NL-09-111, Official Exhibit - NYS000171-00-BD01 - Entergy (NL-09-111), Additional Information Regarding Renewal Application-IPEC RAI 2.3A.3.11-1 and Buried Piping and Tanks Inspection Clarifications, IP Nuclear Generating Unit Nos. 2 and 3, Excerpted
| ML12334A709 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 08/06/2009 |
| From: | Dacimo F Entergy Nuclear Northeast |
| To: | Atomic Safety and Licensing Board Panel, Document Control Desk, Office of Nuclear Reactor Regulation |
| SECY RAS | |
| References | |
| RAS 21566, 50-247-LR, 50-286-LR, ASLBP 07-858-03-LR-BD01, NL-09-111 | |
| Download: ML12334A709 (23) | |
Text
{{#Wiki_filter: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 Docket #: 05000247 l 05000286 NYS000171 Exhibit #: NYS000171-00-BD01 Identified: 10/15/2012 Submitted: December 16, 2011 Admitted: 10/15/2012 Withdrawn: Rejected: Stricken: Other: Entergy Nuclear Northeast Indian Point Energy Center 450 Broadway, GSB P.O. Box 249 Buchanan, NY 10511-0249 Tel (914) 788-2055 Fred Dacimo Vice President License Renewal NL-09-111 August 6, 2009 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001
SUBJECT:
Additional Information Regarding License Renewal Application - IPEC RAI2.3A.3.11-1 and Buried Piping and Tanks Inspection Clarifications Indian Point Nuclear Generating Unit Nos. 2 & 3 Docket Nos. 50-247 and 50-286 License Nos. DPR-26 and DPR-64
REFERENCE:
- 1. Entergy Letter dated November 16, 2007, F. R. Dacimo to Document Control Desk, "Reply to Request for Additional Information Regarding License Renewal Application" (NL-07-138)
- 2. Entergy Letter dated July 27,2009, F. R. Dacimo to Document Control Desk, "Questions Regarding Buried Piping Inspections" (NL-09-106)
- 3. Telephone Conference Call Held on August 4, 2009, Between the U.S. Nuclear Regulatory Commission and Entergy Nuclear Operations, Inc., Pertaining to the Indian Point Nuclear Generating Unit Nos. 2 and 3, License Renewal Application - IPEC RAI 2.3A.3.11-1 Clarification
- 4. Telephone Conference Call Held on August 5,2009, Between the U.S. Nuclear Regulatory Commission and Entergy Nuclear Operations, Inc., Pertaining to the Indian Point Nuclear Generating Unit Nos. 2 and 3, License Renewal Application - Buried Piping and Tanks Inspection
Dear Sir or Madam:
On August 4 and August 5, 2009 Teleconferences were held between the U.S. Nuclear Regulatory Commission and Entergy Nuclear Operations, Inc. concerning our response to RAI 2.3A.3.11-1 in Reference 1 and Buried Piping and Tanks Inspection information in Reference 2. In response to staff questions, Entergy Nuclear Operations, Inc is providing, in Attachment 1, a IPEC RAI 2.3A.3.11-1 and Buried Piping and Tanks Inspection clarifications pertaining to the License Renewal Application for Indian Point 2 and Indian Point 3. IA(2~
. ~UU:
NL-09-111 Page 2 of 2 If you have any questions, or require additional information, please contact Mr. Robert Walpole at 914-734-6710. I declare under penalty of perjury that the foregoing is true and correct. Executed on
<8 (lJ>(()9 .
Si~ FRO/dmt
Attachment:
- 1. Additional Information Regarding License Renewal Application -
IPEC RAI 2.3A.3.11-1 and Buried Piping and Tanks Inspection Clarifications
- 2. IPEC Commitment List, Revision 11 cc: Mr. Samuel J. Collins, Regional Administrator, NRC Region I Mr. Sherwin E. Turk, NRC Office of General Counsel, Special Counsel Ms. Kimberly Green, NRC Safety Project Manager Mr. John Boska, NRR Senior Project Manager Mr. Paul Eddy, New York State Department of Public Service NRC Resident Inspector's Office Mr. Francis J. Murray, President and CEO, NYSEROA IPEG PA OAG0001683
ATTACHMENT 1 TO NL-09-111 Additional Information Regarding License Renewal Application - IPEC RAI 2.3A.3.11-1 and Buried Piping and Tanks Inspection Clarifications
.. ::~
ENTERGY NUCLEAR OPERATIONS, INC. INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 & 3 DOCKET NOS. 50-247 AND 50-286 IPEG PA OAG0001684
Attachment 1 NL-09-111 Page 1 of 1 INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 AND 3 LICENSE RENEWAL APPLICATION IPEC RAI2.3A.3.11-1 AND BURIED PIPING AND TANKS INSPECTION CLARIFICATIONS RAI 2.3A.3.11-1 Clarification The IP1 fire protection components that are referenced in the RAI 2.3A.3.11-1 response are specifically used only to support IP1 and do not have an intended function for IP2 or IP3. They are not required to demonstrate IP2 or IP3 compliance with 10 CFR 50.48 and therefore, are not in the scope of license renewal. The IP1 components are credited in the IP1 fire protection program which meets the requirements of 10 CFR 50.48(f). Buried Piping and Tanks Inspection Program - Clarification .. Program Improvements Resulting from Operating Experience Entergy will employ inspection methods with demonstrated effectiveness for detection of aging effects during the period of extended operation The Electric Power Research Institute is evaluating a number of techniques for application to the commercial nuclear power industry, e.g., guided wave ultrasonic technology. Entergy will employ an inspection method that has been demonstrated effective by EPRI to address issues with degradation of buried components. Commitment Include in the Buried Piping and Tanks Inspection Program described in LRA Section B.1.6 a' risk 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 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. IPEG PA OAG0001685
ATTACHMENT 2 TO NL-09-111 IPEC Commitment Letter, Revision 11
'c' _' :_,._, ~ . '.
0.' J
. ... . - .: .... ~ - .. "-,' .....-:.:
ENTERGY NUCLEAR OPERATIONS, INC. INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 & 3 DOCKET NOS. 50-247 AND 50-286 IPEG PA OAG0001686
Attachment 2 NL-09-111 Page 1 of 18 List of Regulatory Commitments Revision 11 The following table identifies those actions committed to by Entergy in this document. Changes are shown as strikethroughs for deletions and underlines for additions.
- 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 the bottom surfaces of the condensate storage tanks, ~013 B.1.1 city water tank, and fire water tanks once during the IP3:
first ten years of the period of extendecj operation. December 12, Enhance the Aboveground Steel Tanks Program for ~015 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 materials for low susceptibility to SCC and clarify the ~013 B.1.2 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 12015 270 preload and loss of material for all external bolting.
~- .-...
IPEG PA OAG0001687
Attachment 2 NL-09-111 Page 2 of 18
- COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRASECTION I AUDIT ITEM 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 2015 Inspection ... '.- Include in the Buried Piping and-Tanks Inspection NL-09-106 Program described-in LRASection B:1.6 a risk assessment of in~scope'buriedpiping and tanks that NL-09-111 includes consideration of. the impacts of buried piping or tank leakage and of conditions affe-cting the risk for corrosion .. Classify pipe ~egments alld 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-scop*e piping and tanks based on the results of the risk assessment. Perform inspections using qualified inspection techniques with. demonstrated effectiveness. IPEC PA OAG0001688
Attachment 2 NL-09-111 Page 3 of 18
- 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 turbine fuel oil storage tanks, IP2 and IP3 EDG fuel oil ~013 S.1.9 day tanks, IP2 SBO/Appendix R diesel generator fuel NL-07-153 Audit items IP3: 128, 129, oil day tankL~nd IP3 Appendix R fuel oil storage tank December 12, 132, and day tan~ once every ten years ..
12015 NL-08-057 491,492, Enhance the Diesel Fuel Monitoring Program to 510 include quarterly sampling and analysis of the IP2 SBO/Append!x R diesel generator fuel oil day tank, IP2 security_ diesel fuel oil storage tank, IP'2 security diesel fuel oil daytqnk,and IP3Appendix"R fuel oil storage tank-. _Particuiates, water and sediment - checks will be pertormed on the samples. Filterable solids acceptance- criterion-will beiess 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 tenyears. IP2: EDG fuel oil storage tanks,.EDG fuel oil day-tanks; SSO/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 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. IPEG PA OAG0001689
Attachment 2 NL-09-111 Page 4 of 18
# COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION I AUDIT ITEM 4 Enhance the Diesel Fuel Monitoring Program to direct Cont the addition of chemicals including biocide when the presence of bioloQical activity is confirmed.
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 12013 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(a)(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 2013 B.1.12, performanevaluatioh-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.
"~', .
- .~
". . ""':"~' ~'.-+-£.,., .
IPEG PA OAG0001690
Attachment 2 NL-09-111 Page 5 of 18
- COMMITMENT IMPLEMENTATION - SOURCE RELATED SCHEDULE LRASECTION I AUDIT ITEM 7- IP2: NL-07-039 A.2.1.12 Enhance the Fire Protection Program to inspect September 28, A.3.1.12 external surfaces of the IP3 RCP oil collection 2013 B.1.13 systems for loss of material each refueling cycle.
Enhance the Fire Protection Program to explicitly IP3: state that the IP2 and IP3 diesel fire pump engine December 12, sub-systems (including the fuel supply line) shall be 2015 observed while the pump is running. Acceptance criteria will be revised to verify that the diesel engine does not exhibit signs of degradation while running; such as fuel oil, lube oil, coolant, or exhaust gas leakage. - Enhance the Fire ProtectionPrograrri to specify that the IP2 and IP3 diesel fire pump engine carbon steel exhaust components are inspected for evidence of corrosion and c~acking at least once. each operating cycle. __ . _ _- Enhance the FIre Protecti()n Piogram for IP3 to visually inspect the cable spreadingrootn-, 480V switchgear room, and EDG room CO2fire suppression system for signs of degradation, such as corrosion and mechanical damage at least once every six months. IPEG PA OAG0001691
Attachment 2 NL~09-111 Page 6 of 18
- COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRASECTION I AUDIT ITEM IP2: NL-07-039 A.2.1.13 8 Enhance the FireWater 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 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 o1.loss of material due to corrosion. These inspections will be performed before the end of the current operating term aild at intervals thereafter during the period of ex1ended operation. Re.sults 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. IPEG PA OAG0001692
Attachment 2 NL-09-111 Page 7 of 18
# COMMITMENT IMPLEMENTATION - SOURCE- RELATED SCHEDULE LRASECTION 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 FluxThimble Tube Inspection Program
.for IP2 and IP3 to specify the acceptance criteria as outlined- inWCAP-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. IPEG PA OAG0001693
Attachment 2 NL-09-111 Page 8 of 18
# 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 in the scope of the program. ~013 B.1.17, NL-07-153 Audit Item
- Safety injection pump lube oil heat exchangers IP3: 52 December 12,
- RHR heat exchangers
~015
- RHR pump seal coolers
* . Non-regenerative heat exchangers
.-. Charging pump seal water heat exchangers
'~~--Ghargingpump fluid drive coolers
'-5 '
. "" .:- ~
- 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 foulinQ, or scalinQ. NL-09-056 11 Delete commitment. IPEG PA OAG0001694
Attachment 2 NL-09-111 Page 9 of 18
# COMMITMENT IMPLEMENTATION SOURCE* RELATED SCHEDULE LRA SECTION I AUDIT ITEM IP2: NL-07-039 A.2.1.18 12 Enhance the Masonry Wall Program for IP2 and IP3 September 28, ... A.3.1.18 to specify that the IP1 intake structure is included in 2013 B.1.19 the program.
IP3: December 12, 2015 Enhance the Metal-Enclosed Bus Inspection Program IP2: NL-07-039 A.2.1.19 13 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 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 . 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 lire-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, A.3.1.21 Program for IP2 and IP3 as described in LRA Section 2013 B,1.22 B.1.22. IP3: December 12, 2015 IPEG PA OAG0001695
Attachment 2 NL-09-111
. Page 10 of 18 # 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 8.1.23 Section 8.1.23. 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 Section 8.1.24. . - . - . " .~.: -. ," 2013 .. 8.1.24
- .".":: ... -:;." ..-. . NL:.. 0]-.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 Connections Program for IP2 and IP3 as described in September 28, A.3.1.24 LRA Section 8.1.25. 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 XLE1, Electrical Cables and 2015 Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements. IPEG PA OAG0001696
Attachment 2 NL-09-111 Page 11 of 18
# COMMITMENT IMPLEMENTATION " SOURCE RELATED SCHEDULE LRA SECTION I AUDIT ITEM 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 B.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 ~015 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. . ,:::," 0 ,. >'", . .. Enhance the Oil Analysis Program for IP2 and IP3 to formalize trending of preliminary oil screening results as well as data provided from independent laboratories. IP2: NL-07-039, A.2.1.26 19 Implement the One-Time Inspection Programfor IP2. . and IP3 as described in LRA Section B.1.27. September 28, A.3.1.26
~013 B.1.27 This new program will be implemented consistent with NL-07-153 Audit item the corresponding program described in NUREG- " IP3:, 173 1801, Section XI,M32, One-Time Inspection. .' December 12,
~015 IP2: N~-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
~013 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 XI,M35, One-Time Inspection of ASME ~015 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
~013 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
~015 operation.
IPEG PA OAG0001697
.Attachment 2 NL-09-111 Page 12 of 18 # COMMITMENT IMPLEMENTATION " SOURCE RELATED SCHEDULE LRASECTION I AUDIT ITEM 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'" , c September 28, . A.3.1.32 and IP3 as described in LRASection' 8.1:.33:' .' 2013 B.1,33 This new program will be implerl)ented ~6nsistent with NL-07-153 Audit item the corresponding program described in NUREG- IP3: 173 1801, Section XI.M33 Selective Leaching of Materials. December 12,
- 2015 IP2: ' NL-07-039 A.2.1.34 24 Enhance the Steam Generator IntegritiProgram for September 28, A.3.1.34 IP2 and IP3 to require that the results of the condition 2013 B.1.35 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 ., A.3.1.35 explicitly specify that the following structures are ' September 28, 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 (I P3)
- city water storage tank foundation
- condensate storage tanks foundation (IP3)
- containment access facility and annex (IP3) ...;.
- discharge canal (IP2/3) .
- emergency lighting poles and foundations (IP2/3)
- fire pumphouse (IP2)
- fire protection pumphouse (I P3)
- fire water storage tank foundations (IP2/3)
- gas turbine 1 fuel storage tank foundation
- maintenance and outage building-elevated passageway (IP2)
IPEG PA OAG0001698
Attachment 2 NL-09-111 Page 13 of 18
- COMMITMENT IMPLEMENTATION: SOURCE~' RELATED SCHEDULE LRA SECTION I AUDIT ITEM
- new station security building (I P2)
- nuclear service building (I P1)
- primary water storage tank foundation (IP3)
- refueling water storage tank foundation (IP3)
- security access and office building (IP3)
- service water pipe chase (IP2/3)
- service water valve pit (I P3) . _
- superheater stack .
- transformer/switchyard support structures (I P2)
.-- - .'-' .' ~ .. .... ..: ... , :. ..
- waste holdup tank pits (I P2/3) - - - -. . ", "
--..~
Enhance the Structures Monitoring Program for IP2 and IP3 to clarify that in addition to structural steel. and concrete, the following.commodities (including. their anchorages) are inspeCted for each structure, as applicable.
. ',' ~ _. -'.. . ".. .
- cable trays and supports,-- .
- concrete portion of reactor vessel supports .
- conduits and supports- -
- cranes, rails and girders
- equipment pads and foundations . ~
- fire proofing (pyrocrete)
- HVAC duct supports
- jib cranes
* "ma:nholes and duct bcinks"'-'-~--'-"
- manways, hatches and hatch covers - I .
- 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 IPEG PA OAG0001699
Attachment 2 NL-09-111 Page 14 of 18
- COMMITMENT IMPLEMENTATION- SOURCE RELATED SCHEDULE LRA SECTION I AUDIT ITEM 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):, IPECwillobtain 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 ~ulfates,pH and chlorides. Additionally, to assess' potential indications of spent fuel pool leakage; IPEC\villsample 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 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 PE~. '. 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 -- . 8.1.37 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, ThermalAging Embrittlement _ 20~5-- . '"
'0-of Cast Austenitic Stainless Steel (CASS) Program: . . ~.
IPEG PA OAG0001700
Attachment 2 NL-09-111 Page 15 of 18
# COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION IAUDIT ITEM IP2: NL-07-039 A.2.1.37 27 Implement the Thermal Aging and Neuttori Irradiation September 28, . A.3.1.37 Embrittlement of Cast Austenitic Stainless Steel 12013 B.1.38 (CASS) Program for IP2 and IP3 as described in LRA NL-07-153 Audit item Section B.1.3S.
IP3: 173 This new program will be implemented consistent with December 12,~ " " . the corresponding program described in NUREG-, 12015 .. 1801 Section XI.M13, Thermal Aging and Neutron* Embrittlement of Cast Austenitic Stainless Steel (CASS) Proqram.
. IP2: NL-07-039 A.2.1.39 28 Enhance the Water Chemistry Control':'" Closed .' ,
Cooling Water Program to maintain vvater qhemistry of ~~f~ember 28, A.3.1.39, B.1.40 the IP2 SBD/Appendix R diesel generator cooling ,"' . NL-OS-057 Audit item system per EPRlguideline~. '. '. ' " IP3: 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. 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 2.1013 '. :'.' :
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 . internals; and (3) upon completion of these programs; December 12, but not less than 24 months before entering th~ period 12013 ",', , " of extended operation, submit an inspection plan for' .. " reactor internals to the NRC for review and approval.' , IP2: NL-07-039 A.2.2.1.2 31 Additional P-T curves will be submitted as required , .-', September. 28,. ~ ~. >:~ - - ~;:A*.3.2.l.2* per 10 CFR 50, Appendix G prior to the period of. 121 extended operation as part of the Reactor. Vessel .' l'-o.1_~ 4.2.3' Surveillance Program . . ".. " _ . ' ; 0 " ' , ' . IP:t
~. ".~::-'.<"'" ".?:.-{;:~~
-' '-- Oece.mber, 1?,
12015 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 82803-3 to the December 12, 4.2.5 NRC three years prior to reaching the RT PTS 12015 NL-OS-127 screening criterion. Alternatively, the site may choose to implement the revised PTS rule when approved. IPEG PA OAG0001701
Attachment 2 NL-09-111 Page 16 of 18
# COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRASECTION I 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: 2011 . 4.3.3 Table 4.3-13 (IP2) and LRA Table 4.3-14 (IP3),' under NL-07~1S3 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' 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 (I P2) 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 CUF may be evaluated. In particular, the . .
pressurizer lower shell will be reviewed to'ensurei .." ' the surge nozzle remains the limiting component.
- 3. Representative CUF values from other plants, .,
adjusted to or enveloping the IPEC plant specific.* c. " external loads may be used if demonstrated 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 valjd C;UF. (2) Consistent with the Fatigue Monitoring Program, Corrective Actions, repair or replace the affected* . c,... ' ":. locations before exceeding a CUF of 1.0. April 30, 2008 NL-07~078 2.1.1.3.S 34 IP2 SBO / Appendix R diesel generator will be installed and operational by April 30, 2008. This committed change to the.facilitymeets the" :.:~~ ... ,Comple!~.:., .~::~L-Q§~9Z4., ' requirements of 10 CFR SO.S9(c)(1) arid, theref6re~ a " .., license amendment pursuant to 10 CFR SO.90 is not required. IPEC PA OAG0001702
Attachment 2 NL-09-111 Page 17 of 18
# COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION I AUDIT ITEM NL-08-127 Audit Item 35 Pe rf orm a one- t*
Ime*Inspe.ct'Ion 0 f..represen t at'Ive '.' :, ~ , IP2: t m r sample area of IP2 containment liner affected by the" ~gf3e be 28, 27 1973 event behind the insulation, prior to entering the f-' 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 IP3containment steel, liner at the December 12, juncture with the concrete floor slab, prior to entering ~015 the extended period-of operation, to assure liner ..' : .' degradation is not occurringinthis:area.* ' Any degradationwil( be ,evaluated fm updating of the. NL-09-018 containment liner analyses as needed: IP2: NL-08-127 Audit Item 36 Perfmll) a one-time,lnspection cmd evaluation of a September 28, 359 sample orpotentially affected I P2. refueling cavity 12013 concrete prim 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 reinfmcing 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 fiuid will be arialy~~d to NL-09-079 determine the composition of the fluid. If additional cme samples are taken prior to the end of the first ten* years of the period of extendedoperation,asample of leakage fluid will be analyzed::~'* .
. IP2:, NL-08-127 Audit Item 37 Enhance the Contairi'mentlnservice Inspection (Cil-Septemb~r 28, 361 IWL) Program to include inspections of the containment usirigenhanced characteriiation of " . 201:3.. ' ..
degradation-(Le., quantifying the'dlmenslons of noted : -~ IP3: indications through the use of optical aids)' during the December 12, period of extended operation. The enhancement includes ot:>taining critical,dimensionaLdata of '., '.' 120. 15.. .' :,'=: I; :'~:.'.""'" ~:,,,. degradation where possible through direct' .' .... . . measurement or the use of scalingtech l1 ologies fo'r . photographs, and the use of consistent vantage points for visual inspections. IPEG PA OAG0001703
Attachment 2 NL-09-111 Page 18 of 18
# 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
~013 values of RTpts or CvUSE, updated-calculations will be provided to the NRC.;:: ", ' c . _
IP3: December 12,
~015 NL-09-079 39 Deleted . , . . ..
Evaluate plant specif.ic and app-~opriate industry IP2: NL-09-106 B.1.6 40 September 28, B.1.22 operating experience and incorporate lessons learned 2013 B.1.23 in establishing appropriate monitoring-and inspection' B.1.24 frequencies to assess aging 'effects fOLthe new aging" _, management programs. ,Docurn~ntation of the IP3. B.1.25 o~erating ~xperience evaluatedJor each new progrC\m~' December 12, B.1.27 Will be available on site for NRC review prior to the--', ~015 B.1.28 B.1.33 period of extended operation. ' c - - ' , - B.1.37 B.1.38
'. ~ ....
.;~ -:-.' .' . ~.'
- . ' ,.~.. . --.: :., ". :
~,;:- . :.
- .~ . -~ '. .. , ~'.- .-~' .;":'
IPEG PA OAG0001704}}