NL-11-090, Official Exhibit - NYS000153-00-BD01 - Entergy Response (NL-11-090) to Request for Additional Information for the Review of the Indian Point Nuclear Generating Unit Number 2 and 3 (Jul. 27, 2011) (Entergy'S July 27 Response)

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Official Exhibit - NYS000153-00-BD01 - Entergy Response (NL-11-090) to Request for Additional Information for the Review of the Indian Point Nuclear Generating Unit Number 2 and 3 (Jul. 27, 2011) (Entergy'S July 27 Response)
ML12334A674
Person / Time
Site: Indian Point  Entergy icon.png
Issue date: 07/27/2011
From: Dacimo F
Entergy Nuclear Northeast, Entergy Nuclear Operations
To:
Atomic Safety and Licensing Board Panel, Document Control Desk, Office of Nuclear Reactor Regulation
SECY RAS
References
RAS 21546, 50-247-LR, 50-286-LR, ASLBP 07-858-03-LR-BD01, NL-11-090
Download: ML12334A674 (25)
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Text

United States Nuclear Regulatory Commission Official Hearing Exhibit Entergy Nuclear Operations, Inc.

In the Matter of:

(Indian Point Nuclear Generating Units 2 and 3)

ASLBP #: 07-858-03-LR-BD01 NYS000153 Docket #: 05000247 l 05000286 Submitted: December 15, 2011 Exhibit #: NYS000153-00-BD01 Identified: 10/15/2012 Admitted: 10/15/2012 Withdrawn:

Rejected: Stricken:

Other:

Entergy Nuclear Northeast Indian Point Energy Center

~Entergx 450 Broadway, GSB P.O. Box 249 Buchanan, NY 10511-0249 Tel (914) 788-2055 Fred Dacimo Vice President Operations License Renewal NL-11-090 July 27, 2011 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

SUBJECT:

Clarification for Request for Additional Information (RAI)

Aging Management Programs Indian Point Nuclear Generating Unit Nos, 2 & 3 Docket Nos. 50-247 and 50-286 License Nos. DPR-26 and DPR-64

REFERENCE:

1. NRC Letter, "Request for Additional Information for the Review of the Indian Point Nuclear Generating Unit Numbers 2 and 3, License Renewal Application," dated June 15, 2011
2. Entergy letter (NL-11-032)," Response to Request for Additional Information (RAI) Aging Management Programs," dated March 28, 2011
3. Entergy letter (NL-11-074)," Response to Request for Additional Information (RAI) Aging Management Programs," dated July 14, 2011

Dear Sir or Madam:

Entergy Nuclear Operations, Inc is providing, in Attachment 1, clarifications of the responses in References 2 and 3. Attachment 2 provides the latest list of regulatory commitments including revised commitments contained in this letter.

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

Docket Nos. 50-247 & 50-286 NL-11-090 Page 2 of 2 I decl~re ,under penalty of perjury that the foregoing is true and correct. Executed on 1.J-7!'!o 1\ .

I Si~

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FRD/cbr

Attachment:

1. Clarification for Request for Additional Information (RAI), Aging Management Programs

Attachment:

2. IPEC List of Regulatory Commitments (Rev. 15) cc: Mr. William Dean, Regional Administrator, NRC Region I Mr. Sherwin E. Turk, NRC Office of General Counsel, Special Counsel Mr. Dave Wrona, NRC Branch Chief, Engineering Review Branch I Mr. John Boska, NRR Senior Project Manager Mr. Paul Eddy, New York State Department of Public Service NRC Resident Inspector's Office Mr. Francis J. Murray, Jr., President and CEO NYSERDA

ATTACHMENT 1 TO NL-ll-090 LICENSE RENEWAL APPLICATION CLARIFICATION FOR REQUEST FOR ADDITIONAL INFORMATION (RAil AGING MANAGEMENT PROGRAMS ENTERGY NUCLEAR OPERATIONS, INC.

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

NL-11-090 Attachment 1 Page 1 of 4 INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 AND 3 LICENSE RENEWAL APPLICATION CLARIFICATION FOR REQUEST FOR ADDITIONAL INFORMATION (RAI)

AGING MANAGEMENT PROGRAMS Changes are shown as strikethroughs for deletions and underlines for additions.

Clarification for RAI 3.0.3.1.6-1 Part 1 A.2.1.22 Non-EO Inaccessible Medium-Voltage Cable Program The Non-EO Inaccessible Medium-Voltage Cable Program is a new program that entails periodic and event EIR¥eR inspections for water collection in cable manholes, and periodic testing of cables. In scope medium-voltage cables (cables with operating voltage from 2kV to 35kV) and low-voltage power cables (400 V to 2 kV) exposed to significant moisture will be tested at least once every six years to provide an indication of the condition of the conductor insulation. Test frequencies are adjusted based on test results and operating experience.

The frequency of inspections for water accumulation in manholes is established based on plant specific operatinq experience with cable wettinq or submergence in manholes (Le., the inspection is performed periodically based on water accumulation over time and event driven occurrences, such as heavy rain or flooding).

The frequency will be program inoludes periodio inspeotions for '!Jater aooumulation in manholes at least once every year (annually). In addition to the periodio manhole inspeotions, inspeotion of event driven ooourrenoes, suoh as heavy rain or flooding will be performed. Inspection frequency will be increased as necessary based on evaluation of inspection results.

The Non-EO Inaccessible Medium-Voltage Cable Program will be implemented prior to the period of extended operation. This new program will be implemented consistent with the corresponding program described in NUREG-1 8001,Section XI,E3, Inaccessible Medium-Voltage Cables Not Subject To 10 CFR 50.49 .

Environmental Oualification Requirements.

A.3.1.22 Non-EO Inaccessible Medium-Voltage Cable Program The Non-EO Inaccessible Medium-Voltage Cable Program is a new program that entails periodic and event GfiveA inspections for water collection in cable manholes, and periodic testing of cables. In scope medium- .

voltage cables (cables with operating voltage from 2kV to 35kV) and low-voltage power cables (400 V to 2 kV) exposed to significant moisture will be tested at least once every six years to provide an indication of the condition of the conductor insulation. Test frequencies are adjusted based on test results and operating experience.

The frequency of inspections for water accumulation in manholes is established based on plant specific operating experience with cable wetting or submergence in manholes (Le., the inspection is performed periodically based on water accumulation over time and event driven occurrences, such as heavy rain or flooding).

NL-11-090 Attachment 1 Page 2 of 4 The frequency will be pregram includes periodic inspoctions for water accumulation in manholes at least once every year (annually). In addition to the periodic manhole inspoctions, inspection of event driven occurrences, such as heavy rain or flooding "'!Jill bo porformod. Inspection frequency will be increased as necessary based on evaluation of inspection results. .

The Non-EQ Inaccessible Medium-Voltage Cable Program will be implemented prior to the period of extended operation. This new program will be implemented consistent with the corresponding program described in NUREG-1 8001,Section XI.E3, Inaccessible Medium-Voltage Cables Not Subject To 10 CFR 50.49 Environmental Qualification Requirements.

Clarification for RAI 3.0.3.1.2-3 A.2.1.S Buried Piping and Tanks Inspection Program The Buried Piping and Tanks Inspection Program is a new program that includes (a) preventive measures to mitigate corrosion and (b) inspections to manage the effects of corrosion on the pressure-retaining capability of buried carbon steel, gray cast iron, and stainless steel components. Preventive measures are in accordance with standard industry practice for maintaining external coatings and wrappings. Buried components are inspected when excavated during maintenance. If trending within the corrective action program identifies susceptible locations, the areas with a history of corrosion problems are evaluated for the need for additional inspection, alternate coating, or replacement.

Prim to entering tho poriod of extendod oporation, plant operating expOFience will be reviewed and multiple inspections will bo completod within the past ton yoars. Additional poriodic inspections will bo performod within the first ten years of the period of oxtonded opOFation.

IP2 will perform 20 direct visual inspections of buried piping during the 10 year period prior the PE~. IP2 will perform 14 direct visual inspections during each 10-year period of the PEO. Soil samples will be taken prior to the PEO and at least once every 10 years in the PE~. Soil will be tested at a minimum of two locations at least three feet below the surface near in-scope piping to determine representative soil conditions for each system. If test results indicate the soil is corrosive then the number of piping inspections will be increa:sed to 20 during each 1O-year period of the PEO. .

A.3.1.S Buried Piping and Tanks Inspection Program The Buried Piping and Tanks Inspection Program is a new program that includes (a) preventive measures to mitigate corrosion and (b) inspections to manage the effects of corrosion on the pressure-retaining capability of buried carbon steel, gray cast iron, and stainless steel components. Preventive measures are in accordance with standard industry practice for maintaining external coatings and wrappings. Buried components are inspected when excavated during maintenance. If trending within the corrective action program identifies susceptible locations, the areas with a history of corrosion problems are evaluated for the need for additional inspection, alternate coating, or replacement.

Prior to entering the period of extended operation, plant operating expOFience ..*.. ill be FOviewed and multiple inspections will be completed within the past ton years. Additional periodic inspections will bo performed within the first ton years of the period of extended operation.

IP3 will perform 14 direct visual inspections of buried piping during the 10 year period prior the PE~. IP3 will perform 16 direct visual inspections during each 10-year period of the PE~. Soil samples will be taken prior to the PEO and at least once every 10 years into the PE~. Soil will be tested at a minimum of two locations at least three feet below the surface near in-scope piping to determine representative soil conditions for each

NL-11-090 Att~chment 1 Page 3 of 4 system. If test results indicate the soil is corrosive then the number of piping inspections will be increased to 22 ;W during each 10-year period of the PEO.

Clarification for RAI B.O.4-1 A.2.1 Aging Management Programs and Activities The integrated plant assessment for license renewal identified aging management programs necessary to provide reasonable assurance that components within the scope of license renewal will continue to perform their intended functions consistent with the current licensing basis (CLB) through the period of extended operation. This section describes the aging management programs and activities required during the period of extended operation. All aging management programs will be implemented prior to entering the period of extended operation.

IPEC quality assurance (QA) procedures, review and approval processes, and administrative controls are implemented in accordance with the requirements of 10 CFR 50, Appendix B. The Entergy Quality Assurance Program applies to safety-related structures and components. Corrective actions and administrative (document) control for both safety-related and nonsafety-related structures and components are accomplished per the existing IPEC corrective action program and document control program and are applicable to all aging management programs and activities that will be required during the period of extended operation. The confirmation process is part of the corrective action program and includes reviews to assure that proposed actions are adequate, tracking and reporting of open corrective actions, and review of corrective action effectiveness. Any follow-up inspection required by the confirmation process is documented in accordance with the corrective action program. The corrective action, confirmation process, and administrative controls of the Entergy (10 CFR Part 50, Appendix B) Quality Assurance Program are applicable to all aging management programs and activities required during the period of extended operation.

The Operating Experience Program (OEP) and the Corrective Action Program (CAP) help to assure continued effectiveness of aging management programs through evaluations of operating experience. The OEP implements the reguirements of NRC NUREG-0737, "Clarification of TMI Action Plan Requirements,"Section I.C.5 and evaluates site, Entergy fleet, and industry operating experience for impact on IPEC. The CAP implements the requirements of 10 CFR 50, Appendix B, Criterion XVI and is used to evaluate and effect appropriate actions in response to operating experience relevant to IPEC that indicates a condition adverse to quality or a non-conformance._

NL-11-090 Attachment 1 Page 4 of 4 A.3.1 Aging Management iPrograms and Activities The integrated plant assessment for license renewal identified aging management programs necessary to provide reasonable assurance that components within the scope of license renewal will continue to perform their intended functions consistent with the current licensing basis (CLB) through the period of extended operation. This section describes the aging management programs and activities required during the period of extended operation. All aging management programs will be implemented prior to entering the period of extended operation.

IPEC quality assurance (QA) procedures, review and approval processes, and administrative controls are implemented in accordance with the requirements of 10 CFR 50, Appendix B. The Entergy Quality Assurance Program applies to safety-related structures and components. Corrective actions and administrative (document) control for both safety-related and non safety-related structures and components are accomplished per the existing IPEC corrective action program and document control program and are applicable to all aging management programs and activities that will be required during the period of extended operation. The confirmation process is part of the corrective action program and includes reviews to assure that proposed actions are adequate, tracking and reporting.of open corrective actions, and review of corrective action effectiveness. Any follow-up inspection required by the confirmation process is documented in accordance with the corrective action program. The corrective action, confirmation process, and administrative controls of the Entergy (10 CFR Part 50, Appendix B) Quality Assurance Program are applicable to all aging management programs and activities required during the period of extended operation.

The Operating Experience Program (OEP) and the Corrective Action Program (CAP) help to assure continued effectiveness of aging management programs through evaluations of operating experience. The OEP implements the requirements of NRC NUREG-0737, "Clarification of TMI Action Plan Requirements,"Section I.C.5 and evaluates site, Entergy fleet, and industry operating experience for impact on IPEC. The CAP implements the requirements of 10 CFR 50, Appendix B, Criterion XVI and is used to evaluate and effect appropriate actions in response to operating experience relevant to IPEC that indicates a condition adverse to quality or a non-conformance.

ATTACHMENT 2 TO NL-11-090 LICENSE RENEWAL APPLICATION IPEC LIST OF REGULATORY COMMITMENTS Rev. 15 ENTERGY NUCLEAR OPERATIONS, INC.

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

NL-11-090 Attachment 2 Page 1 of 17 List of Regulatory Commitments Rev. 15 The following table identifies those actions committed to by Entergy in this document.

Changes are shown as strikethroughs for deletiens and underlines for additions.

  1. COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRASECTION I AUDIT ITEM IP2: NL-07"039 A.2.1.1 1 Enhance the Aboveground Steel Tanks Program for September 28, A.3.1.1 IP2 and IP3 to perform thickness measurements of 2013 8.1.1 the bottom surfaces of the condensate storage tanks, 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.

IP2: NL-07-039 A.2.1.2 2 Enhance the Bolting Integrity Program for IP2 and IP3

. September 28, A.3.1.2 to clarify that actual yield strength is used in selecting 2013 B.1.2 materials for low susceptibility to SCC and clarify the prohibition on use of lubricants containing MoS2 for IP3: 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.

IP2: NL-07-039 A.2.1.5 3 Implement the Buried Piping and Tanks Inspection September 28, A.3.1.5 Program for IP2 and IP3 as described in LRA Section 2013 B.1.6 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 12015 Inspection.

Include in the Buried Piping and Tanks Inspection . NL-09-106 Program described in LRA Section 8.1.6 a risk NL-09-111 assessment of in-scope buried piping and tanks that 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 0f 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 direct visual inspection.

NL~11-090 Attachment 2 Page 2 of 17*

  1. COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRASECTION 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 2013 B.1.9 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 December 12, 132, 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 SBOIAppendix 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/1. 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 ta.nk, 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 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,

NL-11-090 Attachment 2 Page 3 of 17

  1. COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRASECTION lAUDIT ITEM IP2: 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 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(a1(2).

IP2: 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 8.1.12, perform an evaluation to determine monitoring is not NL-07-153 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.

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

~013 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 ~015 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-11-090 Attachment 2 Page 4 of 17

  1. COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION I AUDIT ITEM IP2: NL-07-039 A.2.1.13 8 Enhance the Fire Water Program to include inspection September 28, A.3.1.13 of IP2 and IP3 hose reels for evidence of corrosion.

2013 8.1.14 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 12015 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.

NL-11-090 Attachment 2 Page 5 of 17

  1. COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION I 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-11-090 Attachment 2 Page 6 of 17

  1. COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRASECTION I AUDIT ITEM IP2: NL-07-039 A.2.1.16 10 Enhance the Heat Exchanger Monitoring Program for September 28, A.3.1.16 IP2 and IP3 to include the following heat exchangers 2013 8.1.17, in the scope of the program.

NL-07-153 Audit Item

  • Safety injection pump lube oil heat exchangers IP3: 52 December 12, .
  • RHR heat exchangers 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
  • Waste gas compressor heat exchangers
  • S80/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.

NL-09-056 11 Delete commitment.

NL-11-090 Attachment 2 Page 7 of 17

  1. COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRASECTION I AUDIT ITEM IP2: NL-07-039 A2.1.18 12 Enhance the Masonry Wall Program for IP2 and IP3 September 28, A3.1.18 to specify that the IP1 intake structure is included in 12013 B.1.19 the program.

IP3:

December 12, 12015 Enhance the Metal-Enclosed Bus Inspection Program IP2: NL-07-039 A2.1.19 13 to add IP2 480V bus associated with substation A to September 28, A3.1.19 the scope of bus inspected. 12013 B.1.20 NL-07-153 Audit Items Enhance the Metal-Enclosed Bus Inspection Program IP3: 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 12015 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.

IP2: NL-07-039 A.2.1.21 14 Implement the Non-EQ Bolted Cable Connections September 28, A3.1.21 Program for IP2 and IP3 as described in LRA Section 2013 B.1.22 B.1.22.

IP3:

December 12, 2015

NL-11-090 Attachment 2 Page 8 of 17

  1. COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRASECTION I AUDIT ITEM IP2: NL-07-039 A.2.1.22 15 Implement the Non-EQ Inaccessible Medium-Voltage September 28, A.3.1.22 Cable Program for IP2 and IP3 as described in LRA 2013 B.1.23 Section 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 XLE3, Inaccessible Medium-Voltage 12015 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 September 28, A.3.1.23 Review Program for IP2 and IP3 as described in LRA 12013 B.1.24 Section 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 XLE2, Electrical Cables and 2015 Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Used in Instrumentation Circuits.

IP2: NL-07~039 A.2.1.24 17 Implement the Non-EQ Insulated Cables and September 28, A.3.1 ;24 Connections Program for IP2 and IP3 as described in 12013 8.1.25 LRA Section 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 XLE1, Electrical Cables and 2015 Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements.

IP2: NL-07-039 A.2.1.25 18 Enhance the Oil Analysis Program for IP2 to sample September 28, A.3.1.25 and analyze lubricating oil used in the SBO/Appendix

~013. 8.1.26 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 the Oil Analysis Program for IP2 and IP3 to formalize trending of preliminary oil screening results as well as data provideq from independent laboratories.

NL-11-090 Attachment 2 Page 9 of 17

  1. COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRASECTION I AUDIT ITEM IP2: NL-07-039 A.2.1.26 19 Implement the One-Time Inspection Program for IP2 September 28, A.3.1.26 and IP3 as described in LRA Section 8.1.27.

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 XLM32, 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.1.28 Section B.1.28.

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 XLM35, One-Time Inspection of ASME 2015 Code Class I Small-Bore Piping.

IP2: NL-07-039 A.2.1.28 21 Enhance the Periodic Surveillance and Preventive.

September 28, A.3.1.28 Maintenance Program for IP2 and IP3 as necessary 2013 B.1.29 to assure that the effects of aging will be managed such that applicable components will continue to IP3:

perform their intended functions consistent with the December 12, current licensing basis through the period of extended 12015 operation.

IP2: NL-07-039 A.2.1.31 22 Enhance the Reactor Vessel Surveillance Program for September 28, A.3.1.31 IP2 and IP3 revising the specimen capsule withdrawal 2013 B.1.32 schedules to draw and test a standby capsule to 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 September 28, A.3.1.32 and IP3 as described in LRA Section B.1 .33.

12013 8.1.33 This new program will be implemented consistent with NL-07-153 Audit item the corresponding program described in NUREG- *IP3: 173 1801, Section XLM33 Selective Leaching of Materials. December 12, 12015 IP2: NL-07-039 A.2.1.34 24 Enhance the Steam Generator Integrity Program for September 28, A.3.1.34 IP2 and IP3 to require that the results of the condition 12013 B.1.35 monitoring assessment are compared to the operational assessment performed for the prior IP3:

operating cycle with differences evaluated.

December 12, 12015 I

NL-11-090 Attachment 2 Page 10 of 17

  1. COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION I AUDIT ITEM 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. ~013 8.1.36
  • 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 ~015 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 (I P3)
  • 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 (lP3)
  • superheater stack
  • .transformerlswitchyard 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)
  • jib cranes
  • manholes and duct banks
  • manways, hatches and hatch covers
  • monorails

NL-11-090 Attachment 2 Page 11 of 17

  1. COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION I AUDIT ITEM
  • 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 and IP3 to perform an engineering evaluation of NL-08-127 Audit Item groundwater samples to assess aggressiveness of 360 groundwater to concrete on a periodic basis (at least once every five years). IPEG 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, IPEG 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 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 and IP3 to perform inspection of the degraded areas Audit Item of the water control structure once per 3 years rather 358 than the normal frequency of once per 5 years during the PEO.

NL-11-090 Attachment 2 Page 12 of 17

  1. COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRASECTION I AUDIT ITEM Enhance the Structures Monitoring Program to include more detailed quantitative acceptance criteria NL-11-032 for inspections of concrete structures in accordance with ACI 349.3R, "Evaluation of Existing Nuclear Safety~Related Concrete Structures" prior to the period of extended operation (PEO).

IP2: NL-07-039 A.2.1.36 26 Implement the Thermal Aging Embrittlement of Cast September 28, A.3.1.36 Austenitic Stainless Steel (CASS) Program for IP2 2013 B.1.37 and IP3 as described in LRA Section 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.

IP2: NL-07-039 A.2.1.37 27 Implement the Thermal Aging and Neutron Irradiation September 28, A.3.1.37 Embrittlement of Cast Austenitic Stainless Steel 2013 B.1.38 (CASS) Program for IP2 and IP3 as described in LRA NL-07-153 Audit item Section B.1.38.

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.

IP2: NL-07-039 A.2.1.39 28 Enhance the Water Chemistry Control- Closed Cooling Water Program to maintain water chemistry of September 28, A.3.1.39

~013 B.1.40 the IP2 SBO/Appendix R diesel generator cooling NL-08-057 Audit item system per EPRI guidelines.

IP3: 509 Enhance the Water Chemistry Control- Closed December 12, Cooling Water Program to maintain the IP2 and IP3 ~015 security generator and fire protection diesel cooling water pH and glycol within limits specified by EPRI guidelines.

IP2: NL-07-039 . A.2.1.40 29 Enhance the Water Chemistry Control- Primary and September 28, B.1.41 Secondary Program for IP2 to test sulfates monthly in 12013 the RWST with a limit of <150 ppb.

IP2: NL-07-039 A.2.1.41 30 For aging management of the reactor vessel internals, September 28, A.3.1.41 IPEC will (1) participate in the industry programs for 2011 investigating and managing aging effects on reactor internals; (2) evaluate and implement the results of IP3:

the industry programs as applicable to the reactor December 12, internals; and (3) upon completion of these programs, 2013 but not less than 24 months before entering the period of extended operation, submit an inspection plan for reactor internals to the NRC for review and approval.

NL-11-090 Attachment 2 Page 13 of 17

  1. COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION I AUDIT ITEM IP2: NL-07-039 A.2.2.1.2 31 Additional P-T curves will be submitted as required September 28, A.3.2.1.2 per 10 CFR 50, Appendix G prior to the period of

~013 4.2.3 extended operation as part of the Reactor Vessel Surveillance Program.

IP3:

December 12,

~015 As required by 10 CFR 50.61 (b)(4), IP3 will submit a IP3: NL-07-039 A.3.2.1.4 32 plant-specific safety analysis for plate B2803-3 to the December 12, 4.2.5 NRC three years prior to reaching the RT PTS ~015 NL-08-127 screening criterion. Alternatively, the site may choose to implement the revised PTS rule when approved.

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

~011 4.3.3 Table 4.3-13 (IP2) and LRA Table 4.3-14 (IP3), under 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, 12013 Detection of Aging Effects, update the fatigue usage calculations using refined fatigue analyses to determine valid CUFs less than 1.0 when accounting Complete NL-10-082 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 GUF.
2. Additional plant-specific locations with a valid GUF may be evaluated. In particular, the pressurizer lower shell will be reviewed to ensure the surge nozzle remains the limiting component.
3. Representative GUF values from other plants, adjusted to or enveloping the IPEG plant specific external loads may be used if demonstrated applicable to IPEG.
4. An analysis using an NRC-approved version of the ASME code or NRC-approved alternative (e.g., NRC-approved code case) may be pertormed 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.

NL-11-090 Attachment 2 Page 14 of 17

  1. COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRASECTION I AUDIT ITEM April 30, 2008 NL-07-078 2.1.1.3.5 34 IP2 SBO / Appendix R diesel generator will be installed and operational by April 30, 2008. This Complete NL-08-074 committed change to the facility meets the requirements of 10 CFR 50.591(1) and, therefore, a license amendment pursuant to 10 CFR 50.90 is not required.

IP2: NL-08-127 Audit Item 35 Perform a one-time inspection of representative September 28, 27 sample area of IP2 containment liner affected by the 2013 1973 event behind the insulation, priorto entering the 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 12015 the extended period of operation, to assure liner degradation is not occurring in this area ..

NL-09-018 Any degradation will be evaluated for updating of the 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 concrete prior to the period of extended operation. 12013 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.

NL-09-079 A sample of leakage fluid will be analyzed to determine the composition of the fluid. If additional core samples are taken prior t6 the end of the first ten years of the period of extended operation, a sample of leakage fluid will be analyzed.

IP2: NL-08-127 Audit Item 37 Enhance the Containment Inservice Inspection (CII-September 28, 361 IWL) Program to include inspections of the

~013 containment using enhanced characterization of degradation (i.e., quantifying the dimensions of noted IP3:

indications through the use of optical aids) during the December 12, period of extended operation. The enhancement

~015 includes obtaining critical dimensional data of degradation where possible through direct measurement or the use of scaling technologies for photographs, and the use of consistent vantage points for visual inspections.

NL-11-090 Attachment 2 Page 15 of 17

  1. COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRASECTION I AUDIT ITEM IP2: NL-08-143 4.2.1 38 For Reactor Vessel Fluence, should future core September 28, loading patterns invalidate the basis for the projected 2013 values of RTpts or CvUSE, updated calculations will be provided to the NRC.

IP3:

. I December 12, 2015 NL-09-079 39 Deleted IP2: NL-09-106 B.1.6 40 Evaluate plant specific and appropriate industry September 28, B.1.22 operating experience and incorporate lessons learned 2013 B.1.23 in establi~hing appropriate monitoring and inspection B.1.24 frequencies to assess aging effects for the new aging IP3: B.1.25 management programs. Documentation of the December 12, B.1.27 o~erating ~xperienc~ evaluated for each new program 2015 B.1.28 will be available on site for NRC review prior to the B.1.33 period of extended operation.

B.1.37 B.1.38 IP2: NL-11-032 N/A 41 IPEG will perform an inspection of steam generators After the for both units to assess the condition of the divider beqinnina of the plate assembly. The examination technique used will be capable of detecting PWSCC in the steam PEO and .J2Qrior o September generator divider plate assemblies. The IP2 steam

>8,2023 NL-11-074 g~n~rator ~ivider plate inspections will be completed Within the first ten years of the period of extended IP3: NL-11-090 operation (PEO). The IP3.steam generator divider Prior to the end plate inspections will be completed within the first of the first refueling outage following the beginning of the PE~.

refueling outage ollowing the beginning of the PE~.

NL-11-090 Attachment 2 Page 16 of 17

  1. COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRASECTION I AUDIT ITEM 42" IPEC will develop a plan for each unit to address the NL-11-032 N/A potential for cracking of the primary to secondary pressure boundary due to PWSCC of tube-to-tubesheet welds.

Each plan will consist of two options.

Option 1 (Analysis) IP2: NL-11-074 IPEC will perform an analytical evaluation redefining Prior to March the pressure boundary in which the tube-to-tubesheet 100 ~8eptomber NL-11-090 weld is no longer included and, therefore, is not , Dfl0'2 required for reactor coolant pressure boundary function. The redefinition of the reactor coolant IP3: Prior to the pressure boundary must _be approved by the NRC end of the first sl:IbmitteEi as part of a license amendment request refuelioo outcme reql:liring approval from tho NRC. lfoliowinQ the beQinninQ of the PEa. gesember ,

Option 2 (Inspection) ._,----

liD 0{\0&;;.

IPEC will perform a one-time inspection of a representative number of tube-to-tubesheet welds in each steam generator to determine if PWSCC cracking is present. If weld cracking is identified: IP2:

a. The condition will be resolved through repair Betweon March or engineering evaluation to justify continued 12020 and March service, as appropriate, and 12024 .
b. An ongoing monitoring program will be IP3: Prior to the established to perform routine tube-to- end of the first tubesheet weld inspections for the remaining refueling outage life of the steam generators. ~ollowing the beginning of the PEa.

IP2: NL-11-032 4.3.3 43 IPEC will review design basis ASME Code Class 1 Prior to fatigue evaluations to determine whether the '

NUREG/CR-6260 locations that have been evaluated September 28, for the effects of the reactor coolant environment on ~013 fatigue usage are the limiting locations for the IP2 and IP3: Prior to IP3 configurations. If more limiting locations are December 12, identified, the most limiting location will be evaluated for the effects of the reactor coolant environment on 12015 fatigue usage.

IPEC will use the NUREG/CR-6909 methodology in the evaluation of the limiting locations consisting of nickel alloy, if any.

NL-11-090 Attachment 2 Page 17 of 17

  1. COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRASECTION I AUDIT ITEM Within 60 days NL-11-032 N/A 44 IPEC will include written explanation and justification of issuance of of any user intervention in future evaluations using the he renewed WESTEMS "Design CUF" module.

pperating license.

Within 60 days NL-11-032 N/A 45 IPEC will not use the NB-3600 option 'of the of issuance of WESTEMS program in future design calculations until he renewed the issues identified during the NRC revieVli of the operating program has been resolved.

license.

IP2: NL-11-032 N/A 46 Include in the IP2 lSI Program that IPEC will perform Prior,to twenty-five volumetric weld metal inspections of September 28, NL-11-074 socket welds during each 10-year lSI interval

~O13 scheduled as specified by IWB-2412 of the ASME Section XI Code during the period of extended operation.

In lieu of volumetric examinations, destructive examinations may be performed, where one destructive examination may be substituted for two volumetric examinations.

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