ML14176A136

2014/06/09 Indian Point Lr Hearing - IPEC License Renewal - Response to Rvi RAIs

ML14176A136
Person / Time
Site:	Indian Point
Issue date:	06/09/2014
From:	- No Known Affiliation
To:	Division of License Renewal
References
Download: ML14176A136 (32)

Text

IPRenewal NPEmails From: Waters, Roger M. [rwater1@entergy.com]

Sent: Monday, June 09, 2014 1:42 PM To: Green, Kimberly Cc: Pickett, Douglas

Subject:

IPEC License Renewal - Response to RVI RAIs Attachments: NL-14-067 final.pdf

Kim, Attached is a pdf of the subject response. The hardcopy will be in the mail shortly to the Document Control Desk.

Roger Waters IPEC Regulatory Assurance 914-254-7714 1

Hearing Identifier: IndianPointUnits2and3NonPublic_EX Email Number: 4538 Mail Envelope Properties (A121135CD9246F4082BF946E6F9FB03951F2ACA7)

Subject:

IPEC License Renewal - Response to RVI RAIs Sent Date: 6/9/2014 1:41:59 PM Received Date: 6/9/2014 1:42:04 PM From: Waters, Roger M.

Created By: rwater1@entergy.com Recipients:

"Pickett, Douglas" <Douglas.Pickett@nrc.gov>

Tracking Status: None "Green, Kimberly" <Kimberly.Green@nrc.gov>

Tracking Status: None Post Office: JDCXMETSP003.etrsouth.corp.entergy.com Files Size Date & Time MESSAGE 204 6/9/2014 1:42:04 PM NL-14-067 final.pdf 137939 Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:

Recipients Received:

Docket Nos. 50-247 & 50-286 NL-14-067 Page 2 of 2

Attachment:

1. Reply to NRC Request for Additional Information Regarding the License Renewal Application

2. License Renewal Application IPEC List of Regulatory Commitments Revision 23 cc: Mr. William Dean, Regional Administrator, NRC Region I Mr. Sherwin E. Turk, NRC Office of General Counsel, Special Counsel Mr. Dave Wrona, NRC Branch Chief, Engineering Review Branch I Ms. Kimberly Green, NRC Sr. Project Manager, Division of License Renewal Mr. Douglas Pickett, NRR Senior Project Manager Ms. Bridget Frymire, New York State Department of Public Service NRC Resident Inspectors Office Mr. John B. Rhodes, President and CEO NYSERDA

ATTACHMENT 1 TO NL-14-067 REPLY TO NRC REQUEST FOR ADDITIONAL INFORMATION REGARDING THE LICENSE RENEWAL APPLICATION ENTERGY NUCLEAR OPERATIONS, INC.

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

NL-14-067 Attachment 1 Page 1 of 5 REQUEST FOR ADDITIONAL INFORMATION, SET 2014-02 RELATED TO INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 AND 3 LICENSE RENEWAL APPLICATION REACTOR VESSEL INTERNALS PROGRAM AND INSPECTION PLAN RAI 11-C Applicant/Licensee Action Item 7 from the staff's final safety evaluation (SE) of MRP-227 requires the applicants/licensees of Babcock & Wilcox (B&W), Combustion Engineering (CE),

and Westinghouse reactors to develop plant-specific analyses to be applied for their facilities to demonstrate that B&W In-Core Monitoring Instrumentation (IMI) guide tube assembly spiders and control rod guide tube (CRGT) assembly spacer castings, CE lower support columns, and Westinghouse lower support column bodies will maintain their functionality during the period of extended operation, and states that these analyses should also consider the possible loss of fracture toughness in these components due to thermal embrittlement (TE) and irradiation embrittlement (IE). For Indian Point Nuclear Generating Unit Nos. 2 and 3 (IP2 and IP3), the equivalent component to the lower support column bodies are the lower internals assembly - column caps (column caps).

By letter dated January 28, 2014, Entergy provided plant specific information on the ferrite content and susceptibility to TE for the Indian Point Nuclear Generating Unit Nos. 2 and 3 lower internals assembly - column caps. Based on its evaluation of the plant-specific material information for the column caps, Entergy concluded that the IP2 and IP3 column caps are not susceptible to TE.

Entergy's conclusion related to TE notwithstanding, the column caps remain susceptible to IE.

The staff is concerned that the linked Primary component for the column caps, the CRGT assembly lower flange welds, is not a good predictor of IE for the column caps since the CRGT lower flange welds receive substantially lower neutron fluence than the column caps (based on the estimated neutron fluence tabulated in MRP-191 for the two components).

Irradiation assisted stress corrosion cracking (IASCC) is the only mechanism of cracking that screened in for the column caps. The CRGT lower flange welds are also not a good predictor for IASCC of the column caps, because the lower flange welds are susceptible to stress corrosion cracking (SCC) and fatigue cracking, but not IASCC.

The staff, therefore, requests that Entergy modify its Reactor Vessel Internals Inspection Plan (RVI Inspection Plan) to provide a link to a Primary component or components that is an appropriate predictor of IE and IASCC of the column caps.

Response to RAI 11-C The following text will be incorporated into the reactor vessel internals (RVI) Inspection Plan for Indian Point Units 2 and 3 regarding a link to a component that is an appropriate predictor of irradiation embrittlement (IE) and irradiation-assisted stress corrosion cracking (IASCC) of the column caps.

NL-14-067 Attachment 1 Page 2 of 5 The lower core plate, which was screened in for IASCC in MRP-191[1], is a leading indicator of cracking in the column caps of the lower support column bodies because it is subject to more severe service conditions. Due to its proximity to the core, the lower core plate experiences both higher fluences and higher gamma heating than the column caps. Additionally, thermally induced tensile stresses are anticipated in the lower core plate while the stresses in the column caps are largely compressive. These factors are expected to contribute to earlier IASCC initiation in the lower core plate, making it a suitable leading indicator of cracking in the column caps.

The lower support column caps at Indian Point Units 2 and 3 have the same irradiation embrittlement mechanism as the wrought stainless steel lower core plate. The 60-year fluence in the top few inches of the lower support column body, which is where the column cap is located, is projected to exceed the threshold for irradiation embrittlement of austenitic stainless steel. Therefore, irradiation embrittlement is considered a damage mechanism in the column caps.

Considering both the cracking mechanism and the likely embrittlement mechanism, a leading indicator of degradation for the column caps is the lower core plate. Since the lower core plate is an Existing Programs component in MRP-227-A [2] and must be inspected as part of the aging management program, it is an appropriate alternate component for predicting aging effects.

The lower core plate will continue to be an Existing Programs component, managed under the Indian Point program for ASME Section XI inspections. The inspection requirement will remain a VT-3 inspection of the accessible upper surface on a ten-year interval. In addition to the standard requirements for assessing extent of condition required under ASME Section XI, a trigger for the Expansion inspection of the lower support column bodies (column caps) for Indian Point Units 2 and 3 will be the confirmed discovery of a service induced flaw in the lower core plate.

The intent of Commitment 47 was to demonstrate that the lower support column bodies will maintain their functionality during the period of extended operation considering the possible loss of fracture toughness due to thermal and irradiation embrittlement. As the staff noted in this RAI 11-C, Entergy has concluded that the IP2 and IP3 column caps (equivalent component to the lower support column bodies) are not susceptible to TE and will modify the Reactor Vessel Internals (RVI) Inspection Plan to credit inspection of the lower core plate as an appropriate predictor of IE and IASCC of the column caps. Therefore, the functionality of the lower support column bodies is assured during the period of extended operation without the need for a functionality analysis. Therefore, Entergy is deleting Commitment 47 (additions are underlined, deletions lined out).

Commitment 47 IPEC will perform and submit analyses that demonstrate that the lower support column bodies will maintain their functionality during the period of extended operation considering the possible loss of fracture toughness due to thermal and irradiation embrittlement. The analyses will be consistent with the IP2/IP3 licensing basis. Deleted.

NL-14-067 Attachment 1 Page 3 of 5 References

1. Materials Reliability Program: Screening, Categorization, and Ranking of Reactor Internals Components for Westinghouse and Combustion Engineering PWR Design (MRP-191).

EPRI, Palo Alto, CA: 2006. 1013234.

2. Materials Reliability Program: Pressurized Water Reactor Internals Inspection and Evaluation Guidelines (MRP-227-A). EPRI, Palo Alto, CA: 2011. 1022863.

RAI 16-B In its September 27, 2013 response to RAI 16-A, Entergy proposed Commitment No. 50 stating that it would provide the NRC staff a detailed inspection plan for the IP2 split pins, including inspection methods, inspection coverage, and inspection frequency, by March 31, 2015, if the planned replacement of the IP2 split pins will not be accomplished in 2016. In order to resolve MRP-227-A Applicant/Licensee Action Item 3, the NRC staff requests Entergy submit the schedule for initial inspection, inspection methods, inspection coverage, and inspection frequency for the IP2 split pins in the event the IP2 split pins are not replaced by 2016, and that Commitment No. 50 be modified accordingly.

Response to RAI 16-B Entergy commits to replacing the IP2 split pins during the 2016 refueling outage (2R22).

Therefore, a schedule for initial inspection, inspection methods, inspection coverage, and inspection frequency for the IP2 split pins is not necessary. Accordingly, Entergy is revising Commitment 50 and the identified LRA sections as follows (additions are underlined, deletions lined out).

Commitment 50 If the planned replacement of the IP2 split pins will not be accomplished in 2016, provide the NRC staff a detailed inspection plan for the IP2 split pins, including inspection methods, inspection coverage, and inspection frequency, by March 31, 2015. Replace the IP2 split pins during the 2016 refueling outage (2R22).

The following paragraph is revised in the Updated Final Safety Analysis Report LRA Section A.2.1.41.

The IP2 guide tube support pins (split pins) will be replaced during the 2016 refueling outage (2R22) are scheduled to be replaced during the 2016 refueling outage. If the planned replacement of the IP2 split pins will not be accomplished in 2016, Entergy will provide the NRC staff a detailed inspection plan, including inspection methods, inspection coverage, and inspection frequency, no later than March 31, 2015.

The following paragraph is revised in LRA Section B.1.42, Reactor Vessel Internals Program, under "Evaluation/1. Scope of Program," new last paragraph:

The IP2 guide tube support pins (split pins) are plant-specific components as discussed in MRP-227-A, Section 4.4.3, "Westinghouse Components." The split pins will be

NL-14-067 Attachment 1 Page 4 of 5 replaced during the 2016 refueling outage (2R22) are scheduled to be replaced during the 2016 refueling outage. See letter NL-12-166, Entergy to NRC, response to RAI 16, dated November 20, 2012, and letter NL-14-067, Entergy to NRC, response to RAI 16B for further discussion. If the planned replacement of the IP2 split pins will not be accomplished in 2016, Entergy will provide the NRC staff a detailed inspection plan, including inspection methods, inspection coverage, and inspection frequency, no later than March 31, 2015.

The revised commitment only affects IP2; therefore, LRA Section A.3.1.41 does not need revision.

RAI 17-A In its September 27, 2013 response to RAI 17, Entergy provided a technical justification for the adequacy of the existing inspection requirements specified in MRP-227-A for the clevis insert bolts, which relies on its American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code),Section XI lnservice Inspection (lSI) Program. Entergy's response included the statement, "[t]he video camera visual inspections at a ten-year interval by qualified personnel that are specified in the ASME Code Section XI and MRP-227-A are capable of identifying wear or dislodged components of the clevis insert cap screws or dowel pins at any location, if they exist." To assure that the type of degradation documented in Westinghouse lnfoGram IG-10-1 would be reliably detected at IP2 and IP3, the staff requests the following additional information:

1. Provide the ASME Code Section XI, Table IWB-2500 Examination Category and Item Number under which the IP2 and IP3 clevis insert bolts are classified.

2. Verify that the ASME Code,Section XI examination of the clevis inserts directly views all the clevis insert bolt heads, dowel pins and locking devices for each clevis insert.

3. If the ASME Code,Section XI examination does not directly view all the clevis insert bolts heads, locking devices, and dowel pins, propose a modification to Entergy's ASME Code,Section XI lSI Program to do so.

4. State when the most recent ASME Code,Section XI inspection of the clevis insert bolts was conducted at IP2 and IP3. Summarize the findings of that inspection for the clevis insert bolts.

Response to RAI 17-A

1. The clevis insert bolts at IP2 and IP3 are inspected as part of the Category B-N-2 Item Number B13.60 inspections.

2. At IPEC, the ASME Code,Section XI examination of the clevis inserts directly views all the clevis insert bolt heads, dowel pins, and locking devices for each clevis insert.

3. At IPEC, the ASME Code,Section XI examination does directly view all the clevis insert bolts heads, locking devices, and dowel pins. The ASME Code requires a VT-3 of these

NL-14-067 Attachment 1 Page 5 of 5 components and the VT-3 requirements include lighting and resolution requirements which will ensure that future inspections will continue to be performed in the same manner as they currently are being performed and, therefore, Entergys ASME Code,Section XI ISI program does not require modification.

4. The most recent ASME Code,Section XI inspection of the clevis insert bolts was conducted at IP2 in 2006 with no recordable indications and at IP3 in 2009 with no recordable indications.

ATTACHMENT 2 TO NL-14-067 LICENSE RENEWAL APPLICATION IPEC LIST OF REGULATORY COMMITMENTS Rev. 23 ENTERGY NUCLEAR OPERATIONS, INC.

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

NL-14-067 Attachment 2 Page 1 of 21 List of Regulatory Commitments Rev. 23 The following table identifies those actions committed to by Entergy in this document.

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

1. COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION

/ AUDIT ITEM IP2: NL-07-039 A.2.1.1 1 Enhance the Aboveground Steel Tanks Program for Complete A.3.1.1 IP2 and IP3 to perform thickness measurements of NL-13-122 B.1.1 the bottom surfaces of the condensate storage tanks, IP3:

city water tank, and fire water tanks once during the December 12, first ten years of the period of extended operation.

2015 Enhance the Aboveground Steel Tanks Program for IP2 and IP3 to require trending of thickness measurements when material loss is detected.

IP2: NL-07-039 A.2.1.2 2 Enhance the Bolting Integrity Program for IP2 and IP3 Complete A.3.1.2 to clarify that actual yield strength is used in selecting B.1.2 materials for low susceptibility to SCC and clarify the IP3:

prohibition on use of lubricants containing MoS2 for Complete NL-07-153 Audit Items bolting.

201, 241, The Bolting Integrity Program manages loss of NL-13-122 270 preload and loss of material for all external bolting.

NL-14-067 Attachment 2 Page 2 of 21

1. COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION

/ AUDIT ITEM IP2: NL-07-039 A.2.1.5 3 Implement the Buried Piping and Tanks Inspection Complete A.3.1.5 Program for IP2 and IP3 as described in LRA Section NL-13-122 B.1.6 B.1.6.

IP3: NL-07-153 Audit Item This new program will be implemented consistent with December 12, 173 the corresponding program described in NUREG- 2015 1801 Section XI.M34, Buried Piping and Tanks Inspection.

Include in the Buried Piping and Tanks Inspection NL-09-106 Program described in LRA Section B.1.6 a risk assessment of in-scope buried piping and tanks that NL-09-111 includes consideration of the impacts of buried piping or tank leakage and of conditions affecting the risk for corrosion. Classify pipe segments and tanks as having a high, medium or low impact of leakage based on the safety class, the hazard posed by fluid contained in the piping and the impact of leakage on reliable plant operation. Determine corrosion risk through consideration of piping or tank material, soil resistivity, drainage, the presence of cathodic protection and the type of coating. Establish inspection priority and frequency for periodic inspections of the in-scope piping and tanks based on the results of the risk assessment. Perform inspections using inspection techniques with demonstrated effectiveness. NL-11-101

NL-14-067 Attachment 2 Page 3 of 21

1. COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION

/ AUDIT ITEM IP2: NL-07-039 A.2.1.8 4 Enhance the Diesel Fuel Monitoring Program to Complete A.3.1.8 include cleaning and inspection of the IP2 GT-1 gas NL-13-122 B.1.9 turbine fuel oil storage tanks, IP2 and IP3 EDG fuel oil IP3: NL-07-153 Audit items day tanks, IP2 SBO/Appendix R diesel generator fuel December 12, 128, 129, oil day tank, and IP3 Appendix R fuel oil storage tank 2015 132, and day tank once every ten years.

NL-08-057 491, 492, Enhance the Diesel Fuel Monitoring Program to 510 include quarterly sampling and analysis of the IP2 SBO/Appendix R diesel generator fuel oil day tank, IP2 security diesel fuel oil storage tank, IP2 security diesel fuel oil day tank, and IP3 Appendix R fuel oil storage tank. Particulates, water and sediment checks will be performed on the samples. Filterable solids acceptance criterion will be less than or equal to 10mg/l. Water and sediment acceptance criterion will be less than or equal to 0.05%.

Enhance the Diesel Fuel Monitoring Program to include thickness measurement of the bottom of the following tanks once every ten years. IP2: EDG fuel oil storage tanks, EDG fuel oil day tanks, SBO/Appendix R diesel generator fuel oil day tank, GT-1 gas turbine fuel oil storage tanks, and diesel fire pump fuel oil storage tank; IP3: EDG fuel oil day tanks, EDG fuel oil storage tanks, Appendix R fuel oil storage tank, and diesel fire pump fuel oil storage tank.

Enhance the Diesel Fuel Monitoring Program to change the analysis for water and particulates to a quarterly frequency for the following tanks. IP2: GT-1 gas turbine fuel oil storage tanks and diesel fire pump fuel oil storage tank; IP3: Appendix R fuel oil day tank and diesel fire pump fuel oil storage tank.

Enhance the Diesel Fuel Monitoring Program to specify acceptance criteria for thickness measurements of the fuel oil storage tanks within the scope of the program.

Enhance the Diesel Fuel Monitoring Program to direct samples be taken and include direction to remove water when detected.

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

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

NL-14-067 Attachment 2 Page 4 of 21

1. COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION

/ AUDIT ITEM IP2: NL-07-039 A.2.1.10 5 Enhance the External Surfaces Monitoring Program Complete A.3.1.10 for IP2 and IP3 to include periodic inspections of NL-13-122 B.1.11 systems in scope and subject to aging management IP3:

review for license renewal in accordance with 10 CFR December 12, 54.4(a)(1) and (a)(3). Inspections shall include areas 2015 surrounding the subject systems to identify hazards to those systems. Inspections of nearby systems that could impact the subject systems will include SSCs that are in scope and subject to aging management review for license renewal in accordance with 10 CFR 54.4(a)(2).

IP2: NL-07-039 A.2.1.11 6 Enhance the Fatigue Monitoring Program for IP2 to Complete A.3.1.11 monitor steady state cycles and feedwater cycles or NL-13-122 B.1.12, perform an evaluation to determine monitoring is not NL-07-153 Audit Item required. Review the number of allowed events and 164 resolve discrepancies between reference documents and monitoring procedures.

IP3:

Enhance the Fatigue Monitoring Program for IP3 to December 12, include all the transients identified. Assure all fatigue 2015 analysis transients are included with the lowest limiting numbers. Update the number of design transients accumulated to date.

NL-14-067 Attachment 2 Page 5 of 21

1. COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION

/ AUDIT ITEM IP2: NL-07-039 A.2.1.12 7 Enhance the Fire Protection Program to inspect Complete A.3.1.12 external surfaces of the IP3 RCP oil collection NL-13-122 B.1.13 systems for loss of material each refueling cycle.

IP3:

Enhance the Fire Protection Program to explicitly December 12, state that the IP2 and IP3 diesel fire pump engine 2015 sub-systems (including the fuel supply line) shall be observed while the pump is running. Acceptance criteria will be revised to verify that the diesel engine does not exhibit signs of degradation while running; such as fuel oil, lube oil, coolant, or exhaust gas leakage.

Enhance the Fire Protection Program to specify that the IP2 and IP3 diesel fire pump engine carbon steel exhaust components are inspected for evidence of corrosion and cracking at least once each operating cycle.

Enhance the Fire Protection Program for IP3 to visually inspect the cable spreading room, 480V switchgear room, and EDG room CO2 fire suppression system for signs of degradation, such as corrosion and mechanical damage at least once every six months.

NL-14-067 Attachment 2 Page 6 of 21

1. COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION

/ AUDIT ITEM IP2: NL-07-039 A.2.1.13 8 Enhance the Fire Water Program to include inspection Complete A.3.1.13 of IP2 and IP3 hose reels for evidence of corrosion.

NL-13-122 B.1.14 Acceptance criteria will be revised to verify no IP3: NL-07-153 Audit Items unacceptable signs of degradation.

December 12, 105, 106 Enhance the Fire Water Program to replace all or test 2015 NL-08-014 a sample of IP2 and IP3 sprinkler heads required for 10 CFR 50.48 using guidance of NFPA 25 (2002 edition), Section 5.3.1.1.1 before the end of the 50-year sprinkler head service life and at 10-year intervals thereafter during the extended period of operation to ensure that signs of degradation, such as corrosion, are detected in a timely manner.

Enhance the Fire Water Program to perform wall thickness evaluations of IP2 and IP3 fire protection piping on system components using non-intrusive techniques (e.g., volumetric testing) to identify evidence of loss of material due to corrosion. These inspections will be performed before the end of the current operating term and at intervals thereafter during the period of extended operation. Results of the initial evaluations will be used to determine the appropriate inspection interval to ensure aging effects are identified prior to loss of intended function.

Enhance the Fire Water Program to inspect the internal surface of foam based fire suppression tanks.

Acceptance criteria will be enhanced to verify no significant corrosion.

NL-14-067 Attachment 2 Page 7 of 21

1. COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION

/ AUDIT ITEM IP2: NL-07-039 A.2.1.15 9 Enhance the Flux Thimble Tube Inspection Program Complete A.3.1.15 for IP2 and IP3 to implement comparisons to wear NL-13-122 B.1.16 rates identified in WCAP-12866. Include provisions to IP3:

compare data to the previous performances and December 12, perform evaluations regarding change to test 2015 frequency and scope.

Enhance the Flux Thimble Tube Inspection Program for IP2 and IP3 to specify the acceptance criteria as outlined in WCAP-12866 or other plant-specific values based on evaluation of previous test results.

Enhance the Flux Thimble Tube Inspection Program for IP2 and IP3 to direct evaluation and performance of corrective actions based on tubes that exceed or are projected to exceed the acceptance criteria. Also stipulate that flux thimble tubes that cannot be inspected over the tube length and cannot be shown by analysis to be satisfactory for continued service, must be removed from service to ensure the integrity of the reactor coolant system pressure boundary.

NL-14-067 Attachment 2 Page 8 of 21

1. COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION

/ AUDIT ITEM IP2: NL-07-039 A.2.1.16 10 Enhance the Heat Exchanger Monitoring Program for Complete A.3.1.16 IP2 and IP3 to include the following heat exchangers NL-13-122 B.1.17, in the scope of the program.

IP3: NL-07-153 Audit Item x Safety injection pump lube oil heat exchangers December 12, 52 2015 x RHR heat exchangers x RHR pump seal coolers x Non-regenerative heat exchangers x Charging pump seal water heat exchangers x Charging pump fluid drive coolers x Charging pump crankcase oil coolers x Spent fuel pit heat exchangers x Secondary system steam generator sample coolers x Waste gas compressor heat exchangers x SBO/Appendix R diesel jacket water heat exchanger (IP2 only)

Enhance the Heat Exchanger Monitoring Program for IP2 and IP3 to perform visual inspection on heat exchangers where non-destructive examination, such as eddy current inspection, is not possible due to heat exchanger design limitations.

Enhance the Heat Exchanger Monitoring Program for IP2 and IP3 to include consideration of material-environment combinations when determining sample population of heat exchangers.

Enhance the Heat Exchanger Monitoring Program for IP2 and IP3 to establish minimum tube wall thickness for the new heat exchangers identified in the scope of the program. Establish acceptance criteria for heat exchangers visually inspected to include no indication of tube erosion, vibration wear, corrosion, pitting, NL-09-018 fouling, or scaling.

NL-09-056 11 Deleted NL-11-101

NL-14-067 Attachment 2 Page 9 of 21

1. COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION

/ AUDIT ITEM IP2: NL-07-039 A.2.1.18 12 Enhance the Masonry Wall Program for IP2 and IP3 Complete A.3.1.18 to specify that the IP1 intake structure is included in NL-13-122 B.1.19 the program.

IP3:

Complete IP2: NL-07-039 A.2.1.19 13 Enhance the Metal-Enclosed Bus Inspection Program Complete A.3.1.19 for IP2 and IP3 to visually inspect the external surface NL-13-122 B.1.20 of MEB enclosure assemblies for loss of material at IP3: NL-07-153 Audit Items least once every 10 years. The first inspection will December 12, 124, occur prior to the period of extended operation and 2015 NL-08-057 133, 519 the acceptance criterion will be no significant loss of material.

NL-13-077 Enhance the Metal-Enclosed Bus Inspection Program to add acceptance criteria for MEB internal visual inspections to include the absence of indications of dust accumulation on the bus bar, on the insulators, and in the duct, in addition to the absence of indications of moisture intrusion into the duct.

Enhance the Metal-Enclosed Bus Inspection Program for IP2 and IP3 to inspect bolted connections at least once every five years if performed visually or at least once every ten years using quantitative measurements such as thermography or contact resistance measurements. The first inspection will occur prior to the period of extended operation.

The plant will process a change to applicable site procedure to remove the reference to re-torquing connections for phase bus maintenance and bolted connection maintenance.

IP2: NL-07-039 A.2.1.21 14 Implement the Non-EQ Bolted Cable Connections Complete A.3.1.21 Program for IP2 and IP3 as described in LRA Section NL-13-122 B.1.22 B.1.22.

IP3:

December 12, 2015

NL-14-067 Attachment 2 Page 10 of 21

1. COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION

/ AUDIT ITEM IP2: NL-07-039 A.2.1.22 15 Implement the Non-EQ Inaccessible Medium-Voltage Complete A.3.1.22 Cable Program for IP2 and IP3 as described in LRA NL-13-122 B.1.23 Section B.1.23.

IP3: NL-07-153 Audit item This new program will be implemented consistent with December 12, 173 the corresponding program described in NUREG- 2015 NL-11-032 1801 Section XI.E3, Inaccessible Medium-Voltage Cables Not Subject To 10 CFR 50.49 Environmental NL-11-096 Qualification Requirements.

NL-11-101 IP2: NL-07-039 A.2.1.23 16 Implement the Non-EQ Instrumentation Circuits Test Complete A.3.1.23 Review Program for IP2 and IP3 as described in LRA NL-13-122 B.1.24 Section B.1.24.

IP3: NL-07-153 Audit item This new program will be implemented consistent with December 12, 173 the corresponding program described in NUREG- 2015 1801 Section XI.E2, Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Used in Instrumentation Circuits.

IP2: NL-07-039 A.2.1.24 17 Implement the Non-EQ Insulated Cables and Complete A.3.1.24 Connections Program for IP2 and IP3 as described in NL-13-122 B.1.25 LRA Section B.1.25.

IP3: NL-07-153 Audit item This new program will be implemented consistent with December 12, 173 the corresponding program described in NUREG- 2015 1801 Section XI.E1, Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements.

NL-14-067 Attachment 2 Page 11 of 21

1. COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION

/ AUDIT ITEM IP2: NL-07-039 A.2.1.25 18 Enhance the Oil Analysis Program for IP2 to sample Complete A.3.1.25 and analyze lubricating oil used in the SBO/Appendix NL-13-122 B.1.26 R diesel generator consistent with the oil analysis for IP3: NL-11-101 other site diesel generators.

December 12, Enhance the Oil Analysis Program for IP2 and IP3 to 2015 sample and analyze generator seal oil and turbine hydraulic control oil.

Enhance the Oil Analysis Program for IP2 and IP3 to formalize preliminary oil screening for water and particulates and laboratory analyses including defined acceptance criteria for all components included in the scope of this program. The program will specify corrective actions in the event acceptance criteria are not met.

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

IP2: NL-07-039 A.2.1.26 19 Implement the One-Time Inspection Program for IP2 Complete A.3.1.26 and IP3 as described in LRA Section B.1.27.

NL-13-122 B.1.27 This new program will be implemented consistent with IP3: NL-07-153 Audit item the corresponding program described in NUREG- December 12, 173 1801,Section XI.M32, One-Time Inspection. 2015 IP2: NL-07-039 A.2.1.27 20 Implement the One-Time Inspection - Small Bore Complete A.3.1.27 Piping Program for IP2 and IP3 as described in LRA NL-13-122 B.1.28 Section B.1.28.

IP3: NL-07-153 Audit item This new program will be implemented consistent with December 12, 173 the corresponding program described in NUREG- 2015 1801,Section XI.M35, One-Time Inspection of ASME Code Class I Small-Bore Piping.

IP2: NL-07-039 A.2.1.28 21 Enhance the Periodic Surveillance and Preventive Complete A.3.1.28 Maintenance Program for IP2 and IP3 as necessary NL-13-122 B.1.29 to assure that the effects of aging will be managed IP3:

such that applicable components will continue to December 12, perform their intended functions consistent with the 2015 current licensing basis through the period of extended operation.

NL-14-067 Attachment 2 Page 12 of 21

1. COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION

/ AUDIT ITEM IP2: NL-07-039 A.2.1.31 22 Enhance the Reactor Vessel Surveillance Program for Complete A.3.1.31 IP2 and IP3 revising the specimen capsule withdrawal NL-13-122 B.1.32 schedules to draw and test a standby capsule to IP3:

cover the peak reactor vessel fluence expected December 12, through the end of the period of extended operation.

2015 Enhance the Reactor Vessel Surveillance Program for IP2 and IP3 to require that tested and untested specimens from all capsules pulled from the reactor vessel are maintained in storage.

IP2: NL-07-039 A.2.1.32 23 Implement the Selective Leaching Program for IP2 Complete A.3.1.32 and IP3 as described in LRA Section B.1.33.

NL-13-122 B.1.33 This new program will be implemented consistent with IP3: NL-07-153 Audit item the corresponding program described in NUREG- December 12, 173 1801,Section XI.M33 Selective Leaching of Materials. 2015 IP2: NL-07-039 A.2.1.34 24 Enhance the Steam Generator Integrity Program for Complete A.3.1.34 IP2 and IP3 to require that the results of the condition NL-13-122 B.1.35 monitoring assessment are compared to the IP3:

operational assessment performed for the prior Complete operating cycle with differences evaluated.

Enhance the Structures Monitoring Program to IP2: NL-07-039 A.2.1.35 25 explicitly specify that the following structures are Complete A.3.1.35 included in the program. NL-13-122 B.1.36 x Appendix R diesel generator foundation (IP3) IP3: NL-07-153 x Appendix R diesel generator fuel oil tank vault December 12, Audit items (IP3) 2015 86, 87, 88, x Appendix R diesel generator switchgear and NL-08-057 417 enclosure (IP3) x city water storage tank foundation x condensate storage tanks foundation (IP3) NL-13-077 x containment access facility and annex (IP3) x discharge canal (IP2/3) x emergency lighting poles and foundations (IP2/3) x fire pumphouse (IP2) x fire protection pumphouse (IP3) x fire water storage tank foundations (IP2/3) x gas turbine 1 fuel storage tank foundation x maintenance and outage building-elevated passageway (IP2) x new station security building (IP2) x nuclear service building (IP1) x primary water storage tank foundation (IP3) x refueling water storage tank foundation (IP3)

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/ AUDIT ITEM x security access and office building (IP3) x service water pipe chase (IP2/3) x service water valve pit (IP3) x superheater stack x transformer/switchyard support structures (IP2) x waste holdup tank pits (IP2/3)

Enhance the Structures Monitoring Program for IP2 and IP3 to clarify that in addition to structural steel and concrete, the following commodities (including their anchorages) are inspected for each structure as applicable.

x cable trays and supports x concrete portion of reactor vessel supports x conduits and supports x cranes, rails and girders x equipment pads and foundations x fire proofing (pyrocrete) x HVAC duct supports x jib cranes x manholes and duct banks x manways, hatches and hatch covers x monorails x new fuel storage racks x sumps NL-13-077 Enhance the Structures Monitoring Program for IP2 and IP3 to inspect inaccessible concrete areas that are exposed by excavation for any reason. IP2 and IP3 will also inspect inaccessible concrete areas in environments where observed conditions in accessible areas exposed to the same environment indicate that significant concrete degradation is occurring.

Enhance the Structures Monitoring Program for IP2 and IP3 to perform inspections of elastomers (seals, gaskets, seismic joint filler, and roof elastomers) to identify cracking and change in material properties and for inspection of aluminum vents and louvers to identify loss of material.

Enhance the Structures Monitoring Program for IP2

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/ AUDIT ITEM and IP3 to perform an engineering evaluation of NL-08-127 Audit Item groundwater samples to assess aggressiveness of 360 groundwater to concrete on a periodic basis (at least once every five years). IPEC will obtain samples from at least 5 wells that are representative of the ground water surrounding below-grade site structures and perform an engineering evaluation of the results from those samples for sulfates, pH and chlorides.

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

Enhance the Structures Monitoring Program for IP2 and IP3 to perform inspection of normally submerged concrete portions of the intake structures at least once every 5 years. Inspect the baffling/grating partition and support platform of the IP3 intake structure at least once every 5 years.

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

Enhance the Structures Monitoring Program to include more detailed quantitative acceptance criteria for inspections of concrete structures in accordance NL-11-032 with ACI 349.3R, Evaluation of Existing Nuclear Safety-Related Concrete Structures prior to the period of extended operation.

NL-11-101 IP2: NL-07-039 A.2.1.36 26 Implement the Thermal Aging Embrittlement of Cast Complete A.3.1.36 Austenitic Stainless Steel (CASS) Program for IP2 NL-13-122 B.1.37 and IP3 as described in LRA Section B.1.37.

IP3: NL-07-153 Audit item This new program will be implemented consistent with December 12, 173 the corresponding program described in NUREG- 2015 1801,Section XI.M12, Thermal Aging Embrittlement of Cast Austenitic Stainless Steel (CASS) Program.

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/ AUDIT ITEM IP2: NL-07-039 A.2.1.37 27 Implement the Thermal Aging and Neutron Irradiation Complete A.3.1.37 Embrittlement of Cast Austenitic Stainless Steel NL-13-122 B.1.38 (CASS) Program for IP2 and IP3 as described in LRA IP3: NL-07-153 Audit item Section B.1.38.

Complete 173 This new program will be implemented consistent with the corresponding program described in NUREG-1801 Section XI.M13, Thermal Aging and Neutron Embrittlement of Cast Austenitic Stainless Steel (CASS) Program.

IP2: NL-07-039 A.2.1.39 28 Enhance the Water Chemistry Control - Closed Complete A.3.1.39 Cooling Water Program to maintain water chemistry of NL-13-122 B.1.40 the IP2 SBO/Appendix R diesel generator cooling IP3: NL-08-057 Audit item system per EPRI guidelines.

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

IP2: NL-07-039 A.2.1.40 29 Enhance the Water Chemistry Control - Primary and Complete B.1.41 Secondary Program for IP2 to test sulfates monthly in NL-13-122 the RWST with a limit of <150 ppb.

IP2: NL-07-039 A.2.1.41 30 For aging management of the reactor vessel internals, Complete A.3.1.41 IPEC will (1) participate in the industry programs for NL-13-122 investigating and managing aging effects on reactor IP3:

internals; (2) evaluate and implement the results of Complete the industry programs as applicable to the reactor internals; and (3) upon completion of these programs, but not less than 24 months before entering the period of extended operation, submit an inspection plan for NL-11-107 reactor internals to the NRC for review and approval.

IP2: NL-07-039 A.2.2.1.2 31 Additional P-T curves will be submitted as required Complete A.3.2.1.2 per 10 CFR 50, Appendix G prior to the period of NL-13-122 4.2.3 extended operation as part of the Reactor Vessel IP3:

Surveillance Program.

December 12, 2015 As required by 10 CFR 50.61(b)(4), IP3 will submit a IP3: NL-07-039 A.3.2.1.4 32 plant-specific safety analysis for plate B2803-3 to the December 12, 4.2.5 NRC three years prior to reaching the RTPTS 2015 NL-08-127 screening criterion. Alternatively, the site may choose to implement the revised PTS rule when approved.

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/ AUDIT ITEM IP2: NL-07-039 A.2.2.2.3 33 At least 2 years prior to entering the period of Complete A.3.2.2.3 extended operation, for the locations identified in LRA NL-13-122 4.3.3 Table 4.3-13 (IP2) and LRA Table 4.3-14 (IP3), under IP3: NL-07-153 Audit item the Fatigue Monitoring Program, IP2 and IP3 will Complete 146 implement one or more of the following:

NL-08-021 (1) Consistent with the Fatigue Monitoring Program, Detection of Aging Effects, update the fatigue usage calculations using refined fatigue analyses to determine valid CUFs less than 1.0 when accounting NL-10-082 for the effects of reactor water environment. This includes applying the appropriate Fen factors to valid CUFs determined in accordance with one of the following:

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

2. Additional plant-specific locations with a valid CUF may be evaluated. In particular, the pressurizer lower shell will be reviewed to ensure the surge nozzle remains the limiting component.

3. Representative CUF values from other plants, adjusted to or enveloping the IPEC plant specific external loads may be used if demonstrated applicable to IPEC.

4. An analysis using an NRC-approved version of the ASME code or NRC-approved alternative (e.g., NRC-approved code case) may be performed to determine a valid CUF.

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

NL-13-122 2.1.1.3.5 34 IP2 SBO / Appendix R diesel generator will be NL-07-078 installed and operational by April 30, 2008. This Complete committed change to the facility meets the NL-08-074 requirements of 10 CFR 50.59(c)(1) and, therefore, a license amendment pursuant to 10 CFR 50.90 is not NL-11-101 required.

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/ AUDIT ITEM IP2: NL-08-127 Audit Item 35 Perform a one-time inspection of representative Complete 27 sample area of IP2 containment liner affected by the NL-13-122 1973 event behind the insulation, prior to entering the period of extended operation, to assure liner degradation is not occurring in this area.

IP3: NL-11-101 Perform a one-time inspection of representative December 12, sample area of the IP3 containment steel liner at the 2015 juncture with the concrete floor slab, prior to entering the period of extended operation, to assure liner degradation is not occurring in this area.

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

IP2: NL-08-127 Audit Item 36 Perform a one-time inspection and evaluation of a Complete NL-11-101 359 sample of potentially affected IP2 refueling cavity NL-13-122 concrete prior to the period of extended operation.

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

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

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

IP2: NL-08-127 Audit Item 37 Enhance the Containment Inservice Inspection (CII-Complete 361 IWL) Program to include inspections of the NL-13-122 containment using enhanced characterization of IP3:

degradation (i.e., quantifying the dimensions of noted Complete indications through the use of optical aids) during the period of extended operation. The enhancement includes obtaining critical dimensional data of degradation where possible through direct measurement or the use of scaling technologies for photographs, and the use of consistent vantage points for visual inspections.

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/ AUDIT ITEM IP2: NL-08-143 4.2.1 38 For Reactor Vessel Fluence, should future core Complete loading patterns invalidate the basis for the projected NL-13-122 values of RTpts or CVUSE, updated calculations will IP3:

be provided to the NRC.

December 12, 2015 NL-09-079 39 Deleted IP2: NL-09-106 B.1.6 40 Evaluate plant specific and appropriate industry Complete B.1.22 operating experience and incorporate lessons learned NL-13-122 B.1.23 in establishing appropriate monitoring and inspection IP3: B.1.24 frequencies to assess aging effects for the new aging December 12, B.1.25 management programs. Documentation of the 2015 B.1.27 operating experience evaluated for each new program B.1.28 will be available on site for NRC review prior to the B.1.33 period of extended operation.

B.1.37 B.1.38 IP2: NL-11-032 N/A 41 IPEC will inspect steam generators for both units to After the assess the condition of the divider plate assembly.

beginning of the The examination technique used will be capable of PEO and prior to detecting PWSCC in the steam generator divider plate September 28, assembly. The IP2 steam generator divider plate 2023 NL-11-074 inspections will be completed within the first ten years of the period of extended operation (PEO). The IP3 IP3: NL-11-090 steam generator divider plate inspections will be Prior to the end completed within the first refueling outage following of the first NL-11-101 the beginning of the PEO.

refueling outage following the beginning of the PEO.

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/ AUDIT ITEM NL-11-032 N/A 42 IPEC will develop a plan for each unit to address the potential for cracking of the primary to secondary pressure boundary due to PWSCC of tube-to-tubesheet welds using one of the following two options.

Option 1 (Analysis)

IPEC will perform an analytical evaluation of the steam generator tube-to-tubesheet welds in order to IP2: NL-11-074 establish a technical basis for either determining that Prior to March 2024 NL-11-090 the tubesheet cladding and welds are not susceptible to PWSCC, or redefining the pressure boundary in IP3: Prior to the which the tube-to-tubesheet weld is no longer end of the first NL-11-096 refueling outage included and, therefore, is not required for reactor coolant pressure boundary function. The redefinition following the of the reactor coolant pressure boundary must be beginning of the approved by the NRC as a license amendment PEO.

request.

Option 2 (Inspection) IP2:

Between March IPEC will perform a one-time inspection of a 2020 and March representative number of tube-to-tubesheet welds in 2024 each steam generator to determine if PWSCC cracking is present. If weld cracking is identified: IP3: Prior to the

a. The condition will be resolved through repair end of the first or engineering evaluation to justify continued refueling outage service, as appropriate, and following the beginning of the

b. An ongoing monitoring program will be PEO.

established to perform routine tube-to-tubesheet weld inspections for the remaining life of the steam generators.

IP2: NL-11-032 4.3.3 43 IPEC will review design basis ASME Code Class 1 Complete fatigue evaluations to determine whether the NUREG/CR-6260 locations that have been evaluated IP3: Prior to NL-13-122 for the effects of the reactor coolant environment on December 12, NL-11-101 fatigue usage are the limiting locations for the IP2 and 2015 IP3 configurations. If more limiting locations are identified, the most limiting location will be evaluated for the effects of the reactor coolant environment on fatigue usage.

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

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/ AUDIT ITEM IP2: NL-11-032 N/A 44 IPEC will include written explanation and justification Complete of any user intervention in future evaluations using the NL-11-101 WESTEMS Design CUF module.

IP3: Prior to NL-13-122 December 12, 2015 IP2: NL-11-032 N/A 45 IPEC will not use the NB-3600 option of the Complete WESTEMS program in future design calculations until NL-11-101 the issues identified during the NRC review of the IP3: Prior to NL-13-122 program have been resolved.

December 12, 2015 IP2: NL-11-032 N/A 46 Include in the IP2 ISI Program that IPEC will perform Complete twenty-five volumetric weld metal inspections of NL-11-074 socket welds during each 10-year ISI interval NL-13-122 scheduled as specified by IWB-2412 of the ASME Section XI Code during the period of extended operation.

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

IP2: NL-12-089 N/A 47 IPEC will perform and submit analyses that Prior to demonstrate that the lower support column bodies will August 15, 2014 NL-13-052 maintain their functionality during the period of NL-13-122 extended operation considering the possible loss of IP3: Prior to fracture toughness due to thermal and irradiation December 12, NL-14-067 embrittlement. The analyses will be consistent with 2015 the IP2/IP3 licensing basis. Deleted.

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/ AUDIT ITEM IP2: NL-12-174 N/A 48 Entergy will visually inspect IPEC underground piping Complete within the scope of license renewal and subject to aging management review prior to the period of IP3: Prior to NL-13-122 extended operation and then on a frequency of at December 12, least once every two years during the period of 2015 extended operation. This inspection frequency will be maintained unless the piping is subsequently coated in accordance with the preventive actions specified in NUREG-1801 Section XI.M41 as modified by LR-ISG-2011-03. Visual inspections will be supplemented with surface or volumetric non-destructive testing if indications of significant loss of material are observed. Consistent with revised NUREG-1801 Section XI.M41, such adverse indications will be entered into the plant corrective action program for evaluation of extent of condition and for determination of appropriate corrective actions (e.g., increased inspection frequency, repair, replacement).

IP2: NL-13-052 A.2.2.2 49 Recalculate each of the limiting CUFs provided in Complete A.3.2.2 section 4.3 of the LRA for the reactor vessel internals to include the reactor coolant environment effects IP3: Prior to NL-13-122 (Fen) as provided in the IPEC Fatigue Monitoring December 12, Program using NUREG/CR-5704 or NUREG/CR-2015 6909. In accordance with the corrective actions specified in the Fatigue Monitoring Program, corrective actions include further CUF re-analysis, and/or repair or replacement of the affected components prior to the CUFen reaching 1.0.

If the planned replacement of the IP2 split pins IP2: NL-13-122 A.2.1.41 50 will not be accomplished in 2016, provide the Prior to March B.1.42 NRC staff a detailed inspection plan for the IP2 31, 2015 NL-14-067 split pins, including inspection methods, inspection coverage, and inspection frequency, Prior to by March 31, 2015. Replace the IP2 split pins completion of during the 2016 refueling outage (2R22). 2R22 IP3: N/A