NL-18-010, Supplemental Information Regarding the Review of the License Renewal Application

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Supplemental Information Regarding the Review of the License Renewal Application
ML18064A136
Person / Time
Site: Indian Point  Entergy icon.png
Issue date: 02/26/2018
From: Vitale A
Entergy Nuclear Northeast
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
CAC MD5407, CAC MD5408, NL-18-010
Download: ML18064A136 (33)
v • d • e


Text

  • Entergy:

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Entergy Nuclear Northeast Indian Point Energy Center 450 Broadway, GSB P.O. Box 249 Buchanan, NY 10511-0249 Tel (914) 254-6700 Anthony J Vitale Site Vice President NL-18-010 February 26, 2018 U.S. Nuclear Regulatory Commission Document Control Desk 11545 Rockville Pike, TWFN-2 F1 Rockville, MD 20852-2738

SUBJECT:

Supplemental Information Regarding the Review of the Indian Point Nuclear Generating Unit Nos. 2 and 3 License Renewal Application (LRA) (CAC Nos.

MD5407 and MD5408)

Docket Nos. 50-247 and 50-286 Licenses Nos. DPR-26 and DPR-64

REFERENCES:

1) USN RC Letter, "Service Water Integrity Aging Management Program Audit Report for the Indian Point Nuclear Generating Unit Nos. 2 and 3, License Renewal Application (CAC Nos. MD5407 and MD5408)," dated September 20, 2017 (ML17250A244)
2) Entergy Letter, "Supplemental Information Regarding the Service Water Integrity Aging Management Program for the Review of the Indian Point Nuclear Generating Unit Nos. 2 and 3 License Renewal Application (LRA)

(CAC Nos. MD5407 and MD5408)," dated November 8, 2017 (NL-17-127)

3) Entergy Letter, "Supplemental Information Regarding the Review of the Indian Point Nuclear Generating Unit Nos. 2 and 3 License Renewal Application (LRA) (CAC Nos. MD5407 and MD5408)," dated December 21, 2017 (NL-17-161)
4) USNRC Email (W. Burton) to Entergy (M. Mirzai, R. Louie), "Staff Response to Entergy Comments on the Summary of the November and December Telecons and Staff Comments on the Annual Update," dated January 10, 2018
5) Entergy Letter, "Amendment 19 to the License Renewal Application (LRA) for Indian Point Nuclear Generating Unit Nos. 2 and 3," dated December 14, 2017 (NL-17-157)
6) USN RC Letter, "Summary of Telephone Conference Calls Held on November 30, 2017 and December 19, 2017, Between the U.S. Nuclear Regulatory Commission and Entergy Nuclear Operations, Inc., Concerning Requests for Additional Information Pertaining to the Indian Point License Renewal Application (TAC. Nos MD5407 / MD5408," dated January 30, 2018 (ML18002A256)

NL-18-010 Docket Nos. 50-247 and 50-286 Page 2 of 3

Dear Sir or Madam:

From August 1 - 3, 2017, the U.S. Nuclear Regulatory Commission (NRC) staff conducted a supplemental, on-site regulatory audit to .gain a better understanding of Entergy Nuclear Operations, lnc.'s (Entergy) Service Water Integrity Program and recent plant-specific operating experience related to the program. Following completion of the audit, the NRC staff issued an audit repc:irt identifying areas where further clarifying information was warranted related to aging management activities for the service water system (Reference 1).

Entergy provided a response to the audit report on November 8, 2017 (Reference 2). On December 19, 2017, Entergy personnel participated in a conference call with members of the NRC staff to discuss the need for additional clarification of the Entergy responses to audit items 2 and 3 from the report of the August 2017 service water audit. Following the conference call, Entergy provided additional clarification to the responses to audit items 2 and 3 (Reference 3).

On January 11, 2018, at the NRC's request (Reference 4), Entergy personnel participated in a conference call with members of the NRC staff to discuss the schedule for performing volumetric inspection of the underlying steel piping at the location of the external carbon fiber repair on service water pipe weld PAB-204. Clarification of the inspection schedule is provided in Attachment 1.

On the January 11, 2018 call, Entergy and the NRC staff also discussed a need for clarification of information provided in the most recent annual amendment to the IPEC LRA (Reference 5).

Clarifying information regarding the annual amendment is provided in Attachment 1.

Changes to the LRA sections resulting from the information provided in Attachment 1 are provided in Attachment 2. Conforming changes to the List of Regulatory Commitments are provided in Attachment 3.

If you have any questions, or require additional information, please contact Mr. Robert Walpole at 914-254-6710.

I declare under penalty of perjury that the foregoing is true and correct. Executed on r- e:'2:> . Zlo , 2018.

Sincerely, A~V/rl

NL-18-010 Docket Nos. 50-247 and 50-286 Page 3 of 3 Attachments: 1. Clarifying Information Regarding the License Renewal Application

2. License Renewal Application Changes as a Result of Clarifying Information
3. License Renewal Application IPEC List of Regulatory Commitments Revision 38 cc: Mr. David C. Lew, Acting Regional Administrator, NRC Region I Mr. William Burton, Senior Project Manager, NRC DLR Mr. Richard V. Guzman, Senior Project Manager, NRC NRR DORL Ms. Bridget Frymire, New York State Department of Public Service Ms. Alicia Barton, President and CEO NYSERDA NRC Resident Inspector's Office

ATTACHMENT 1 to NL-18-010 CLARIFYING INFORMATION REGARDING THE LICENSE RENEWAL APPLICATION Additions are underlined and deletions are lined through.

ENTERGY NUCLEAR OPERATIONS, INC.

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

NL-18-010 Docket Nos. 50-247 and 50-286

  • Attachment 1 Page 1 of 3 Audit Report Item 2 The first topic of discussion during the phone call on January 11, 2018 was Audit Report Item 2, specifically the timing for the volumetric inspection of the underlying steel piping at the location of the external carbon fiber repair on service water pipe weld PAB-204. The following is a revised response to Audit Report Item 2 that clarifies that the piping will be inspected in 2021.

NRC AUDIT REPORT ITEM 2 Installation of External Carbon Fiber Repair on Service Water Pipe Weld PAB-204. The staff reviewed engineering change (EC) 61654 'and noted that the repair of the non-safety-related pipe was "designed to act as the original piping should the weld fail and structural integrity compromised." The EC specified that the installation include: (a) seven layers of wrap, (b) a 6 inch overlap, and (c) a minimum total wrap length of 6 feet upstream and downstream of the weld. The staff reviewed WO 00404774-01 and noted that, except for the specified overlap at the elbow, all installation parameters were met. For the overlap at the elbow, the staff reviewed ECN 72788 for allowing the field to fit up the carbon fiber wrap with additional layers to compensate for the inability to uniformly obtain a 6 inch overlap.

Because the credited piping material changed from carbon steel to a nonmetallic composite, Entergy may need to address different aging effects with different inspection requirements. In addition Entergy may need alternate inspection techniques, because the inability to detect leakage through the composite material may not allow the detection of ongoing internal corrosion at locations where structural integrity is needed at the carbon steel-to-nonmetallic composite interface. To address the issues introduced by this repair, the staff needs additional information regarding: a) the aging effects that need to be managed for the nonmetallic composite ~aterial (with associated aging management program, if applicable) and b) confirmation that degradation of cement-lined service water piping has not occurred at locations other than at welds (e.g. mid-span between-welds) such that alternate inspection requirements would be needed to confirm the structural integrity near the carbon steel to nonmetallic composite interface locations.

RESPONSE

A section of IP3 24-inch diameter service water return piping, including an elbow, was overlaid with carbon fiber-reinforced epoxy at elevation 41 feet in the primary auxiliary building due to corrosion adjacent to the downstream elbow to pipe weld. The carbon fiber-reinforced epoxy overlay provides strength and design characteristics equivalent to the original piping. The piping was prepared prior to application to ensure that the carbon fiber-reinforced epoxy material properly adheres to the pipe.

Aging effects that could occur for the carbon fiber-'reinforced epoxy were evaluated.

The carbon fiber-reinforced epoxy material is a bidirectional carbon fiber fabric saturated with epoxy resin. Because the internal surface of the carbon fiber-reinforced epoxy coating is tightly adhered to the carbon steel surface of the piping, no aging effects requiring management could occur without a through-wall leak in the underlying carbon steel piping. The minimum wall thickness of the piping was 0.121 inches in January, 2015, after approximately 40 years of

NL-18-010 Docket Nos. 50-247 and 50-286 Attachment 1 Page 2 of 3 operation. This corresponds to a corrosion rate of approximately 0.006 inches per year. At IP3, the assumed service water piping corrosion rate is 0.012 inches per year. Using a corrosion rate of just less than 0.012 inches per year instead of the calculated corrosion rate, localized corrosion would not be through-wall by April 30, 2025. As discussed in Reference 5, Entergy has filed an amendment to the IPEC License Renewal Application (LRA) changing the end date of the proposed term of the renewed license for IP3 to April 30, 2025. Based on this, the internal surface of the carbon fiber-reinforced epoxy is not expected to be in contact with raw water prior to the end of the renewed license term. Entergy will perform a volumetric examination at the location identified with the minimum wall thickness in ~2015 to confirm that the carbon steel piping is not degrading at a rate that will result in exposure of the internal surface of the carbon fiber-reinforced epoxy to raw water prior to the end of the renewed license term. The volumetric examination will be performed_prior to 12/31/21 in 2021. Therefore, a line item with an internal environment for the carbon fiber-reinforced epoxy is not necessary in revised LRA Table 3.3.2-2-IP3.

The external surface of the carbon fiber-reinforced epoxy is exposed to a cool indoor air environment with low light exposure, conditions that minimize the potential for aging effects due to temperature or ultraviolet light. In addition, the raw discharge water (service water) flowing through the piping is heated from the numerous loads that it cools, thereby reducing the potential for condensation. Although aging effects would be minimized due to these operating conditions, operating experience relative to long-term aging effects of carbon fiber-reinforced epoxy installations at nuclear plants is limited. As a result, aging effects will conservatively be identified for the carbon fiber-reinforced epoxy. Since the carbon fiber-reinforced epoxy entails fibrous material similar to fiberglass and both utilize epoxy, aging effects applicable to fiberglass are deemed potential aging effects. Cracking, blistering, and loss of material are conservatively identified as aging effects for the carbon fiber-reinforced epoxy external surface. Visual inspection performed in accordance with the Periodic Surveillance and Preventive Maintenance Program will manage these aging effects.

Entergy reviewed relevant OE of the service water system for the period of 2004-2016 and did not find relevant examples of leakage of the concrete lined piping at locations "mid-span" of the carbon steel welds. Therefore, no alternate inspection requirements are needed to confirm structural integrity near the carbon steel to nonmetallic composite interface locations.

The LRA is revised as shown in Attachment 2 with additions underlined and deletions lined through.

NL-18-010 Docket Nos. 50-247 and 50-286 Attachment 1 Page 3 of 3 Annual Update Amendment In Reference 5 it was documented that an engineering change at IPEC necessitated a change to LRA Table 3.3.2-19-4-IP2 to reflect the addition of long-radius coated elbows on the steam jet air ejectors. During the call on January 11, 2018. additional infor.mation was requested on the coating and the credited aging management program.

The elbows affected by the change are on the first stage of the steam jet air ejectors which are in scope for license renewal under 10CFR54.4(a)(2). The discharge from the steam jet air ejectors exhausts to the condenser and the elbows wopld normally be under a vacuum while in service. The new elbows are coated with a vapor-phase diffused aluminide coating 0.003 -

0.005 inch thickness applied by a gas vapor to the pipe ID. Because the coating is diffused into the parent alloy, it will not spall, peel, or blister in use. Based on this information, loss of coating integrity is not an aging effect requiring management for the elbows. The appropriate program to manage the effects of aging on the elbows is the Flow Accelerated Corrosion (FAC) Program.

The necessary change to LRA Table 3.3.2-19-4-IP2, is shown in Attachment 2.

ATTACHMENT 2 to NL-18-010 LICENSE RENEWAL APPLICATION CHANGES AS A RESULT OF CLARIFYING INFORMATION Additions are underlined and deletions are lined through.

'-

ENTERGY NUCLEAR OPERATIONS, INC.

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

NL-18-010 Docket Nos. 50-247 and 50-286 Attachment 2 Page 1 of 2 8.1.29 PERIODIC SURVEILLANCE AND PREVENTIVE MAINTENANCE Program Description The Periodic Surveillance and Preventive Maintenance Program is an existing program that includes periodic inspections and tests that manage aging effects not managed by other aging management programs. In addition to specific activities in the plant's preventive maintenance program and surveillance program, the Periodic Surveillance and Preventive Maintenance Program includes enhancements to add new activities. The preventive maintenance and surveillance testing activities are generally implemented through repetitive tasks or routine monitoring of plant operations. Credit for program activities has been taken in the aging management review of the following systems and structures. All activities are new unless otherwise noted.

Service water system Visually inspect the surface of the carbon fiber-reinforced epoxy overlay on line 405 in the Unit 3 primary auxiliary building to manage cracking, blistering, and loss of material.

The inspection will be performed each operating cycle.

Revise program documents to specify a one-time volumetric examination on line 405 at the location identified with the minimum wall thickness in ~2015 to confirm that the carbon steel piping is not degrading at a rate that will result in exposure of the internal surface of the carbon fiber-reinforced epoxy to raw water prior to the end of the renewed license term. The volumetric examination will be performed_prior to 12131121 in 2021.

The following enhancements will be implemented prior to December 31, 2018.

Attributes Affected Enhancements

1. Scope of Program Program activity guidance documents will
3. Parameters Monitored or be developed or revised as necessary to Inspected assure that the effects of aging will be
4. Detection of Aging Effects managed such that applicable components will continue to perform their intended
6. Acceptance Criteria functions consistent with the current licensing basis through the period of extended operation.

NL-18-010 Docket Nos. 50-247 and 50-286 Attachment 2 Page 2 of 2 Table 3.3.2-19-4 Condensate System Nonsafety-Related Components Potentially Affecting Safety Functions Summary of Aging Management Review Table 3.3.2-19-4-IP2: Condensate System Aging Effect NUREG-Component Intended Aging Management Table 1 Material Environment Requiring 1801 Vol. 2 Notes Type Function Programs Item Management Item Piping Pressure Metal with Steam (int) Loss of coating Goating integFity -- -- F boundary internal integFitymaterial Flow Accelerated aluminide Corrosion coating

ATTACHMENT 3 to NL-18-010 LICENSE RENEWAL APPLICATION IPEC LIST OF REGULATORY COMMITMENTS Rev.38 ENTERGY NUCLEAR OPERATIONS, INC.

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

_,,I NL-18-010 Docket Nos. 50-247 and 50-286 Attachment 3 Page 1 of 22 List of Regulatory Commitments Rev.38 The following table identifies those actions committed to by Entergy in this document.

Changes are shown as strike-through for deletions and underlines for additions.

  1. COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION/

AUDIT ITEM IP2: Complete NL-07-039 A.2.1.1 1 Enhance the Aboveground Steel Tanks Program for 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, city water tank, and fire water tanks once during the first ten years of the period of extended operation.

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

IP2 & IP3: NL-14-147 A.2.1.1 Implement LRA Sections, A.2.1.1, A.3.1.1 and B.1.1, December 31, 2019 A.3.1.1 as shown in NL-14-147.

B.1.1 IP2 & IP3: NL-15-092 A.2.1.1 Implement LRA Sections, A.2.1.1 and B.1.1, as December 31, 2019 B.1.1 shown in NL-15-092 IP2: Complete NL-07-039 A.2.1.2 2 Enhance the Bolting Integrity Program for IP2 and A.3.1.2 IP3 to clarify that actual yield strength is used in IP3: Complete B.1.2 selecting materials for low susceptibility to sec and clarify the prohibition on use of lubricants containing NL-07-153 Audit Items MoS2 for bolting.

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

NL-18-010 Docket Nos. 50-247 and 50-286 Attachment 3 Page 2 of 22

  1. COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION/

AUDIT ITEM IP2: Complete NL-07-039 A.2.1.5 3 Implement the Buried Piping and Tanks Inspection A.3.1.5 Program for IP2 and IP3 as described in LRA IP3: Complete NL-13-122 8.1.6 Section 8.1.6.

NL-07-153 Audit Item This new program will be implemented consistent NL-15-121 173 with the corresponding program described in NUREG-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 8.1.6 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 NL-11-101"-

demonstrated effectiveness.

4 IP2: Complete NL-07-039 A.2.1.8 Enhance the Diesel Fuel Monitoring Program to A.3.1.8 include cleaning and inspection of the IP2 GT-1 gas IP3: Complete NL-13-122 8.1.9 turbine fuel oil storage tanks, IP2 and IP3 EOG fuel NL-07-153 Audit items oil day tanks, IP2 SBC/Appendix R diesel generator NL-15-121 128, 129, fuel oil day tank, and IP3 Appendix R fuel oil storage 132, tank 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 SBC/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 1Omg/1. Water and sediment acceptance criterion will be less than or equal to. 0.05%.

NL-18-010 Docket Nos. 50-247 and 50-286 Attachment 3 Page 3 of 22

  1. COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION/

,J AUDIT ITEM Enhance the Diesel Fuel Monitoring Program to include thickness measurement of the bottom of the following tanks once every ten years. IP2: EOG fuel oil storage tanks, EOG 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: EOG fuel oil day tanks, EOG fuel oil storage tanks, Appendix R fuel oil sto~age 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.

IP2: Complete NL-07-039 A.2.1.10 5 Enhance the External Surfaces Monitoring Program 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 review for license renewal in accordance with 10 CFR 54.4(a)(1) and (a)(3). Inspections shall include areas 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).

NL-18-010 Docket Nos. 50-247 and 50-286 Attachment 3 Page 4 of 22

  1. COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION/

AUDIT ITEM IP2 & IP3: NL-14-147 A.2.1.10 Implement LRA Sections A.2.1.10, A.3.1.1 O and December 31, 2019 A.3.1.10 B.1.11, as shown in NL-14-147.

B.1.11 IP2: Complete NL-07-039 A.2.1.11 6 Enhance the Fatigue Monitoring Program for IP2 to 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 IP3: Complete NL-15-121 and monitoring procedures.

Enhance the Fatigue Monitoring Program for IP3 to include all the transients identified. Assure all fatigue analysis transients are included with the lowest )

  • limiting numbers. Update the number of design transients accumulated to date.

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

Enhance the Fire Protection Program to explicitly NL-15-121 state that the IP2 and IP3 diesel fire pump engine 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 EOG room CO 2 fire suppression system for signs of degradation, such as corrosion and mechanical damage at least once every six months.

NL-18-010 Docket Nos. 50-247 and 50-286 Attachment 3 Page 5 of 22

  1. COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION/

AUDIT ITEM IP2: Complete NL-07-039 A.2.1.13 8 Enhance the Fire Water Program to include A.3.1.13 inspection of IP2 and IP3 hose reels for evidence of NL-13-122 B.1.14 corrosion. Acceptance criteria will be revised to NL-07-153 Audit Items verify no unacceptable signs of degradation.

105, 106 Enhance the Fire Water Program to replace all or NL-08-014 test 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.

IP2 & IP3: NL-14-147 A.2.1.13 Implement LRA Sections, A.2.1.13, A.3.1.13 and December 31, 2019 A.3.1.13 B.1.14, as shown in NL-14-147.

B.1.14 IP2 & IP3: NL-15-019 A.2.1.13 Implement LRA Sections A.2.1.13, A.3.1.13 and December 31, 2019 A.3.1.13 B.1.14, as shown in NL-15-019 B.1.14 IP2 & IP3: NL-15-092 A.2.1.13 Implement LRA Sections A.2.1.13; A.3.1.13 and December 31, 2019 A.3.1.13 B.1.14, as shown in NL-15-092 B.1.14

NL-18-010 Docket Nos. 50-247 and 50-286 Attachment 3 Page 6 of 22

  1. COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION/

AUDIT ITEM IP2 & IP3: NL-16-122 A.2.1.13 Implement LRA Sections A.2.1.13, A.3.1.13 and December 31, 2017 A.3.1.13 B.1.14, as shown in NL-16-122 B.1.14 IP2 & IP3: NL-17-052 A.2.1.13 Implement LRA Sections A.2.1.13, A.3.1.13, and December 31, 2017 A.3.1.13 B.1.14, as shown in NL-17-052 B.1.14 IP2: Complete NL-07-039 A.2.1.15 9 Enhance the Flux Thimble Tube Inspection Program A.3.1.15 for IP2 and IP3 to implement comparisons to wear IP3: Complete NL-13-122 B.1.16 rates identified in WCAP-12866. Include provisions NL-15-121 to compare data to the previous performances and perform evaluations regarding change to test 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-18-010 Docket Nos. 50-247 and 50-286 Attachment 3 Page 7 of 22

  1. COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION/

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

NL-07-153 Audit Item

  • RHR heat exchangers
  • RHR pump seal coolers
  • Non-regenerative heat exchangers
  • Charging pump seal water heat exchangers
  • Charging pump fluid drive coolers
  • Charging pump crankcase oil coolers
  • Spent fuel pit heat exchangers
  • Waste gas compressor heat exchangers
  • 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 NL-09-018 include no indication of tube erosion, vibration wear, corrosion, pitting, fouling, or scaling.

NL-09-056 11 Deleted NL-11-101 IP2: Complete NL-07-039 A.2.1.18 12 Enhance the Masonry Wall Program for IP2 and IP3 A.3.1.18 to specify that the IP1 intake structure is included in IP3: Complete NL-13-122 B.1.19 the program.

NL-18-010 Docket Nos. 50-247 and 50-286 Attachment 3 Page 8 of 22

  1. COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION/

AUDIT ITEM 13 IP2: Complete NL-07-039 A.2.1.19 Enhance the Metal-Enclosed Bus Inspection A.3.1.19 Program for IP2 and IP3 to visually inspect the IP3: Complete NL-13-122 B.1.20 external surface of MEB enclosure assemblies for NL-07-153 Audit Items loss of material at least once every 10 years. The NL-15-121 124, first inspection will occur prior to the period of NL-08-057 133,519 extended operation and 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" I connections for phase bus maintenance and bolted connection maintenance.

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

NL-15-121 15 IP2: Complete NL-07-039 A.2.1.22 Implement the Non-EQ Inaccessible Medium-A.3.1.22 Voltage Cable Program for IP2 and IP3 as described in LRA Section B.1.23. IP3: Complete NL-13-122 B.1.23 NL-07-153 Audit item This new program will be implemented consistent NL-15-121 173 with the corresponding program described in NL-11-032 NUREG-1801 Section XI.E3, Inaccessible Medium-Voltage Cables Not Subject To 10 CFR 50.49 NL-11-096 Environmental Qualification Requirements.

NL-11-101

NL-18-010 Docket Nos. 50-247 and 50-286 Attachment 3 Page 9 of 22

  1. COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION/,

AUDIT ITEM IP2: Complete NL-07-039 A.2.1.23 16 Implement the Non-EQ Instrumentation Circuits Test A.3.1.23 Review Program for IP2 and IP3 as described in IP3: Complete NL-13-122 8.1.24 LRA Section 8.1.24.

NL-07-153 Audit item This new program will be implemented consistent NL-15-121 173 with the corresponding program described in NUREG-1801 Section XI.E2, Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Used in Instrumentation Circuits.

IP2: Complete NL-07-039 A.2.1.24 17 Implement the Non-EQ Insulated Cables and A.3.1.24 Connections Program for IP2 and IP3 as described IP3: Complete NL-13-122 8.1.25 in LRA Section 8.1.25.

' NL-07-153 Audit item This new program will be implemented consistent NL-15-121 173 with the corresponding program described in NUREG-1801 Section XI.E1, Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements.

IP2: Complete NL-07-039 A.2.1.25 18 Enhance the Oil Analysis Program for IP2 to sample A.3.1.25 and analyze lubricating oil used in the S80/Appendix IP3: Complete NL-13-122 8.1.26 R diesel generator consistent with the oil analysis for NL-11-101 other site diesel generators.

NL-15-121 Enhance the Oil Analysis Program for IP2 and IP3 to 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.

NL-18-010 Docket Nos. 50-247 and 50-286 Attachment 3 Page 10 of 22

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

IP3: Complete NL-13-122 B.1.27 This new program will be implemented consistent NL-07-153 Audit item with the corresponding program described in NL-15-121 173 NUREG-1801,Section XI.M32, One-Time Inspection.

IP2: Complete NL-07-039 A.2.1.27 20 Implement the One-Time Inspection - Small Bore A.3.1.27 Piping Program for IP2 and IP3 as described in LRA IP3: Complete NL-13-122 B.1.28 Section B.1.28.

NL-07-153 Audit item This new program will be implemented consistent NL-15-121 173 with the corresponding program described in NUREG-1801,Section XI.M35, One-Time Inspection of ASME Code Class I Small-Bore Piping.

IP2: Complete NL-07-039 A.2.1.28 21 Enhance the Periodic Surveillance and Preventive A.3.1.28 Maintenance Program for IP2 and IP3 as necessary IP3: Complete NL-13-122 B.1;29 to assure that the effects of aging will be managed NL-15-121 such that applicable components will continue to perform their intended functions consistent with the current licensing basis through the period of extended operation.

IP2 & IP3: NL-16-122 A.2.1.28 Implement LRA Sections A.2.1.28, A.3.1.28 and December 31, 2017 A.3.1.28 B.1.29, as shown in NL-16-122 B.1.29 IP2 & IP3: NL-17-052 A.2.1.28 Implement LRA Sections A.2.1.28, A.3.1.28 and December 31, 2017 A.3.1.28 B.1.29, as shown in NL-17-052 B.1.29 IP2 & IP3: NL-17-155 A.2.1.28 Implement LRA Sections A.2.1.28, 1 A.3.1.28 and becember31, 2018 A.3.1.28 B.1.29, as shown in NL-17-155 B.1.29 Implement LR/\ Section 8.1.29 as shown in NL 17  !~ -

llnr, o 1ari.

-* NL 17 161 8.1.29 e - ,--

  • --L~-'"),t r,nAQ

-

IP2 & IP3: NL-18-010 B.1.29 lm12lement LRA Section B.1.29 as shown in NL December 31, 2018 010 1

This section was erroneously identified in NL-17-155

NL-18-010 Docket Nos. 50-247 and 50-286 Attachment 3 Page 11 of 22

  1. - COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION/

AUDIT ITEM IP2: Complete NL-07-039 A.2.1.31 22 Enhance the Reactor Vessel Surveillance Program A.3.1.31 for IP2 and IP3 revising the specimen capsule IP3: Complete NL-13-122 , B.1.32 withdrawal schedules to draw and test a standby NL-15-121 capsule to cover the peak reactor vessel fluence expected through the end of the period of extended operation.

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

IP3: Complete NL-13-122 B.1.33 This new program will be implemented consistent NL-07-153 Audit item with the corresponding program described in NL-15-121 173 NUREG-1801,Section XI.M33 Selective Leaching of Materials.

IP2: Complete NL-07-039 A.2.1.34 24 Enhance the Steam Generator Integrity Program for A.3.1.34 IP2 and IP3 to require that the results of the IP3: Complete NL-13-122 B.1.35 condition monitoring assessment are compared to the operational assessment performed for the prior operating cycle with differences evaluated.

Enhance the Structures Monitoring Program to IP2: Complete NL-07-039 A.2.1.35 25 explicitly specify that the following structures are A.3.1.35 included in the program. IP3: Complete NL-13-122 B.1.36

  • Appendix R diesel generator foundation (IP3) NL-07-153
  • Appendix R diesel generator fuel oil tank vault NL-15-121 Audit items (IP3) 86, 87, 88,
  • Appendix R diesel generator switchgear and NL-08-057 417 enclosure (IP3)
  • condensate storage tanks foundation (IP3)
  • containment access facility and annex (IP3)
  • discharge canal (IP2/3)
  • fire pumphouse (IP2)
  • fire protection pumphouse (IP3)
  • fire water storage tank foundations (IP2/3)
  • gas turbine 1 fuel storage tank foundation
  • maintenance and outage building-elevated passageway (IP2)

NL-18-010 Docket Nos. 50-247 and 50-286 Attachment 3 Page 12 of 22

  1. COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION/

AUDIT ITEM

  • new station security building (IP2)
  • nuclear service building (IP1)
  • primary water storage tank foundation (IP3)
  • refueling water storage tank foundation (IP3)
  • security access and office building (IP3)
  • transformer/switchyard support structures (IP2)
  • waste holdup tank pits (IP2/3) NL-14-146 Enhance the Structures Monitoring Program for IP2 and IP3 to clarify that in addition to structural steel and concrete, the following commodities (including their anchorages) are inspected for each structure as applicable.
  • cable trays and supports
  • concrete portion of reactor vessel supports
  • conduits and supports
  • cranes, rails and girders
  • equipment pads and foundations
  • fire proofing (pyrocrete)
  • jib cranes
  • manholes and duct banks
  • manways, hatches and hatch covers
  • monorails
  • new fuel storage racks
  • 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

NL-18-010 Docket Nos. 50-247 and 50-286 Attachment 3 Page 13 of 22

  1. COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION/

AUDIT ITEM identify cracking and change in material properties and for inspection of aluminum vents and louvers to identify loss of material.

Enhance the Structures Monitoring Program for IP2 and IP3 to perform an engineering evaluation of groundwater samples to assess aggressiveness of groundwater to concrete on a periodic basis (at least NL-08-127 once every five years). IPEC will obtain samples Audit Item from at least 5 wells that are representative of the 360 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 of the water control structure once per 3 years rather than the normal frequency of once per 5 years during the PEO. Audit Item

'

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

NL-11-101

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AUDIT ITEM IP2: Complete NL-07-039 A.2.1.36 26 Implement the Thermal Aging Embrittlement of Cast A.3.1.36 Austenitic Stainless Steel (CASS) Program for IP2 IP3: Complete NL-13-122 8.1.37 and IP3 as described in LRA Section 8.1.37.

NL-07-153 Audit item This new program will be implemented consistent NL-15-121 173 with the corresponding program described in NUREG-1801,Section XI.M12, Thermal Aging Embrittlement of Cast Austenitic Stainless Steel (CASS) Program.

IP2: Complete NL-07-039 A.2.1.37 27 Implement the Thermal Aging and Neutron A.3.1.37 Irradiation Embrittlement of Cast Austenitic Stainless IP3: Complete NL-13-122 8.1.38 Steel (CASS) Program for IP2 and IP3 as described NL-07-153 Audit item iri LRA Section 8.1.38.

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: Complete NL-07-039 A.2.1.39 28 Enhance the Water Chemistry Control - Closed A.3.1.39 Cooling Water Program to maintain water chemistry IP3: Complete NL-13-122 8.1.40 of the IP2 SBC/Appendix R diesel generator cooling NL-08-057 Audit item system per EPRI guidelines.

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: Complete NL-07-039 A.2.1.40 29 Enhance the Water Chemistry Control - Primary and 8.1.41

?econdary Program for IP2 to test sulfates monthly NL-13-122 in the RWST with a limit of <150 ppb.

IP2: Complete NL-07-039 A.2.1.41 30 For aging management of the reactor vessel A.3.1.41 internals, IPEC will (1) participate in the industry IP3: Complete NL-13-122 programs for investigating and managing aging effects on reactor internals; (2) evaluate and implement the .results of 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 NL-11-107 operation, submit an inspection plan for reactor internals to the NRC for review and approval.

NL-18-010 Docket Nos. 50-247 and 50-286 Attachment 3 Page 15 of 22

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AUDIT ITEM IP2: Complete NL-07-039 A.2.2.1.2 31 Additional P-T curves will be submitted as required A.3.2.1.2 per 10 CFR 50, Appendix G prior to the period of IP3: Complete NL-13-122 4.2.3 extended operation as part of the Reactor Vessel NL-15-121 Surveillance Program.

As required by 10 CFR 50.61(b)(4), IP3 will submit a IP3: NL-07-039 A.3.2.1.4 32 plant-specific safety analysis for plate 82803-3 to the ~pproximately 6 NL-07-140 4.2.5 NRC three years prior to reaching the RT PTs years after entering NL-08-014 screening criterion. Alternatively, the site may lhe PEO NL-08-127 choose to implement the revised PTS rule when approved.

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AUDIT ITEM 33 IP2: Complete NL-07-039 A.2.2.2.3 At least 2 years prior to entering the period of extended operation, for the locations identified in A.3.2.2.3 IP3: Complete NL-13-122 4.3.3 LRA Table 4.3-13 (IP2) and LRA Table 4.3-14 (IP3),

NL-07-153 Audit item under the Fatigue Monitoring Program, IP2 and IP3 will implement one or more of the following: 146 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 NRG-approved version of the ASME code or NRG-approved alternative (e.g., NRG-approved code case) may be performed to determine a valid CUF.

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

34 Complete NL-13-122 2.1.1.3.5 IP2 SBO / Appendix R diesel generator will be NL-07-078 installed and operational by April 30, 2008. This 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 required. NL-11-101

NL-18-010 Docket Nos. 50-247 and 50-286 Attachment 3 Page 17 of 22

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AUDIT ITEM 35 IP2: Complete NL-08-127 Audit Item Perform a one-time inspection of representative sample area of IP2 containment liner affected by the 27 NL-13-122 1973 event behind the insulation, prior to entering the period of extended operation, to assure liner IP3: Complete degradation is not occurring in this area.

NL-11-101 Perform a one-time inspection of representative NL-15-121 sample area of the IP3 containment steel liner at the 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.

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

37 IP2: Complete NL-08-127 Audit Item Enhance the Containment lnservice Inspection (CII-IWL) Program to include inspections of the 361 IP3: Complete NL-13-122 containment using enhanced characterization of degradation (i.e., quantifying the dimensions of noted 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.

  • NL-18-010 Docket Nos. 50-247 and 50-286 Attachment 3 Page 18 of 22
  1. COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION/

AUDIT ITEM IP2: Complete NL-08-143 4.2.1 38 For Reactor Vessel Fluence, should future core loading patterns invalidate the basis for the projected IP3: Complete NL-13-122 values of RTpts or CvUSE, updated calculations will NL-15-121 be provided to the NRC.

NL-09-079 39 Deleted IP2: Complete NL-09-106 B.1.6 40 Evaluate plant specific and appropriate industry B.1.22 operating experience and incorporate lessons IP3: Complete NL-13-122 B.1.23 learned in establishing appropriate monitoring and NL-15-121 B.1.24 inspect(on frequencies to assess aging effects for the B.1.25 new aging management programs. Documentation B.1.27 of the operating experience evaluated for each new B.1.28 program will be available on site for NRC review B.1.33 prior to the period of extended operation.

B.1.37 B.1.38 NL-17-005 N/A 41 Deleted

NL-18-010 Docket Nos. 50-247 and 50-286 Attachment 3 Page 19 of 22

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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: Complete NL-11-074 establish a technical basis for either determining that IP3: Complete NL-11-090 the tubesheet cladding and welds are not susceptible to PWSCC, or redefining the pressure boundary in NL-11-096 which the tube-to-tubesheet weld is r:,o longer included and, therefore, is not required for reactor IP2: NL-17-005 coolant pressure boundary function. The redefinition Not Applicable of the reactor coolant pressure boundary must be approved by the NRG as a license amendment IP3: Not Applicable request.

Option 2 (Inspection)

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

a. The condition will be resolved through repai~

or engineering evaluation to justify continued service, as appropriate, and

b. An ongoing monitoring program will be established to perform routine tube-to-tubesheet weld inspections for the remaining life of the steam generators.

NL-18-010 Docket Nos. 50-247 and 50-286 Attachment 3 Page 20 of 22

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AUDIT ITEM IP2: Complete NL-11-032 4.3.3 43 IPEC will review design basis ASME Code Class 1 fatigue evaluations to determine whether the IP3: Complete NUREG/CR-6260 locations that have been NL-13-122 evaluated for the effects of the reactor coolant NL-'11-101 environment on fatigue usage are the limiting

' NL-15-121 locations for the IP2 and 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.

IP2: Complete NL-11--032 N/A 44 JPEC will include written explanation and justification of any user intervention in future evaluations using IP3: Complete NL-11-101 the WESTEMS "Design CUF" module.

NL-13-'122 NL-15-121 IP2: Complete NL-11-032 N/A 45 IPEC will not use the NB-3600 option of the WESTEMS program in future design calculations IP3: Complete NL-11-101 until the issues identified during the NRC review of NL-13-122 the program have been resolved.

NL-15-121 IP2: Complete NL-11-032 N/A 46 Include in the IP2 ISi Program that IPEC will perform 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.

47 Deleted. NL-14-093 N/A

NL-18-010 Docket Nos. 50-247 and 50-286 Attachment 3 Page 21 of 22

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AUDIT ITEM 48 Entergy ,will visually inspect IPEC underground IP2: Complete NL-12-174 NIA piping within the scope of license renewal and IP3: Complete subject to aging management review prior to the NL-13-122 period of extended operation and then on a NL-15-121 frequency of at least once every two years during the period of 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: Complete NL-13-052 A.2.2.2 49 Recalculate each of the limiting CUFs provided in A.3.2.2 section 4.3 of the LRA for the reactor vessel internals IP3: Complete to include the reactor coolant environment effects NL-13-122 (Fen) as provided in the IPEC Fatigue Monitoring NL-15-121 Program using NUREG/CR-5704 or NUREG/CR-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 CU Fen reaching 1.0.

Replace the IP2 split pins during the 2016 IP2: Complete NL-13-122 A.2.1.41 50 refueling outage (2R22). B.1.42 IP3: N/A NL-14-067 IP2 & IP3: NL-14-147 A.2.1.33 51 Enhance the Service Water Integrity Program by December 31, 2017 A.3.1.33 implementing LRA Sections A.2.1.33, A.3.1.33 and B.1.34 B.1.34, as shown in NL-14-147.

IP2 & IP3: NL-16-122 A.2.1.33 Implement LRA Sections A.2.1.33, A.3.1.33 and December 31, 2017 A.3.1.33 B.1.34, as shown in NL-16-122 B.1.34

NL-18-010 Docket Nos. 50-247 and 50-286 Attachment 3 Page 22 of 22

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AUDIT ITEM IP2 & IP3: NL-17-052 A.2.1.33 Implement LRA Sections A.2.1.33, A.3.1.33 and December 31, 2017 A.3.1.33 B.1.34, as shown in NL-17-052 B.1.34 IP2 & IP3: NL-17-155 A.2.1.33 Implement LRA Sections A.2.1.33, A.3.1.33 and December 31, 2018 A.3.1.33 B.1.34, as shownrin NL-17-155 B.1.34 IP2 & IP3: NL-17-161 A.2.1.33 Implement LRA Sections A.2.1.33, A.3.1.33 and December 31, 2018 A.3.1.33 B.1.34, as shown in NL-17-161 B.1.34 IP2 & IP3: NL-15-019 A.2.1.42 52 Implement the Coating Integrity Program for IP2 and December 31, 2024 A.3.1.42 IP3 as described in LRA Section B.1.42, as shown in B.1.43 NL-15-019.

May 31, 2018 NL-17-053 A.2.1.2 53 Revise Bolting Integrity Program to include visual A.3.1.2 inspection of a representative sample of closure B.1.2 bolting (bolt heads, nuts, and threads) from components with an internal environment of a clear gas, such as air or nitrogen. A representative sample will be 20 percent of the population (for each bolting material and environment combination) up to a maximum of 25 fasteners during each 10-year period of the period of extended operation. The inspections will be performed when the bolting is removed to the extent that the bolting threads and bolt heads are accessible for inspections that cannot be performed during visual inspection with the threaded fastener installed.

Enhance the Steam Generator Integrity Program as December 31, 2017 NL-17-060 A.2.1.34 54 follows. A.3.1.34 B.1.35

  • Revise applicable procedures to specify a general visual inspection of the steam generator channel head.

Revise the Buried Piping and Tanks Inspection December 31, 2017 NL-17-084 A.2.1.5 55 Program for IP2 and IP3 to incorporate the changes A.3.1.5 shown in LRA Sections A.2.1.5 and A.3.1.5 in letter NL-17-084.

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