NL-08-0991, License Renewal - LRA Annual Update, LRA Amendment 2, and Updated Future Action Commitment List

License Renewal - LRA Annual Update, LRA Amendment 2, and Updated Future Action Commitment List

ML081930741
Person / Time
Site:	Vogtle
Issue date:	06/26/2008
From:	Tynan T Southern Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NL-08-0991
Download: ML081930741 (26)

Text

Tom Tynan Southern Nuclear Vice President - Vogtle Operating Company, Inc.

7821 River Road Waynesboro, Georgia 30830 Tel 7068263151 Fax 706.8263321 June 26, 2008 SOUTHERN COMPANY A.

Energy to Serve fOur Wo rId SM Docket Nos.: 50-424 NL-08-0991 50-425 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Vogtle Electric Generating Plant License Renewal - LRA Annual Update, LRA Amendment 2, and Updated Future Action Commitment List Ladies and Gentlemen:

By letter dated June 27, 2007, Southern Nuclear Operating Company (SNC) submitted a License Renewal Application (LRA) for Vogtle Electric Generating Plant (VEGP) Units 1 and 2, seeking to extend the terms of the operating licenses an additional 20 years beyond the current expiration dates. Amendment 1 to the LRA was provided by letter dated March 20, 2008.

During Nuclear Regulatory Commission (NRC) review of the LRA, SNC is required by 10 CFR 54.21 (b) to report changes to the VEGP current licensing basis that materially affect the contents of the LRA, including the Updated Final Safety Analysis Report supplement. SNC has completed a review of the pertinent documentation and identified the following changes, which materially affect the contents of the VEGP LRA:

• Implementation of Measurement Uncertainty Recapture (MUR) Power Uprate

• Installation of full structural weld overlays on the Unit 1 pressurizer spray nozzle, pressurizer safety and relief nozzles, and the pressurizer surge nozzle MUR Power Uprate has also been the subject of recent Requests for Additional Information (RAls) by the NRC staff. Enclosure 1 of this letter describes the LRA changes made necessary by both the annual update and the RAI responses.

Other LRA changes are necessary as a result of additional RAI responses.

These amendments are also described in Enclosure 1.

U. S. Nuclear Regulatory Commission NL-08-0991 Page 2 SNC's responses to RAls also resulted in changes to the VEGP License Renewal Commitment List. Enclosure 2 is the updated VEGP License Renewal Future Action Commitment List.

Mr. T. E. Tynan states he is a Vice President of Southern Nuclear Operating Company, is authorized to execute this oath on behalf of Southern Nuclear Operating Company and to the best of his knowledge and belief, the facts set forth in this letter are true.

The NRC commitments contained in this letter are provided in Enclosure 2, Updated VEGP License Renewal Future Action Commitment List.

Respectfully submitted, SOUTHERN NUCLEAR OPERATING COMPANY

?f.'1~

T. E. Tynan Vice President - Vogtle Sworn to and subscribed before me this & day of qUn1L. ,2008.

cJwn40-0~~

NOJary Public .

Notary Public, 8ur:~a County, Georgia

" . Uy Commission Expires January 13. 2012 My commission expires: _

TET/JAM/daj

Enclosures:

1. VEGP License Renewal Application Amendment 2

2. VEGP License Renewal Future Action Commitment List cc: Southern Nuclear Operating Company Mr. J. T. Gasser, Executive Vice President wlo Enclosure Mr. D. H. Jones, Vice President - Engineering wlo Enclosure Mr. M. J. Ajluni, Manager, Nuclear Licensing wi Enclosure Mr. N. J. Stringfellow, Licensing Supervisor, Vogtle wi Enclosure RType: CVC7000 U. S. Nuclear RegUlatory Commission Mr. L. A. Reyes, Regional Administrator wi Enclosure Mr. R. A. Jervey, I\JRR Project Manager - Vogtle wi Enclosure Mr. G. J. McCoy, Senior Resident Inspector - Vogtle wi Enclosure State of Georgia Mr. N. Holcomb, Commissioner - Department of Natural Resources wlo Enclosure

Enclosure 1 NL-08-0991 Vogtle Electric Generating Plant Units 1 and 2 Application for License Renewal - Amendment 2 Changes Resulting from Annual Update and RAI Responses RAI The previously submitted license amendment in response to RAI 4.3-2 is revised as 4.3-2 follows:

Section 4.3.1.5.3, page 4.3-6 nd Make the following changes in the 2 paragraph:

• Change "0.12127" to "0.11344" in the last sentence.

Table 4.3.1-3, page 4.3-19 Make the following changes in the line for the "Surge line hot leg nozzle" in the "Final Analysis Using Projected CUF Calculated by FatiguePro" portion of the table:

• Change "0.12127" to "0.11344" under Calculated EAF.

Audit The previously submitted license amendment in response to Audit Question 4.3-12 is Question revised as follows:

4.3-12 Replace the last two paragraphs of the previous revision to Section 4.3.1 .7 with the following:

Therefore, if the usage factor calculated for the nozzle subjected to operating transients is less than the design usage factor, it may be concluded that the adjacent class 1 auxiliary piping components' usage factors would be less than their design usage factors if evaluated for the same operating transients.

Therefore, the existing HELB analyses for CVCS piping remain valid as long as the Fatigue Monitoring Program maintains the CUF of the charging nozzles less than or equal to 1.0 (see Section 4.3.1.5.4).

In summary, the existing VEGP HELB analyses have been shown to remain valid for the period of extended operation, except for the VEGP HELB analysis for CVCS piping which is maintained valid by the Fatigue Monitoring Program.

Therefore, this TLAA has been demonstrated to be acceptable for the period of extended operation in accordance with 10 CFR 54.21 (c)(1 )(i) and 10 CFR 54.21 (c)(1 )(iii).

Section A.3.2.1, page A-28 Replace the first paragraph of the revision to Section A.3.2.1 , on Page A-28, to say the following:

The existing VEGP HELB analyses have been shown to remain valid for the period of extended operation as long as the Fatigue Monitoring Program maintains the CUF of the charging nozzles less than or equal to 1.0. Therefore, this TLAA has been demonstrated to be acceptable for the period of extended operation in accordance with 10 CFR 54.21 (c)(1 )(i) and 10 CFR 54.21 (c)(1 )(iii).

I

Enclosure 1 Nl-08-0991 Vogtle Electric Generating Plant Units 1 and 2 Application for License Renewal - Amendment 2 Changes Resulting from Annual Update and RAI Responses RAI s Section 1.4, page 1.4-1 4.2.1-04, Replace the second paragraph with the following:

4.2.1-05, The nuclear steam supply system (NSSS) for each of the VEGP units is a and pressurized water reactor designed and supplied by Westinghouse Electric 8.3.25 Corporation with a licensed net core power output of 3625.6 MWt. Turbine generator output is approximately 1249.8 MWe.

and Annual Update Section 4.3.1.6, page 4.3-9 Replace the first paragraph with the following:

Full structural weld overlays have been installed on the Unit 1 and Unit 2 pressurizer spray nozzle, pressurizer safety and relief nozzles, and the pressurizer surge nozzle.

Section 4.2, page 4.2-1 Replace the last two paragraphs that begin, "For VEGP, 56 EFPY is sufficient. .." with the following:

For VEGP, 55.3 EFPY is a sufficient (and conservative) basis to cover the current term and the period of extended operation. This equates to operating at greater than 99% capacity factor between 26 day outages every 18 months for the remainder of plant life (60 years). The End-at-Life (EOl) basis for the Reactor Vessel Neutron Embrittlement analyses results in the following sections is 57 EFPY at the pre-MUR Uprate VEGP licensed power level. SNC has received a VEGP license amendment for a Measurement Uncertainty Recapture (MUR) Uprate. The MUR Uprate increases the VEGP licensed power level approximately 1.7%. The chan~e was implemented on Unit 1 during the 2008 spring outage that ended April 24' and will be implemented on Unit 2 later in 2008. The impact of approval of the MUR Uprate on the Reactor Vessel Neutron Embrittlement analyses results for each unit is that the VEGP EOl basis for the analyses in lRA Section 4.2 becomes 56.3 EFPY at the MUR Uprate power level. In summary, the results for the Reactor Vessel Neutron Embrittlement analyses bound the projected 55.3 EFPY at EOl for an operating term of 60 years.

19 The 60-year capsule has been analyzed for Unit 1 with a fluence of 3.53 x 10 n/cm 2 19 2 (E>1.0MeV), which exceeds the 3.20 x 10 n/cm (E>1.0MeV) fluence value in Table 19 4.2.1-1. However, for Unit 2, the 60-year capsule only has a fluence of 2.98 x 10 2

n/cm (E>1.0MeV), which is equivalent to 55.5 EFPY. For Unit 2, the applicability of the resultant curves and analyses in Section 4.2 is restricted to the limiting EFPY for the capsule data (55.5 EFPY). Operation above that fluence would require an update of the evaluation in accordance with Appendix G rules.

The calculations have been updated to address both the additional 20 years of operation and the MUR Uprate and they are addressed in the following sections:

Section 4.2.1, page 4.2-2 Replace the last two paragraphs with the following:

Table 4.2.1-1 summarizes the Unit 1 and 2 beltline peak fluence values for EOl at the inner wall (surface), 1/4T and 3/4T locations (Ref. 4) for 57 EFPY before MUR Uprate or for 56.3 EFPY after MUR Uprate.

2

Enclosure 1 Nl-08-0991 Vogtle Electric Generating Plant Units 1 and 2 Application for License Renewal - Amendment 2 Changes Resulting from Annual Update and RAI Responses Table 4.2.1-2 summarizes the Unit 1 and 2 extended beltline peak fluence values for EOl at the inner wall (surface), 1/4T and 3/4T locations for 57 EFPY before MUR Uprate or for 56.3 EFPY after MUR Uprate. The fluence analysis of the I upper shell and nozzles determined that these additional materials will exceed the 1x1 017 n/cm 2 (E>1.0 MeV) threshold.

RAI s Section 4.2.2, page 4.2-3 rd 4.2.1-04, Add the following as a 3 paragraph:

4.2.1-05, The calculations discussed above were performed before MUR Uprate assuming a and conservative EOl of 57 EFPY. Implementation of the MUR Uprate reduces the EOl assumed in the calculations discussed above from 57 EFPY to 56.3 EFPY. Current B.3.25 projections indicate that actual EOl will be no more than 55.3 EFPY.

and Annual Table 4.2.2-1, page 4.2-4 Update Change the Table title to "VEGP Unit 1 Predicted EOl USE Calculations For all the Beltline Region Materials For License Renewal c" Table 4.2.2-1, page 4.2-5 Add the following as Note C at the bottom of the table:

(C) Values calculated for 57EFPY Pre-MUR Uprate/56.3 EFPY with MUR Uprate.

Actual EOl is projected to be 55.3 EFPY.

Table 4.2.2-2, page 4.2-6 Change the Table title to "VEGP Unit 2 Predicted EOl USE Calculations For all the Beltline Region Materials For License Renewal c" Table 4.2.2-2, page 4.2-7 Add the following as Note C at the bottom of the table:

(C) Values calculated for 57EFPY Pre-MUR Uprate/56.3 EFPY with MUR Uprate.

Actual EOl is projected to be 55.3 EFPY.

Section 4.2.3, page 4.2-8 rd Add the following as a 3 paragraph:

The calculations discussed above were performed before MUR Uprate assuming a conservative EOl of 57 EFPY. Implementation of the MUR Uprate reduces the EOl assumed in the calculations discussed above from 57 EFPY to 56.3 EFPY. Current projections indicate that actual EOl will be no more than 55.3 EFPY. For comparison with the MUR Uprate WCAP-16736-P, Tables 4.2.3-3 and 4.2.3-4 are included to show the RpTS values for the beltline materials on each unit at 57 EFPY after MUR 19 2 Uprate. The fluence used in Table 4.2.3-3 is 3.24 x 10 n/cm (MeV> 1.0). The 19 2 fluence used in Table 4.2.3-4 is 3.06 x 10 n/cm (MeV> 1.0).

Table 4.2.3-1, page 4.2-10 Change Note A at the bottom of the table to read:

(A) EOl Fluence (at the end of the period of extended operation) is conservatively assumed to be 3.20x1 019n/cm2 E > 1.0 MeV for the beltline region and 17 8.92x1 0 n/cm2 E>1.0 MeV forthe extended beltline region. This EOl fluence is equivalent to 57 EFPY without MUR Uprate or 56.3 EFPY with MUR Uprate. Actual EOl fluence is projected to be equivalent to no more than 55.3 EFPY.

3

Enclosure 1 NL-08-0991 Vogtle Electric Generating Plant Units 1 and 2 Application for License Renewal - Amendment 2 Changes Resulting from Annual Update and RAI Responses RAI s Table 4.2.3-2, page 4.2-12 4.2.1-04, 4.2.1-05, Change Note A at the bottom of the table to read:

and (A) EOL Fluence (at the end of the period of extended operation) is conservatively assumed to be 3.02x1 019n/cm2 E > 1.0 MeV for the beltline region and B.3.25 7.61 x1 017 n/cm2 E>1.0 MeV for the extended beltline region. This EOL fluence is and equivalent to 57 EFPY without MUR Uprate or 56.3 EFPY with MUR Uprate.

Actual EOL fluence is projected to be equivalent to no more than 55.3 EFPY.

Annual Update Section 4.2.4, page 4.2-13 Add the following to the end of the section as a new paragraph:

The calculations discussed above were performed before MUR Uprate assuming a conservative EOL of 57 EFPY. Implementation of the MUR Uprate reduces the EOL assumed in the calculations discussed above from 57 EFPY to 56.3 EFPY. Current projections indicate that actual EOL will be no more than 55.3 EFPY.

Tables 4.2.3-3 and 4.2.3-4, page 4.2-13 Add Tables 4.2.3-3 and 4.2.3-4 as shown in the attachment after Table 4.2.3-2.

Section 4.2.4, page 4.2-13 Add the following to the end of the section as a new paragraph:

The calculations discussed above were performed before MUR Uprate assuming a conservative EOL of 57 EFPY. Implementation of the MUR Uprate reduces the EOL assumed in the calculations discussed above from 57 EFPY to 56.3 EFPY. Current projections indicate that actual EOL will be no more than 55.3 EFPY.

I 4

Attachment 1 NL-08-0991 Vogtle Electric Generating Plant Units 1 and 2 Application for License Renewal - Attachment to Amendment 2 Changes Resulting from Annual Update and RAI Responses Table 4.2.3-3 VEGP Unit 1 Values of RTPTS at 57 EFPY after MUR Uprate.w Unit 1 Material RG 1.99 R2 CF FF.lID. aRTPTSfS:d IRT NDTIUI!Ql MarginLfl RT PTSLEl Method (OF) (OF) (OF) (OF)

(OF)

Intermediate Shell Plate 103.5 Position 1.1 53.1 1.309 69.5 0 34 88805-1 Intermediate Shell Plate 123.5 Position 1.1 53.1 1.309 69.5 20 34 88805-2 Position 1.1 38.4 1.309 50.3 30 34 114.3 Intermediate Shell Plate 88805-3 Position 2.1 37.8 1.309 49.5 30 34fill 113.5 Lower Shell Plate 88606-1 Position 1.1 32.8 1.309 42.9 20 34 96.9 Lower Shell Plate 88606-2 Position 1.1 35.2 1.309 46.1 20 34 100.1 Lower Shell Plate 88606-3 Position 1.1 41.9 1.309 54.9 10 34 98.9 Position 1.1 34.5 1.309 45.2 -80 45.2 10.4 Inter. Shell Longitudinal Weld Seam 101-124A,8,C Position 2.1 20.8 1.309 27.2 -80 27.2 -25.6 Position 1.1 34.5 1.309 45.2 -80 45.2 10.4 Intermediate to Lower Shell Girth Weld Seam 101-171 Position 2.1 20.8 1.309 27.2 -80 27.2 -25.6 Position 1.1 34.5 1.309 45.2 -80 45.2 10.4 Lower Shell Long. Weld Seams 101-142A,8,C Position 2.1 20.8 1.309 27.2 -80 27.2 -25.6 A. EOl Fluence (at the end of the period of extended operation) is conservatively 19 assumed to be 3.24x10 n/cm 2 (E > 1.0 MeV) for the beltline. This EOl fluence is equivalent to 57 EFPY with MUR Uprate. Actual EOl fluence is projected to be equivalent to no more than 55.3 EFPY.

B. FF = fluence factor = f (0.28 - 0.1 log (f))

C. ~RTpTs = CF

• FF D. Initial RTNOT values are measured values E. M = 2 *( crj 2 + crt,2)1/2 F. RTPTS = RTNOT(U) + ~RT PTS + Margin (OF) 5

Attachment 1 NL-08-0991 Vogtle Electric Generating Plant Units 1 and 2 Application for License Renewal - Attachment to Amendment 2 Changes Resulting from Annual Update and RAI Responses Table 4.2.3-4 VEGP Unit 2 Values of RTpTs at 57 EFPY after MUR Uprate f8l Unit 2 RG 1.99 R2 CF aRTpTS!Ql IRT NDTIUlilll Margin!&). RTPTSiEl.

Material FFiID Method (OF) (OF) (OF) (OF) (OF)

Intermediate Shell Plate Position 1.1 44.0 1.295 57.0 10 34 101.0 R4-1 Intermediate Shell Plate 1.295 Position 1.1 37.0 47.9 10 34 91.9 R4-2 Intermediate Shell Plate 1.295 Position 1.1 31.0 40.1 30 34 104.1 R4-3 Lower Shell Plate B8825-1 Position 1.1 37.0 1.295 47.9 40 34 121.9 Lower Shell Plate R8-1 Position 1.1 44.0 1.295 57.0 40 34 131.0 Position 1.1 31.0 1.295 40.1 50 34 124.1 I Lower Shell Plate B8628-1 Position 2.1 20.4 1.295 26.4 50 17 93.4 Position 1.1 43.3 1.295 56.1 -10 56 102.1 Inter. Shell Longitudinal Weld Seam 101-124A,B,C Position 2.1 21.5 1.295 27.8 -10 27.8 45.6 Position 1.1 43.3 1.295 56.1 -30 56 82.1 Intermediate to Lower Shell Girth Weld Seam 101-171 Position 2.1 21.5 1.295 27.8 -30 27.8 25.6 Position 1.1 43.3 1.295 56.1 -10 56 102.1 Lower Shell Long. Weld Seam 101-142A,B,C Position 2.1 21.5 1.295 27.8 -10 27.8 45.6 G. EOl Fluence (at the end of the period of extended operation) is conservatively assumed to be 3.06x10 19 n/cm 2 (E > 1.0 MeV) for the beltline. This EOl fluence is equivalent to 57 EFPY with MUR Uprate. Actual EOl fluence is projected to be equivalent to no more than 55.3 EFPY.

H. FF = fluence factor = f (0.28 - 0.1 log (I))

I. L\RT PTS = CF

• FF J. Initial RT NOT values are measured values K. M = 2 *(o} + cr~2)1/2 L. RTPTS = RTNOT(U) + L\RTPTS + Margin (OF) 6

Vogtle Electric Generating Plant License Renewal - LRA Annual Update Enclosure 2 Updated Future Action Commitment List Page 1 of 18

NL-08-0991 VEGP License Renewal Future Action Commitment List ITEM UFSAR RELATED SUPPLEMENT LRA NO. COMMITMENT SCHEDULE LOCATION SECTIONS!

REFS 1 Implement the ACCW System Carbon Steel Components Program as described in A.2.1 Prior to the period 8.3.1 VEGP LRA Section 8.3.1. of extended operation 2 Implement the 80lting Integrity Program as described in VEGP LRA Section 8.3.2. A.2.2 Prior to the period 8.3.2 of extended operation 3 Enhance 80ric Acid Corrosion Control Program documents to address the effects A.2.3 Prior to the period 8.3.3 of borated water leakage onto materials other than steels, including electrical of extended components (e.g., electrical connectors), that are susceptible to boric acid operation corrosion.

4 Implement the 8uried Piping and Tanks Inspection Program as described in VEGP A.2.4 Prior to the period 8.3.4 LRA Section 8.3.4. of extended operation 5 Implement the CASS RCS Fitting Evaluation Program as described in VEGP LRA A.2.5 Prior to the period 8.3.5 Section 8.3.5. of extended operation Page 2 of 18

NL-08-0991 VEGP License Renewal Future Action Commitment List ITEM UFSAR RELATED NO. SUPPLEMENT SCHEDULE LRA COMMITMENT LOCATION SECTIONSI REFS 6 Enhance Closed Cooling Water Program documents to indicate the components in A.2.6 Prior to the period B.3.6 each system that are most susceptible to various corrosion mechanisms and to of extended ensure that corrosion monitoring is appropriately accomplished. This qualitative operation assessment will be based on an understanding of corrosion principles associated with closed cooling water chemistries and on review of system, plant, and industry operating experience. Parameters considered in the review will include system flow parameters (focusing on identification of stagnant regions and on intermittently operated systems), normal operating temperatures, and component geometries (e.g. creviced areas).

7 Implement the External Surfaces Monitoring Program as described in VEGP LRA A.2.8 Prior to the period B.3.8 Section B.3.8. of extended operation Page 3 of 18

NL-08-0991 VEGP License Renewal Future Action Commitment List ITEM UFSAR RELATED NO. COMMITMENT SUPPLEMENT SCHEDULE LRA LOCATION SECTIONSI REFS 8 Implement the following enhancements to the Fire Protection Program: A.2.9 Prior to the period B.3.9 of extended

• Wall thickness evaluations will be performed on water suppression piping operation, except systems using non-intrusive volumetric testing or visual inspections to ensure for sprinkler head that wall thicknesses are within acceptable limits. Initial wall thickness replacement or evaluations will be performed before the end of the current operating term.

testing; Subsequent evaluations will be performed at plant specific intervals during the period of extended operation. The plant specific inspection intervals will be determined based on previous evaluations and site operating experience. Sprinkler head

• A sample of sprinkler heads will be inspected using the guidance of NFPA 25 replacement or "Inspection, Testing and Maintenance of Water-Based Fire Protection Systems" testing will be (1998 Edition), Section 2-3.1.1, or NFPA 25 (2002 Edition), Section 5.3.1.1.1. implemented prior Where sprinkler heads have been in service for 50 years, they will be replaced to 50 years from or representative samples from one or more sample areas will be submitted to time system was a recognized testing laboratory for field service testing. This sampling will be placed in service.

performed every 10 years after the initial field service testing. The 50 years of time in service begins when the system was placed in service, not when the plant became operational.

• Fire Protection Program procedures will be revised to provide more detailed instructions for visual inspection of Fire Pump Diesel fuel supply lines for leakage, corrosion, and general degradation while the engine is running during fire suppression system pump tests.

9 Enhance the Flux Thimble Tube Inspection Program by preparing an overall A.2.11 Prior to the period B.3.11 program procedure documenting the Flux Thimble Tube Inspection Program of extended administration and implementing activities credited for license renewal. operation Page 4 of 18

NL-08-0991 VEGP License Renewal Future Action Commitment List ITEM UFSAR RELATED NO. SUPPLEMENT LRA COMMITMENT SCHEDULE LOCATION SECTIONSI REFS 11 Implement the following enhancements to the Generic Letter 89-13 Program: A.2.12 Prior to the period 8.3.12 of extended

• Develop an overall program procedure for the Generic Letter 89-13 Program to operation describe the various program activities that comprise Generic Letter 89-13 Program and their implementing controls such as chemistry procedures, maintenance activities, scheduled surveillances, or other mechanisms.

• Add inspection of the NSCW Transfer Pumps' casings and bolting.

• Add the NSCW Cooling Tower spray nozzles as a specific item to be inspected during the cooling tower inspection.

12 Implement the Nickel Alloy Management Program for Non-Reactor Vessel Closure A.2.14 Program 8.3.14 Head Penetration Locations as described in VEGP LRA Section B.3.14. implementation to The program will be based on the following commitments: be completed prior to the period (1) SNC will continue to participate in industry initiatives directed at resolving of extended PWSCC issues, such as owner's group programs and the Electric Power operation Research Institute Materials Reliability Program. This is an ongoing commitment. Numbered items are implemented (2) SNC will comply with applicable NRC Orders. This is an ongoing commitment. as noted in the (3) SNC will submit a program inspection plan for VEGP that includes item.

implementation of applicable Bulletins, Generic Letters, and staff accepted industry guidance. The inspection plan will also include assessments of each of the ten aging management program elements defined in Section A.1.2.3 of NUREG-1800 Revision 1. The inspection plan will be submitted to the staff for review and approval not less than 24 months prior to entering the period of extended operation for VEGP Units 1 and 2.

Page 5 of 18

NL-08-0991 VEGP License Renewal Future Action Commitment List ITEM UFSAR RELATED NO. SUPPLEMENT LRA COMMITMENT SCHEDULE LOCATION SECTIONSI REFS 13 The Nickel Alloy Management Program for Reactor Vessel Closure Head A.2.15 Ongoing B.3.15 Penetrations will implement commitments for reactor vessel closure head penetrations associated with nickel alloys from:

(1) NRC Orders, Bulletins, and Generic Letters, and; (2) Staff-accepted industry guidelines.

14 Implement the following enhancements to the Oil Analysis Program: A.2.16 Prior to the period B.3.16 of extended

• An overall program procedure or guideline will be prepared to formalize the operation sampling and analysis activities performed.

• Viscosity, relative level of oxidation, and flash point of lubricating oil samples will be determined for components where the lubricating oil is changed based on its analyzed condition (instead of being changed on a regular schedule regardless of condition). The relative level of oxidation of the lubricating oil will be monitored by analysis of the neutralization number or other appropriate parameter(s). Flash point monitoring will be performed for those components which have the potential for contamination of the lubricating oil with a light hydrocarbon such as fuel oil.

• For both components with periodic lubricating oil changes and components where the lubricating oil is changed based on analyzed condition, if a lubricating oil sample exceeds the limits established for the wear metal content screening, the lubricating oil from that component will be subjected to additional testing. The additional testing may include detailed particle counting, elemental analysis, or analytical ferrography as necessary to validate the initial screening results and to diagnose the source of the particUlates.

Page 6 of 18

NL-08-0991 VEGP License Renewal Future Action Commitment List ITEM UFSAR RELATED SUPPLEMENT LRA NO. COMMITMENT SCHEDULE LOCATION SECTIONSI REFS 15 Implement the One-Time Inspection Program as described in VEGP LRA Section A.2.17 Inspections will be 8.3.17 8.3.17. performed within a window of ten years immediately proceeding the period of extended operation.

16 Implement the One-Time Inspection Program for ASME Class 1 Small 80re Piping A.2.18 Inspections will be 8.3.18 as described in VEGP LRA Section 8.3.18. performed within a window of ten years immediately proceeding the period of extended operation.

17 Implement the One-Time Inspection Program for Selective Leaching as described A.2.19 Inspections will be 8.3.19 in VEGP LRA Section 8.3.19. performed within a window of ten years immediately proceeding the period of extended operation.

Page 7 of 18

Enclosure 2 Nl-08-0991 VEGP License Renewal Future Action Commitment List ITEM UFSAR RELATED SUPPLEMENT LRA NO. COMMITMENT SCHEDULE LOCATION SECTIONSI REFS 18 Enhance the Periodic Surveillance and Preventive Maintenance Activities to include A.2.21 Prior to the period 8.3.21 the following: of extended operation

• Steam Generator Blowdown Secondary Sample Bath Shell inspections

• Steam Generator Blowdown Corrosion Product Monitor cooler shell inspections

• Potable Water System water heater housing inspections (for the in-scope water heaters) 19 Implement the Piping and Duct Inspection Program as described in LRA Section A.2.22 Prior to the period B.3.22 B.3.22. of extended operation Page 8 of 18

NL-08-0991 VEGP License Renewal Future Action Commitment List ITEM UFSAR RELATED SUPPLEMENT LRA NO. COMMITMENT SCHEDULE LOCATION SECTIONSI REFS 20 Implement the Reactor Vessel Internals Program as described in LRA Section A.2.24 Program 8.3.24 8.3.24. implementation to be completed The program will be based on the following commitments:

prior to the period (1) SNC will participate in the industry program for investigating and managing of extended aging effects on reactor internals. This is an ongoing commitment. operation; (2) SNC will evaluate and implement the results of the industry programs, such as Numbered items the Electric Power Research Institute Material Reliability Program, as are implemented applicable to the VEGP reactor internals. This commitment will be fully as noted in the implemented prior to the period of extended operation. item.

(3) SNC will submit an inspection plan for the VEGP reactor internals to the NRC for review and approval not less than 24 months before entering the period of extended operation for VEGP Units 1 and 2. This inspection plan will address the bases, inspection methods, and acceptance criteria associated with aging management of the reactor vessel thermal sleeves and the core support lugs (along with the associated support pads and attachment welds).

Page 9 of 18

NL-08-0991 VEGP License Renewal Future Action Commitment List ITEM UFSAR RELATED NO. COMMITMENT SUPPLEMENT SCHEDULE LRA LOCATION SECTIONS!

REFS 21 Implement the following enhancements to the Reactor Vessel Surveillance A.2.25 As noted in the 8.3.25 Program: numbered items (1) Prior to completion of testing of the last surveillance capsule in each unit, action will be taken to ensure that tested and untested specimens from all capsules removed from the VEGP reactor vessels remain in storage.

(2) Alternate dosimetry will be installed to monitor neutron fluence on the reactor vessel after removal of the last surveillance capsule in that unit. This enhancement will be implemented prior to removal of the last surveillance capsule in each unit.

23 Implement the following enhancements to the Structural Monitoring Program: A.2.32 Prior to the period 8.3.32 of extended

• The scope of the Structural Monitoring Program will be expanded to include the operation additional structures that require monitoring for license renewal.

• The scope of inspection for structures that require monitoring for license renewal will be clarified. An area-based inspection will be performed unless a detailed inspection scope is provided.

• The Structural Monitoring Program scope for hangers and supports will be clarified.

• Program requirements will be revised to include periodic ground water monitoring to confirm that groundwater chemistry remains non-aggressive as defined in NUREG 1801.

• Underwater inspection of the NSCW cooling tower basins, including appropriate inspection and acceptance criteria, will be added to the Structural Monitoring Program.

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NL-08-0991 VEGP License Renewal Future Action Commitment List ITEM UFSAR RELATED NO. SUPPLEMENT LRA COMMITMENT SCHEDULE LOCATION SECTIONS!

REFS 24 Enhance the Structural Monitoring Program - Masonry Walls to include monitoring A.2.33 Prior to the period 8.3.33 of masonry walls in the structures that are in scope for license renewal, but are not of extended currently monitored under the program. operation 25 Implement the Non-EO Cables and Connections Program as described in LRA A.2.34 Implement 8.3.34 Section 8.3.34. program and complete first inspection prior to the period of extended operation 26 Implement the Non-EO Inaccessible Medium-Voltage Cables Program as described A.2.35 Implement 8.3.35 in LRA Section 8.3.35. program and complete first inspection prior to the period of extended operation Page 11 of 18

NL-08-0991 VEGP License Renewal Future Action Commitment List ITEM UFSAR RELATED SUPPLEMENT LRA NO. COMMITMENT SCHEDULE LOCATION SECTIONSI REFS 27 Implement the Non-EO Cable Connections One-Time Inspection Program as A.2.36 Inspections will be 8.3.36 described in LRA Section 8.3.36. performed within a window of five years immediately proceeding the period of extended operation.

28 Implement the following enhancements to the Fatigue Monitoring Program: A.2.38 No later than two 8.3.38 years prior to the

• Implementing documents will be revised to address the effect of the full period of structural weld overlays applied to the pressurizer spray and surge nozzles on extended the stress-based module calculation of CUF.

operation

• The VEGP UFSAR will be revised to require fatigue monitoring of the Accumulator/RHR nozzles and pressurizer heater penetrations.

• Implementing documents will be revised to reduce acceptable CUF values to account for environmental fatigue effects for those NUREG-6260 locations monitored for fatigue.

• The implementing procedure for the Fatigue Monitoring Program will be enhanced to explicitly require that the corrective action initiated for exceeding the acceptance criteria of a CUF less than or equal to 1.0 includes a review to identify and assess any additional affected reactor coolant pressure boundary locations.

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NL-08-0991 VEGP License Renewal Future Action Commitment List ITEM UFSAR RELATED SUPPLEMENT LRA NO. COMMITMENT SCHEDULE LOCATION SECTIONS!

REFS 29 To ensure that the fatigue cycle limits are not exceeded, SNC will replace the A.3.2.5 As stated in the 4.3.5 steam generator secondary side handhole bolts after 30 years of service. The commitment B.3.2 hand hole bolts have been previously replaced and are scheduled to be replaced again during the spring outages in 2026 and 2028 for Units 1 and 2, respectively.

Alternatively, a less restrictive replacement schedule may be developed and documented based on potential updated analyses initiated by the Bolting Integrity Program.

30 To ensure that the fatigue cycle limits are not exceeded, SNC will replace the A.3.2.5 As stated in the 4.3.5 steam generator secondary side manway bolts after 30 years of service. The commitment B.3.2 manway bolts have never been replaced and are scheduled for replacement during the spring outages in 2017 and 2019 for Units 1 and 2, respectively.

Alternatively, a less restrictive replacement schedule may be developed and documented based on potential updated analyses initiated by the Bolting Integrity Program.

31 The VEGP Pressure-Temperature Limits Report (for each unit) will be updated to A.3.1.5 Prior to the unit 4.2.5 address neutron embrittlement for a 60-year operating life, including any changes A.3.6.4 entering the 4.7.4 to the cold-overpressure mitigation system setpoints. period of extended operation Page 13 of 18

NL-08-0991 VEGP License Renewal Future Action Commitment List ITEM UFSAR RELATED SUPPLEMENT LRA NO. COMMITMENT SCHEDULE LOCATION SECTIONSI REFS 32 Implement a replacement schedule for the small diameter (::; 2-inch) flexible hoses None Prior to the period described below: of extended operation 2.3.3.25

• Radiation Monitoring System flexible hoses associated with the vent stack radiation monitor sample line.

• Emergency Diesel Generator System flexible hoses associated with the fuel oil 2.3.3.20 supply lines from the fuel oil headers to the fuel injector pumps.

• ACCW System flexible hoses associated with the normal charging pump motor 2.3.3.6 coolers.

2.3.3.20

• Hydrogen Recombiner and Monitoring System flexible hoses associated with the calibration gas and oxygen bottles.

2.3.4.1

• Main Steam System flexible hoses between the ARV hydraulic actuator and the hand pump unit.

2.3.3.23

• Drain System flexible hoses installed on the Containment Bldg Tendon Gallery Sump Pump discharge lines.

2.3.3.19

• Fire Protection System flexible hoses associated with the fire pump diesel fuel oil system.

33 Ensure the fatigue monitoring limits implemented as part of the Fatigue Monitoring A.3.2.1 No later than two 4.3.1.7 Program are adequate to ensure that charging and letdown intermediate break years prior to the location CUF values remain less than 0.1 for 60 years of operation. period of extended operation Page 14 of 18

NL-08-0991 VEGP License Renewal Future Action Commitment List ITEM UFSAR RELATED SUPPLEMENT LRA NO. COMMITMENT SCHEDULE LOCATION SECTIONSI REFS 34 The cranes within the scope of the Overhead and Refueling Crane Inspection A.2.20 Prior to the period B.3.20 Program are routinely inspected; however the existing procedures do not explicitly of extended identify inspection of structural components for excessive wear, corrosion, and operation misalignment in all cases. As a result, SNC will enhance applicable plant procedures to explicitly identify inspection of crane rails and crane structural components for loss of material due to corrosion and wear, and for indication of rail misalignment:

a) Procedure 93246-C "Polar Crane" will be enhanced to include inspection of crane rails and crane structural components (e.g., bridge) for loss of material due to corrosion; inspection of crane rails for loss of material due to wear, and for indication of rail misalignment.

b) Procedure 27315-C "Spent Fuel Cask Crane" will be enhanced to include inspection of crane rails for loss of material due to corrosion.

c) Procedure 27340-C "Refueling Machine" will be enhanced to include inspection of crane rails and crane structural components (e.g., bridge) for loss of material due to corrosion, and for indication of rail misalignment.

d) Procedure 27342-C "Fuel Handling Machine Bridge Crane" will be enhanced to include inspection of crane rails and crane structural components (e.g., bridge) for loss of material due to corrosion; inspection of crane rails for loss of material due to wear, and for indication of rail misalignment.

35 This is a new commitment in response to Audit Question 4.3-14. New No later than two SNC will revise the FatiguePro software to calculate a minimum projected value of Commitment years prior to the 1 for any events that may potentially occur, period of extended operation Page 15 of 18

NL-08-0991 VEGP License Renewal Future Action Commitment List ITEM UFSAR RELATED SUPPLEMENT LRA NO. COMMITMENT SCHEDULE LOCATION SECTIONS!

REFS 36 This is a new commitment in response to Audit Question 4.7-01. New No later than two 4.7.1 SNC will verify the LBB evaluation in WCAP-10551-P, Addendum 1 meets the Commitment years prior to the conditions of that process or have it re-performed using the acceptable process. period of extended operation 37 This is a new commitment in response to Audit Question B.3.28-04. New Prior to the period B.3.28 To ensure the Boral spent fuel racks will continue to perform their intended function Commitment of extended during the period of extended operation, VEGP will monitor spent fuel pool operation aluminum concentrations and implement corrective actions if adverse trends are identified. Additionally, SNC will monitor industry experience related to Boral and will take appropriate actions if significant degradation of Boral is identified.

38 This is a new commitment in response to RAI 4.3-2. New No later than two 4.3.1.5 SNC commits to revise the FatiguePro initial CUF values for the Unit 1 and Unit 2 Commitment years prior to hot leg surge nozzles, pressurizer surge nozzles, and pressurizer heater entering the penetrations to double the current values and recalculate the current and projected period of CUFs. extended operation.

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NL-08-0991 VEGP License Renewal Future Action Commitment List ITEM UFSAR RELATED SUPPLEMENT LRA NO. COMMITMENT SCHEDULE LOCATION SECTIONS!

REFS 39 This is a new commitment in response to RAI 4.3-04. New No later than two SNC commits to implement a fatigue management software program that uses six Commitment years prior to stress components in the stress based fatigue calculation. The software will be entering the appropriately benchmarked against an ASME N8-3200 fatigue analysis and the period of stress based fatigue monitoring locations will be modeled with the as-built extended configuration. The new software will be used to re-project 60-year CUF values for operation.

the monitored locations. When those locations were evaluated for environmental effects on fatigue, the new software will also be used to demonstrate the environmental effects on fatigue will be adequately managed for those locations during the period of extended operation. This software will be put in service at least two years prior to the period of extended operation.

40 This is a new commitment in response to a question raised during the IP-71 002 New No later than two 8.3.32 inspection. Commitment years prior to the The following changes will be made to the Structural Monitoring Program in order to period of enhance evaluation and trending of findings: extended operation

1) Guidance will be given regarding proper documentation of condition adverse to quality and its probable causes for any CR written against a finding during structural monitoring program walkdown.

2) For any finding (e.g., crack, leakage, etc.) guidance will be given for data to be collected and evaluated.

3) More explicit direction will be given for trending of the problems.

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NL-08-0991 VEGP License Renewal Future Action Commitment List ITEM UFSAR RELATED SUPPLEMENT LRA NO. COMMITMENT SCHEDULE LOCATION SECTIONSI REFS 41 This is a new commitment in response to a question raised during the IP-71 002 New No later than two 8.3.30 inspection. Commitment years prior to the 8.3.31 period of The following changes will be made to the IWE and IWL programs in order to extended enhance evaluation and trending of findings: operation

1) More explicit direction will be given to the Registered Professional Engineer for trending and evaluating conditions (including evidence of tendon grease leakage) identified during concrete visual examinations.

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