and Licensing Board and the parties regarding Entergy's August 9, 2010 submittal Of a notice to the U.S. Nuclear Regulatory Commission ("NRC") regarding completion of Commitment 33 to the Indian Point Units 2 and 3 License Renewal Application associated with the Fatigue Monitoring Program. See NL-10-082, Letter from Fred Dacimo, Entergy, to NRC Document Control Desk, "License Renewal Application - Completion of Commitment #33 Regarding the Fatigue Monitoring Program" (August 9, 2010). A copy of NL-10-082 is attached for your referehce. Counsel is providing this notification insofar as the completion of.

Commitment 33 may be relevant and material to admitted contentions NYS-26/26A and Riverkeeper TC- 1/ 1A.

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Morgan Lewis, Lawrence G. McDade, Chairman COUNSELORS AT LAW Dr. Richard E. Wardwell Dr. Kaye D. Lathrop August 10, 2010 Page 2 Respectfully submitted, Kathryn M. Sutton, Esq.

Paul M. Bessette, Esq.

Counsel for Entergy Nuclear Operations, Inc.

CBM/als Attachment cc: Service List

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of Docket Nos. 50-247-LR and

) 50-286-LR ENTERGY NUCLEAR OPERATIONS, INC. )

)

(Indian Point Nuclear Generating Units 2 and 3) )

) August 10, 2010 CERTIFICATE OF SERVICE I hereby certify that copies of the letter entitled "Notification of Entergy's Submittal Regarding Completion of Commitment 33 for Indian Point Units 2 and 3," dated August 10, 2010, were served this 10th day of August, 2010 upon the persons listed below, by first class mail and e-mail as shown below.

Administrative Judge Administrative Judge Lawrence G: McDade, Chair Kaye D. Lathrop Atomic Safety and Licensing Board Panel Atomic Safety and Licensing Board Panel Mail Stop: T-3 F23 190 Cedar Lane E.

U.S. Nuclear Regulatory Commission Ridgway, CO 81432 Washington, DC 20555-0001 (E-mail: kdl2(@,nrc.gov)

(E-mail: Igmrl (nrc.gov)

Administrative Judge Office of the Secretary*

Richard E. Wardwell Attn: Rulemaking and Adjudications Staff Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Mail Stop: T-3 F23 Washington, D.C. 20555-0001 U.S. Nuclear Regulatory Commission (E-mail: hearingdocket(Thnrc.gov)

Washington, DC 20555-0001 (E-mail: rew~nrc. gov)

Office of Commission Appellate Adjudication Josh Kirstein, Law Clerk U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Board Panel Mail Stop: O-16G4 Mail Stop: T-3 F23 Washington, DC 20555-0001 U.S. Nuclear Regulatory Commission (E-mail: ocaamail(ai),nrc.gov) Washington, DC 20555-0001 (E-mail: Josh.Kirstein@(nrc.gov)

Page 2 Sherwin E. Turk, Esq. Greg Spicer, Esq.

Beth N. Mizuno, Esq. Office of the Westchester County Attorney David E. Roth, Esq. 148 Martine Avenue, 6th Floor Brian G. Harris, Esq. White Plains, NY 10601 Andrea Z. Jones, Esq. (E-mail: _gsslgwestchestergov.com)

Office of the General Counsel Mail Stop: 0-15 D21 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 (E-mail: set(anrc.gov)

(E-mail: bnm I @nrc.gov)

(E-mail: david.roth(inrc.gov)

(E-mail: brian.harrisanrc.gov)

(E-mail: andrea.jones(Rnrc.gov)

Manna Jo Greene Thomas F. Wood, Esq.

Environmental Director Daniel Riesel, Esq.

Hudson River Sloop Clearwater, Inc. Ms. Jessica Steinberg, J.D.

724 Wolcott Avenue Sive, Paget & Riesel, P.C.

Beacon, NY 12508 460 Park Avenue (E-mail: mannaio(clearwater.org) New York, NY 10022 (E-mail: driesel Rcsprlaw.com)

(E-mail: j steinbergQ(sprlaw.com)

Stephen C. Filler, Board Member John Louis Parker, Esq.

Hudson River Sloop Clearwater, Inc. Regional Attorney 303 South Broadway, Suite 222 Office of General Counsel, Region 3 Tarrytown, NY 10591 NYS Dept. of Environmental Conservation (E-mail: sfiller(anylawline.com) 21 S. Putt Corners Road New Paltz, New York 12561-1620 (E-mail: jlparker(.gw.dec.state.ny.us)

Ross Gould, Member Michael J. Delaney, V.P. - Energy Hudson River Sloop Clearwater, Inc. New York City Economic Development 10 Park Avenue, #5L Corp.

New York, NY 10016 110 William Street (E-mail: rgouldesqgr(nmail.com) New York, NY 10038 (E-mail: mdelaney(@nycedc.com)

Page 3 Phillip Musegaas, Esq. Daniel E. O'Neill, Mayor Deborah Brancato, Esq. James Siermarco, M.S.

Riverkeeper, Inc. Liaison to Indian Point 828 South Broadway Village of Buchanan Tarrytown, NY 10591 Municipal Building (E-mail: phillip(Ziriverkeeper.org) 236 Tate Avenue (E-mail: dbrancatodriverkeeper.org) Buchanan, NY 10511-1298 (E-mail: vob(abestweb.net)

Robert D. Snook, Esq. Mylan L. Denerstein, Esq.

Assistant Attorney General Executive Deputy Attorney General, Office of the Attorney General Social Justice State of Connecticut Office of the Attorney General 55 Elm Street of the State of New York P.O. Box 120 120 Broadway, 25 h Floor Hartford, CT 06141-0120 New York, New York 10271 (E-mail: Robert.Snook(opo.state.ct.us) (E-mail: Mylan.Denerstein2oag. state.ny.us)

Andrew M. Cuomo, Esq. Janice A. Dean Attorney General of the State of New York Office of the Attorney General John J. Sipos, Esq. of the State of New York Charlie Donaldson Esq. Assistant Attorney General Assistants Attorney General 120 Broadway, 26th Floor The Capitol New York; New York 10271 Albany, NY 12224-0341 (E-mail: Janice.Dean(ioag.state.ny.us)

(E-mail: i ohn.sipos(d-oag.state.ny.us)

Joan Leary Matthews, Esq.

Senior Attorney for Special Projects Office of the General Counsel New York State Department of Environmental Conservation 625 Broadway, 14th Floor Albany, NY 12207 (E-mail: jlmatthe(agw. dec. state.ny.us)

Page 4

  • Original and 2 copies provided to the Office oftla Secretary.

Paul M. Bessette, Esq.

Counsel for Entergy Nuclear Operations, Inc.

DBJ/65420875.1

Entergy Nuclear Northeast Ah Indian Point Energy Center 450 Broadway, GSB

!ýEnteqy P.O. Box 249 Buchanan, N.Y. 10-511-0249 Tel (9.14) 788-2055 Fred Dacimno Vice President License Renewal NL-10-082 August 9, 2010 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

SUBJECT:

License Renewal Application - Completion of Commitment #33 Regarding the Fatigue Monitoring Program Indian Point Nuclear Generating Unit Nos. 2 and 3 Docket Nos. 50-247 and 50-286 License Nos. DPR-26 and DPR-64 REFERENCE 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)
4. Entergy Letter dated October 11, 2007, F. R, Dacirio to Document Control Desk, "License Renewal Application (LRA)." (NL-07-124)
5. Entergy Letter November 14, 2007, F. R, Dacimo to Document Control Desk, "Supplement to License Renewal Application (LRA)

Environmental Report References" (NL-07-133)

Dear Sir or Madam:

In the referenced letters, Entergy Nuclear Operations, Inc. applied for renewal of the Indian Point Energy Center operating license. This letter contains information supporting the completion of commitment 33 to the License Renewal Application regarding the Fatigue Monitoring Program.

NL-10-082 Docket Nos. 50-247 and 50-286 Page 2 of 2 There are no new commitments identified in this submittal. If you have any questions, or require additional information, please contact Mr. Robert Walpole at 914-734-6710.

Sincerely, FD/mb Attachments: 1. Environmental Fatigue Evaluations

2. List of Regulatory Commitments cc: Mr. S. J. Collins, Regional Administrator, NRC Region I Mr. J. Boska, Senior Project Manager, NRC, NRR, DORL Mr. Sherwin E. Turk, NRC Office of General Counsel, Special Counsel Ms. Kimberly Green, NRC Safety Project Manager NRC Resident Inspectors Office, Indian Point Mr. Paul Eddy, NYS Dept. of Public Service Mr. Francis J. Murray, Jr., President and CEO, NYSERDA

ATTACHMENT 1 TO NL-10-082 Environmental Fatigue Evaluations ENTERGY NUCLEAR OPERATIONS, INC INDIAN POINT NUCLEAR GENERATING UNITS 2 AND 3 DOCKET NOS. 50-247 & 50-286

Attachment 1 NL-10-082 Docket Nos. 50-247 and 50-286 Page 1 of 4 INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 AND 3 LICENSE RENEWAL APPLICATION ENVIRONMENTAL FATIGUE EVALUATIONS Environmental Fatigue Evaluation for Indian Point Unit 2 and Unit 3 Entergy has applied-for renewed operating licenses for Indian Point Nuclear Generating Unit 2 and Unit 3 (IP2 and IP3). In the license renewal application, Entergy committed to address environmentally assisted fatigue. Entergy's commitment, amended by letter, NL-08-021, dated January 22, 2008, reads as follows.

At least 2 years prior to entering the period of extended operation, for the locations identified in LRA Table 4.3-13 (1P2) and LRA Table 4.3-14 (1P3), under the Fatigue Monitoring Program, IP2 and IP3 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 refined 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:

I. For locations in LRA Table 4.3-13 (IP2) and LRA Table 4.3-14 (IP3), with existing fatigue analysis valid for the period of extended operation, use the existing CUF.

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

Entergy has updated the fatigue usage calculations using refined fatigue analyses to determine CUFs when accounting for the effects of reactor water environment. This includes applying the appropriate Fen factors to valid CUFs for the locations shown in LRA Table 4.3-13 and LRA Table 4.3-14.

The tables from the LRA are repeated as follows with the updated CUF values inserted.

The results of the refined analyses are shown in the tables as underlined values.

Attachment 1 NL-10-082 Docket Nos. 50-247 and 50-286 Page 2 of 4 Table 4.3-13 1P2 Cumulative Usage Factors for NUREG/CR-6260 Limiting Locations Per NUREG/CR-6583 or I2Plant- UE/R50 NUREG-6260 Generic SP2 Plant- Material CUF of NUREGICR-5704 Location Location Type Record Fen Environmentall y Adjusted CUF Vessel shell and Bottom head to lower head shell LAS 0.004 2.45 0.01 2 Vessel inlet and Reactor vessel outlet nozzles inlet nozzle LAS 0.05 2.45, 0.12 2 Vessel inlet and Reactor vessel LAS 0.281 2.45 0.69 outlet nozzles outlet nozzle 3 Pressurizer surge. Pressurizer. 0 2 0.6 line nozzles surge. line LAS, nozzle 0.109 1.74 0.188 3 Pressurizer surge Surge line piping 0k  : 9 line piping to safe end weld SS 0.062 13.26 .0.822_

4 RCS piping Charging system 9.9 .

charging system nozzle SS nozzle 0.0323 8.7 0.2809 5 RCS piping safety NA NAý . 4W injection nozzle SS 0.1083 7.8975 0.8553 6 RHR Class 1 piping NA NAa 41. NAe SS 0.0721 13.08 0.9434.

Attachment 1 NL-10-082 Docket Nos. 50-247 and 50-286 Page 3 of 4 Table 4.3-14 IP3 Cumulative'Usage Factors for NUREGICR-6260 Limiting Locations Per NUREGCR-6583 or IP3 Plant- Material CUF of NUREGICR-5704 Specific Location Type Record Fen Environmentally Adjusted CUF 1 Vessel shell and lower Bottom head to head shell LAS 0.02 2.45 0.05 2 Vessel inlet and outlet Reactor vessel nozzles inlet nozzle LAS 0.049 2.45 0.12 2 Vessel inlet and outlet Reactor vessel nozzles outlet nozzle LAS 0.259 2.45 0.64 3 Pressurizer surge line Pressurizer surge . 2-46 2-.

nozzles line nozzle LAS 0.0903 1.74 0.157 3 Pressurizer surge line Surge line piping I 6.38 2046 piping to safe end weld 0.0411 14.45 0.594 4 RCS piping charging NA NAý 6 NAa system nozzle SS 3.98 0.722 5 RCS piping safety NA NA' 6 NAý injection nozzle 0.1709 5.0117 0.8565 6

RHR Class 1 piping NA NA22NA 0.1279 7.79 0.9961

Attachment 1 NL-10-082 Docket Nos. 50-247 and 50-286 Page 4 of 4, As described in LRA Section 4.3.3 and shown in Tables 4.3-13 and 4.3-14, the CUFs for the reactor vessel locations were not changed. The evaluation documented in the LRA used bounding Fens applied to the CUFs of record forthe bottom head to shell region, the reactor vessel inlet nozzle and the reactor vessel outlet nozzle. The tables show the Cumulative Usage Factors are all below 1.0 for these three locations for both units.

The stress and fatigue evaluations for the remaining piping components listed in Table 4.3-13 and 4.3-14 were performed using standard methods of the ASME Code, Section Ill. Detailed stress models of the surge line hot leg nozzle, pressurizer surge nozzle, reactor coolant piping charging system nozzle, reactor coolant piping safety injection nozzle, and the RHR system class -1 piping locations were prepared. The analyst developed detailed stress history inputs for all transients considered in the evaluation, which were subsequently used to provide detailed.

inputs used in the EAF evaluations. The ASME Code evaluations were performed for the piping components to reduce conservatism in the analyses or because the current licensing basis (CLB) qualification was to the ANSI B31.1 Power Piping Code, which did not require a fatigue usage factor calculation. The evaluations were limited to the stress qualifications related to the fatigue requirements of the ASME Code. The primary stress qualifications documented in the CLB remain applicable for the components evaluated.

The evaluation of EAF was accomplished through the application of Fen factors, as described in NUREG/CR-5704 for the stainless steels in the pressurizer surge line, the reactor coolant piping charging and safety injection system nozzles, and the RHR system Class 1.piping. In addition, Fen factors for the pressurizer surge nozzle dissimilar metal weld also considered the carbon steel factors in NUREG/CR-6583. The Fen factors are calculated based on detailed inputs described in the applicable NUREG and are directly applied to the ASME Code fatigue results.

The refined fatigue analyses of the Indian Point Unit 2 and Unit 3 piping locations corresponding to the locations identified in NUREG/CR-6260 for older vintage Westinghouse plants demonstrate that cumulative fatigue usage factors including consideration of reactor water environmental effects are below a value of 1.0 for transients postulated for 60 years of operation.

The results of this evaluation resolve commitment number 33 in the NRC Safety Evaluation Report on license renewal for Indian Point Nuclear Generating Unit 2 and Unit 3.

ATTACHMENT 2 TO NL-10-082 List of Regulatory Commitments ENTERGY NUCLEAR OPERATIONS, INC INDIAN POINT NUCLEAR GENERATING UNITS 2 AND 3 DOCKET NOS. 50-247 & 50-286

Attachment 2 NL-10-082 Docket Nos. 50-247 and 50-286 Page 1 of 17 List of Regulatory Commitments Rev. 12 The following table identifies those actions committed to by Entergy in this document.

Changes are shown as strikethroughs for deletie.s and underlines for additions.

  1. COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION

/_AUDIT ITEM

  • IP2: NL-07-039 A.2.1.1 Enhance the Aboveground Steel Tanks Program for September 28, A.3.1.1 IP2 and IP3 to perform thickness measurements of etmr 2.1.1 the bottom surfaces of the condensate storage tanks, 013 B.1.1 city water tank, and fire water tanks once during the 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 I measurements when material loss is detected.

IP2: NL--07-039 A.2.1.2 2 Enhance the Bolting Integrity Program for IP2 and IP3 Sp2 b 28, A.3.1.2 to clarify that actual yield strength is used in selecting 2eptember 28, A.3.1.2 materials for low susceptibility to SCC and clarify the prohibition on use of lubricants containing MoS 2 for IP3: NL-07-153 Audit Items bolting. December 12, 201,241, The Bolting Integrity Program manages loss of 015 270 preload and loss of material for all external bolting.

(ft Attachment 2 NL-10-082 Docket Nos. 50-247 and 50-286 Page 2 of 17

  1. COMMITMENT IMPLEMENTATION SCHEDULE SOURCE I LRARELATED SECTION

/ AUDIT ITEM Implement the Buried Piping and Tanks Inspection IP2: NL-07-039 A.2.1.5 3

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.

Include in the Buried Piping and Tanks Inspection NL-09-106 Program described in LRA Section B.1.6 a risk assessment of in-scope buried piping and tanks that NL-09-1 11 includes consideration of the impacts of buried piping or tank leakage and of conditions affecting the risk for corrosion. Classify pipe segments and tanks as having a high, medium or low impact of leakage based on the safety class, the hazard posed by fluid contained in the piping and the impact of leakage on reliable plant operation. Determine corrosion risk through consideration of piping or tank material, soil resistivity, drainage, the presence of cathodic protection and the type of coating. Establish

  • inspection priority and frequency for periodic inspections of the in-scope piping and tanks based on the results of the risk assessment. Perform inspections using inspection techniques with demonstrated effectiveness.

K Attachment 2 NL-10-082 Docket Nos. 50-247 and 50-286 Page 3 of 17 COMMITMENT IMPLEMENTATION SOURCE I RELATED SCHEDULE LRA SECTION I AUDIT ITEM IP2: NL-07-039 A.2.1.8 4 Enhance the Diesel Fuel Monitoring Program to September 28, A.3.1.8 include cleaning and inspection of the IP2 GT-1 gas B.1.9 2013 turbine fuel oil storage tanks, IP2 and IP3 EDG fuel oil NL-07-153 Audit items day tanks, IP2 SBO/Appendix R diesel generator fuel IP3: 128,129, oil day tank, and IP3 Appendix R fuel oil storage tank 132, December 12, and day tank once every ten years. 2015 NL-08-057 491,492, Enhance the Diesel Fuel Monitoring Program to 510 include quarterly sampling and analysis of the IP2 SBO/Appendix R diesel generator fuel oil day tank, IP2 security diesel fuel oil storage 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 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, EDG fuel oil storage 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 andparticulates 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 and include direction to remove water when detected.

Revise applicable procedures to direct sampling of the onsite portable fuel oil contents prior to transferring the contents to the storage tanks.

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

Attachment 2 NL- 10-082 Docket Nos. 50-247 and 50-286 Page 4 of 17

  1. COMMITMENT IMPLEMENTATION SOURCE, RELATED SCHEDULE LRA SECTION

"_ IAUDIT

/_ ITEM 5 Enhance the External Surfaces Monitoring Program IP2: NL-07-039 A.2.1.10 for IP2 and IP3 to include periodic inspections of 2013 eptember 28, B.1.11 A.3.1.10 system s in scope and subject to aging m anagem ent . . ... ........

review for license renewal in accordance with 10 CFR 54.4(a)(1) and (a)(3). Inspections shall include areas December surrounding the subject systems to identify hazards to .2015 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).

6 Enhance the Fatigue Monitoring Program for IP2 to SP2: NL-07-039 A.2.1.11 monitor steady state cycles and feedwater cycles or 2eptember 28, A.3.1.11 perform an evaluation to determine monitoring is not N 7013 B. 1.12, required. Review the number of allowed events and NL-07-153 Audit Item resolve discrepancies between reference documents 164 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

IP2: NL-07-039 A.2.1.12 7 Enhance the Fire Protection Program to inspect Sptb 28, A.3.1.12 external surfaces of the IP3 RCP oil collection eptember 28, A.3.1.12 systems for loss of material each refueling cycle. 2013 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.

Attachment 2 NL-10-082 Docket Nos. 50-247 and 50-286 Page 5 of 17

  1. COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION

__*__ IAUDIT ITEM 8 Enhance the Fire Water Program to include inspection IP2: NL-07-039 A.2.1.13 of IP2 and IP3 hose reels for evidence of corrosion. 2013 2 I.B.1.14 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 significant corrosion. __

. I-

Attachment 2, NL-10-082" Docket Nos. 50-247 and 50-286 Page 6 of 17 COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION

__ / AUDIT ITEM 9 Enhance the Flux Thimble TubeInspection Program IP2: NL-07-039 A.2.1.15 September 28, A.3.1.15

  • ,for IP2 and IP3 to implement comparidons to wear 2013 B.1.16 rates identified in WCAP-12866. Include provisions to .01 compare data to the previous. performances and P3:

perform evaluations regarding change to test December 12, D 12015, frequency and scope.

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.

Attachment 2 NL-10-082 Docket Nos. 50-247 and 50-286 Page 7 of 17

  1. COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION

__II_._-_..... / AUDIT ITEM 10 Enhance the Heat Exchanger Monitoring Program for P2: NL-07-039 A.2.1.16 I P2 and IP3 to include the following heat exchangers eptember 28, A.3.1.16 in the scope of the program. 013 B.1.17, NL*w07-153 Audit Item

, Safety injection pump lube oil heat exchangers IP3: w52

  • 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 indication of tube erosion, vibration wear, corrosion, pitting, NL-09-018 fouling, or scaling.

11 Delete commitment. NL-09-056

Attachment 2 NL-10-082 Docket Nos. 50-247 and 50-286 Page 8 of 17

  1. COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION

/_AUDIT ITEM 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 eptember 28, A.3.1.18 the program013 B.1.19 IP3:

December 12, 2015 13 Enhance the Metal-Enclosed Bus Inspection Program 1P2: NL-07-039 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 NL-07-153 Audit Items Enhance the Metal-Enclosed Bus Inspection Program 1P3: 124, for IP2 and IP3 to visually inspect the external surface December 12, NL-08-057 133, 519 of MEB enclosure assemblies for loss of material at 2015 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 to add acceptance criteria for MEB internal visual inspections to include the absence of indications of dust accumulation on the bus bar, on the insulators, and in the duct, in addition to the absence of indications of moisture intrusion into the duct.

Enhance the Metal-Enclosed Bus Inspection Program for IP2 and IP3 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.

14 Implement the Non-EQ Bolted Cable Connections IP2: NL-07-039 A.2.1.21 Program for IP2 and IP3 as described in LRA Section eptember 28, A.3.1.21 B.1.22. 013 B.1.22 IP3:

December 12, 2015

Attachment 2 NL-10-082 Docket Nos. 50-247 and 50-286 Page 9 of 17 COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION

__"_ / AUDIT ITEM IP2: NL-07-039 A.2.1 .22 15 Implement the Non-EQ Inaccessible Medium-Voltage Ip2 b 28, A.3.1.22 Cable Program for-IP2 and IP3 as described in LRA eptember 28,.1.2 Section B.1.23. 03...

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 015 Cables Not Subject To 10 CFR 50.49 Environmental Qualification Requirements.

IP2: NL-07-039 A.2.1.23 16 Implement the Non-EQ Instrumentation Circuits Test 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 IP3: 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 eP2: NL-07-039 A.2.1.24 Connections Program for IP2 and IP3 as described in eptember 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.-

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 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 theOil Analysis Program for IP2 and IP3 to formalize trending of preliminary oil screening results as well as data provided from independent laboratories. I

4.'

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/AUDIT ITEM Implement the One-Time Inspection Program for IP2. IP2: NL-07-039 A.2.1.26 19 described in LRA Section B.1.27. September 28, A.3.1.26 and P3 as 2013 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 IP2: NL-07-039 A.2.1.27 20 Implement the One-Time Inspection - Small Bore September 28, A.3.1.27 Piping Program for IP2 and IP3 as described in LRA 2013 B.31.28 Section B.1.28.

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.M35, One-Time Inspection of ASME ý_015 Code Class I Small-Bore Piping....

21 Enhance the Periodic Surveillance and Preventive eP2: NL-07-059 A.2.1.28 Maintenance Program for IP2 and IP3 as necessary 013 2.1.29 to assure that the effects of aging will be managed y _013 B.1.29 such that applicable components will continue to perform their intended functions consistent with the DP3 1 current licensing basis through the period of extended December 12, operation. 2015 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 IP3:

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 vessel are maintained in storage.

IP2: NL-07-039 A.2.1.32 23 Implement the Selective Leaching Program for IP2 Sp2 b 28, A.3.1.32 and IP3 as described in LRA Section B.1.33. eptember 28, 2013 A1.332 B. 1.33 This new program will be implemented consistent with NL-07-153 Audit item the corresponding program described in NUREG- IP3: 173 1801,Section XI.M33 Selective Leaching of Materials. December 12,

__015

Attachment 2 NL-10-082 Docket Nos. 50-247 and 50-286 Page 11 of 17 COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION

"___ AUDIT ITEM 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 eptember 28,"B.1.

2013 A.3.1.34 35 monitoring assessment are compared to the operational assessment performed for the prior IP3:

operating cycle with differences evaluated.

December 12, 2015 Enhance the Structures Monitoring Program to IP2: NL-07-039 A.2.1.35 25 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 items (IP3) December 12, 86, 87, 88,
  • Appendix R diesel generator switchgear and 2015 NL-08-057 417 enclosure (IP3)

" city water storage tank foundation

  • condensate storage tanks foundation (IP3)

" containment access facility and annex (IP3)

  • discharge canal (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)

  • nuclear service building (IP1)

" primary water storage tank foundation (IP3)

  • refueling water storage tank foundation (IP3)
  • security access and office building (IP3)
  • superheater stack
  • transformer/switchyard support structures (IP2)
  • waste holdup tank pits (1P2/3)

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

Attachment 2 NL-10-082 Docket Nos. 50-247 and 50-286 Page 12 of 17

  1. COMMITMENT IMPLEMENTATION SOURCE I RELATED SCHEDULE LRA SECTION

/ AUDIT ITEM

  • 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.

Enhance the Structures Monitoring Program for IP2 NL-08-127 Audit Item and IP3 to perform an engineering evaluation of 360 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 and perform an engineering evaluation of the results from those samples for sulfates, pH and chlorides.

Additionally, to assess potential indications of spent fuel pool leakage, IPEC will sample for tritium in groundwater wells in close proximity to the IP2 spent fuel pool at least once every 3 months.

Enhance the Structures Monitoring Program for IP2 and IP3 to perform inspection of normally submerged

______ .5. 1

Attachment 2 NL-10-082 Docket Nos. 50-247 and 50-286 Page 13 of 17 COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION

! AUDIT ITEM concrete portions of the intake structures at least once every 5 years. Inspect the baffling/grating partition and support platform of the IP3 intake structure at least once every 5 years.

Enhance the Structures Monitoring Program for IP2 Audit Item and IP3 to perform inspection of the degraded areas 358 of the water control structure once per 3 years rather than the normal frequency of once per 5 years during the PEO.

26' Implement the Thermal Aging Embrittlement of Cast SP2: 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. 01353 .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 015 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 ISP3: 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 83.1.40 system per EPRI guidelines.. NP3: 509 Enhance the Water Chemistry Control - Closed December 12, Cooling Water Program to maintain the IP2 and IP3 2015 security generator and fire protection diesel cooling water pH and glycol within limits specified by EPRI guidelines.

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 eptember 28, B.1.41 the RWST with a limit of <1 50 ppb.

Attachment 2 1NL-1 0-082 Docket Nos. 50-247 and 50-286 Page 14 of 17

  1. COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION

_ AUDIT ITEM 30 For aging management of the reactor vessel internals, IP2: NL-07-039 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 internals; (2) evaluate and implement the results of IP3:

the industry programs as applicable to the reactor internals; and (3) upon completion of these programs, De r1 013 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: NL-07-039 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. 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 NL-08-127 screening criterion. Alternatively, the site may choose to implement the revised PTS rule when approved.

Attachment 2 NL-10-082 Docket Nos. 50-247 and 50-286 Page 15 of. 17 COMMITMENT IMPLEMENTATIONI SOURCE RELATED SCHEDULE LRA SECTION

/ AUDIT ITEM IP2: NL-07-039 A.2.2.2.3 33 At least 2 years prior to entering the period of September 28, A.3.2.2.3 extended operation, for the locations identified in LRA

.Table 4.3-13 (lP2) and LRA Table 4.3-14 (IP3), under 2011 4.3.3 NL-07-153 Audit item the Fatigue Monitoring Program, IP2 and IP3 will IP3: 146 implement one or more of the following: December 12, NL-08-021 (1) Consistent with the Fatigue Monitoring Program, 2013 Detection of Aging Effects, update the fatigue usage calculations using refined fatigue analyses to determine valid CUFs less than 1.0 when accounting Comolete NL-1 0-082 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 (IP3), with existing fatigue analysis valid for the period of extended operation, use the existing CUF.
2. Additional plant-specific locations with a valid CUF may beevaluated. 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) Consistent with the Fatigue Monitoring Program, Corrective Actions, repair or replace the affected locations before exceeding a CUF of 1.0.

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 Complete NL-08-074 requirements of 10 CFR 50.59(c)(1) and, therefore, a license amendment pursuant to 10 CFR 50.90 is not required.

Attachment 2 NL-1 0-082 Docket Nos. 50-247 and 50-286 Page 16 of 17,-

COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION

_ AUDIT ITEM.

IP2:NL-08-127 Audit Item 35 Perform a one-time inspection of representative eP2: 28, 27 eptember 28, 27 sample area of IP2 containment liner affected by the 1.973 event behind the insulation, prior to entering the 2013 extended period of operation, to assure liner degradation is not occurring in this area.

Perform a one-time inspection of representative IP3:

sample area of the IP3 containment steel liner at the December 12, juncture with the concrete floor slab, prior to entering 2015 the extended period of operation, to assure liner degradation is not occurring in this area.

Any degradation will be evaluated for updating of the NL-09-018 containment liner analyses as needed.

IP2: NL-08-127 Audit Item 36 Perform a one-time Inspection and evaluation of a September 28, 359 sample of potentially affected IP2 refueling cavity 208, concrete prior to the period of extended operation.

The sample will be obtained by core boring the refueling cavity~wall in an area that is susceptible to exposure to borated water leakage. The inspection will include an assessment of embedded reinforcing steel.

Additional core bore samples will be taken, if the NL-09-056 leakage is not stopped, prior to the end of the first ten years of the period of extended operation.

A sample of leakage fluid will be analyzed to NL-09-079 determine the composition of the fluid. If additional core samples are taken prior to the end of the first ten years of the period of extended operation, a sample of leakage fluid will be analyzed.

37 Enhance the Containment Inservice Inspection (CII- IP2: NL-08-127 Audit Item IWL) Program to include inspections of the September 28, 361 containment using enhanced characterization of 013 degradation (i.e., quantifying the dimensions of noted indications through the use of optical aids) during the IP3:

period of extended operation. The enhancement December 12, includes obtaining critical dimensional data of 015 degradation where possible through direct measurement or the use of scaling technologies for photographs, and the use of consistent vantage points for visual inspections. _ __I_____

Attachment 2 NL-10-082 Docket Nos. 50-247 and 50-286 Page 17 of 17

  1. COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION I AUDIT ITEM IP2: NL-08-143 4.2.1 38 For Reactor Vessel Fluence, should future core p2: 28.

loading patterns invalidate the basis for the projected eptember 28, values of RTpts or CvUSE, updated calculations will be provided to the NRC. IP3:

December 12, 2015 39 Deleted NL09079 IP2: NL-09-106 B.1.6 40 Evaluate plant specific and appropriate industry eptember928, B.1.2 operating experience and incorporate lessons learned eptember 28, B.1.22 in establishing appropriate monitoring and inspection 2013 B.1.23 B.1.24 B.1.25 frequencies to assess aging effects for the new aging P3:

management programs. Documentation of the December 12, B.1.27 operating experience evaluated for each new program 015 B.1.28 will be available on site for NRC review prior to the B.1.28 period of extended operation. B.1.33 B.1.37

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