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Lr - Davis-Besse Updated Commitment List
	ML13024A275
Person / Time
Site:	Davis Besse
Issue date:	01/22/2013
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To:	; Division of License Renewal
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Davis-BesseNPEm Resource From: dorts@firstenergycorp.com Sent: Tuesday, January 22, 2013 9:02 AM To: CuadradoDeJesus, Samuel Cc: custerc@firstenergycorp.com

Subject:

Davis-Besse Updated Commitment List Attachments: DBLR Commitment List thru Amend 37.doc; DBLR Commitment List thru Amend 37.pdf; DBLR Commitment List thru Amend 36 trk chgs.doc Sam..... for your information / use.

Steve Dort FENOC License Renewal ----------------------------------------- The information contained in this message is intended only for the personal and confidential use of the recipient(s) named above. If the reader of this message is not the intended recipient or an agent responsible for delivering it to the intended recipient, you are hereby notified that you have received this document in error and that any review, dissemination, distribution, or copying of this message is strictly prohibited. If you have received this communication in error, please notify us immediately, and delete the original message.

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Hearing Identifier: Davis_BesseLicenseRenewal_Saf_NonPublic Email Number: 4023 Mail Envelope Properties (OFFE5CDC03.C406163A-ON85257AFB.004CD240-85257AFB.004D0CC8)

Subject:

Davis-Besse Updated Commitment List Sent Date: 1/22/2013 9:01:34 AM Received Date: 1/22/2013 9:01:50 AM From: dorts@firstenergycorp.com Created By: dorts@firstenergycorp.com Recipients:

"custerc@firstenergycorp.com" <custerc@firstenergycorp.com>

Tracking Status: None "CuadradoDeJesus, Samuel" <Samuel.CuadradoDeJesus@nrc.gov>

Tracking Status: None Post Office: FirstEnergyCorp.com Files Size Date & Time MESSAGE 678 1/22/2013 9:01:50 AM DBLR Commitment List thru Amend 37.doc 284224 DBLR Commitment List thru Amend 37.pdf 140009 DBLR Commitment List thru Amend 36 trk chgs.doc 318016 Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:

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Davis Besse Nuclear Power Station, Unit No. 1 License Renewal Future Commitments (Through LRA Amendment 37)

Table A-1 Davis-Besse License Renewal Commitments Related LRA Item Implementation Commitment Source Section No./

Number Schedule Comments 1 Enhance the Aboveground Steel Tanks Inspection Program to: Prior to LRA A.1.2

Include a volumetric examination of tank bottoms to detect April 22, 2017 and B.2.2 evidence of loss of material due to crevice, general, or pitting corrosion, or to confirm a lack thereof. Establish the examination FENOC Response to technique, the inspection locations, and the acceptance criteria Letter NRC RAI for the examination of the tank bottoms. Require that L-11-153 B.2.2-1 from unacceptable inspection results be entered into the FENOC NRC Letter Corrective Action Program. The volumetric examination of the dated tank bottoms will be performed within five years after entering April 20, 2011 the period of extended operation. Additional opportunistic tank bottom inspections will be performed whenever the tanks are drained.

2 Implement the Boral Monitoring Program as described in LRA April 22, 2017 LRA A.1.5 Section B.2.5. B.2.5 3 Enhance the Buried Piping and Tanks Inspection Program to: Prior to LRA A.1.7

Add 1) bolting for buried Fire Protection System piping and 2) April 22, 2017 and B.2.7 the emergency diesel fuel oil storage tanks (DB-T153-1, DB- and T153-2) to the scope of the program. FENOC Response to

Conduct annual ground potential surveys of the cathodic Letter NRC RAI protection system using the acceptance criteria listed in L-11-153 B.2.7-1 from NACE RP0285 2002 and NACE SP0169-2007. Monitor cathodic NRC Letter Page 1 of 33

Table A-1 Davis-Besse License Renewal Commitments Related LRA Item Implementation Commitment Source Section No./

Number Schedule Comments protection voltage and current monthly to determine dated the effectiveness of cathodic protection systems and, thereby, April 20, 2011 the effectiveness of corrosion mitigation. Trend voltage, current, and ground potential readings and evaluate for adverse changes.

Require that the activity of the jockey fire pump or equivalent parameter be monitored on at least a monthly interval.

Conduct a flow test by the end of the next refueling outage when unexplained changes in jockey pump activity are observed.

Require that the directed buried pipe inspection locations be selected based on risk.

Require that the minimum number of buried in-scope piping inspections during the 30-40, 40-50, and 50-60 year operating period is one steel safety-related piping segment and one steel piping segment containing hazardous material. Perform the directed buried steel pipe and tank inspections each ten year interval based upon the following table. Each inspection will have a minimum of 10 feet of piping inspected.

Preventive # of inspections of safety # of Hazmat inspections Actions related piping or tanks or % of pipe length A 1 (Note 2) 1 (Note 2)

B 1 2%

C 4 5%

D 8 10 %

Note 1: Preventive actions are categorized as follows:

A. - Cathodic protection, in accordance with NACE SP0169-2007 or NACE RP0285-2002, was installed for at least 5 years prior to entering the period of extended operation and was operational for 90% of the time Page 2 of 33

Table A-1 Davis-Besse License Renewal Commitments Related LRA Item Implementation Commitment Source Section No./

Number Schedule Comments during that 5 years or cathodic protection was operational for 90% of the time since the last inspection conducted under this program.

B. - Cathodic protection, in accordance with NACE SP0169-2007 or NACE RP0285-2002, was installed for less than 5 years prior to entering the period of extended operation or was operational for less than 90% of the time during that 5 years or cathodic inspection was operational for less than 90% of the time since the last inspection conducted under this program C. - Protective coatings are in place and no mechanical coating damage due to the backfill, but cathodic protection is not provided or not in accordance with criteria A or B and the period of extended operation has not been entered.

D. - Criteria of A, B, and C not met.

Note 2: Only one inspection is required for piping which is both safety-related and contains hazardous material.

Require that the EDG Fuel Oil Storage Tanks (DB-T153-1 and DB-T153-2) be inspected prior to entering the period of extended operation. The inspection will be either a visual inspection of at least 25% of each tank and include at least some portion of the tank top and bottom or, an internal inspection consisting of UT measurements with at least one measurement per square foot of the surface of the tanks.

These inspections are not required if it is demonstrated that the tanks are cathodically protected in accordance with NACE SP0169-2007 or NACE RP0285-2002.

Require that a visual and volumetric inspection of the underground piping within the borated water piping trench will Page 3 of 33

Table A-1 Davis-Besse License Renewal Commitments Related LRA Item Implementation Commitment Source Section No./

Number Schedule Comments be performed during each 10-year period beginning no sooner than 10 years prior to the entry into the period of extended operation.

Require that if adverse indications are detected, additional buried in-scope piping inspections be performed in order to provide reasonable assurance of the integrity of buried piping.

Base the selection of components to be examined on previous examination results, trending, risk ranking, and areas of cathodic protection failures or gaps, if applicable. Continue additional sampling until reasonable assurance of the integrity of buried piping is provided.

Require that an inspection of buried Fire Protection System bolting will be performed when the bolting becomes accessible during opportunistic or focused inspections.

Require that the inspections of buried piping be conducted using visual (VT-3 or equivalent) inspection methods. Excavation shall be a minimum of 10 linear feet of piping, with all surfaces of the pipe exposed.

4 Implement the Collection, Drainage, and Treatment Components April 22, 2017 LRA A.1.9 Inspection Program as described in LRA Section B.2.9. B.2.9 5 Implement the Electrical Cable Connections Not Subject to Prior to LRA A.1.11 10 CFR 50.49 Environmental Qualification Requirements Inspection April 22, 2017 and B.2.11 as described in LRA Section B.2.11.

Enhance the Electrical Cable Connections Not Subject to FENOC Response to 10 CFR 50.49 Environmental Qualification Requirements Letter NRC RAI 3.6-3 Inspection to:

L-11-134 from NRC

Include high voltage connections to confirm the absence of Letter dated aging effects for metallic electrical connections. April 5, 2011 Page 4 of 33

Table A-1 Davis-Besse License Renewal Commitments Related LRA Item Implementation Commitment Source Section No./

Number Schedule Comments 6 Implement the Electrical Cables and Connections Not Subject to April 22, 2017 LRA A.1.12 10 CFR 50.49 Environmental Qualification Requirements Program B.2.12 as described in LRA Section B.2.12.

7 Implement the Electrical Cables and Connections Not Subject to April 22, 2017 LRA A.1.13 10 CFR 50.49 Environmental Qualification Requirements Used in B.2.13 Instrumentation Circuits Program as described in LRA Section B.2.13.

8 Enhance the External Surfaces Monitoring Program to: Prior to LRA A.1.15

Add systems which credit the program for license renewal but April 22, 2017 and B.2.15 do not have Maintenance Rule intended functions to the scope of the program. FENOC Responses to

Perform opportunistic inspections of surfaces that are Letters NRC RAIs inaccessible or not readily visible during normal plant operations L-11-153, 3.3.2.2.5-1 and or refueling outages, such as surfaces that are insulated. L-11-166 B.2.2-2 from Surfaces that are accessible will be inspected at a frequency not and NRC Letter to exceed one refueling cycle. L-11-238 dated

Perform, in conjunction with the Inspection of Internal Surfaces April 20, 2011, in Miscellaneous Piping and Ducting Program, inspection and NRC RAI surveillance of elastomers and polymers exposed to air-indoor 3.3.2-2 from uncontrolled or air-outdoor environments, but not replaced on a NRC Letter set frequency or interval (i.e., are long-lived), for evidence of dated cracking and change in material properties (hardening and loss May 2, 2011, of strength) and loss of material due to wear. Specify RAI 3.3.2.2.5-2 acceptance criteria of no unacceptable visual indications of from cracks or discoloration that would lead to loss of function prior to NRC Letter the next inspection, and of no hardening as evidenced by a loss dated of suppleness during manipulation.

July 12, 2011,

Perform inspection of the control room emergency ventilation Page 5 of 33

Table A-1 Davis-Besse License Renewal Commitments Related LRA Item Implementation Commitment Source Section No./

Number Schedule Comments system air-cooled condensing unit cooling coil tubes and fins and and the station blackout diesel generator radiator tubes and fins Supplemental for visible evidence of external surface conditions that could RAI OIN-352 result in a reduction in heat transfer. Specify acceptance criteria from of no unacceptable visual indications of fouling (build up of dirt NRC Region III or other foreign material) that would lead to loss of function prior IP-71002 to the next scheduled inspection. Inspection

Manage cracking of copper alloys with greater than 15 percent zinc and stainless steel components exposed to an outdoor air environment through plant system inspections and walkdowns for evidence of leakage. Specify acceptance criteria of no unacceptable visual indications of cracks that would lead to loss of function prior to the next scheduled inspection.

Include inspection parameters and acceptance criteria for polymers, elastomers and metallic components as applicable in system inspection and walkdown documentation. Retain system inspection and walkdown documentation in plant records.

9 Enhance the Fatigue Monitoring Program to: Prior to LRA A.1.16

Provide for updates of the fatigue usage calculations on an as April 22, 2017 and B.2.16 needed basis if an allowable cycle limit is approached. When the number of accrued cycles is within 75% of the allowable FENOC Responses to cycle limit for any transient, a condition report will be generated. Letter NRC RAIs For any transient whose cycles are projected to exceed the L-11-166 B.2.16-3, allowable cycle limit by the end of the next plant operating cycle B.2.16-4 (Davis-Besse operating cycles are normally two years in and duration), the program will require an update of the fatigue B.2.16-5 usage calculation for the affected component(s). from

Establish an acceptance criterion for maintaining the cumulative NRC Letter fatigue usage below the Code design limit of 1.0 through the dated Page 6 of 33

Table A-1 Davis-Besse License Renewal Commitments Related LRA Item Implementation Commitment Source Section No./

Number Schedule Comments period of extended operation, including environmental effects April 20, 2011 where applicable 10 Enhance the Fire Water Program to: April 22, 2017 LRA A.1.18

Perform periodic ultrasonic testing for wall thickness of B.2.18 representative above-ground water suppression piping that is not periodically flow tested but contains, or has contained, stagnant water. The ultrasonic testing will be performed prior to the period of extended operation and at appropriate intervals thereafter, based on engineering evaluation of the initial results.

Perform at least one opportunistic or focused visual inspection of the internal surface of buried fire water piping and of similar above-ground fire water piping, within the five-year period prior to the period of extended operation, to confirm whether conditions on the internal surface of above-ground fire water piping can be extrapolated to be indicative of conditions on the internal surface of buried fire water piping.

Perform representative sprinkler head sampling (laboratory field service testing) or replacement prior to 50 years in-service (installed), and at 10-year intervals thereafter, in accordance with NFPA 25, or until there are no untested sprinkler heads that will see 50 years of service through the end of the period of extended operation.

Perform opportunistic fire water supply and water-based suppression system internal inspections each time a fire water supply or water-based suppression system (including fire pumps) is breached for repair or maintenance. These internal visual inspections must be demonstrated to be: 1) representative of water supply and water-based suppression locations, 2) performed on a reasonable basis (frequency), and Page 7 of 33

Table A-1 Davis-Besse License Renewal Commitments Related LRA Item Implementation Commitment Source Section No./

Number Schedule Comments

3) capable of evaluating wall thickness and flow capability. If the internal inspections cannot be completed of a representative sample, then ultrasonic testing inspections will be used to complete the representative sample.

11 Implement the Inaccessible Power Cables Not Subject to Prior to LRA A.1.21 10 CFR 50.49 Environmental Qualification Requirements Program April 22, 2017 and B.2.21 as described in LRA Section B.2.21.

Enhance the Inaccessible Power Cables Not Subject to FENOC Responses to 10 CFR 50.49 Environmental Qualification Requirements Letter NRC RAIs Program to:

L-11-134 B.2.21-1 and

Include inaccessible underground lower service voltage cables B.2.21-3 from (400VAC to 2kV). NRC Letter

Not use significant voltage (defined as being subjected to dated system voltage for more than twenty-five percent of the time) as April 5, 2011 a criterion for inclusion into the program.

Include inspection of electrical manholes which contain power cables within the scope of the program.

Inspect electrical manholes at least once per year. The frequency of inspections for accumulated water will be established and adjusted based on plant-specific inspection results. Also, manhole inspections will be performed in response to event-driven occurrences (e.g., heavy rain or flooding).

Include a requirement in preventive maintenance activities PM 4297, PM 4294, PM 8025, and PM 4296 to generate a condition report in cases where in scope inaccessible non-EQ power cable manhole inspection identifies submerged cables.

Although the Inaccessible Power Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Program is a new program, preventive maintenance activities Page 8 of 33

Table A-1 Davis-Besse License Renewal Commitments Related LRA Item Implementation Commitment Source Section No./

Number Schedule Comments exist for inspection of water accumulation in the manholes associated with the in scope inaccessible non-EQ power cables.

Perform cable testing on a frequency of at least every 6 years.

Testing will be evaluated for more frequent performance based on test results and operating experience.

12 Enhance the Masonry Wall Inspection to: Prior to LRA A.1.27

Include and list the structures within the scope of license April 22, 2017 and B.2.27 renewal that credit the program for aging management.

Add an action to follow the documentation requirement of FENOC Response to 10 CFR 54.37, including submittal of records of structural Letter NRC RAI evaluations to records management. L-11-153 B.2.39-5 from

Specify that for each masonry wall, the extent of observed NRC Letter masonry cracking or degradation of steel edge supports or dated bracing is evaluated to ensure that the current evaluation basis April 5, 2011 is still valid. Corrective action is required if the extent of masonry cracking or steel degradation is sufficient to invalidate the evaluation basis. An option is to develop a new evaluation basis that accounts for the degraded condition of the wall (i.e., acceptance by further evaluation).

Specify that for the masonry walls within the scope of license renewal, inspections will be conducted at least once every five years, with provisions for more frequent inspections in areas where significant loss of material or cracking is observed to ensure there is no loss of intended function between inspections.

Page 9 of 33

Table A-1 Davis-Besse License Renewal Commitments Related LRA Item Implementation Commitment Source Section No./

Number Schedule Comments 13 Implement the One-Time Inspection as described in LRA Section Prior to LRA A.1.30 B.2.30. Enhance the One-Time Inspection to: April 22, 2017 and B.2.30

Include enhanced visual (EVT-1 or equivalent) or surface examination (magnetic particle, liquid penetrant), or volumetric FENOC Responses to (RT or UT) inspections to detect and characterize cracking due Letters NRC RAI to cyclic loading of the stainless steel makeup pump casings L-11-166, 3.3.2.2.4.3-1 (DB-P37-1 and 2) of the Makeup and Purification System. The L-11-237, from one-time inspections will provide verification of the absence of NRC Letter cracking due to cyclic loading. and L-11-252 dated May 2, 2011, and Supplemental Question -

Makeup Pump Casing Inspections 14 Implement the PWR Reactor Vessel Internals Program as described April 22, 2017 LRA A.1.32 in LRA Section B.2.32. B.2.32 15 In association with the PWR Reactor Vessel Internals Program, a Prior to LRA A.1.32 plant-specific inspection plan for ensuring the implementation of April 22, 2015

and B.2.32 MRP-227 program guidelines, as amended by the safety evaluation for MRP-227, and Davis-Besse's responses to the plant-specific action items, as identified in Section 4.2 of the safety evaluation for FENOC Response to MRP-227, will be submitted for NRC review and approval. Letter NRC RAI L-11-252 B.2.32-1 from

NOTE: The inspection plan will be submitted no later than two NRC Letter years after issuance of the renewed operating license or two years dated prior to the beginning of the period of extended operation July 11, 2011 (April 22, 2015), whichever is earlier.

Page 10 of 33

Table A-1 Davis-Besse License Renewal Commitments Related LRA Item Implementation Commitment Source Section No./

Number Schedule Comments 16 Enhance the Reactor Head Closure Studs Program as follows: April 22, 2017 LRA A.1.34

Select an alternate stable lubricant that is compatible with the and B.2.34 fastener material and the environment. A specific precaution against the use of compounds containing sulfur (sulfide), FENOC Response to including molybdenum disulfide (MoS2), as a lubricant for the Letter NRC RAI reactor head closure stud assemblies will be included in the L-11-218 B.2.34-1 from program. NRC Letter

Preclude the future use of replacement closure stud bolting dated fabricated from material with actual measured yield strength June 20, 2011 greater than or equal to 150 ksi except for use of the existing spare reactor head closure stud bolting.

17 Enhance the Reactor Vessel Surveillance Program as follows: April 22, 2017 LRA A.1.35

The Capsule Insertion and Withdrawal Schedule for B.2.35 Davis-Besse will be revised to schedule testing of the TE1-C capsule.

18 Implement the Selective Leaching Inspection as described in LRA April 22, 2017 LRA A.1.36 Section B.2.36. B.2.36 19 Implement the Small Bore Class 1 Piping Inspection as described in Completed within LRA A.1.37 LRA Section B.2.37. the six year and B.2.37 period prior to April 22, 2017.

FENOC Response to Letter NRC RAI L-11-153 B.2.37-2 from NRC Letter dated April 20, 2011 Page 11 of 33

Table A-1 Davis-Besse License Renewal Commitments Related LRA Item Implementation Commitment Source Section No./

Number Schedule Comments 20 Enhance the Structures Monitoring Program to: Prior to LRA A.1.39

Include and list the structures within the scope of license April 22, 2017 B.2.39 renewal that credit the program for aging management. FENOC

Include aging effect terminology (e.g., loss of material, cracking, Letters Responses to change in material properties, and loss of form). L-11-153, NRC RAIs

List ACI 349.3R and ANSI/ASCE 11-90 as references and L-11-237, B.2.39-4, indicate that they provide guidance for the selection of L-11-292, B.2.39-5, parameters monitored or inspected. L-11-317, B.2.39-6 and and

Clarify that a "structural component for inspection includes each L-12-455 B.2.39-7 of the component types identified within the scope of license from renewal as requiring aging management.

NRC Letter

Require the responsible engineer to review site raw water pH, dated chlorides, and sulfates test results prior to the inspection to take April 5, 2011, into account the raw water chemistry for any unusual trends B.2.39-11 and during the period of extended operation. Raw water chemistry 3.5.2.3.12-4 data shall be collected at least once every five years. Data from collection dates shall be staggered from year to year (summer- NRC Letter winter-summer) to account for seasonal variation. dated

Perform an inspection for loss of material for carbon steel July 21, 2011, structural components subject to aggressive groundwater. Supplemental Require the use of the FENOC Corrective Action Program for RAI B.2.39-11 identified concrete or steel degradation. from telecon

Specify that, upon notification that a below-grade structural wall held with the or other in-scope concrete or metal structural component will NRC on become accessible through excavation, a follow-up action is September 13, initiated to the responsible engineer to inspect the exposed 2011, surfaces for age-related degradation. Such inspections will Supplemental include concrete examination using acceptance criteria from RAI OIN-380 from Region III Page 12 of 33

Table A-1 Davis-Besse License Renewal Commitments Related LRA Item Implementation Commitment Source Section No./

Number Schedule Comments NUREG-1801, XI.S6, Program element 6. Degradation found IP-71002 that exceeds the acceptance criteria will be trended and Inspection, processed through the FENOC Corrective Action Program. and

List ACI 349.3R, ANSI/ASCE 11-90, and EPRI Report 1007933 RAI B.2.4-1a as references and indicate that they provide guidance for from detection of aging effects. NRC Letter dated

Add an action to follow the documentation requirement of November 14, 10 CFR 54.37, including submittal of records of structural 2012 evaluations to records management.

Revise to add sufficient acceptance criteria and critical parameters to trigger an increased level of inspection and initiation of corrective action. Indicate that ACI 349.3R provides acceptable guidelines which will be considered in developing acceptance criteria for concrete structural elements, steel liners, joints, coatings, and waterproofing membranes. Plant specific quantitative degradation limits, similar to the three-tier hierarchy acceptance criteria from Chapter 5 of ACI 349.3R, will be developed and added to the inspection procedure. The Structures Monitoring Program procedure will also be enhanced to reflect the Periodic Evaluation criteria defined in chapter 3.3 of ACI 349.3R. The Structures Monitoring Program procedure will include the prioritization process to develop a representative sample of areas to inspect in accordance with ACI 349.3R.

Require that personnel performing the structural inspections meet qualifications that are commensurate with ACI 349.3R, Evaluation of Existing Nuclear Safety-Related Concrete Structures, Chapter 7, Qualifications of Evaluation Team.

The program procedure will be enhanced by specifying that, for Page 13 of 33

Table A-1 Davis-Besse License Renewal Commitments Related LRA Item Implementation Commitment Source Section No./

Number Schedule Comments the structures within the scope of license renewal, inspections will be conducted at least once every five years.

Conduct a baseline inspection of the structures within the scope of license renewal prior to entering the period of extended operation.

Require optical aids, scaling technologies, mechanical lifts, ladders or scaffolding for tall structures or difficult to reach areas of structures to allow visual inspections that meet the guidelines of Chapter 5 of ACI 349.3R. Select the areas to be inspected in accordance with the guidelines of Chapter 5 of ACI 349.3R to reflect the Periodic Evaluation criteria defined in Chapter 3.3 of ACI 349.3R. Include the prioritization process in the selection methodology to develop a representative sample of areas to inspect in accordance with ACI 349.3R.

Monitor elastomeric vibration isolators and structural sealants for cracking, loss of material and hardening.

Supplement visual inspection of elastomeric vibration isolation elements by feel to detect hardening if the vibration isolation function is suspect.

Identify that:

o Loose bolts and nuts and cracked high strength bolts are not acceptable unless accepted by engineering evaluation; o Structural sealants are acceptable if the observed loss of material, cracking, and hardening will not result in loss of sealing; and, o Elastomeric vibration isolation elements are acceptable if there is no loss of material, cracking, or hardening that could lead to the reduction or loss of isolation function.

Page 14 of 33

Table A-1 Davis-Besse License Renewal Commitments Related LRA Item Implementation Commitment Source Section No./

Number Schedule Comments

Require that high strength (i.e., ASTM A540 Grade B23) structural bolting materials with an actual measured yield strength greater than or equal to 150 kilo-pounds per square inch (ksi) and greater than 1 inch in nominal diameter are monitored for stress corrosion cracking (SCC). Perform periodic visual inspections of susceptible ASTM A540 bolting to identify locations where A540 bolting may be exposed to a potentially corrosive environment for SCC. Complete the initial visual inspections prior to entering the period of extended operation, and perform recurring inspections at an interval not to exceed five years. Perform volumetric examination (i.e., ultrasonic testing) on a sampling basis of bolting exposed to a corrosive environment, as determined by engineering evaluation, to a depth of at least 12 inches.

Require that personnel performing ultrasonic testing (UT) examinations of structural bolting have a current ASME Code Section XI, Appendix VIII, Supplement 8 endorsement.

Revise the applicable structural bolting specifications to prevent future use of A540 bolting with measured yield strength equal to or exceeding 150 ksi.

21 Enhance the Water Control Structures Inspection to: Prior to LRA A.1.40

Include the Service Water Discharge Structure which is within April 22, 2017 and B.2.40 the scope of license renewal.

Include parameters monitored and inspected for water control FENOC Responses to structures, including the Service Water Discharge Structure, in Letter NRC RAI accordance with applicable inspection elements listed in L-11-153 B.2.39-6 from Section C.2 of Regulatory Guide 1.127 Revision 1. Descriptions and NRC Letter of concrete conditions will conform with the appendix to the L-11-292 dated American Concrete Institute (ACI) publication, ACI 201. The use April 5, 2011, Page 15 of 33

Table A-1 Davis-Besse License Renewal Commitments Related LRA Item Implementation Commitment Source Section No./

Number Schedule Comments of photographs for comparison of previous and present and conditions will be included as a part of the inspection program. Supplemental

Specify that water control structure periodic inspections are to RAI OIN-379 be performed at least once every five years. from Region III IP-71002

Add an action to follow the documentation requirement of Inspection 10 CFR 54.37, including submittal of records of structural evaluations to records management.

Add sufficient acceptance criteria and critical parameters to trigger an increased level of inspection and initiation of corrective action. Indicate that ACI 349.3R provides acceptable guidelines which will be considered in developing acceptance criteria for water control structures. Plant-specific quantitative degradation limits, similar to the three-tier hierarchy acceptance criteria from Chapter 5 of ACI 349.3R, will be developed and added to the inspection procedure. The Structures Monitoring Program procedure will also be enhanced to reflect the Periodic Evaluation criteria defined in chapter 3.3 of ACI 349.3R. The Structures Monitoring Program procedure will include the prioritization process to develop a representative sample of areas to inspect in accordance with ACI 349.3R.

Conduct a baseline inspection of the structures within the scope of license renewal prior to entering the period of extended operation.

Require that loose bolts and nuts, cracked high strength bolts, and degradation of piles and sheeting (sheet pilings) are accepted by engineering evaluation or subject to corrective actions. Engineering evaluation will be documented and based on codes, specifications and standards such as American Institute of Steel Construction (AISC) specifications, Structural Page 16 of 33

Table A-1 Davis-Besse License Renewal Commitments Related LRA Item Implementation Commitment Source Section No./

Number Schedule Comments Engineering Institute / American Society of Civil Engineers (SEI/ASCE) 11, and codes, specifications or standards referenced in the Davis-Besse current licensing basis.

22 Enclose or otherwise protect the safety-related station ventilation April 22, 2017 N/A N/A radiation monitors located in the Turbine Building such that leakage and spray from surrounding piping systems does not adversely impact the intended function of the radiation monitors.

23 In association with the TLAA for effects of environmentally assisted Prior to LRA A.2.3.4.2 fatigue of the high pressure injection (HPI) nozzle safe end including April 22, 2017 and A.2.7.4 the associated Alloy 82/182 weld (weld that connects the safe end to the nozzle), replace the HPI nozzle safe end including the associated Alloy 82/182 weld for all four HPI nozzles prior to the FENOC Responses to period of extended operation. Apply the Fatigue Monitoring Program Letters NRC RAIs to evaluate the environmental effects and manage cumulative L-11-107 4.7.4-1 from fatigue damage for the replacement high pressure injection (HPI) and NRC Letter nozzle safe ends and associated welds. L-11-203 dated April 15, 2011, 4.3-18 from NRC Letter dated June 17, 2011, and 4.7.4-1 from NRC Letter dated October 11, 2011 Page 17 of 33

Table A-1 Davis-Besse License Renewal Commitments Related LRA Item Implementation Commitment Source Section No./

Number Schedule Comments 24 Apply the elements of corrective actions, confirmation process, and Prior to LRA A.1 administrative controls in the Quality Assurance Program Manual to April 22, 2017 and the credited aging management programs and activities for safety-FENOC Response to related and nonsafety-related structures and components Letter NRC RAI 3.0 determined to require aging management for the period of extended L-11-166 from operation.

NRC Letter dated May 2, 2011 25 Enhance the Steam Generator Tube Integrity Program to: Prior to LRA A.1.38

Include gross visual inspection of the steam generator tube to April 22, 2017 and B.2.38 tubesheet welds coupled with eddy-current inspection (i.e.,

bobbin coil or rotating coil examinations) of the tubes to monitor FENOC Response to for cracking and degradation of the tube-to-tubesheet welds Letter NRC RAI (Alloy 600). Schedule the gross visual inspection of the tube-to- L-12-001 3.1.2.2.16-3 tubesheet welds concurrent with eddy-current inspection of the from steam generator tubes that are scheduled in accordance with NRC Letter Davis-Besse Technical Specification 5.5.8 such that 100% of dated the tube-to-tubesheet welds (includes both the hot leg and cold December 27, leg welds) are inspected at sequential periods of 60 effective full 2011 power months. Perform the gross visual inspection of the tube to tubesheet welds through remote-visual examination using a manipulator camera to obtain a straight-on view of the weld with a visual acuity sufficient to detect evidence of degradation.

Perform the gross visual inspections using personnel who are qualified for American Society of Mechanical Engineers (ASME) code visual examination (i.e., are certified VT-1 or VT-3 examiners) and are knowledgeable in the type of tube-to-tubesheet welds being examined (i.e., fillet welds). Define the acceptance criteria for the gross visual inspections and the Page 18 of 33

Table A-1 Davis-Besse License Renewal Commitments Related LRA Item Implementation Commitment Source Section No./

Number Schedule Comments eddy-current inspections as no indication of cracking or relevant conditions of degradation.

26 Obtain and evaluate for degradation a concrete core bore from two Prior to FENOC Responses to representative inaccessible concrete components of an in-scope December 31, Letters NRC RAI structure subjected to aggressive groundwater prior to entering the 2014 L-11-153, B.2.39-3 from period of extended operation. Based on the results of the initial core L-11-237, NRC Letter bore sample, evaluate the need for collection and evaluation of and dated representative concrete core bore samples at additional locations L-11-292 April 5, 2011, that may be identified during the period of extended operation as RAI B.2.39-11 having aggressive groundwater infiltration. Select additional core from bore sample locations based on the duration of observed NRC Letter aggressive groundwater infiltration. Document identified concrete or dated steel degradation in the FENOC Corrective Action Program. July 21, 2011, and Supplemental RAI B.2.39-11 from telecon held with the NRC on September 13, 2011 Page 19 of 33

Table A-1 Davis-Besse License Renewal Commitments Related LRA Item Implementation Commitment Source Section No./

Number Schedule Comments 27 DBNPS Surveillance Test Procedure DB-PF-03009, Revision 06, Prior to FENOC Response to Containment Vessel and Shielding Building Visual Inspection, April 22, 2017 Letter NRC RAI Subsection 2.1.2, shall be enhanced to state, Personnel who L-11-134 B.2.1-1 from perform general visual examinations of the exterior surface of the NRC Letter Containment Vessel and the interior and exterior surfaces of the dated Shield Building shall meet the requirements for a general visual April 5, 2011 examiner in accordance with Nuclear Operating Procedure NOP-CC-5708, Written Practice for the Qualification and Certification of Nondestructive Examination Personnel. These individuals shall be knowledgeable of the types of conditions which may be expected to be identified during the examinations.

28 Enhance the Fuel Oil Chemistry Program to: Prior to LRA A.1.20

Require that internal surfaces of emergency diesel generator April 22, 2017 and B.2.20 fuel oil storage tanks and day tanks, diesel oil storage tank, diesel fire pump day tank, and station blackout diesel generator FENOC Responses to day tank are periodically drained (at least once every 10 years) Letters NRC RAIs for cleaning and are visually inspected to detect potential L-11-134 B.2.20-1 and degradation. If degradation is identified in a diesel fuel tank by and B.2.20-2 from visual inspections, a volumetric inspection is performed. L-11-238 NRC Letter

Require that biological activity be monitored and trended at dated least quarterly. April 5, 2011, and Supplemental RAI OIN-368 from NRC Region III IP-71002 Inspection Page 20 of 33

Table A-1 Davis-Besse License Renewal Commitments Related LRA Item Implementation Commitment Source Section No./

Number Schedule Comments 29 Enhance the Cranes and Hoists Inspection Program to: Prior to LRA A.1.10

Include visual inspections for loose bolts and missing or loose April 22, 2017 and B.2.10 nuts in crane, monorail and hoist inspection procedures at the same frequency as inspections of rails and structural FENOC Response to components. Letter NRC RAI L-11-153 B.2.10-2 from NRC Letter dated April 20, 2011 Page 21 of 33

Table A-1 Davis-Besse License Renewal Commitments Related LRA Item Implementation Commitment Source Section No./

Number Schedule Comments 30 Enhance the Leak Chase Monitoring Program to: Prior to LRA A.1.25

Include acceptance criteria such that measurement of leakage April 22, 2017 and B.2.25 from any monitoring line exceeding 15 ml/min will be documented in the Corrective Action Program for evaluation and FENOC Responses to potential corrective actions. Evaluation will include consideration Letters NRC RAI of more frequent monitoring. L-11-153 B.2.25-5 from

Analyze collected leak chase drainage for pH monthly and for and NRC Letter iron every six months. The initial acceptance criteria will be 7.0 L-11-238 dated to 8.0 for pH. The results for iron will be monitored and trended April 5, 2011 to insure that there is no indication of corrosion of the reinforcing and bars in the walls or floor of the pool and pits. An acceptance RAIs B.2.25-7 criterion for the iron analyses will be developed after three years and B.2.39-10 of measurements. Analyses that exceed the limits will be from documented in the Corrective Action Program. NRC Letter

Perform the leak chase inspection and cleaning recurring dated preventive maintenance (PM) activity every 18 months. July 21, 2011

Inspect once per year for leakage migrating through the accessible outside walls and floor (from the ceiling side) of the pool and pits. Document the inspection results and retain in plant records. Indication of leakage through the walls will be documented in the Corrective Action Program.

31 Incorporate reference to and the preventative actions of the Prior to FENOC Response to Research Council for Structural Connections Specification for April 22, 2017 Letter NRC RAI Structural Joints Using ASTM A325 or A490 Bolts into the L-11-153 B.2.39-8 from Davis-Besse specifications and implementing procedures that NRC Letter address Davis-Besse structural bolting within the scope of dated license renewal. April 5, 2011 Page 22 of 33

Table A-1 Davis-Besse License Renewal Commitments Related LRA Item Implementation Commitment Source Section No./

Number Schedule Comments 32 Enhance the Closed Cooling Water Chemistry program to: Prior to LRA A.1.8

Document the results of periodic inspections of opportunity, April 22, 2017 and B.2.8 performed when components are opened for maintenance, repair, or surveillance. FENOC Response to

Ensure that a representative sample of piping and components Letters NRC RAI will be inspected on a 10-year interval, with the first inspection L-11-153 B.2.8-1 from taking place prior to entering the period of extended operation. and NRC Letter

Ensure that component cooling water radiochemistry is sampled L-11-354 dated on a weekly interval to verify the integrity of the letdown coolers April 20, 2011 and seal return coolers. and Supplemental RAI 2.3.3.18-4 from telecom held with the NRC on November 9, 2011 33 Phase 1 Phase 1: FENOC Response to Perform the following actions to reduce or mitigate the refueling Action 1 prior to Letter NRC RAI canal leaks inside containment: December 31, L-11-252 B.2.39-9 from

1. Select and implement a leak detection method to locate the 2014 NRC Letter leakage area. dated July 27, 2011

2. Evaluate temporary and permanent repair methods to stop Action 2 prior to or significantly reduce the leakage, and implement a December 31, repair plan. 2016 Phase 2 Perform the following actions to evaluate the impact of refueling Phase 2:

Page 23 of 33

Table A-1 Davis-Besse License Renewal Commitments Related LRA Item Implementation Commitment Source Section No./

Number Schedule Comments canal leaks on concrete and reinforcing steel structures. Action 1 prior to Discontinue core bores, testing and reinforcing steel inspections December 31, when indications of refueling canal leakage are no longer present: 2014

1. Perform a core bore in the south wall of the east-west section of the core flood pipe tunnel. Action 2 prior to

a. Assess borated water degradation of the concrete by December 31, testing the core bore sample for compressive 2023 strength and by petrographic examination, and evaluate the results.

Action 3 -

b. Conduct a visual examination of the concrete and Ongoing reinforcing steel to identify aging effects (e.g.,

concrete degradation or steel corrosion). Enter identified aging effects into the FENOC Corrective Action Program and evaluate in accordance with the requirements of the current licensing basis Maintenance Rule Program.

2. If leakage from the refueling canal has not been eliminated or resumes by the beginning of the period of extended operation, then evaluate the concrete structures in a manner similar to the way that they were evaluated under Phase 2, Action 1. However, use acceptance criteria from the American Concrete Institute (ACI) Report 349.3R for the evaluation.

3. If leakage from the refueling canal has not been eliminated or resumes during the period of extended operation, then evaluate the concrete structures again in a manner similar to the way that they were evaluated under Phase 2, Action 2.

Perform evaluations every ten years until the end of the period of extended operation.

Page 24 of 33

Table A-1 Davis-Besse License Renewal Commitments Related LRA Item Implementation Commitment Source Section No./

Number Schedule Comments 34 Enhance the Bolting Integrity Program to: Prior to LRA A.1.4

Select an alternate stable lubricant that is compatible with the April 22, 2017 and B.2.4 fastener material and the environment. A specific precaution against the use of compounds containing sulfur (sulfide), FENOC Response to including molybdenum disulfide (MoS2), as a lubricant will be Letter NRC RAI included in the program. L-11-153 B.2.4-3 from NRC Letter dated April 20, 2011 35 Perform the following actions for each of two examinations (Phase 1 Phase 1 prior to FENOC Response to and Phase 2) of the Containment Vessel in the sand pocket region: December 31, Letter NRC RAI

Perform nondestructive examination (NDE) of the 2014 L-11-252 B.2.22-5 from Containment Vessel from the outer surface at five areas of NRC Letter previously-identified groundwater in-leakage. dated and July 21, 2011 o Examine the vessel at a minimum of three vertical grid locations at 12 inches nominal horizontal spacing at each Phase 2 prior to area. Examine the Containment Vessel at a minimum of December 31, three elevations: 2025

1. approximately 3 inches below the existing grout-to-vessel interface in the sand pocket region;

2. at the existing grout-to-vessel interface level in the sand pocket region; and,

3. approximately 3 inches above the existing grout-to-vessel interface in the sand pocket region.

Compare the ultrasonic test (UT) thickness readings to minimum ASME Code vessel thickness requirements and to the results obtained during previous UT examinations of the Containment Vessel. Determine the need for maintenance or repair of the Page 25 of 33

Table A-1 Davis-Besse License Renewal Commitments Related LRA Item Implementation Commitment Source Section No./

Number Schedule Comments Containment Vessel based on the results and evaluation of the examinations.

Document the results of each of the two examinations in the work order system. Document and evaluate adverse conditions in accordance with the FENOC Corrective Action Program for an evaluation of potential degradation of the steel Containment Vessel thickness over the longer term.

36 Perform the following actions related to the Containment Vessel Ongoing FENOC Response to sand pocket region each refueling outage: Letter NRC RAI

Perform visual inspection of 100 percent of the accessible areas L-11-252 B.2.22-5 from of the wetted outer surface of the Containment Vessel in the and NRC Letter sand pocket region. L-11-354 dated July 21, 2011

Perform visual inspection of accessible dry areas of the outer and surface of the Containment Vessel in the sand pocket region Supplemental and the areas above the grout-to-steel interface up to RAI B.2.22-5 Elevation 566 feet + 3 inches, - 1 inch. from telecons

Perform visual inspection for deterioration (e.g., missing or held with the damaged grout) of accessible grout and the containment NRC on exterior moisture barrier in the sand pocket area. October 5 and

Perform opportunistic visual inspections of inaccessible areas of November 14, the Containment Vessel in the sand pocket region when such 2011 areas are made accessible.

Perform opportunistic visual inspections for deterioration (e.g.,

missing or damaged grout) of inaccessible grout in the sand pocket region when such areas are made accessible.

Inaccessible grout is the grout below the normally-exposed surface of the grout in the sand pocket area.

Address issues of pitting or microbiologically-influenced Page 26 of 33

Table A-1 Davis-Besse License Renewal Commitments Related LRA Item Implementation Commitment Source Section No./

Number Schedule Comments corrosion (MIC), and degraded grout, moisture barrier or sealant identified during the inspections using the FENOC Corrective Action Program.

Sample the water in the sand pocket region when sufficient volumes are available. The number of sampled water volumes will be determined by the number of water volumes observed and the size of those water volumes. Analyze the sample(s) for pH, chlorides, iron and sulfates. Treat or wash (or a combination thereof) the sand pocket area to reduce measured chloride concentrations to less than 250 parts per million (ppm) if the concentration of chlorides in a sample exceeds 250 ppm.

Note: Water samples may be taken at different times during each outage. Engineering judgment may be used to determine the priority of the chemical analyses to be performed if sufficient water is not available in a given sample for all analyses.

Page 27 of 33

Table A-1 Davis-Besse License Renewal Commitments Related LRA Item Implementation Commitment Source Section No./

Number Schedule Comments 37 Perform and evaluate core bores of the ECCS Pump Room No. 1 Phase 1 prior to FENOC Responses to wall and the Room 109 ceiling. December 31, Letters NRC RAI

The core bores will be deep enough to expose reinforcing bar in 2014 L-11-153 B.2.39-2 from the wall and ceiling. The core samples from the core bores will and NRC Letter be examined for signs of corrosion or chemical effects of boric dated and L-11-238 acid on the concrete or reinforcing bars. The examination will April 5, 2011, include a petrographic examination. The reinforcing steel that and will be exposed for a visual inspection will have corrosion Phase 2 prior to RAI B.2.39-10 products collected for testing. Degradation identified from the December 31, from samples will be entered into the FENOC Corrective Action 2020 NRC Letter Program. The core bores will be performed in areas where dated leakage has been observed in the past. July 21, 2011

The first set of core bores will be performed prior to the end of 2014 (Phase 1).

The second set of core bores will be performed prior to the end of 2020 (Phase 2).

Further core bores will be conducted, if warranted, based on the evaluation of the results of the inspection and testing of the core bores or if spent fuel pool leakage through the wall or ceiling recurs after the second set of core bores is performed. If spent fuel pool leakage through another wall or ceiling is identified, then core bores will be performed in a manner similar to that stated for the ECCS Pump Room No. 1 wall and the Room 109 ceiling.

Page 28 of 33

Table A-1 Davis-Besse License Renewal Commitments Related LRA Item Implementation Commitment Source Section No./

Number Schedule Comments 38 Evaluate the concrete cracking observed on the underside of the Prior to FENOC Responses to spent fuel pool for necessary repairs. April 22, 2017 Letters NRC RAI Note: A core bore of the Room 109 ceiling will be performed by the L-11-153 B.2.39-2 from end of 2014 (see license renewal commitment 37). Degradation and NRC Letter identified from the samples will be entered into the FENOC dated L-11-238 Corrective Action Program. The condition of the concrete and the April 5, 2011, reinforcing steel will be evaluated at that time to assist in and determining what repairs, if any, need to be made to the underside RAI B.2.39-10 of the spent fuel pool concrete. The criterion for determining the from need to repair the cracking will be the continued capability of the NRC Letter structures to perform their intended functions during the period of dated extended operation. July 21, 2011 39 Address the potential for borated water degradation of the steel Phase 1 prior to FENOC Responses to containment vessel through the following actions: December 31, Letters NRC RAIs

Access the inside surface of the embedded steel containment. A 2014 L-11-153 B.2.22-2 from core bore will be completed by the end of 2014 (Phase 1). If and and NRC Letter necessary, a second core bore will be completed by the end of L-11-237 dated Phase 2 prior to 2020 (Phase 2). If there is evidence of the presence of borated April 5, 2011, December 31, water in contact with the steel containment vessel, conduct and 2020 non-destructive testing (NDT) to determine what effect, if any, B.2.22-6 from the borated water has had on the steel containment vessel. NRC Letter Based on the results of NDT, perform a study to determine the dated effect through the period of extended operation of any identified July 27, 2011 loss of thickness in the steel containment due to exposure to borated water.

Page 29 of 33

Table A-1 Davis-Besse License Renewal Commitments Related LRA Item Implementation Commitment Source Section No./

Number Schedule Comments 40 Implement the Inspection of Internal Surfaces in Miscellaneous Prior to LRA A.1.41 Piping and Ducting Program as described in LRA Section B.2.41. April 22, 2017 and B.2.41 FENOC Responses to Letter NRC RAIs L-11-153 3.3.2.2.5-1 and 3.3.2.71-2 from NRC Letter dated April 20, 2011 41 Establish a preventive maintenance task to periodically replace the Prior to FENOC Response to flexible connections exposed to fuel oil in the Fuel Oil System. April 22, 2017 Letter NRC RAI L-11-166 3.3.2.3.12-2 from NRC Letter dated May 2, 2011 42 Enhance the Fatigue Monitoring Program to: Prior to LRA A.1.16

Evaluate additional plant-specific component locations in the April 22, 2016 and B.2.16 reactor coolant pressure boundary that may be more limiting than those considered in NUREG/CR-6260. This evaluation will FENOC Response to include identification of the most limiting fatigue location Letter NRC RAI exposed to reactor coolant for each material type (i.e., CS, LAS, L-11-166 B.2.16-2 from SS, and NBA) and that each bounding material/location will be NRC Letter evaluated for the effects of the reactor coolant environment on dated fatigue usage. Nickel based alloy items will be evaluated using April 20, 2011 NUREG/CR-6909. Submit the evaluation to the NRC one year prior to the period of extended operation.

Page 30 of 33

Table A-1 Davis-Besse License Renewal Commitments Related LRA Item Implementation Commitment Source Section No./

Number Schedule Comments 43 Ensure that the current station operating experience review process Prior to FENOC Response to includes future reviews of plant-specific and industry operating April 22, 2017 Letter NRC RAI experience to confirm the effectiveness of the License Renewal L-11-188 B.1.4-1 from aging management programs, to determine the need for programs NRC Letter to be enhanced, or indicate a need to develop new aging dated management programs. May 19, 2011 44 Cathodically protect the EDG fuel oil storage tanks (DB-T153-1 and Prior to FENOC Response to DB-T153-2) and the in-scope fuel oil and Service Water buried April 22, 2017 Letter NRC RAI piping in accordance with NACE SP0169-2007 or L-11-203 B.2.7-1 from NACE RP0285-2002. NRC Letter dated April 20, 2011, as modified per telecon with the NRC held on June 7, 2011 45 Implement the Nuclear Safety-Related Coatings Program as Prior to FENOC A.1.42 described in LRA Section B.2.42. April 22, 2017 Letter B.2.42 L-11-203 Response to NRC RAI XI.S8-1 from NRC Letter dated April 5, 2011 Page 31 of 33

Table A-1 Davis-Besse License Renewal Commitments Related LRA Item Implementation Commitment Source Section No./

Number Schedule Comments 46 Implement the Shield Building Monitoring Program as described in Prior to LRA A.1.43 LRA Section B.2.43. April 22, 2017 and B.2.43 FENOC Response to Letter NRC RAI L-12-028 B.2.16-2 from NRC Letter dated December 27, 2012 47 Enhance the Inservice Inspection (ISI) Program - IWE to: Prior to LRA A.1.22

Include surface examinations to monitor for cracking of April 22, 2017 and B.2.22 containment stainless steel penetration sleeves, dissimilar metal welds, bellows, and steel components that are subject to cyclic FENOC Responses to loading but have no current licensing basis fatigue analysis. Letter NRC RAI The inspection sample size will include 10 percent of the L-11-238 B.2.22-7 from containment penetration population that are subject to cyclic and NRC Letter loading but have no current licensing basis fatigue analysis. L-11-292 dated Penetrations included in the inspection sample will be scheduled July 21, 2011, for examination in each 10-year ISI interval that occurs during and the period of extended operation. Should fatigue analyses be Supplemental performed in the future for the subject containment penetrations, RAI B.2.22-7 the surface examinations will no longer be required. from NRC telecons held on September 13 and 16, 2011 Page 32 of 33

Table A-1 Davis-Besse License Renewal Commitments Related LRA Item Implementation Commitment Source Section No./

Number Schedule Comments 48 Complete an investigation and needed repairs or modification of the Prior to FENOC Response to degraded portion of the safety-related intake canal embankment. April 22, 2017 Letter NRC RAI L-11-238 B.2.40-2 from NRC Letter dated July 21, 2011 49 Enhance the Nickel-Alloy Management Program to: Prior to FENOC A.1.28

Provide for inspection of dissimilar metal butt welds in April 22, 2017 Letter B.2.28 accordance with the requirements of ASME Code Case L-11-238 Response to N-770-1, Alternative Examination Requirements and NRC RAI Acceptance Standards for Class 1 PWR Piping and Vessel B.2.28-1 from Nozzle Butt Welds Fabricated with UNS N06082 or UNS NRC Letter W86182 Weld Filler Material With or Without Application of dated Listed Mitigation Activities,Section XI, Division 1, as July 27, 2011 modified by the Code of Federal Regulations, 10 CFR 50.55a(g)(6)(ii)(F).

Page 33 of 33

Davis Besse Nuclear Power Station, Unit No. 1 License Renewal Future Commitments (Through LRA Amendment 37)

Table A-1 Davis-Besse License Renewal Commitments Related LRA Item Implementation Commitment Source Section No./

Number Schedule Comments 1 Enhance the Aboveground Steel Tanks Inspection Program to: Prior to LRA A.1.2 x Include a volumetric examination of tank bottoms to detect April 22, 2017 and B.2.2 evidence of loss of material due to crevice, general, or pitting corrosion, or to confirm a lack thereof. Establish the examination FENOC Response to technique, the inspection locations, and the acceptance criteria Letter NRC RAI for the examination of the tank bottoms. Require that L-11-153 B.2.2-1 from unacceptable inspection results be entered into the FENOC NRC Letter Corrective Action Program. The volumetric examination of the dated tank bottoms will be performed within five years after entering April 20, 2011 the period of extended operation. Additional opportunistic tank bottom inspections will be performed whenever the tanks are drained.

2 Implement the Boral Monitoring Program as described in LRA April 22, 2017 LRA A.1.5 Section B.2.5. B.2.5 3 Enhance the Buried Piping and Tanks Inspection Program to: Prior to LRA A.1.7 x Add 1) bolting for buried Fire Protection System piping and 2) April 22, 2017 and B.2.7 the emergency diesel fuel oil storage tanks (DB-T153-1, DB- and T153-2) to the scope of the program. FENOC Response to x Conduct annual ground potential surveys of the cathodic Letter NRC RAI protection system using the acceptance criteria listed in L-11-153 B.2.7-1 from NACE RP0285 2002 and NACE SP0169-2007. Monitor cathodic NRC Letter Page 1 of 33

Table A-1 Davis-Besse License Renewal Commitments Related LRA Item Implementation Commitment Source Section No./

Number Schedule Comments protection voltage and current monthly to determine dated the effectiveness of cathodic protection systems and, thereby, April 20, 2011 the effectiveness of corrosion mitigation. Trend voltage, current, and ground potential readings and evaluate for adverse changes.

x Require that the activity of the jockey fire pump or equivalent parameter be monitored on at least a monthly interval.

Conduct a flow test by the end of the next refueling outage when unexplained changes in jockey pump activity are observed.

x Require that the directed buried pipe inspection locations be selected based on risk.

x Require that the minimum number of buried in-scope piping inspections during the 30-40, 40-50, and 50-60 year operating period is one steel safety-related piping segment and one steel piping segment containing hazardous material. Perform the directed buried steel pipe and tank inspections each ten year interval based upon the following table. Each inspection will have a minimum of 10 feet of piping inspected.

Preventive # of inspections of safety # of Hazmat inspections Actions related piping or tanks or % of pipe length A 1 (Note 2) 1 (Note 2)

B 1 2%

C 4 5%

D 8 10 %

Note 1: Preventive actions are categorized as follows:

A. - Cathodic protection, in accordance with NACE SP0169-2007 or NACE RP0285-2002, was installed for at least 5 years prior to entering the period of extended operation and was operational for 90% of the time Page 2 of 33

Table A-1 Davis-Besse License Renewal Commitments Related LRA Item Implementation Commitment Source Section No./

Number Schedule Comments during that 5 years or cathodic protection was operational for 90% of the time since the last inspection conducted under this program.

B. - Cathodic protection, in accordance with NACE SP0169-2007 or NACE RP0285-2002, was installed for less than 5 years prior to entering the period of extended operation or was operational for less than 90% of the time during that 5 years or cathodic inspection was operational for less than 90% of the time since the last inspection conducted under this program C. - Protective coatings are in place and no mechanical coating damage due to the backfill, but cathodic protection is not provided or not in accordance with criteria A or B and the period of extended operation has not been entered.

D. - Criteria of A, B, and C not met.

Note 2: Only one inspection is required for piping which is both safety-related and contains hazardous material.

x Require that the EDG Fuel Oil Storage Tanks (DB-T153-1 and DB-T153-2) be inspected prior to entering the period of extended operation. The inspection will be either a visual inspection of at least 25% of each tank and include at least some portion of the tank top and bottom or, an internal inspection consisting of UT measurements with at least one measurement per square foot of the surface of the tanks.

These inspections are not required if it is demonstrated that the tanks are cathodically protected in accordance with NACE SP0169-2007 or NACE RP0285-2002.

x Require that a visual and volumetric inspection of the underground piping within the borated water piping trench will Page 3 of 33

Table A-1 Davis-Besse License Renewal Commitments Related LRA Item Implementation Commitment Source Section No./

Number Schedule Comments be performed during each 10-year period beginning no sooner than 10 years prior to the entry into the period of extended operation.

x Require that if adverse indications are detected, additional buried in-scope piping inspections be performed in order to provide reasonable assurance of the integrity of buried piping.

Base the selection of components to be examined on previous examination results, trending, risk ranking, and areas of cathodic protection failures or gaps, if applicable. Continue additional sampling until reasonable assurance of the integrity of buried piping is provided.

x Require that an inspection of buried Fire Protection System bolting will be performed when the bolting becomes accessible during opportunistic or focused inspections.

x Require that the inspections of buried piping be conducted using visual (VT-3 or equivalent) inspection methods. Excavation shall be a minimum of 10 linear feet of piping, with all surfaces of the pipe exposed.

4 Implement the Collection, Drainage, and Treatment Components April 22, 2017 LRA A.1.9 Inspection Program as described in LRA Section B.2.9. B.2.9 5 Implement the Electrical Cable Connections Not Subject to Prior to LRA A.1.11 10 CFR 50.49 Environmental Qualification Requirements Inspection April 22, 2017 and B.2.11 as described in LRA Section B.2.11.

Enhance the Electrical Cable Connections Not Subject to FENOC Response to 10 CFR 50.49 Environmental Qualification Requirements Letter NRC RAI 3.6-3 Inspection to:

L-11-134 from NRC x Include high voltage connections to confirm the absence of Letter dated aging effects for metallic electrical connections. April 5, 2011 Page 4 of 33

Table A-1 Davis-Besse License Renewal Commitments Related LRA Item Implementation Commitment Source Section No./

Number Schedule Comments 6 Implement the Electrical Cables and Connections Not Subject to April 22, 2017 LRA A.1.12 10 CFR 50.49 Environmental Qualification Requirements Program B.2.12 as described in LRA Section B.2.12.

7 Implement the Electrical Cables and Connections Not Subject to April 22, 2017 LRA A.1.13 10 CFR 50.49 Environmental Qualification Requirements Used in B.2.13 Instrumentation Circuits Program as described in LRA Section B.2.13.

8 Enhance the External Surfaces Monitoring Program to: Prior to LRA A.1.15 x Add systems which credit the program for license renewal but April 22, 2017 and B.2.15 do not have Maintenance Rule intended functions to the scope of the program. FENOC Responses to x Perform opportunistic inspections of surfaces that are Letters NRC RAIs inaccessible or not readily visible during normal plant operations L-11-153, 3.3.2.2.5-1 and or refueling outages, such as surfaces that are insulated. L-11-166 B.2.2-2 from Surfaces that are accessible will be inspected at a frequency not and NRC Letter to exceed one refueling cycle. L-11-238 dated x Perform, in conjunction with the Inspection of Internal Surfaces April 20, 2011, in Miscellaneous Piping and Ducting Program, inspection and NRC RAI surveillance of elastomers and polymers exposed to air-indoor 3.3.2-2 from uncontrolled or air-outdoor environments, but not replaced on a NRC Letter set frequency or interval (i.e., are long-lived), for evidence of dated cracking and change in material properties (hardening and loss May 2, 2011, of strength) and loss of material due to wear. Specify RAI 3.3.2.2.5-2 acceptance criteria of no unacceptable visual indications of from cracks or discoloration that would lead to loss of function prior to NRC Letter the next inspection, and of no hardening as evidenced by a loss dated of suppleness during manipulation.

July 12, 2011, x Perform inspection of the control room emergency ventilation Page 5 of 33

Table A-1 Davis-Besse License Renewal Commitments Related LRA Item Implementation Commitment Source Section No./

Number Schedule Comments system air-cooled condensing unit cooling coil tubes and fins and and the station blackout diesel generator radiator tubes and fins Supplemental for visible evidence of external surface conditions that could RAI OIN-352 result in a reduction in heat transfer. Specify acceptance criteria from of no unacceptable visual indications of fouling (build up of dirt NRC Region III or other foreign material) that would lead to loss of function prior IP-71002 to the next scheduled inspection. Inspection x Manage cracking of copper alloys with greater than 15 percent zinc and stainless steel components exposed to an outdoor air environment through plant system inspections and walkdowns for evidence of leakage. Specify acceptance criteria of no unacceptable visual indications of cracks that would lead to loss of function prior to the next scheduled inspection.

x Include inspection parameters and acceptance criteria for polymers, elastomers and metallic components as applicable in system inspection and walkdown documentation. Retain system inspection and walkdown documentation in plant records.

9 Enhance the Fatigue Monitoring Program to: Prior to LRA A.1.16 x Provide for updates of the fatigue usage calculations on an as April 22, 2017 and B.2.16 needed basis if an allowable cycle limit is approached. When the number of accrued cycles is within 75% of the allowable FENOC Responses to cycle limit for any transient, a condition report will be generated. Letter NRC RAIs For any transient whose cycles are projected to exceed the L-11-166 B.2.16-3, allowable cycle limit by the end of the next plant operating cycle B.2.16-4 (Davis-Besse operating cycles are normally two years in and duration), the program will require an update of the fatigue B.2.16-5 usage calculation for the affected component(s). from x Establish an acceptance criterion for maintaining the cumulative NRC Letter fatigue usage below the Code design limit of 1.0 through the dated Page 6 of 33

Table A-1 Davis-Besse License Renewal Commitments Related LRA Item Implementation Commitment Source Section No./

Number Schedule Comments period of extended operation, including environmental effects April 20, 2011 where applicable 10 Enhance the Fire Water Program to: April 22, 2017 LRA A.1.18 x Perform periodic ultrasonic testing for wall thickness of B.2.18 representative above-ground water suppression piping that is not periodically flow tested but contains, or has contained, stagnant water. The ultrasonic testing will be performed prior to the period of extended operation and at appropriate intervals thereafter, based on engineering evaluation of the initial results.

x Perform at least one opportunistic or focused visual inspection of the internal surface of buried fire water piping and of similar above-ground fire water piping, within the five-year period prior to the period of extended operation, to confirm whether conditions on the internal surface of above-ground fire water piping can be extrapolated to be indicative of conditions on the internal surface of buried fire water piping.

x Perform representative sprinkler head sampling (laboratory field service testing) or replacement prior to 50 years in-service (installed), and at 10-year intervals thereafter, in accordance with NFPA 25, or until there are no untested sprinkler heads that will see 50 years of service through the end of the period of extended operation.

x Perform opportunistic fire water supply and water-based suppression system internal inspections each time a fire water supply or water-based suppression system (including fire pumps) is breached for repair or maintenance. These internal visual inspections must be demonstrated to be: 1) representative of water supply and water-based suppression locations, 2) performed on a reasonable basis (frequency), and Page 7 of 33

Table A-1 Davis-Besse License Renewal Commitments Related LRA Item Implementation Commitment Source Section No./

Number Schedule Comments

3) capable of evaluating wall thickness and flow capability. If the internal inspections cannot be completed of a representative sample, then ultrasonic testing inspections will be used to complete the representative sample.

11 Implement the Inaccessible Power Cables Not Subject to Prior to LRA A.1.21 10 CFR 50.49 Environmental Qualification Requirements Program April 22, 2017 and B.2.21 as described in LRA Section B.2.21.

Enhance the Inaccessible Power Cables Not Subject to FENOC Responses to 10 CFR 50.49 Environmental Qualification Requirements Letter NRC RAIs Program to:

L-11-134 B.2.21-1 and x Include inaccessible underground lower service voltage cables B.2.21-3 from (400VAC to 2kV). NRC Letter x Not use significant voltage (defined as being subjected to dated system voltage for more than twenty-five percent of the time) as April 5, 2011 a criterion for inclusion into the program.

x Include inspection of electrical manholes which contain power cables within the scope of the program.

x Inspect electrical manholes at least once per year. The frequency of inspections for accumulated water will be established and adjusted based on plant-specific inspection results. Also, manhole inspections will be performed in response to event-driven occurrences (e.g., heavy rain or flooding).

x Include a requirement in preventive maintenance activities PM 4297, PM 4294, PM 8025, and PM 4296 to generate a condition report in cases where in scope inaccessible non-EQ power cable manhole inspection identifies submerged cables.

Although the Inaccessible Power Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Program is a new program, preventive maintenance activities Page 8 of 33

Table A-1 Davis-Besse License Renewal Commitments Related LRA Item Implementation Commitment Source Section No./

Number Schedule Comments exist for inspection of water accumulation in the manholes associated with the in scope inaccessible non-EQ power cables.

x Perform cable testing on a frequency of at least every 6 years.

Testing will be evaluated for more frequent performance based on test results and operating experience.

12 Enhance the Masonry Wall Inspection to: Prior to LRA A.1.27 x Include and list the structures within the scope of license April 22, 2017 and B.2.27 renewal that credit the program for aging management.

x Add an action to follow the documentation requirement of FENOC Response to 10 CFR 54.37, including submittal of records of structural Letter NRC RAI evaluations to records management. L-11-153 B.2.39-5 from x Specify that for each masonry wall, the extent of observed NRC Letter masonry cracking or degradation of steel edge supports or dated bracing is evaluated to ensure that the current evaluation basis April 5, 2011 is still valid. Corrective action is required if the extent of masonry cracking or steel degradation is sufficient to invalidate the evaluation basis. An option is to develop a new evaluation basis that accounts for the degraded condition of the wall (i.e., acceptance by further evaluation).

x Specify that for the masonry walls within the scope of license renewal, inspections will be conducted at least once every five years, with provisions for more frequent inspections in areas where significant loss of material or cracking is observed to ensure there is no loss of intended function between inspections.

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Table A-1 Davis-Besse License Renewal Commitments Related LRA Item Implementation Commitment Source Section No./

Number Schedule Comments 13 Implement the One-Time Inspection as described in LRA Section Prior to LRA A.1.30 B.2.30. Enhance the One-Time Inspection to: April 22, 2017 and B.2.30 x Include enhanced visual (EVT-1 or equivalent) or surface examination (magnetic particle, liquid penetrant), or volumetric FENOC Responses to (RT or UT) inspections to detect and characterize cracking due Letters NRC RAI to cyclic loading of the stainless steel makeup pump casings L-11-166, 3.3.2.2.4.3-1 (DB-P37-1 and 2) of the Makeup and Purification System. The L-11-237, from one-time inspections will provide verification of the absence of NRC Letter cracking due to cyclic loading. and L-11-252 dated May 2, 2011, and Supplemental Question -

Makeup Pump Casing Inspections 14 Implement the PWR Reactor Vessel Internals Program as described April 22, 2017 LRA A.1.32 in LRA Section B.2.32. B.2.32 15 In association with the PWR Reactor Vessel Internals Program, a Prior to LRA A.1.32 plant-specific inspection plan for ensuring the implementation of April 22, 2015

and B.2.32 MRP-227 program guidelines, as amended by the safety evaluation for MRP-227, and Davis-Besse's responses to the plant-specific action items, as identified in Section 4.2 of the safety evaluation for FENOC Response to MRP-227, will be submitted for NRC review and approval. Letter NRC RAI L-11-252 B.2.32-1 from

NOTE: The inspection plan will be submitted no later than two NRC Letter years after issuance of the renewed operating license or two years dated prior to the beginning of the period of extended operation July 11, 2011 (April 22, 2015), whichever is earlier.

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Table A-1 Davis-Besse License Renewal Commitments Related LRA Item Implementation Commitment Source Section No./

Number Schedule Comments 16 Enhance the Reactor Head Closure Studs Program as follows: April 22, 2017 LRA A.1.34 x Select an alternate stable lubricant that is compatible with the and B.2.34 fastener material and the environment. A specific precaution against the use of compounds containing sulfur (sulfide), FENOC Response to including molybdenum disulfide (MoS2), as a lubricant for the Letter NRC RAI reactor head closure stud assemblies will be included in the L-11-218 B.2.34-1 from program. NRC Letter x Preclude the future use of replacement closure stud bolting dated fabricated from material with actual measured yield strength June 20, 2011 greater than or equal to 150 ksi except for use of the existing spare reactor head closure stud bolting.

17 Enhance the Reactor Vessel Surveillance Program as follows: April 22, 2017 LRA A.1.35 x The Capsule Insertion and Withdrawal Schedule for B.2.35 Davis-Besse will be revised to schedule testing of the TE1-C capsule.

18 Implement the Selective Leaching Inspection as described in LRA April 22, 2017 LRA A.1.36 Section B.2.36. B.2.36 19 Implement the Small Bore Class 1 Piping Inspection as described in Completed within LRA A.1.37 LRA Section B.2.37. the six year and B.2.37 period prior to April 22, 2017.

FENOC Response to Letter NRC RAI L-11-153 B.2.37-2 from NRC Letter dated April 20, 2011 Page 11 of 33

Table A-1 Davis-Besse License Renewal Commitments Related LRA Item Implementation Commitment Source Section No./

Number Schedule Comments 20 Enhance the Structures Monitoring Program to: Prior to LRA A.1.39 x Include and list the structures within the scope of license April 22, 2017 B.2.39 renewal that credit the program for aging management. FENOC x Include aging effect terminology (e.g., loss of material, cracking, Letters Responses to change in material properties, and loss of form). L-11-153, NRC RAIs x List ACI 349.3R and ANSI/ASCE 11-90 as references and L-11-237, B.2.39-4, indicate that they provide guidance for the selection of L-11-292, B.2.39-5, parameters monitored or inspected. L-11-317, B.2.39-6 and and x Clarify that a "structural component for inspection includes each L-12-455 B.2.39-7 of the component types identified within the scope of license from renewal as requiring aging management.

NRC Letter x Require the responsible engineer to review site raw water pH, dated chlorides, and sulfates test results prior to the inspection to take April 5, 2011, into account the raw water chemistry for any unusual trends B.2.39-11 and during the period of extended operation. Raw water chemistry 3.5.2.3.12-4 data shall be collected at least once every five years. Data from collection dates shall be staggered from year to year (summer- NRC Letter winter-summer) to account for seasonal variation. dated x Perform an inspection for loss of material for carbon steel July 21, 2011, structural components subject to aggressive groundwater. Supplemental Require the use of the FENOC Corrective Action Program for RAI B.2.39-11 identified concrete or steel degradation. from telecon x Specify that, upon notification that a below-grade structural wall held with the or other in-scope concrete or metal structural component will NRC on become accessible through excavation, a follow-up action is September 13, initiated to the responsible engineer to inspect the exposed 2011, surfaces for age-related degradation. Such inspections will Supplemental include concrete examination using acceptance criteria from RAI OIN-380 from Region III Page 12 of 33

Table A-1 Davis-Besse License Renewal Commitments Related LRA Item Implementation Commitment Source Section No./

Number Schedule Comments NUREG-1801, XI.S6, Program element 6. Degradation found IP-71002 that exceeds the acceptance criteria will be trended and Inspection, processed through the FENOC Corrective Action Program. and x List ACI 349.3R, ANSI/ASCE 11-90, and EPRI Report 1007933 RAI B.2.4-1a as references and indicate that they provide guidance for from detection of aging effects. NRC Letter dated x Add an action to follow the documentation requirement of November 14, 10 CFR 54.37, including submittal of records of structural 2012 evaluations to records management.

x Revise to add sufficient acceptance criteria and critical parameters to trigger an increased level of inspection and initiation of corrective action. Indicate that ACI 349.3R provides acceptable guidelines which will be considered in developing acceptance criteria for concrete structural elements, steel liners, joints, coatings, and waterproofing membranes. Plant specific quantitative degradation limits, similar to the three-tier hierarchy acceptance criteria from Chapter 5 of ACI 349.3R, will be developed and added to the inspection procedure. The Structures Monitoring Program procedure will also be enhanced to reflect the Periodic Evaluation criteria defined in chapter 3.3 of ACI 349.3R. The Structures Monitoring Program procedure will include the prioritization process to develop a representative sample of areas to inspect in accordance with ACI 349.3R.

x Require that personnel performing the structural inspections meet qualifications that are commensurate with ACI 349.3R, Evaluation of Existing Nuclear Safety-Related Concrete Structures, Chapter 7, Qualifications of Evaluation Team.

x The program procedure will be enhanced by specifying that, for Page 13 of 33

Table A-1 Davis-Besse License Renewal Commitments Related LRA Item Implementation Commitment Source Section No./

Number Schedule Comments the structures within the scope of license renewal, inspections will be conducted at least once every five years.

x Conduct a baseline inspection of the structures within the scope of license renewal prior to entering the period of extended operation.

x Require optical aids, scaling technologies, mechanical lifts, ladders or scaffolding for tall structures or difficult to reach areas of structures to allow visual inspections that meet the guidelines of Chapter 5 of ACI 349.3R. Select the areas to be inspected in accordance with the guidelines of Chapter 5 of ACI 349.3R to reflect the Periodic Evaluation criteria defined in Chapter 3.3 of ACI 349.3R. Include the prioritization process in the selection methodology to develop a representative sample of areas to inspect in accordance with ACI 349.3R.

x Monitor elastomeric vibration isolators and structural sealants for cracking, loss of material and hardening.

x Supplement visual inspection of elastomeric vibration isolation elements by feel to detect hardening if the vibration isolation function is suspect.

x Identify that:

o Loose bolts and nuts and cracked high strength bolts are not acceptable unless accepted by engineering evaluation; o Structural sealants are acceptable if the observed loss of material, cracking, and hardening will not result in loss of sealing; and, o Elastomeric vibration isolation elements are acceptable if there is no loss of material, cracking, or hardening that could lead to the reduction or loss of isolation function.

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Table A-1 Davis-Besse License Renewal Commitments Related LRA Item Implementation Commitment Source Section No./

Number Schedule Comments x Require that high strength (i.e., ASTM A540 Grade B23) structural bolting materials with an actual measured yield strength greater than or equal to 150 kilo-pounds per square inch (ksi) and greater than 1 inch in nominal diameter are monitored for stress corrosion cracking (SCC). Perform periodic visual inspections of susceptible ASTM A540 bolting to identify locations where A540 bolting may be exposed to a potentially corrosive environment for SCC. Complete the initial visual inspections prior to entering the period of extended operation, and perform recurring inspections at an interval not to exceed five years. Perform volumetric examination (i.e., ultrasonic testing) on a sampling basis of bolting exposed to a corrosive environment, as determined by engineering evaluation, to a depth of at least 12 inches.

x Require that personnel performing ultrasonic testing (UT) examinations of structural bolting have a current ASME Code Section XI, Appendix VIII, Supplement 8 endorsement.

x Revise the applicable structural bolting specifications to prevent future use of A540 bolting with measured yield strength equal to or exceeding 150 ksi.

21 Enhance the Water Control Structures Inspection to: Prior to LRA A.1.40 x Include the Service Water Discharge Structure which is within April 22, 2017 and B.2.40 the scope of license renewal.

x Include parameters monitored and inspected for water control FENOC Responses to structures, including the Service Water Discharge Structure, in Letter NRC RAI accordance with applicable inspection elements listed in L-11-153 B.2.39-6 from Section C.2 of Regulatory Guide 1.127 Revision 1. Descriptions and NRC Letter of concrete conditions will conform with the appendix to the L-11-292 dated American Concrete Institute (ACI) publication, ACI 201. The use April 5, 2011, Page 15 of 33

Table A-1 Davis-Besse License Renewal Commitments Related LRA Item Implementation Commitment Source Section No./

Number Schedule Comments of photographs for comparison of previous and present and conditions will be included as a part of the inspection program. Supplemental x Specify that water control structure periodic inspections are to RAI OIN-379 be performed at least once every five years. from Region III IP-71002 x Add an action to follow the documentation requirement of Inspection 10 CFR 54.37, including submittal of records of structural evaluations to records management.

x Add sufficient acceptance criteria and critical parameters to trigger an increased level of inspection and initiation of corrective action. Indicate that ACI 349.3R provides acceptable guidelines which will be considered in developing acceptance criteria for water control structures. Plant-specific quantitative degradation limits, similar to the three-tier hierarchy acceptance criteria from Chapter 5 of ACI 349.3R, will be developed and added to the inspection procedure. The Structures Monitoring Program procedure will also be enhanced to reflect the Periodic Evaluation criteria defined in chapter 3.3 of ACI 349.3R. The Structures Monitoring Program procedure will include the prioritization process to develop a representative sample of areas to inspect in accordance with ACI 349.3R.

x Conduct a baseline inspection of the structures within the scope of license renewal prior to entering the period of extended operation.

x Require that loose bolts and nuts, cracked high strength bolts, and degradation of piles and sheeting (sheet pilings) are accepted by engineering evaluation or subject to corrective actions. Engineering evaluation will be documented and based on codes, specifications and standards such as American Institute of Steel Construction (AISC) specifications, Structural Page 16 of 33

Table A-1 Davis-Besse License Renewal Commitments Related LRA Item Implementation Commitment Source Section No./

Number Schedule Comments Engineering Institute / American Society of Civil Engineers (SEI/ASCE) 11, and codes, specifications or standards referenced in the Davis-Besse current licensing basis.

22 Enclose or otherwise protect the safety-related station ventilation April 22, 2017 N/A N/A radiation monitors located in the Turbine Building such that leakage and spray from surrounding piping systems does not adversely impact the intended function of the radiation monitors.

23 In association with the TLAA for effects of environmentally assisted Prior to LRA A.2.3.4.2 fatigue of the high pressure injection (HPI) nozzle safe end including April 22, 2017 and A.2.7.4 the associated Alloy 82/182 weld (weld that connects the safe end to the nozzle), replace the HPI nozzle safe end including the associated Alloy 82/182 weld for all four HPI nozzles prior to the FENOC Responses to period of extended operation. Apply the Fatigue Monitoring Program Letters NRC RAIs to evaluate the environmental effects and manage cumulative L-11-107 4.7.4-1 from fatigue damage for the replacement high pressure injection (HPI) and NRC Letter nozzle safe ends and associated welds. L-11-203 dated April 15, 2011, 4.3-18 from NRC Letter dated June 17, 2011, and 4.7.4-1 from NRC Letter dated October 11, 2011 Page 17 of 33

Table A-1 Davis-Besse License Renewal Commitments Related LRA Item Implementation Commitment Source Section No./

Number Schedule Comments 24 Apply the elements of corrective actions, confirmation process, and Prior to LRA A.1 administrative controls in the Quality Assurance Program Manual to April 22, 2017 and the credited aging management programs and activities for safety-FENOC Response to related and nonsafety-related structures and components Letter NRC RAI 3.0 determined to require aging management for the period of extended L-11-166 from operation.

NRC Letter dated May 2, 2011 25 Enhance the Steam Generator Tube Integrity Program to: Prior to LRA A.1.38 x Include gross visual inspection of the steam generator tube to April 22, 2017 and B.2.38 tubesheet welds coupled with eddy-current inspection (i.e.,

bobbin coil or rotating coil examinations) of the tubes to monitor FENOC Response to for cracking and degradation of the tube-to-tubesheet welds Letter NRC RAI (Alloy 600). Schedule the gross visual inspection of the tube-to- L-12-001 3.1.2.2.16-3 tubesheet welds concurrent with eddy-current inspection of the from steam generator tubes that are scheduled in accordance with NRC Letter Davis-Besse Technical Specification 5.5.8 such that 100% of dated the tube-to-tubesheet welds (includes both the hot leg and cold December 27, leg welds) are inspected at sequential periods of 60 effective full 2011 power months. Perform the gross visual inspection of the tube to tubesheet welds through remote-visual examination using a manipulator camera to obtain a straight-on view of the weld with a visual acuity sufficient to detect evidence of degradation.

Perform the gross visual inspections using personnel who are qualified for American Society of Mechanical Engineers (ASME) code visual examination (i.e., are certified VT-1 or VT-3 examiners) and are knowledgeable in the type of tube-to-tubesheet welds being examined (i.e., fillet welds). Define the acceptance criteria for the gross visual inspections and the Page 18 of 33

Table A-1 Davis-Besse License Renewal Commitments Related LRA Item Implementation Commitment Source Section No./

Number Schedule Comments eddy-current inspections as no indication of cracking or relevant conditions of degradation.

26 Obtain and evaluate for degradation a concrete core bore from two Prior to FENOC Responses to representative inaccessible concrete components of an in-scope December 31, Letters NRC RAI structure subjected to aggressive groundwater prior to entering the 2014 L-11-153, B.2.39-3 from period of extended operation. Based on the results of the initial core L-11-237, NRC Letter bore sample, evaluate the need for collection and evaluation of and dated representative concrete core bore samples at additional locations L-11-292 April 5, 2011, that may be identified during the period of extended operation as RAI B.2.39-11 having aggressive groundwater infiltration. Select additional core from bore sample locations based on the duration of observed NRC Letter aggressive groundwater infiltration. Document identified concrete or dated steel degradation in the FENOC Corrective Action Program. July 21, 2011, and Supplemental RAI B.2.39-11 from telecon held with the NRC on September 13, 2011 Page 19 of 33

Table A-1 Davis-Besse License Renewal Commitments Related LRA Item Implementation Commitment Source Section No./

Number Schedule Comments 27 DBNPS Surveillance Test Procedure DB-PF-03009, Revision 06, Prior to FENOC Response to Containment Vessel and Shielding Building Visual Inspection, April 22, 2017 Letter NRC RAI Subsection 2.1.2, shall be enhanced to state, Personnel who L-11-134 B.2.1-1 from perform general visual examinations of the exterior surface of the NRC Letter Containment Vessel and the interior and exterior surfaces of the dated Shield Building shall meet the requirements for a general visual April 5, 2011 examiner in accordance with Nuclear Operating Procedure NOP-CC-5708, Written Practice for the Qualification and Certification of Nondestructive Examination Personnel. These individuals shall be knowledgeable of the types of conditions which may be expected to be identified during the examinations.

28 Enhance the Fuel Oil Chemistry Program to: Prior to LRA A.1.20 x Require that internal surfaces of emergency diesel generator April 22, 2017 and B.2.20 fuel oil storage tanks and day tanks, diesel oil storage tank, diesel fire pump day tank, and station blackout diesel generator FENOC Responses to day tank are periodically drained (at least once every 10 years) Letters NRC RAIs for cleaning and are visually inspected to detect potential L-11-134 B.2.20-1 and degradation. If degradation is identified in a diesel fuel tank by and B.2.20-2 from visual inspections, a volumetric inspection is performed. L-11-238 NRC Letter x Require that biological activity be monitored and trended at dated least quarterly. April 5, 2011, and Supplemental RAI OIN-368 from NRC Region III IP-71002 Inspection Page 20 of 33

Table A-1 Davis-Besse License Renewal Commitments Related LRA Item Implementation Commitment Source Section No./

Number Schedule Comments 29 Enhance the Cranes and Hoists Inspection Program to: Prior to LRA A.1.10 x Include visual inspections for loose bolts and missing or loose April 22, 2017 and B.2.10 nuts in crane, monorail and hoist inspection procedures at the same frequency as inspections of rails and structural FENOC Response to components. Letter NRC RAI L-11-153 B.2.10-2 from NRC Letter dated April 20, 2011 Page 21 of 33

Table A-1 Davis-Besse License Renewal Commitments Related LRA Item Implementation Commitment Source Section No./

Number Schedule Comments 30 Enhance the Leak Chase Monitoring Program to: Prior to LRA A.1.25 x Include acceptance criteria such that measurement of leakage April 22, 2017 and B.2.25 from any monitoring line exceeding 15 ml/min will be documented in the Corrective Action Program for evaluation and FENOC Responses to potential corrective actions. Evaluation will include consideration Letters NRC RAI of more frequent monitoring. L-11-153 B.2.25-5 from x Analyze collected leak chase drainage for pH monthly and for and NRC Letter iron every six months. The initial acceptance criteria will be 7.0 L-11-238 dated to 8.0 for pH. The results for iron will be monitored and trended April 5, 2011 to insure that there is no indication of corrosion of the reinforcing and bars in the walls or floor of the pool and pits. An acceptance RAIs B.2.25-7 criterion for the iron analyses will be developed after three years and B.2.39-10 of measurements. Analyses that exceed the limits will be from documented in the Corrective Action Program. NRC Letter x Perform the leak chase inspection and cleaning recurring dated preventive maintenance (PM) activity every 18 months. July 21, 2011 x Inspect once per year for leakage migrating through the accessible outside walls and floor (from the ceiling side) of the pool and pits. Document the inspection results and retain in plant records. Indication of leakage through the walls will be documented in the Corrective Action Program.

31 Incorporate reference to and the preventative actions of the Prior to FENOC Response to Research Council for Structural Connections Specification for April 22, 2017 Letter NRC RAI Structural Joints Using ASTM A325 or A490 Bolts into the L-11-153 B.2.39-8 from Davis-Besse specifications and implementing procedures that NRC Letter address Davis-Besse structural bolting within the scope of dated license renewal. April 5, 2011 Page 22 of 33

Table A-1 Davis-Besse License Renewal Commitments Related LRA Item Implementation Commitment Source Section No./

Number Schedule Comments 32 Enhance the Closed Cooling Water Chemistry program to: Prior to LRA A.1.8 x Document the results of periodic inspections of opportunity, April 22, 2017 and B.2.8 performed when components are opened for maintenance, repair, or surveillance. FENOC Response to x Ensure that a representative sample of piping and components Letters NRC RAI will be inspected on a 10-year interval, with the first inspection L-11-153 B.2.8-1 from taking place prior to entering the period of extended operation. and NRC Letter x Ensure that component cooling water radiochemistry is sampled L-11-354 dated on a weekly interval to verify the integrity of the letdown coolers April 20, 2011 and seal return coolers. and Supplemental RAI 2.3.3.18-4 from telecom held with the NRC on November 9, 2011 33 Phase 1 Phase 1: FENOC Response to Perform the following actions to reduce or mitigate the refueling Action 1 prior to Letter NRC RAI canal leaks inside containment: December 31, L-11-252 B.2.39-9 from

1. Select and implement a leak detection method to locate the 2014 NRC Letter leakage area. dated July 27, 2011

2. Evaluate temporary and permanent repair methods to stop Action 2 prior to or significantly reduce the leakage, and implement a December 31, repair plan. 2016 Phase 2 Perform the following actions to evaluate the impact of refueling Phase 2:

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Table A-1 Davis-Besse License Renewal Commitments Related LRA Item Implementation Commitment Source Section No./

Number Schedule Comments canal leaks on concrete and reinforcing steel structures. Action 1 prior to Discontinue core bores, testing and reinforcing steel inspections December 31, when indications of refueling canal leakage are no longer present: 2014

1. Perform a core bore in the south wall of the east-west section of the core flood pipe tunnel. Action 2 prior to

a. Assess borated water degradation of the concrete by December 31, testing the core bore sample for compressive 2023 strength and by petrographic examination, and evaluate the results.

Action 3 -

b. Conduct a visual examination of the concrete and Ongoing reinforcing steel to identify aging effects (e.g.,

concrete degradation or steel corrosion). Enter identified aging effects into the FENOC Corrective Action Program and evaluate in accordance with the requirements of the current licensing basis Maintenance Rule Program.

2. If leakage from the refueling canal has not been eliminated or resumes by the beginning of the period of extended operation, then evaluate the concrete structures in a manner similar to the way that they were evaluated under Phase 2, Action 1. However, use acceptance criteria from the American Concrete Institute (ACI) Report 349.3R for the evaluation.

3. If leakage from the refueling canal has not been eliminated or resumes during the period of extended operation, then evaluate the concrete structures again in a manner similar to the way that they were evaluated under Phase 2, Action 2.

Perform evaluations every ten years until the end of the period of extended operation.

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Table A-1 Davis-Besse License Renewal Commitments Related LRA Item Implementation Commitment Source Section No./

Number Schedule Comments 34 Enhance the Bolting Integrity Program to: Prior to LRA A.1.4 x Select an alternate stable lubricant that is compatible with the April 22, 2017 and B.2.4 fastener material and the environment. A specific precaution against the use of compounds containing sulfur (sulfide), FENOC Response to including molybdenum disulfide (MoS2), as a lubricant will be Letter NRC RAI included in the program. L-11-153 B.2.4-3 from NRC Letter dated April 20, 2011 35 Perform the following actions for each of two examinations (Phase 1 Phase 1 prior to FENOC Response to and Phase 2) of the Containment Vessel in the sand pocket region: December 31, Letter NRC RAI x Perform nondestructive examination (NDE) of the 2014 L-11-252 B.2.22-5 from Containment Vessel from the outer surface at five areas of NRC Letter previously-identified groundwater in-leakage. dated and July 21, 2011 o Examine the vessel at a minimum of three vertical grid locations at 12 inches nominal horizontal spacing at each Phase 2 prior to area. Examine the Containment Vessel at a minimum of December 31, three elevations: 2025

1. approximately 3 inches below the existing grout-to-vessel interface in the sand pocket region;

2. at the existing grout-to-vessel interface level in the sand pocket region; and,

3. approximately 3 inches above the existing grout-to-vessel interface in the sand pocket region.

x Compare the ultrasonic test (UT) thickness readings to minimum ASME Code vessel thickness requirements and to the results obtained during previous UT examinations of the Containment Vessel. Determine the need for maintenance or repair of the Page 25 of 33

Table A-1 Davis-Besse License Renewal Commitments Related LRA Item Implementation Commitment Source Section No./

Number Schedule Comments Containment Vessel based on the results and evaluation of the examinations.

x Document the results of each of the two examinations in the work order system. Document and evaluate adverse conditions in accordance with the FENOC Corrective Action Program for an evaluation of potential degradation of the steel Containment Vessel thickness over the longer term.

36 Perform the following actions related to the Containment Vessel Ongoing FENOC Response to sand pocket region each refueling outage: Letter NRC RAI x Perform visual inspection of 100 percent of the accessible areas L-11-252 B.2.22-5 from of the wetted outer surface of the Containment Vessel in the and NRC Letter sand pocket region. L-11-354 dated July 21, 2011 x Perform visual inspection of accessible dry areas of the outer and surface of the Containment Vessel in the sand pocket region Supplemental and the areas above the grout-to-steel interface up to RAI B.2.22-5 Elevation 566 feet + 3 inches, - 1 inch. from telecons x Perform visual inspection for deterioration (e.g., missing or held with the damaged grout) of accessible grout and the containment NRC on exterior moisture barrier in the sand pocket area. October 5 and x Perform opportunistic visual inspections of inaccessible areas of November 14, the Containment Vessel in the sand pocket region when such 2011 areas are made accessible.

x Perform opportunistic visual inspections for deterioration (e.g.,

missing or damaged grout) of inaccessible grout in the sand pocket region when such areas are made accessible.

Inaccessible grout is the grout below the normally-exposed surface of the grout in the sand pocket area.

x Address issues of pitting or microbiologically-influenced Page 26 of 33

Table A-1 Davis-Besse License Renewal Commitments Related LRA Item Implementation Commitment Source Section No./

Number Schedule Comments corrosion (MIC), and degraded grout, moisture barrier or sealant identified during the inspections using the FENOC Corrective Action Program.

x Sample the water in the sand pocket region when sufficient volumes are available. The number of sampled water volumes will be determined by the number of water volumes observed and the size of those water volumes. Analyze the sample(s) for pH, chlorides, iron and sulfates. Treat or wash (or a combination thereof) the sand pocket area to reduce measured chloride concentrations to less than 250 parts per million (ppm) if the concentration of chlorides in a sample exceeds 250 ppm.

Note: Water samples may be taken at different times during each outage. Engineering judgment may be used to determine the priority of the chemical analyses to be performed if sufficient water is not available in a given sample for all analyses.

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Table A-1 Davis-Besse License Renewal Commitments Related LRA Item Implementation Commitment Source Section No./

Number Schedule Comments 37 Perform and evaluate core bores of the ECCS Pump Room No. 1 Phase 1 prior to FENOC Responses to wall and the Room 109 ceiling. December 31, Letters NRC RAI x The core bores will be deep enough to expose reinforcing bar in 2014 L-11-153 B.2.39-2 from the wall and ceiling. The core samples from the core bores will and NRC Letter be examined for signs of corrosion or chemical effects of boric dated and L-11-238 acid on the concrete or reinforcing bars. The examination will April 5, 2011, include a petrographic examination. The reinforcing steel that and will be exposed for a visual inspection will have corrosion Phase 2 prior to RAI B.2.39-10 products collected for testing. Degradation identified from the December 31, from samples will be entered into the FENOC Corrective Action 2020 NRC Letter Program. The core bores will be performed in areas where dated leakage has been observed in the past. July 21, 2011 x The first set of core bores will be performed prior to the end of 2014 (Phase 1).

x The second set of core bores will be performed prior to the end of 2020 (Phase 2).

x Further core bores will be conducted, if warranted, based on the evaluation of the results of the inspection and testing of the core bores or if spent fuel pool leakage through the wall or ceiling recurs after the second set of core bores is performed. If spent fuel pool leakage through another wall or ceiling is identified, then core bores will be performed in a manner similar to that stated for the ECCS Pump Room No. 1 wall and the Room 109 ceiling.

Page 28 of 33

Table A-1 Davis-Besse License Renewal Commitments Related LRA Item Implementation Commitment Source Section No./

Number Schedule Comments 38 Evaluate the concrete cracking observed on the underside of the Prior to FENOC Responses to spent fuel pool for necessary repairs. April 22, 2017 Letters NRC RAI Note: A core bore of the Room 109 ceiling will be performed by the L-11-153 B.2.39-2 from end of 2014 (see license renewal commitment 37). Degradation and NRC Letter identified from the samples will be entered into the FENOC dated L-11-238 Corrective Action Program. The condition of the concrete and the April 5, 2011, reinforcing steel will be evaluated at that time to assist in and determining what repairs, if any, need to be made to the underside RAI B.2.39-10 of the spent fuel pool concrete. The criterion for determining the from need to repair the cracking will be the continued capability of the NRC Letter structures to perform their intended functions during the period of dated extended operation. July 21, 2011 39 Address the potential for borated water degradation of the steel Phase 1 prior to FENOC Responses to containment vessel through the following actions: December 31, Letters NRC RAIs x Access the inside surface of the embedded steel containment. A 2014 L-11-153 B.2.22-2 from core bore will be completed by the end of 2014 (Phase 1). If and and NRC Letter necessary, a second core bore will be completed by the end of L-11-237 dated Phase 2 prior to 2020 (Phase 2). If there is evidence of the presence of borated April 5, 2011, December 31, water in contact with the steel containment vessel, conduct and 2020 non-destructive testing (NDT) to determine what effect, if any, B.2.22-6 from the borated water has had on the steel containment vessel. NRC Letter Based on the results of NDT, perform a study to determine the dated effect through the period of extended operation of any identified July 27, 2011 loss of thickness in the steel containment due to exposure to borated water.

Page 29 of 33

Table A-1 Davis-Besse License Renewal Commitments Related LRA Item Implementation Commitment Source Section No./

Number Schedule Comments 40 Implement the Inspection of Internal Surfaces in Miscellaneous Prior to LRA A.1.41 Piping and Ducting Program as described in LRA Section B.2.41. April 22, 2017 and B.2.41 FENOC Responses to Letter NRC RAIs L-11-153 3.3.2.2.5-1 and 3.3.2.71-2 from NRC Letter dated April 20, 2011 41 Establish a preventive maintenance task to periodically replace the Prior to FENOC Response to flexible connections exposed to fuel oil in the Fuel Oil System. April 22, 2017 Letter NRC RAI L-11-166 3.3.2.3.12-2 from NRC Letter dated May 2, 2011 42 Enhance the Fatigue Monitoring Program to: Prior to LRA A.1.16 x Evaluate additional plant-specific component locations in the April 22, 2016 and B.2.16 reactor coolant pressure boundary that may be more limiting than those considered in NUREG/CR-6260. This evaluation will FENOC Response to include identification of the most limiting fatigue location Letter NRC RAI exposed to reactor coolant for each material type (i.e., CS, LAS, L-11-166 B.2.16-2 from SS, and NBA) and that each bounding material/location will be NRC Letter evaluated for the effects of the reactor coolant environment on dated fatigue usage. Nickel based alloy items will be evaluated using April 20, 2011 NUREG/CR-6909. Submit the evaluation to the NRC one year prior to the period of extended operation.

Page 30 of 33

Table A-1 Davis-Besse License Renewal Commitments Related LRA Item Implementation Commitment Source Section No./

Number Schedule Comments 43 Ensure that the current station operating experience review process Prior to FENOC Response to includes future reviews of plant-specific and industry operating April 22, 2017 Letter NRC RAI experience to confirm the effectiveness of the License Renewal L-11-188 B.1.4-1 from aging management programs, to determine the need for programs NRC Letter to be enhanced, or indicate a need to develop new aging dated management programs. May 19, 2011 44 Cathodically protect the EDG fuel oil storage tanks (DB-T153-1 and Prior to FENOC Response to DB-T153-2) and the in-scope fuel oil and Service Water buried April 22, 2017 Letter NRC RAI piping in accordance with NACE SP0169-2007 or L-11-203 B.2.7-1 from NACE RP0285-2002. NRC Letter dated April 20, 2011, as modified per telecon with the NRC held on June 7, 2011 45 Implement the Nuclear Safety-Related Coatings Program as Prior to FENOC A.1.42 described in LRA Section B.2.42. April 22, 2017 Letter B.2.42 L-11-203 Response to NRC RAI XI.S8-1 from NRC Letter dated April 5, 2011 Page 31 of 33

Table A-1 Davis-Besse License Renewal Commitments Related LRA Item Implementation Commitment Source Section No./

Number Schedule Comments 46 Implement the Shield Building Monitoring Program as described in Prior to LRA A.1.43 LRA Section B.2.43. April 22, 2017 and B.2.43 FENOC Response to Letter NRC RAI L-12-028 B.2.16-2 from NRC Letter dated December 27, 2012 47 Enhance the Inservice Inspection (ISI) Program - IWE to: Prior to LRA A.1.22 x Include surface examinations to monitor for cracking of April 22, 2017 and B.2.22 containment stainless steel penetration sleeves, dissimilar metal welds, bellows, and steel components that are subject to cyclic FENOC Responses to loading but have no current licensing basis fatigue analysis. Letter NRC RAI The inspection sample size will include 10 percent of the L-11-238 B.2.22-7 from containment penetration population that are subject to cyclic and NRC Letter loading but have no current licensing basis fatigue analysis. L-11-292 dated Penetrations included in the inspection sample will be scheduled July 21, 2011, for examination in each 10-year ISI interval that occurs during and the period of extended operation. Should fatigue analyses be Supplemental performed in the future for the subject containment penetrations, RAI B.2.22-7 the surface examinations will no longer be required. from NRC telecons held on September 13 and 16, 2011 Page 32 of 33

Table A-1 Davis-Besse License Renewal Commitments Related LRA Item Implementation Commitment Source Section No./

Number Schedule Comments 48 Complete an investigation and needed repairs or modification of the Prior to FENOC Response to degraded portion of the safety-related intake canal embankment. April 22, 2017 Letter NRC RAI L-11-238 B.2.40-2 from NRC Letter dated July 21, 2011 49 Enhance the Nickel-Alloy Management Program to: Prior to FENOC A.1.28 x Provide for inspection of dissimilar metal butt welds in April 22, 2017 Letter B.2.28 accordance with the requirements of ASME Code Case L-11-238 Response to N-770-1, Alternative Examination Requirements and NRC RAI Acceptance Standards for Class 1 PWR Piping and Vessel B.2.28-1 from Nozzle Butt Welds Fabricated with UNS N06082 or UNS NRC Letter W86182 Weld Filler Material With or Without Application of dated Listed Mitigation Activities,Section XI, Division 1, as July 27, 2011 modified by the Code of Federal Regulations, 10 CFR 50.55a(g)(6)(ii)(F).

Page 33 of 33

Davis Besse Nuclear Power Station, Unit No. 1 License Renewal Future Commitments (Through LRA Amendment 3437)

Table A-1 Davis-Besse License Renewal Commitments Related LRA Item Implementation Commitment Source Section No./

Number Schedule Comments 1 Enhance the Aboveground Steel Tanks Inspection Program to: Prior to LRA A.1.2

Include a volumetric examination of tank bottoms to detect April 22, 2017 and B.2.2 evidence of loss of material due to crevice, general, or pitting corrosion, or to confirm a lack thereof. Establish the examination FENOC Response to technique, the inspection locations, and the acceptance criteria Letter NRC RAI for the examination of the tank bottoms. Require that L-11-153 B.2.2-1 from unacceptable inspection results be entered into the FENOC NRC Letter Corrective Action Program. The volumetric examination of the dated tank bottoms will be performed within five years after entering April 20, 2011 the period of extended operation. Additional opportunistic tank bottom inspections will be performed whenever the tanks are drained.

2 Implement the Boral Monitoring Program as described in LRA April 22, 2017 LRA A.1.5 Section B.2.5. B.2.5 3 Enhance the Buried Piping and Tanks Inspection Program to: Prior to LRA A.1.7

Add 1) bolting for buried Fire Protection System piping and 2) April 22, 2017 and B.2.7 the emergency diesel fuel oil storage tanks (DB-T153-1, DB- and T153-2) to the scope of the program. FENOC Response to

Conduct annual ground potential surveys of the cathodic Letter NRC RAI protection system using the acceptance criteria listed in L-11-153 B.2.7-1 from NACE RP0285 2002 and NACE SP0169-2007. Monitor cathodic NRC Letter Page 1 of 33

Table A-1 Davis-Besse License Renewal Commitments Related LRA Item Implementation Commitment Source Section No./

Number Schedule Comments protection voltage and current monthly to determine dated the effectiveness of cathodic protection systems and, thereby, April 20, 2011 the effectiveness of corrosion mitigation. Trend voltage, current, and ground potential readings and evaluate for adverse changes.

Require that the activity of the jockey fire pump or equivalent parameter be monitored on at least a monthly interval.

Conduct a flow test by the end of the next refueling outage when unexplained changes in jockey pump activity are observed.

Require that the directed buried pipe inspection locations be selected based on risk.

Require that the minimum number of buried in-scope piping inspections during the 30-40, 40-50, and 50-60 year operating period is one steel safety-related piping segment and one steel piping segment containing hazardous material. Perform the directed buried steel pipe and tank inspections each ten year interval based upon the following table. Each inspection will have a minimum of 10 feet of piping inspected.

Preventive # of inspections of safety # of Hazmat inspections Actions related piping or tanks or % of pipe length A 1 (Note 2) 1 (Note 2)

B 1 2%

C 4 5%

D 8 10 %

Note 1: Preventive actions are categorized as follows:

A. - Cathodic protection, in accordance with NACE SP0169-2007 or NACE RP0285-2002, was installed for at least 5 years prior to entering the period of extended operation and was operational for 90% of the time Page 2 of 33

Table A-1 Davis-Besse License Renewal Commitments Related LRA Item Implementation Commitment Source Section No./

Number Schedule Comments during that 5 years or cathodic protection was operational for 90% of the time since the last inspection conducted under this program.

B. - Cathodic protection, in accordance with NACE SP0169-2007 or NACE RP0285-2002, was installed for less than 5 years prior to entering the period of extended operation or was operational for less than 90% of the time during that 5 years or cathodic inspection was operational for less than 90% of the time since the last inspection conducted under this program C. - Protective coatings are in place and no mechanical coating damage due to the backfill, but cathodic protection is not provided or not in accordance with criteria A or B and the period of extended operation has not been entered.

D. - Criteria of A, B, and C not met.

Note 2: Only one inspection is required for piping which is both safety-related and contains hazardous material.

Require that the EDG Fuel Oil Storage Tanks (DB-T153-1 and DB-T153-2) be inspected prior to entering the period of extended operation. The inspection will be either a visual inspection of at least 25% of each tank and include at least some portion of the tank top and bottom or, an internal inspection consisting of UT measurements with at least one measurement per square foot of the surface of the tanks.

These inspections are not required if it is demonstrated that the tanks are cathodically protected in accordance with NACE SP0169-2007 or NACE RP0285-2002.

Require that a visual and volumetric inspection of the underground piping within the borated water piping trench will Page 3 of 33

Table A-1 Davis-Besse License Renewal Commitments Related LRA Item Implementation Commitment Source Section No./

Number Schedule Comments be performed during each 10-year period beginning no sooner than 10 years prior to the entry into the period of extended operation.

Require that if adverse indications are detected, additional buried in-scope piping inspections be performed in order to provide reasonable assurance of the integrity of buried piping.

Base the selection of components to be examined on previous examination results, trending, risk ranking, and areas of cathodic protection failures or gaps, if applicable. Continue additional sampling until reasonable assurance of the integrity of buried piping is provided.

Require that an inspection of buried Fire Protection System bolting will be performed when the bolting becomes accessible during opportunistic or focused inspections.

Require that the inspections of buried piping be conducted using visual (VT-3 or equivalent) inspection methods. Excavation shall be a minimum of 10 linear feet of piping, with all surfaces of the pipe exposed.

4 Implement the Collection, Drainage, and Treatment Components April 22, 2017 LRA A.1.9 Inspection Program as described in LRA Section B.2.9. B.2.9 5 Implement the Electrical Cable Connections Not Subject to Prior to LRA A.1.11 10 CFR 50.49 Environmental Qualification Requirements Inspection April 22, 2017 and B.2.11 as described in LRA Section B.2.11.

Enhance the Electrical Cable Connections Not Subject to FENOC Response to 10 CFR 50.49 Environmental Qualification Requirements Letter NRC RAI 3.6-3 Inspection to:

L-11-134 from NRC

Include high voltage connections to confirm the absence of Letter dated aging effects for metallic electrical connections. April 5, 2011 Page 4 of 33

Table A-1 Davis-Besse License Renewal Commitments Related LRA Item Implementation Commitment Source Section No./

Number Schedule Comments 6 Implement the Electrical Cables and Connections Not Subject to April 22, 2017 LRA A.1.12 10 CFR 50.49 Environmental Qualification Requirements Program B.2.12 as described in LRA Section B.2.12.

7 Implement the Electrical Cables and Connections Not Subject to April 22, 2017 LRA A.1.13 10 CFR 50.49 Environmental Qualification Requirements Used in B.2.13 Instrumentation Circuits Program as described in LRA Section B.2.13.

8 Enhance the External Surfaces Monitoring Program to: Prior to LRA A.1.15

Add systems which credit the program for license renewal but April 22, 2017 and B.2.15 do not have Maintenance Rule intended functions to the scope of the program. FENOC Responses to

Perform opportunistic inspections of surfaces that are Letters NRC RAIs inaccessible or not readily visible during normal plant operations L-11-153, 3.3.2.2.5-1 and or refueling outages, such as surfaces that are insulated. L-11-166 B.2.2-2 from Surfaces that are accessible will be inspected at a frequency not and NRC Letter to exceed one refueling cycle. L-11-238 dated

Perform, in conjunction with the Inspection of Internal Surfaces April 20, 2011, in Miscellaneous Piping and Ducting Program, inspection and NRC RAI surveillance of elastomers and polymers exposed to air-indoor 3.3.2-2 from uncontrolled or air-outdoor environments, but not replaced on a NRC Letter set frequency or interval (i.e., are long-lived), for evidence of dated cracking and change in material properties (hardening and loss May 2, 2011, of strength) and loss of material due to wear. Specify RAI 3.3.2.2.5-2 acceptance criteria of no unacceptable visual indications of from cracks or discoloration that would lead to loss of function prior to NRC Letter the next inspection, and of no hardening as evidenced by a loss dated of suppleness during manipulation.

July 12, 2011,

Perform inspection of the control room emergency ventilation Page 5 of 33

Table A-1 Davis-Besse License Renewal Commitments Related LRA Item Implementation Commitment Source Section No./

Number Schedule Comments system air-cooled condensing unit cooling coil tubes and fins and and the station blackout diesel generator radiator tubes and fins Supplemental for visible evidence of external surface conditions that could RAI OIN-352 result in a reduction in heat transfer. Specify acceptance criteria from of no unacceptable visual indications of fouling (build up of dirt NRC Region III or other foreign material) that would lead to loss of function prior IP-71002 to the next scheduled inspection. Inspection

Manage cracking of copper alloys with greater than 15 percent zinc and stainless steel components exposed to an outdoor air environment through plant system inspections and walkdowns for evidence of leakage. Specify acceptance criteria of no unacceptable visual indications of cracks that would lead to loss of function prior to the next scheduled inspection.

Include inspection parameters and acceptance criteria for polymers, elastomers and metallic components as applicable in system inspection and walkdown documentation. Retain system inspection and walkdown documentation in plant records.

9 Enhance the Fatigue Monitoring Program to: Prior to LRA A.1.16

Provide for updates of the fatigue usage calculations on an as April 22, 2017 and B.2.16 needed basis if an allowable cycle limit is approached. When the number of accrued cycles is within 75% of the allowable FENOC Responses to cycle limit for any transient, a condition report will be generated. Letter NRC RAIs For any transient whose cycles are projected to exceed the L-11-166 B.2.16-3, allowable cycle limit by the end of the next plant operating cycle B.2.16-4 (Davis-Besse operating cycles are normally two years in and duration), the program will require an update of the fatigue B.2.16-5 usage calculation for the affected component(s). from

Establish an acceptance criterion for maintaining the cumulative NRC Letter fatigue usage below the Code design limit of 1.0 through the dated Page 6 of 33

Table A-1 Davis-Besse License Renewal Commitments Related LRA Item Implementation Commitment Source Section No./

Number Schedule Comments period of extended operation, including environmental effects April 20, 2011 where applicable 10 Enhance the Fire Water Program to: April 22, 2017 LRA A.1.18

Perform periodic ultrasonic testing for wall thickness of B.2.18 representative above-ground water suppression piping that is not periodically flow tested but contains, or has contained, stagnant water. The ultrasonic testing will be performed prior to the period of extended operation and at appropriate intervals thereafter, based on engineering evaluation of the initial results.

Perform at least one opportunistic or focused visual inspection of the internal surface of buried fire water piping and of similar above-ground fire water piping, within the five-year period prior to the period of extended operation, to confirm whether conditions on the internal surface of above-ground fire water piping can be extrapolated to be indicative of conditions on the internal surface of buried fire water piping.

Perform representative sprinkler head sampling (laboratory field service testing) or replacement prior to 50 years in-service (installed), and at 10-year intervals thereafter, in accordance with NFPA 25, or until there are no untested sprinkler heads that will see 50 years of service through the end of the period of extended operation.

Perform opportunistic fire water supply and water-based suppression system internal inspections each time a fire water supply or water-based suppression system (including fire pumps) is breached for repair or maintenance. These internal visual inspections must be demonstrated to be: 1) representative of water supply and water-based suppression locations, 2) performed on a reasonable basis (frequency), and Page 7 of 33

Table A-1 Davis-Besse License Renewal Commitments Related LRA Item Implementation Commitment Source Section No./

Number Schedule Comments

3) capable of evaluating wall thickness and flow capability. If the internal inspections cannot be completed of a representative sample, then ultrasonic testing inspections will be used to complete the representative sample.

11 Implement the Inaccessible Power Cables Not Subject to Prior to LRA A.1.21 10 CFR 50.49 Environmental Qualification Requirements Program April 22, 2017 and B.2.21 as described in LRA Section B.2.21.

Enhance the Inaccessible Power Cables Not Subject to FENOC Responses to 10 CFR 50.49 Environmental Qualification Requirements Letter NRC RAIs Program to:

L-11-134 B.2.21-1 and

Include inaccessible underground lower service voltage cables B.2.21-3 from (400VAC to 2kV). NRC Letter

Not use significant voltage (defined as being subjected to dated system voltage for more than twenty-five percent of the time) as April 5, 2011 a criterion for inclusion into the program.

Include inspection of electrical manholes which contain power cables within the scope of the program.

Inspect electrical manholes at least once per year. The frequency of inspections for accumulated water will be established and adjusted based on plant-specific inspection results. Also, manhole inspections will be performed in response to event-driven occurrences (e.g., heavy rain or flooding).

Include a requirement in preventive maintenance activities PM 4297, PM 4294, PM 8025, and PM 4296 to generate a condition report in cases where in scope inaccessible non-EQ power cable manhole inspection identifies submerged cables.

Although the Inaccessible Power Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Program is a new program, preventive maintenance activities Page 8 of 33

Table A-1 Davis-Besse License Renewal Commitments Related LRA Item Implementation Commitment Source Section No./

Number Schedule Comments exist for inspection of water accumulation in the manholes associated with the in scope inaccessible non-EQ power cables.

Perform cable testing on a frequency of at least every 6 years.

Testing will be evaluated for more frequent performance based on test results and operating experience.

12 Enhance the Masonry Wall Inspection to: Prior to LRA A.1.27

Include and list the structures within the scope of license April 22, 2017 and B.2.27 renewal that credit the program for aging management.

Add an action to follow the documentation requirement of FENOC Response to 10 CFR 54.37, including submittal of records of structural Letter NRC RAI evaluations to records management. L-11-153 B.2.39-5 from

Specify that for each masonry wall, the extent of observed NRC Letter masonry cracking or degradation of steel edge supports or dated bracing is evaluated to ensure that the current evaluation basis April 5, 2011 is still valid. Corrective action is required if the extent of masonry cracking or steel degradation is sufficient to invalidate the evaluation basis. An option is to develop a new evaluation basis that accounts for the degraded condition of the wall (i.e., acceptance by further evaluation).

Specify that for the masonry walls within the scope of license renewal, inspections will be conducted at least once every five years, with provisions for more frequent inspections in areas where significant loss of material or cracking is observed to ensure there is no loss of intended function between inspections.

Page 9 of 33

Table A-1 Davis-Besse License Renewal Commitments Related LRA Item Implementation Commitment Source Section No./

Number Schedule Comments 13 Implement the One-Time Inspection as described in LRA Section Prior to LRA A.1.30 B.2.30. Enhance the One-Time Inspection to: April 22, 2017 and B.2.30

Include enhanced visual (EVT-1 or equivalent) or surface examination (magnetic particle, liquid penetrant), or volumetric FENOC Responses to (RT or UT) inspections to detect and characterize cracking due Letters NRC RAI to cyclic loading of the stainless steel makeup pump casings L-11-166, 3.3.2.2.4.3-1 (DB-P37-1 and 2) of the Makeup and Purification System. The L-11-237, from one-time inspections will provide verification of the absence of NRC Letter cracking due to cyclic loading. and L-11-252 dated May 2, 2011, and Supplemental Question -

Makeup Pump Casing Inspections 14 Implement the PWR Reactor Vessel Internals Program as described April 22, 2017 LRA A.1.32 in LRA Section B.2.32. B.2.32 15 In association with the PWR Reactor Vessel Internals Program, a Prior to LRA A.1.32 plant-specific inspection plan for ensuring the implementation of April 22, 2015

and B.2.32 MRP-227 program guidelines, as amended by the safety evaluation for MRP-227, and Davis-Besse's responses to the plant-specific action items, as identified in Section 4.2 of the safety evaluation for FENOC Response to MRP-227, will be submitted for NRC review and approval. Letter NRC RAI L-11-252 B.2.32-1 from

NOTE: The inspection plan will be submitted no later than two NRC Letter years after issuance of the renewed operating license or two years dated prior to the beginning of the period of extended operation July 11, 2011 (April 22, 2015), whichever is earlier.

Page 10 of 33

Table A-1 Davis-Besse License Renewal Commitments Related LRA Item Implementation Commitment Source Section No./

Number Schedule Comments 16 Enhance the Reactor Head Closure Studs Program as follows: April 22, 2017 LRA A.1.34

Select an alternate stable lubricant that is compatible with the and B.2.34 fastener material and the environment. A specific precaution against the use of compounds containing sulfur (sulfide), FENOC Response to including molybdenum disulfide (MoS2), as a lubricant for the Letter NRC RAI reactor head closure stud assemblies will be included in the L-11-218 B.2.34-1 from program. NRC Letter

Preclude the future use of replacement closure stud bolting dated fabricated from material with actual measured yield strength June 20, 2011 greater than or equal to 150 ksi except for use of the existing spare reactor head closure stud bolting.

17 Enhance the Reactor Vessel Surveillance Program as follows: April 22, 2017 LRA A.1.35

The Capsule Insertion and Withdrawal Schedule for B.2.35 Davis-Besse will be revised to schedule testing of the TE1-C capsule.

18 Implement the Selective Leaching Inspection as described in LRA April 22, 2017 LRA A.1.36 Section B.2.36. B.2.36 19 Implement the Small Bore Class 1 Piping Inspection as described in Completed within LRA A.1.37 LRA Section B.2.37. the six year and B.2.37 period prior to April 22, 2017.

FENOC Response to Letter NRC RAI L-11-153 B.2.37-2 from NRC Letter dated April 20, 2011 Page 11 of 33

Table A-1 Davis-Besse License Renewal Commitments Related LRA Item Implementation Commitment Source Section No./

Number Schedule Comments 20 Enhance the Structures Monitoring Program to: Prior to LRA A.1.39

Include and list the structures within the scope of license April 22, 2017 B.2.39 renewal that credit the program for aging management. FENOC

Include aging effect terminology (e.g., loss of material, cracking, Letters Responses to change in material properties, and loss of form). L-11-153, NRC RAIs

List ACI 349.3R and ANSI/ASCE 11-90 as references and L-11-237, B.2.39-4, indicate that they provide guidance for the selection of L-11-292, B.2.39-5, parameters monitored or inspected. and B.2.39-6 L-11-317, and

Clarify that a "structural component for inspection includes each and B.2.39-7 of the component types identified within the scope of license L-12-455 from renewal as requiring aging management.

NRC Letter

Require the responsible engineer to review site raw water pH, dated chlorides, and sulfates test results prior to the inspection to take April 5, 2011, into account the raw water chemistry for any unusual trends B.2.39-11 and during the period of extended operation. Raw water chemistry 3.5.2.3.12-4 data shall be collected at least once every five years. Data from collection dates shall be staggered from year to year (summer- NRC Letter winter-summer) to account for seasonal variation. dated

Perform an inspection for loss of material for carbon steel July 21, 2011, structural components subject to aggressive groundwater. Supplemental Require the use of the FENOC Corrective Action Program for RAI B.2.39-11 identified concrete or steel degradation. from telecon

Specify that, upon notification that a below-grade structural wall held with the or other in-scope concrete or metal structural component will NRC on become accessible through excavation, a follow-up action is September 13, initiated to the responsible engineer to inspect the exposed 2011, surfaces for age-related degradation. Such inspections will and include concrete examination using acceptance criteria from Supplemental RAI OIN-380 Page 12 of 33

Table A-1 Davis-Besse License Renewal Commitments Related LRA Item Implementation Commitment Source Section No./

Number Schedule Comments NUREG-1801, XI.S6, Program element 6. Degradation found from Region III that exceeds the acceptance criteria will be trended and IP-71002 processed through the FENOC Corrective Action Program. Inspection,

List ACI 349.3R, ANSI/ASCE 11-90, and EPRI Report 1007933 and as references and indicate that they provide guidance for RAI B.2.4-1a detection of aging effects. from NRC Letter

Add an action to follow the documentation requirement of dated 10 CFR 54.37, including submittal of records of structural November 14, evaluations to records management. 2012

Revise to add sufficient acceptance criteria and critical parameters to trigger an increased level of inspection and initiation of corrective action. Indicate that ACI 349.3R provides acceptable guidelines which will be considered in developing acceptance criteria for concrete structural elements, steel liners, joints, coatings, and waterproofing membranes. Plant specific quantitative degradation limits, similar to the three-tier hierarchy acceptance criteria from Chapter 5 of ACI 349.3R, will be developed and added to the inspection procedure. The Structures Monitoring Program procedure will also be enhanced to reflect the Periodic Evaluation criteria defined in chapter 3.3 of ACI 349.3R. The Structures Monitoring Program procedure will include the prioritization process to develop a representative sample of areas to inspect in accordance with ACI 349.3R.

Require that personnel performing the structural inspections meet qualifications that are commensurate with ACI 349.3R, Evaluation of Existing Nuclear Safety-Related Concrete Structures, Chapter 7, Qualifications of Evaluation Team.

The program procedure will be enhanced by specifying that, for Page 13 of 33

Table A-1 Davis-Besse License Renewal Commitments Related LRA Item Implementation Commitment Source Section No./

Number Schedule Comments the structures within the scope of license renewal, inspections will be conducted at least once every five years.

Conduct a baseline inspection of the structures within the scope of license renewal prior to entering the period of extended operation.

Require optical aids, scaling technologies, mechanical lifts, ladders or scaffolding for tall structures or difficult to reach areas of structures to allow visual inspections that meet the guidelines of Chapter 5 of ACI 349.3R. Select the areas to be inspected in accordance with the guidelines of Chapter 5 of ACI 349.3R to reflect the Periodic Evaluation criteria defined in Chapter 3.3 of ACI 349.3R. Include the prioritization process in the selection methodology to develop a representative sample of areas to inspect in accordance with ACI 349.3R.

Monitor elastomeric vibration isolators and structural sealants for cracking, loss of material and hardening.

Supplement visual inspection of elastomeric vibration isolation elements by feel to detect hardening if the vibration isolation function is suspect.

Identify that:

o Loose bolts and nuts and cracked high strength bolts are not acceptable unless accepted by engineering evaluation; o Structural sealants are acceptable if the observed loss of material, cracking, and hardening will not result in loss of sealing; and, o Elastomeric vibration isolation elements are acceptable if there is no loss of material, cracking, or hardening that could lead to the reduction or loss of isolation function.

Page 14 of 33

Table A-1 Davis-Besse License Renewal Commitments Related LRA Item Implementation Commitment Source Section No./

Number Schedule Comments

Require that high strength (i.e., ASTM A540 Grade B23) Formatted: Bullets and Numbering structural bolting materials with an actual measured yield strength greater than or equal to 150 kilo-pounds per square inch (ksi) and greater than 1 inch in nominal diameter are monitored for stress corrosion cracking (SCC). Perform periodic visual inspections of susceptible ASTM A540 bolting to identify locations where A540 bolting may be exposed to a potentially corrosive environment for SCC. Complete the initial visual inspections prior to entering the period of extended operation, and perform recurring inspections at an interval not to exceed five years. Perform volumetric examination (i.e., ultrasonic testing) on a sampling basis of bolting exposed to a corrosive environment, as determined by engineering evaluation, to a depth of at least 12 inches.

Require that personnel performing ultrasonic testing (UT) examinations of structural bolting have a current ASME Code Section XI, Appendix VIII, Supplement 8 endorsement.

Revise the applicable structural bolting specifications to prevent future use of A540 bolting with measured yield strength equal to or exceeding 150 ksi.

21 Enhance the Water Control Structures Inspection to: Prior to LRA A.1.40

Include the Service Water Discharge Structure which is within April 22, 2017 and B.2.40 the scope of license renewal.

Include parameters monitored and inspected for water control FENOC Responses to structures, including the Service Water Discharge Structure, in Letter NRC RAI accordance with applicable inspection elements listed in L-11-153 B.2.39-6 from Section C.2 of Regulatory Guide 1.127 Revision 1. Descriptions and NRC Letter of concrete conditions will conform with the appendix to the L-11-292 dated American Concrete Institute (ACI) publication, ACI 201. The use April 5, 2011, Page 15 of 33

Table A-1 Davis-Besse License Renewal Commitments Related LRA Item Implementation Commitment Source Section No./

Number Schedule Comments of photographs for comparison of previous and present and conditions will be included as a part of the inspection program. Supplemental

Specify that water control structure periodic inspections are to RAI OIN-379 be performed at least once every five years. from Region III IP-71002

Add an action to follow the documentation requirement of Inspection 10 CFR 54.37, including submittal of records of structural evaluations to records management.

Add sufficient acceptance criteria and critical parameters to trigger an increased level of inspection and initiation of corrective action. Indicate that ACI 349.3R provides acceptable guidelines which will be considered in developing acceptance criteria for water control structures. Plant-specific quantitative degradation limits, similar to the three-tier hierarchy acceptance criteria from Chapter 5 of ACI 349.3R, will be developed and added to the inspection procedure. The Structures Monitoring Program procedure will also be enhanced to reflect the Periodic Evaluation criteria defined in chapter 3.3 of ACI 349.3R. The Structures Monitoring Program procedure will include the prioritization process to develop a representative sample of areas to inspect in accordance with ACI 349.3R.

Conduct a baseline inspection of the structures within the scope of license renewal prior to entering the period of extended operation.

Require that loose bolts and nuts, cracked high strength bolts, and degradation of piles and sheeting (sheet pilings) are accepted by engineering evaluation or subject to corrective actions. Engineering evaluation will be documented and based on codes, specifications and standards such as American Institute of Steel Construction (AISC) specifications, Structural Page 16 of 33

Table A-1 Davis-Besse License Renewal Commitments Related LRA Item Implementation Commitment Source Section No./

Number Schedule Comments Engineering Institute / American Society of Civil Engineers (SEI/ASCE) 11, and codes, specifications or standards referenced in the Davis-Besse current licensing basis.

22 Enclose or otherwise protect the safety-related station ventilation April 22, 2017 N/A N/A radiation monitors located in the Turbine Building such that leakage and spray from surrounding piping systems does not adversely impact the intended function of the radiation monitors.

23 In association with the TLAA for effects of environmentally assisted Prior to LRA A.2.3.4.2 fatigue of the high pressure injection (HPI) nozzle safe end including April 22, 2017 and A.2.7.4 the associated Alloy 82/182 weld (weld that connects the safe end to the nozzle), replace the HPI nozzle safe end including the associated Alloy 82/182 weld for all four HPI nozzles prior to the FENOC Responses to period of extended operation. Apply the Fatigue Monitoring Program Letters NRC RAIs to evaluate the environmental effects and manage cumulative L-11-107 4.7.4-1 from fatigue damage for the replacement high pressure injection (HPI) and NRC Letter nozzle safe ends and associated welds. L-11-203 dated April 15, 2011, 4.3-18 from NRC Letter dated June 17, 2011, and 4.7.4-1 from NRC Letter dated October 11, 2011 Page 17 of 33

Table A-1 Davis-Besse License Renewal Commitments Related LRA Item Implementation Commitment Source Section No./

Number Schedule Comments 24 Apply the elements of corrective actions, confirmation process, and Prior to LRA A.1 administrative controls in the Quality Assurance Program Manual to April 22, 2017 and the credited aging management programs and activities for safety-FENOC Response to related and nonsafety-related structures and components Letter NRC RAI 3.0 determined to require aging management for the period of extended L-11-166 from operation.

NRC Letter dated May 2, 2011 25 Enhance the Steam Generator Tube Integrity Program to: Prior to LRA A.1.38

Include gross visual inspection of the steam generator tube to April 22, 2017 and B.2.38 tubesheet welds coupled with eddy-current inspection (i.e.,