NL-09-079, Reply to Request for Additional Information Regarding Offsite Power, Refueling Cavity, and Unit 2 Auxiliary Feedwater Pump Room Fire Event

Reply to Request for Additional Information Regarding Offsite Power, Refueling Cavity, and Unit 2 Auxiliary Feedwater Pump Room Fire Event

ML091750166
Person / Time
Site:	Indian Point
Issue date:	06/12/2009
From:	Dacimo F Entergy Nuclear Northeast
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NL-09-079
Download: ML091750166 (72)

Text

Enteray Nuclear Northeast Indian Point Energy Center SEntergy 450 Broadway, GSB P.O. Box 249 Buchanan, NY 10511-0249 Tel (914) 788-2055 Fred Dacimo Vice President License Renewal NL-09-079 June 12, 2009 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001

SUBJECT:

Reply to Request for Additional Information Regarding Offsite Power, Refueling Cavity, and Unit 2 Auxiliary Feedwater Pump Room Fire Event Indian Point Nuclear Generating Unit Nos. 2 & 3 Docket Nos. 50-247 and 50-286 License Nos. DPR-26 and DPR-64

REFERENCES:

1. NRC Letter dated May 20, 2009, "Request for Additional Information for the Review of the Indian Point Nuclear Generating Unit Nos. 2 and 3, License Renewal Application - Offsite Power, Refueling Cavity, and Unit 2 Auxiliary Feedwater Pump Room Fire Event

Dear Sir or Madam:

Entergy Nuclear Operations, Inc is providing, in Attachment I, the additional information requested in the referenced letter pertaining to NRC review of the License Renewal Application for Indian Point 2 and Indian Point 3. The additional information provided in this transmittal addresses staff questions regarding Offsite Power, Refueling Cavity, and Unit 2 Auxiliary Feedwater Pump Room Fire Event. Attachment 2 consists of Revision 9 to the list of regulatory commitments.

If you have any questions, or require additional information, please contact Mr. Robert Walpole at 914-734-6710.

I declare under penalty of perjury that the foregoing is true and correct. Executed on Sincerely, kiz~

NL-09-079 Page 2 of 2 FRD/dmt

Attachment:

1. Reply to Request for Additional Information Regarding Offsite Power, Refueling Cavity, and Unit 2 Auxiliary Feedwater Pump Room Fire Event

2. List of Regulatory Commitments, Revision 9 cc: Mr. Samuel J. Collins, Regional Administrator, NRC Region I Mr. Sherwin E. Turk, NRC Office of General Counsel, Special Counsel Ms. Kimberly Green, NRC Safety Project Manager Mr. Kenneth Chang, NRC Branch Chief, Engineering Review Branch I Mr. John Boska, NRR Senior Project Manager Mr. Paul Eddy, New York State Department of Public Service NRC Resident Inspector's Office Mr. Francis J. Murray, President and CEO, NYSERDA

ATTACHMENT 1 TO NL-09-079 Reply to Request for Additional Information Regarding Offsite Power, Refueling Cavity, and Unit 2 Auxiliary Feedwater Pump Room Fire Event ENTERGY NUCLEAR OPERATIONS, INC.

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

Attachment 1 NL-09-079 Page 1 of 51 INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 AND 3 LICENSE RENEWAL APPLICATION REQUEST FOR ADDITIONAL INFORMATION OFFSITE POWER, REFUELING CAVITY, AND UNIT 2 AUXILIARY FEEDWATER PUMP ROOM FIRE EVENT RAI 2.5-4 In license renewal application (LRA) Section 2.5, as clarified in LRA Amendment 3, dated March 24, 2008, the applicant included in the scope of license renewal the structures and components for one offsite circuit path (138 kV/Station Auxiliary Transformer circuit, the immediate access circuit). The applicant is requested to explain why the second offsite circuit (the delayed access circuit) path, from the first inter-tie with the offsite distribution systems at the Buchanan substations to the safety buses, was not included in the scope of license renewal.

Specifically, the applicant is requested to explain why the components up to and including either 138 kV circuit breaker F1 or 345 kV circuit breaker F7 for IP2 and either 138 kV circuit breaker F3 or 345 kV circuit breaker F7 for IP3 were not included in the scope of license renewal.

Response for RAI 2.5-4 The components up to and including either 138 kV circuit breaker F1 or 345 kV circuit breaker F7 for IP2 and either 138 kV circuit breaker F3 or 345 kV circuit breaker F7 for IP3 were not included in the scope of license renewal because they do not meet the scoping criteria of 10 CFR 54.4. The scoping for offsite power recovery was in accordance with the guidance provided in a staff letter dated April 1, 2002. That letter states, "For purposes of the license renewal rule, the staff has determined that the plant system portion of the offsite power system that is used to connect the plant to the offsite power source should be included within the scope of the rule." The breakers identified in this RAI are part of the offsite power source; and not plant system components that are used to connect the plant to the offsite power source.

Discussion The second offsite circuit path was explicitly added in response to RAI 2.5-1.

RAI 2.5-1 (Dated 10/24/07; ML0729200270) asked the following question.

According to the above, both paths from the safety-related 480 Volt (V) buses to the first circuit breaker from the offsite line, used to control the offsite circuits to the plant, should be age managed. The guidance does not specify that the switchyard is not part of the plant system nor that the switchyard does not need to be included in the scope of license renewal. Explain in detail which high voltage breakers and other components in the switchyard will be connected from the startup transformers up to the offsite power system for the purpose of SBO recovery.

Attachment 1 NL-09-079 Page 2 of 51 RAI 2.5-1 Response Excerpt (Dated 11/16/2007)

General Design Criterion 17 of 10 CFR Part 50, Appendix A, specifies that electric power from the transmission network to the onsite electric distribution system be supplied by two physically independent circuits to minimize the likelihood of their simultaneous failure. As discussed in IP2 UFSAR Section 8.1.2.1, "10 CFR 50 Appendix A General Design Criterion 17 - Electric Power Systems," the two physically independent circuits supplying offsite power to IP2 are the Buchanan Substation via the Con Edison 138 kV system feeder and the Buchanan 13.8 kV system feeder. The 138 kV system feeder is the primary offsite power source connected to the 6.9 kV buses through the station auxiliary transformer. The 13.8 kV system feeder is the secondary offsite power source connected to the 6.9 kV buses through the GT autotransformer. The station auxiliary transformer and the GT autotransformer perform the functions assigned to the typical startup transformers referred to in the April 1, 2002 letter.

LRA Figure 2.5-2 showed only the primary offsite power source or the 6.9kV source from the 138kV/6.9kV station auxiliary transformer, which is connected to the Buchanan substation through the Con Edison 138kV feeder. Figure 2.5-2 is revised as shown in this response to add the secondary offsite power feeder from the 13.8 kV Buchanan substation via the GT autotransformer.

As shown in the revised LRA Figure 2.5-2, the 6.9 kV buses receive power from the two independent sources of offsite power via the 138 kV / 6.9 kV station auxiliary transformer or the 13.8 kV / 6.9 kV GT autotransformer. The station auxiliary transformer is connected to the 138 kV Buchanan substation, the primary offsite power source, via switchyard bus, overhead transmission conductors, and underground transmission conductors through motor-operated disconnect F3A, which is located at the Buchanan substation. The GT autotransformer is connected to the 13.8 kV Buchanan substation, the secondary offsite power source, via underground medium voltage cable through breaker F2-3, which is located at the Buchanan substation.

General Design Criterion 17 of 10 CFR Part 50, Appendix A, specifies that electric power from the transmission network to the onsite electric distribution system be supplied by two physically independent circuits to minimize the likelihood of their simultaneous failure. As discussed in IP3 UFSAR Section 8.2.1, "Network Interconnection", and 8.2.3, "Emergency Power- Sources Description," the two physically independent circuits supplying offsite power to IP3 are the Buchanan Substation via the Con Edison 138 kV system feeder and the Buchanan 13.8 kV system feeder. The 138 kV system feeder is the primary offsite power source connected to the 6.9 kV buses through the station auxiliary transformer. The 13.8 kV system feeder is the secondary offsite power source connected to the 6.9 kV buses through the GT autotransformer. The station auxiliary transformer and the GT autotransformer perform the functions assigned to the typical startup transformers referred to in the April 1, 2002 letter.

Attachment 1 NL-09-079 Page 3 of 51 LRA Figure 2.5-3 showed only the primary offsite power source or the 6.9kV source from the 138kV/6.9kV station auxiliary transformer, which is connected to the Buchanan substation through the Con Edison 138kV feeder.. Figure 2.5-3 is revised as shown in this response to add the secondary offsite power feeder from the 13.8 kV Buchanan substation via the GT autotransformer.

As shown in the revised LRA Figure 2.5-3, the 6.9 kV buses receive power from, the two independent sources of offsite power via the 138 kV / 6.9 kV station auxiliary transformer or the 13.8 kV / 6.9 kV GT autotransformer. The station auxiliary transformer is connected to the 138 kV Buchanan substation, the primary offsite power source, via switchyard bus and overhead transmission conductors through breaker BT2-6, which is located at the Buchanan substation.

The GT autotransformer is connected to the 13.8 kV Buchanan substation, the secondary offsite power source, via underground medium voltage cable through breaker F3-1, which is located at the Buchanan substation.

(Revised LRA Figures 2.5-2 and 2.5-3 were also provided with this RAI response.)

Based on discussions with the NRC staff on 12/12/07 and 1/30/08 this RAI response was revised for the IP2 138 kV connection point.

RAI 2.5-1 Response Clarification Excerpt (Dated 3/24/2008)

As shown in the revised LRA Figure 2.5-2, the 6.9 kV buses receive offsite power from either the 138 kV / 6.9 kV station auxiliary transformer or the 13.8 kV / 6.9 kV GT autotransformer. The station auxiliary transformer is connected to the 138 kV Buchanan substation, the primary offsite power source, via switchyard bus, overhead transmission conductors, and underground transmission conductors through rectcr poratod diccon.ect F3A switchyard breakers F2 and ST 3-4, which ieare located at the Buchanan substation. The GT autotransformer is connected to the 13.8 kV Buchanan substation, the secondary offsite power source, via underground medium voltage cable through breaker F2-3, which is located at the Buchanan substation.

(A revised LRA Figure 2.5-2 was also provided with this RAI clarification.)

The boundaries described in the RAI 2.5-1 response were determined in accordance with the guidance provided in a staff letter dated April 1, 2002. The following excerpt from the RAI 2.5-1 response discusses this determination.

RAI 2.5-1 Response Excerpt (Dated 11/16/2007)

The staff position in the letter dated April 1, 2002, "Staff Guidance on Scoping of Equipment Relied on to Meet the Requirements of the Station Blackout (SBO)

Rule (10 CFR 50.63) for License Renewal (10 CFR 54.4(a)(3))" is that the plant system portion of the offsite power system should be included within the scope of license renewal. Specifically, the letter states,

Attachment 1 NL-09-079 Page 4 of 51 "For purposes of the license renewal rule, the staff has determined that the plant system portion of the offsite power system that is used to connect the plant to the offsite power source should be included within the scope of the rule."

Implementation of the staff position requires definition of the offsite power source. The April 1, 2002 letter states:

"The offsite power systems of U.S. nuclear power plants consist of a transmission system (grid) component that provides a source of power and a plant system component that connects that power source to a plant's onsite electrical distribution system which powers safety equipment. The staff has historically relied upon the well-distributed, redundant, and interconnected nature of the grid to provide the necessary level of reliability to support nuclear power plant operations."

In this discussion, the staff defines the offsite power source as the transmission system or the grid. The staff refers to the well-distributed, redundant, and interconnected nature of the grid. The Buchanan substation, which includes the 345 kV, the 138 kV, and the 13.8 kV sections, is a key element of the well-distributed, redundant and interconnected grid or transmission system that constitutes the offsite power source for IP2 and IP3.

The Buchanan substation provides for the interconnection of multiple sources of power and provides dispatch control for a multiple county transmission network. The multiple power sources are interconnected through switchyard bus, transmission conductors, and breakers within the substation. In keeping with the guidance in the letter dated April 1, 2002, the SBO recovery paths from the plant systems to the offsite power system or grid connection are included in scope for license renewal.

The 138 kV circuit breaker F1, the 345 kV circuit breaker F7, and the 138 kV circuit breaker F3 are part of the Buchanan Substation, which is part of the well-distributed, redundant and interconnected grid or transmission system that constitutes the offsite power source for IP2 and IP3. In other words, these breakers are part of the transmission system (grid) component that provides a source of power; and not plant system components that connect that power source to the plant's onsite electrical distribution system which powers safety equipment. The Buchanan Substation is not the IP2 or IP3 switchyard. The Buchanan Substation is part of the Con Edison transmission and distribution system, and it provides distribution to Westchester County and the New York City area with 345 kV, 138 kV, and 13.8 kV transmission lines. The Con Edison transmission system does not perform a function that meets the license renewal scoping criteria of 10 CFR 54.4.

The breakers conservatively included in scope for the offsite power recovery path are the interface points added to the Buchanan Substation during the construction of IP2 and IP3. As stated in LRA Section 2.5:

Attachment 1 NL-09-079 Page 5 of 51 In addition to the plant electrical systems, certain switchyard components required to restore offsite power following a station blackout were conservatively included within the scope of license renewal even though those components are not relied on in safety analyses or plant evaluations to perform a function that demonstrates compliance with the Commission's regulations for station blackout (SBO) (10 CFR 50.63).

The breakers are shown on LRA Figure 2.5-2 (Amended by letter dated 3/24/2008), and LRA Figure 2.5-3 (Amended by letter dated 11/16/2007).

Follow-up RAI 2: Open Item 3.0.3.2.15-1 The purpose of this follow-up request for additional information (RAI) is to request additional information and clarification to help the staff to understand the applicant's May 1, 2009 response to Follow-up RAI 1 for Open Item 3.0.3.2.15-1. Specifically, the staff requests the following:

(a) In part (a) of the applicant's response, Figures 1 through 4 do not clearly identify the flow path from the refueling cavity liner to the A, B, and C water exit locations.

Therefore, please provide the following additional descriptive information. In an elevation view (similar to Figure 2), cut through each of the exit locations A, B, and C, showing the horizontal and vertical dimension between the entry point through the liner and the exit location. To the extent possible, describe the possible circumferential traverse of the leakage, from the entry point through the liner to the exit location.

(b) The staff requests the applicant to provide the following additional information/clarification regarding the revised license renewal commitments in part (b) of the applicant's response:

(1) The current remediation plan has targeted the 2014 outage for completion.

Please identify actions that will be taken if the remediation plan is unsuccessful.

(2) Identify the specific location and number of the concrete core samples (e.g., the three water exit locations) that will be removed and tested (i) during the upcoming 2010 refueling outage, and (ii) at 10 years into the extended period of operation (if a permanent solution for the leakage has not been achieved, in accordance with Entergy's current remediation plan). Define the tests that will be performed, and the objective of each test.

(3) Please advise if the revised commitments in the applicant's May 1, 2009 response include chemical analysis of the leaking water (i) during the upcoming 2010 refueling outage, and (ii) at 10 years into the extended period of operation.

Please identify the analyses that will be performed, and the objective of each analysis.

Attachment 1 NL-09-079 Page 6 of 51 Response for Follow-up RAI 2: Open Item 3.0.3.2.15-1

a. Based on leakage investigations, the reactor refueling cavity begins to leak when the water in the cavity reaches an approximate elevation between 80'- 85'. As can be seen on the attached elevation views of the cavity (Figures 1 thru 4), horizontal weld seams exist between these elevations, but the exact liner leakage points are unknown. We can, however, make the following observations regarding the relationship between the leakage areas in the concrete structure denoted as points A, B and C, and conditions of the cavity liner:

1. Above point A, defects in the CeramAlloy patch along a horizontal weld seam located on the south wall at an elevation between 80'- 85' has been observed. The CeramAlloy patch material that covers several weld seams was a previous attempt to mitigate the cavity leakage. This is a potential cavity liner leak point for the observed leakage on the concrete structure at point A.

2. Above the exit point denoted as B, defects in a CeramAlloy patch along a horizontal weld seam located at an elevation between 80'- 85' on the south wall has been observed. This patch area is an extension from the area discussed in item 1 above. In addition, the upper internals stand support base is attached to the cavity floor above the vicinity of the observed leakage in the concrete structure at point B. Both these areas in the cavity liner are potential leak point sources for the observed leakage at point B.

3. Above the observed leakage area in the concrete structure denoted as point C, defects in both the CeramAlloy patches along weld seams and potential defects in the weld seams themselves at the north cavity wall have been observed. These defects are located approximately 10-15' above the cavity floor and are potential leak points for the leakage observed at point C.

b. The following provides Entergy's response to part (b) of the staff's request.

1. Should the remediation plan for the cavity liner targeted for completion during the 2014 outage be unsuccessful, Entergy will perform additional monitoring to assess the condition of potentially affected structures. To assure continued structural integrity of the reactor refueling cavity reinforced concrete walls, Entergy will perform further core sampling and inspect reinforcing steel at suspect locations as described in item 3.

2. (i) During the upcoming 2010 outage, a total of 3 core bore samples will be taken from the reinforced concrete walls that form the outer shell of the reactor refueling cavity steel liner. The locations of these core bores will be chosen based on the following.

> Locations in the vicinity of observed liner/liner patch degradation in relative proximity to the observed leak points A, B and C on the concrete structure.

> Accessibility of suspect areas based on the principle of As Low As Reasonably Achievable (ALARA) and physical interferences.

Attachment 1 NL-09-079 Page 7of 51 The core samples will be tested and chemically analyzed to determine the effect, if any, past leakage has had on the concrete properties. The objectives of the physical and chemical tests of the concrete core samples are as follows.

Determine the compressive strength of concrete.

Determine boron and chloride concentration in concrete.

) Determine pH of concrete.

In addition, a petrographic examination will be performed on the core samples to evaluate the cementitious matrix, and, to the extent possible, determine the durability of the concrete.

In addition, reinforcing steel in the core sample areas will be exposed and inspected. Visual inspections of the reinforcing steel will be performed to determine the extent of material loss, if any, from the steel as a result of the borated water leakage.

2. (ii) -Ifa solution to the leakage has not been achieved, Entergy will perform core samples and reinforcing steel inspections prior to 10 years into the period of extended operation. Locations of the core samples will be chosen based on the extent and location of the leakage remaining following previous repair efforts. Core samples will be tested and chemically analyzed as discussed under part 2 above. Visual inspections of the reinforcing steel will be performed to determine the extent of material loss, if any, from the steel as a result of the borated water leakage.

3. (I and ii) Revised Commitment 36 includes chemical analysis of water leakage from the refueling cavity. During the upcoming 2010 outage, Entergy will collect water samples from the cavity leak and perform chemical analysis.

If the leakage has not been stopped, Entergy will collect additional water samples of the leak during the same outage as the core samples are taken no later than 10 years into the period of extended operation. The water that is collected will be analyzed for the following.

Boron concentration pH

> Iron

> Calcium Results of the analysis will be evaluated to assess the aggressiveness of the leaking fluid to reinforced concrete structures.

Attachment 1 NL-09-079 Page 8 of 51 FIGURE 1 VIEW FROM NORTHWEST AREA OF SUSPECTED FAILED CERAMALLOY PATCH ý-10 FT--H LEAKAGE BEGINS PLATE TO PLATE AT 80-85 FT. ELEV. WELDS (TYPICAL)

POINT "Ci' 69 FT. ELEV.

REACTOR .- POINT "B" VESSEL 64 FT. ELEV.

BIOLOGICAL SHIELD WALL

Attachment 1 NL-09-079 Page 9 of 51 VIEW FROM SOUTHWEST FIGURE 2 AREA OF SUSPECTED FAILED CERAMALLOY PATCH LEAKAGE BEGINS AT 85 FT.

ELEV.

,PLATE TO PLATE WELDS BOTTOM SLAB 5 FT THICK POINT "B" 64 FT. ELEV. ý REACTOR VESSEL BIOLOGICAL SHIELD WALL

Attachment 1 NL-09-079 Page 10 of 51 FIGURE 3 1"3.91 s 95 FT EL, REFUELING CAVITY CONCRETE

-LEAKAGE BEGINS AT 80-85 FT. ELEV.

0>

3,9

__ __ 69 FT EL, k POINT "A" POINT //c REACTOR VESSEL BIOLOGICAL SHIELD WALL 46 FT EL, VIEW DIMENSIONS LOOKING EAST IN FEET

Attachment 1 NL-09-079 Page 11 of 51 95 FT, EL. 13.9 - FIGURE 4 CAVITY CAVITY EXTERIOR INTERIOR

-LINER PLATE LEAKAGE BEGINS AT 80-85 FT. ELEV. I I

,. UPPER INTERNALS SUPPORT STAND e9 FT, EL, II I 64 FT, EL, 9,4 POINT 'B" OPEN PASSAGE 46 FT. E-L, _

1VID / LOOKING NORTH DIMENSIONS IN FEET

Attachment 1 NL-09-079 Page 12 of 51 RAI 3.4.2-2 By letter dated January 27, 2009, Entergy responded to RAI 3.4.2-1, and provided clarifying details regarding the passive, long-lived component types, materials, environments, aging effects and aging management programs for systems, structures and components that support the auxiliary feedwater (AFW) pump room fire event at Indian Point Nuclear Generating Unit No. 2 (IP2) that were not already within the scope of license renewal for 10 CFR 54.4(a)(1) or (a)(2).

The staff reviewed the response and determined that the systems contain passive, long-lived components made of materials that when exposed to the stated environments may experience aging effects as described in the GALL Report, which must be managed during the period of extended operation in accordance with 10 CFR 54.21 (a)(3).

By letter dated May 1, 2009, Entergy submitted a revised commitment list which included a new commitment (Commitment 39) to install a fixed automatic fire suppression system for IP2 in the AFW pump room which would make the suppression configuration of the room similar to that of the AFW pump room at Unit 3.

Because the planned installation is not yet part of the current licensing basis, the staff cannot make a finding consistent with the requirement in 10 CFR 54.29(a). Therefore, the staff requests that the applicant provide information to demonstrate that the effects of aging will be adequately managed so that the intended function(s) will maintained consistent with the current licensing basis for the period of extended operation as required by 10 CFR 54.21(a)(3). Specifically, the staff requests that the applicant list all aging effects and the aging management programs needed to manage the aging effects for the component types provided in the January 27, 2009 letter.

Response for RAI 3.4.2-2 As stated in the initial response to RAI 3.4.2-1 in the January 27, 2009 letter, the function of supporting safe shutdown in the event of a fire in the auxiliary feed pump room is confirmed on an ongoing basis since the required SSCs are performing their intended functions under design basis conditions during normal operation. Performance of intended functions during normal plant operation demonstrates that the systems and components can perform those functions for one hour in the event of a fire in the auxiliary feedwater pump room. Nevertheless, the additional information requested by the staff is provided below in the form of revised tables from the response to RAI 3.4.2-1 provided in the January 27, 2009 letter. This additional information includes aging effects and aging management programs to manage the aging effects for the component types that support the AFW pump room fire event that were not already included in scope and subject to aging management review for 10CFR54.4(a)(1) or (a)(2).

These tables identify changes as st*iketh*uq for deletions and underlines for additions. During the revision of these tables, the following changes to line items in the tables were identified outside of the addition of aging effects and programs.

new line items identifying cracking as an aging effect for tubing in the condensate system and loss of material due to selective leaching in heat exchanger tubes for the instrument air system.

Attachment 1 NL-09-079 Page 13 of 51 new line items for component type "strainers" in the city water system and the IP1 station air system

> new line items for component type "strainer housings" made of copper alloy

>15% zn in the city water system

> deleted line items for component type "expansion joint" made of elastomer in the condensate system since elastomer expansion joints are replaced on a specified time period

> new line items for pump casings made of gray cast iron and stainless steel in the circulating water system

> revised line items in the service water system to change environment from "air-outdoor (ext)" to "condensation (ext)" for consistency with other LRA tables

> revised line items for environment of "treated water (int)" to include "> 140 0 F" for high temperature aging effects

> revised line item for pump casings in the wash water system to change material to "stainless steel" from "carbon steel"

> revised line item for pump casings for the river water system to change material to "gray cast iron" from "carbon steel"

> revised line item for pump casings for the fresh water cooling system to change material to "titanium" from "copper alloy"

> Replaced Note 408 with the following:

408 The "air - treated" environment is the equivalent of dried air and for the purposes of evaluating aluminum components, the "air - treated" environment is drier than the NUREG-1 801 defined "air - indoor uncontrolled".

The addition of aging management programs to these tables also resulted in necessary revisions for Appendix A, UFSAR Supplement and Appendix B, Aging Management Programs and Activities which are also provided with this response.

The following revised tables are provided in response to RAI 3.4.2-2.

Attachment I NL-09-079 Page 14 of 51 Table 3.4.2-5-1-IP2 Conventional Closed Cooling System Components Required to Support AFW Pump Room Fire Event Summary of Aging Management Review Table 3.4.2-5-1-1P2: Conventional Closed Cooling System (CCC)

Component Type ntneAggMagmnt Intended Aging Effect Aging Management 1801 NUREG-Vol. 2 Item I Table Noe Notes Function Material Environment Requiring Programs Management Item Heatexchanger Pressure CNe_ VII.E1-2 3.3.1-51 498 boundarya C r Treated water (ext) Loss e Water Chemistry Control (AP-34) D heatT ,t waa Le= - Closed Cooling Water Heat exchanger Heat transfer Copper alloy Treated water (ext) F Water Chemistry Control VI1.C2-2 3.3.1-52 488 (tubes1 >15% zn - Closed Cooling Water (AP-80) _B Hetecaar Pesr opralyVII.C2-6 3.3.1-84 408 Heat exchansge Pressure Copper alloy Treated water (ext) Loss of material Selective Leaching AP-6 C absboundary >15% zn fAP-43) C Pressure _______VII.CI-3 3.3.1-82 408 Heat exchanger boury Copper alloy Treated water-Raw Nene None VC-3e 3 (tubes) heary and >15% zn water (int) Loss of material Service Water Integrity (A65) C Heat exchanger Copper alloy VILQC-6 3.3.1-83 C Heat transfer >15% zn Raw water (int) Fouling Service Water Integrity (A 72)

(tubes) ___________

Heat exchanger Pressure Copper alloy Raw water (nt) Loss of material Selective Leaching VII.C1-4 3.3.1-84 C (tubes) boundary >15% zn w 1 e(A66)

Attachment 1 NL-09-079 Page 15 of 51 Table 3.4.2-5-2-1P2 Condensate System Components Required to Support AFW Pump Room Fire Event Summary of Aging Management Review

Attachment 1 NL-09-079 Page 16 of 51 Table 3.4.2-5-2-1P2 Condensate Svstem (CONDI Intended Aging Effect Aging Management NUREG- Table I Component Type ntn Material Environment Requiring 1801 Vol. 2 Notes Component Type _Function Management Programs Item Item Heatexchanger Pressure exchangertrialWater NeP,e Chemistry Control ... 4N8 F

Htueat boundary and Titanium Steam (ext) Loss of materialWaeChmsrCotlF

( seat~ansfeF - Primary & Secondary Heat exchanger Water Chemistry Control .... 408 ue Heat transfer Titanium Steam (ext) Fouling - Primary & Secondary F Pressure None -- - 4 Heatexchanger None Periodic Surveillance F (tubes) boundary and Titanium Raw water (int) Loss of material and Preventive heat-tr-ansfe* Maintenance Heat exchanger Periodic Surveillance .... 408 Heat transfer Titanium Raw water (int) Fouling and Preventive F (tubes)

Maintenance Heat exchanger P sNoneNne VIII.A-5 3.4.1-15 408 (tubes) boundary and Copper alloy Treated water (int) Loss of material Water Chemistry Control (SP-61) heaLs oansfe Primary & Secondary Heat exchanger Heat transfer Copper alloy Treated water int) F Water Chemistry Control VIII.E-10 3.4.1-9 408 (tubes) - Primary & Secondary (SP-58) A, 404 Pressure VIII.G-8 3.4.1-10 408 Heat exchanger (tubes) boundary and Copper alloy Lube oil (ext) Loss of material Oil Analysis (SP-53) D, 405 heat-t-anffe* ___________s Heat exchanger Heat transfer Copper alloy Lube oil (ext) Fouling Oil Analysis VIII.G-8 3.4.1-10 408 (tubes (SP-53) 0D405 Heat exchanger Pressure Stainless None None VI1e.11-3 3.4.1-37 408 Steam (ext) Water Chemistry Control (SP-43) C (tubes) boundary steel Loss of material Primary & Secondry

Attachment 1 NL-09-079 Page 17 of 51 Table 3.4.2-5-2-1P2 Condensate System (COND)

Intended Aging Effect Aging Management 8UREG- Tob. I Component Type Function Material Environment Requiring Programs 1801 Vol. 2 Item Notes Management Item Heat exchanger Pressure Stainless Steam (ext) Cracking Water Chemistry Control VIII.B1-2 3.4.1-39 408 (tubes) boundary steel - Primary & Secondary (SPL-4) C Heat exchange Water Chemistry Control .. 408 qtuesHHeat transfer stael Steam (ext) ol - Primary & Secondary G Stainless Treated water None NWae n lE-36 VCi 3.4.1-16 40 4 Heat exchanger Pressure (tubes) boundary steel > 140°F (int) Loss of material Water Chemistry Control y L-2 A 404 (tubs) ounar~

stel ____ __________- Primary Seco~ndar Heat exchanger Pressure Stainless Treated water Cracking Water Chemistry Control VIII.E-30 3.4.1-14 408 (tubes) boundary steel > 140°F (int) - Primary & Secondary (SP-17) ,404 HeatHeat transfer Stainless Treated water Water Chemistry Control VIII.E-13 3.4.1-9 (ubes) steel > 1400 F (int) Fouling - Primary & Secondary SP-40) A 404 Pressure NoPe NG% 408 Heat exchanger (tubes) boundary Titanium Treated water (int) Water Chemistry Control Loss of material-Prmy&Seody F

- Primary & Secondary Heat exchanger Heat transfer Titanium Treated water (int) Fouling Water Chemistry Control .... 408 (tubes) - Primary & Secondary F Pressure None NO% 48 Heat exchanger (tubes) boundary Titanium Steam (ext) iWater Chemistry Control Loss of material-Prmy&Seody F

- Primary & Secondary Heat exchanger Heat transfer H naaese Titanium Steam (ext) Fouling Water Chemistry Control

- Primary & Secondary

.... 408 F

Ne NOne VIII.E-34 3.4.1-4 408 Pressure Pipingboundary Carbon steel Treated water (int) Los e Water Chemistry Control (S-) A, 404 Loss of material - Primary & Secondary

Attachment I NL-09-079 Page 18 of 51 Table 3.4.2-5-2-1P2 Condensate System (COND)

Aging Effect NUREG-Component Type Function Material Environment Requiring Aging Management 1801 Vol. 2 Table I Notes

____________Function Pressure ______________ Management Cakn-VIi-O Programs Item Item 3.4.1-1 408 boundary Carbon steel Treated water (int) Cracking - Metal Fatigue - TLAA (S-08) C Pressure e VIII.H-7 3.4.1-28 408 Pipingboundary Carbon steel Air - indoor (ext) Loss of material Axternaq N% Nofefe VIII.H-7 3.4.1-28 408 Pressure Sight glass boundary Carbon steel Air - indoor (ext) Loss of material Axternq boundry Lss o matrialMonitoring Pressure No~e None VIII.E-34 3.4.1-4 408 Sight glass boundary Carbon steel Treated water (int) L Water Chemistry Control (S-1) A 404

- Primary & Secondary PrsueVIII.I-5 3.4.1-40 408 Sight glass Pressure Glass Air - indoor (ext) None None VSP-5 A boundary i5FP-91 A Pressure VIII.I-8 3.4.1-40 408 A

Sight glass boure Glass Treated water (int) None None VSP-8 boundary jE31A Pressure ____ NOe VIII.H-7 3.4.1-28 408 Thermowell boundary Carbon steel Air - indoor (ext) Loss of material n cq Axter NOe% VIII.E-34 3.4.1-4 408 Thermowell Boundary Pressure Carbon steel Treated water (int) Lose Lossof f aera ateral- Water Chemistry

-Pimy&Seody Control (S-10) A 404 Primary & Secondary Throel Pressure Crcig- VIi-O 3411 408 Thermowell Boundary Carbon steel Treated water (int) Cracking Metal Fatigue - TLAA (SV11I-10 3.4.1-1 C

Attachment I NL-09-079 Page 19 of 51 Table 3.4.2-5-2-1P2 Condensate System (COND)

Aging Effect NUREG-Intended Agina Manggems Tem Component Type Function Material Environment Requiring Angranme 1801 Vol. 2 te Notes ComponentType Function_ Management Item Pressure Stainless VIII.1-10 3.4.1-41 408 Thermowell boundary steel Air - indoor (ext) None None 2 A Pressure Stainless Treated water No~ne NoRe VIII.E-29 3.4.1-16 408 Thermowell boury steeless of mater Water Chemistry Control (SP-16) A, 404 boundary steel > 140°F (int) Loss of material - Primary & Secondary Pressure Stainless Treated water Water Chemistry Control VIII.E-30 3.4.1-14 A, 404 boundary steel > 140°F (int) - Primary & Secondary (SP-17)

Pressure Stainless Treated water Cracking - Metal Fatigue - TLAA VIIEl-16 3.3.1-2 C, 406 Thermowell boundary steel > 140°F (int) faatu (6-571 NOe VIII.E-29 3.4.1-16 408 Tubing Pressure Stainless Treated water No% Water Chemistry Control (SP-16) A, 404 boundary steel > 140°F (int) Loss of material - Primary & Secondary Pressure Stainless Treated water Water Chemistry Control VIII.E-30 3.4.1-14 408 Tubing boundary steel > 140°F (int) Cracking - Primary & Secondary (SP-17) A 404 Pressure Stainless Treated water Cracking - VII.EI-16 3.3.1-2 408 Tubing boundary steel >140F (it) t Metal Fatigue - TLAA (A-57) C, 406 Pressure Stainless VIII.I-10 3.4.1-41 A Tubing boundary steel Air - indoor (ext) None None (SP-12)

Pressure N% Noe% VIII.E-34 3.4.1-4 408 Valve body ur Carbon steel Treated water (int) e Water Chemistry Control S A. 404 boundary CLoss of material _ Primary & Secondary PrsueCracking - VIII.B1-10 3.4.1-1 408 Valve body boundarye Carbon steel Treated water (int) C Metal Fatigue - TLAA VS-08) C

________~~ fatgue_8__

Attachment 1 NL-09-079 Page 20 of 51 T~hIA 2A2~L2~IP2 CnndAn~t~ Rvs~t~m ~COND~

AgngEfetNUREG- Tal IntendedAging Effect Aging Management NUEG TableVI Component Type ntn Material Environment Requiring 1801 Vol. 2 Notes Function Management Programs Item Item 6 -

NO-e VIII.H-7 3.4.1-28 408 ValvePressure Carbon steel Air - indoor (ext) External Surfaces (S-29) A boundary Loss of material Monitoring Treated water NO% VIII.E-29 3.4.1-16 408 Pressure Stainless Valve body stl > (int) Loss of material Water Chemistry Control (SP-16) A, 404 steel Valvebodyboundary > 140°F(int)l - Primary & Secondary Pressure Stainless Treated water Water Chemistry Control VIII.E-30 3.4.1-14 408 Valve body boundary steel > 1400 F (int) Crackinq - Primary & Secondary (SP-17) A.404 Pressure Stainless Treated water Crackingque - TLAA VII.E-16 3.3.1-2 408 Valve body boundary steel >fatigue MetlFatgA-57) C 406 Pressure Stainless VIII.I-10 3.4.1-41 408 Valve body boundary steel Air- indoor (ext) None None (SP-12) A

Attachment 1 NL-09-079 Page 21 of 51 Table 3.4.2-5-3-1P2 Circulating Water System Components Required to Support AFW Pump Room Fire Event Summary of Aging Management Review Table 3.4.2-5-3-1P2 Circulating Water System (CIRC)

CopnnIye Fnctionde Intended Material Maeil Eniomnt Environment RqiingEfc Requiring Aging Effect AgingPrograms Management 1801 10Vo.2 NUREG-Vol. 2 TbeI Item Table Notes Noe Component Type Function Management Item gPressure NOe NeOe VII.I-1 3.3.1-43 409 boundary Carbon steel Air- outdoor (ext) Loss of material Bolting Integrity (AP-28) C NeNO VIII.E-1 3.4.1-11 488 Pressure Bolting boury Carbon steel Soil (ext) Lsome Buried Piping And Tanks a(S-01) C boundary Loss of material Inspection Pressure Periodic Surveillance VIII.G-36 3.4.1-8 E boundary Carbon steel Raw water (ext) Loss of material and Preventive (S-12)

Maintenance NGe% VII.C1-1 3.3.1-75 408 Pressure Ne Ne, Periodic Surveillance (AP-75) E boundary Elastomer Raw water (int) Cracking and Preventive Maintenance Change of Periodic Surveillance VII.C1-1 3.3.1-75 408 Pressure Expansion ioint boundary Elastomer Raw water (int) material and Preventive (AP-75) E properties Maintenance NRe - -- 408 Pressure NGne Periodic Surveillance G Expansion joint boundary Elastomer Air-outdoor (ext) Cracking and Preventive Maintenance

Attachment I NL-09-079 Page 22 of 51 Table 3.4.2-5-3-1P2 Circulating Water System (CIRC)

Intended Aging Effect Aging Management NUREG0 Table I Copntt Type Component y eFunction nMteildevrnmn Requiring Management Programs Vol. 2NoeItem 1801Item Pressure Change of Periodic Surveillance -- -- 408 Expansion int boundary Elastomer Air -outdoor (ext) material and Preventive G properties Maintenance P eNe VILI.E-1 3.4.1-11 408 Piping boundary Carbon steel Soil (ext) Loss of material Buried Piping And Tanks (S-01) C aInspection Pressure NeiNe VIII.H-8 3.4.1-28 408 Piping boundary Carbon steel Air outdoor (ext) Loss ofme External Surfaces S A Noe VIII.G-36 3.4.1-8 408 Piping Pressure Carbon steel Raw water (int) NOe Periodic Surveillance (S-12) E boundary Loss of material and Preventive Maintenance Pressure Nee eA VJII.H-8 3.4.1-28 408 Pump casing boundary Carbon steel Air-outdoor (ext) Loss of material Axternaq N41e VIII.G-36 3.4.1-8 498 Pump casing Pressure Carbon steel Raw water (int) Nene Periodic Surveillance (S-12 E boundary Loss of material and Preventive Maintenance Pressure Periodic Surveillance VIII.G-36 3.4.1-8 408 Pump casing boundary Carbon steel Raw water (ext) Loss of material and Preventive (S-12) E Maintenance

Attachment 1 NL-09-079 Page 23 of 51 Table 3.4.2-5-3-1P2 Circulating Water System (CIRC)

Aging Effect NUREG-Component Type Intended Material Environment Requiring Aging Management 1801 Vol 2 Table 1 Notes Function Management Programs Item Item Periodic Surveillance VIII.E-27 3.4.1-32 E Pressure Loss of material and Preventive (SP-36)

Pump casing boundary Stainless steel Raw water (int)

Maintenance Pressure Periodic Surveillance VIII.E-27 3.4.1-32 E Pump casing Pressure Stainless steel Raw water (ext) Loss of material and Preventive (SP-36) boundarv Maintenance Pressure External Surfaces VIII.H-8 3.4.1-28 A Pump casing boundary Gray cast iron Air-outdoor (ext) Loss of material Monitoring (S-411 Periodic Surveillance VIII.G-36 3.4.1-8 E Pressure Pump casing boundary Gray cast iron Raw water (int) Loss of material and Preventive (S-12)

Maintenance Pressure VIII.A-7 3.4.1-36 C Gray cast iron Raw water (int) Loss of material Selective Leaching (SP-28)

Pump casing boundary Pressure Periodic Surveillance VIII.G-36 3.4.1-8 E Pump casing boundary Gray cast iron Raw water (ext) Loss of material and Preventive (S-12)

Maintenance Pressure VIll.A-7 3.4.1-36 C Gray cast iron Raw water (ext) Loss of material Selective Leachingq (SP-28)

Pump casing boundary

Attachment 1 NL-09-079 Page 24 of 51 Table 3.4.2-5-4-1P2 City Water System Components Required to Support AFW Pump Room Fire Event Summary of Aging Management Review Table 3.4.2-5-4-1P2 City Water System (CYW)

Aging Effect NUREG- Table N MaterialFuntio Environment AgingProram Management 1801 Vol. 22 Item Notes Component Type Intended Requiring Management Item Pressure None NOne VII.1-4 3.3.1-43 408 boundary Carbon steel Air- indoor Loss of material Bolting Integrity (AP-27) A Pressure Stainless VII.J-15 3.3.1-94 4098 Bolting boundary steel Air - indoor (ext) None None (AP-17) C Pressure NOe% NOne VII.I-1 3.3.1-43 408 Bolting boundary Carbon steel Air- outdoor (ext) Loss of material Bolting Integrity (AP-28) A NonsreSanls Ls me r None ngIegri..

--- 408 BoltingPressure Stainless Air - outdoor (ext)

Loss of material BoltingInteqrity G_4_8 boundary steel Pressure Stainless VII.J-15 3.3.1-94 408 Flex hose boundary steel Air-indoor (ext) None None (AP-171 A Nrsurotanese NoneOn

- -- 408 4ei Flex hose Pressure Stainless Treated water (int) Ls me boundary steel Loss of material One-Time Inspection G_ 07 No% None VII.l-9 3.3.1-58 408 Pressure Loss of material MntrnSurfaces PipingPiigboundary Carbon steel Air-outdoor (ext) External (A-78) A Monitoring NO Nne VII.1-8 3.3.1-58 498 Pressure A Piping boury Carbon steel Air-indoor (ext) Loss of material External Surfaces (A-77) b d Monitoring

Attachment 1 NL-09-079 Page 25 of 51 Table 3.4.2-5-4-1P2 City Water System (CYW)

Intended Aging Effect Aging Management 1UREG- Tol. I Component Type Function Material Environment Requiring Programs 1801 Vol. 2 Item Notes Function Management Item N~er - -- 408 Carbon steel Treated water (int) Noe Periodic Surveillance G, 407 Piping Pressure boundary Loss of material and Preventive Maintenance Pressure Stainless Aid (ext) None None VII.J-15 -3.3.1-94 408 Piping boundary steel ir-inoor ( (AP-17) A NeQe - -- 408 Piping Pressure Stainless Air-outdoor (ext) Lon e External Surfaces G boundary steel Loss of material Monitoring Piping Pressure Stainless T e r nt) Ne_,e_-_--_4 08 boundary steel Treated water (int) Loss of material One-Time Inspection G, 407 NN4e VII.I-9 3.3.1-58 408 Pressure Sight Sgtgas glass boundary Carbon steel Air-outdoor (ext) Loss Loss of material e Monitoringq External Surfaces (A-78) A NGe - -- 408 Pressure Nente Periodic Surveillance ce G 407 bou re Carbon steel Treated water (int) Non e rial iodP rve n Sight glass boundary Loss of material and Preventive Maintenance Glass Air-outdoor (ext) None None 4G8 Sight glass Pressure boundary G Pressure Glass Treated water (int) None None 407 Sight glass boundary 2A4 0 Stainless -- 407 Strainer Filtration Steel Treated water (int) Loss of material One-Time Inspection -

Attachment 1 NL-09-079 Page 26 of 51 Table 3.4.2-5-4-1P2 City Water System (CYW)

Intended Materia Enirnmnt Aging Reuiinm Effect NUREG-1e1Vo.t Table I Component Type Function Material Environment Requiring Programs 1801 Vol. 2 Item Notes Management Item Stainless - -- G 407 Strainer Filtration Stess Treated water (ext) Loss of material One-Time Inspection - -

_______________Steel Pressure N% VII.I-8 3.3.1-58 408 Strainer housing boundary Carbon steel Air-indoor (ext) Loss of of material External Surfaces (A-77) A bounaryLos ateialMonitoring Pressure Nenie Periodic Surveillance .... 408 Strainer housing boundary Carbon steel Treated water (int) Loss of material and Preventive G 407 Maintenance Strainer housing Pressure Copper alloy Air-indoor (ext) None None V.F-3 3.2.1-53 C boundary >15% zn Periodic Surveillance G 407 Strainer housing Pressure Copper alloy Treated water (int) Loss of material and Preventive boundary >15% zn Maintenance Strainer housing Pressure Treated water (int) Loss of material alloy TCopper Selective Leaching - -407 boundary >15% zn Pressure Stainless Air-indoor (ext) None None VII.J-15 3.3.1-94 408 Strainer housing steel -17 A Strainer housing boundary Pressure steel Stainless Trete-waerGi407en Treated water (int) os Nonee I c- 40 9 onayselLoss of material One-Time Inspection G 40 7 Pressure Stainless T d ( Ne NGne --... 408 Tubing bonay selTreated water (int) ________ __________G0 Tubigboundary steel Loss of material One-Time Inspection G 07 Tubing Pressure Stainless Air - outdoor (ext) N1ne Eene r--s408 --

boundary steel Loss of material External Surfaces G Monitoring

Attachment 1 NL-09-079 Page 27 of 51 Table 3.4.2-5-4-1P2 City Water System (CYW)

Intended Aging Effect Aging Management NUREG- Table 1 Component Type Function Material Environment Requiring AgigMame 1801 Vol. 2 te Notes Management Item Pressure Stainless VII.J-15 3.3.1-94 408 Tubing boundary steel Air - indoor (ext) None None (AP-17) A NG% -- 408 Valve body Pressure Carbon steel Treated water (int) Ne_ Periodic Surveillance G 407 boundary Loss of material and Preventive Maintenance Pressure None VII.I-9 3.3.1-58 408 Valve body boundary Carbon steel Air - outdoor (ext) Loss of material External Surfaces A-) A Monitoring Pressure NOe Nne% VII.1-8 3.3.1-58 408 Valve body boundary Carbon steel Air - indoor (ext) Loss of material External Surfaces A Valveboundary VPressure Stainless steel Treated water (int) NOne Loss of material None One-Time Inspection .... 408 G 07 Pressure Stainless None NOne Valve body boundary steel Air - outdoor (ext) Loss of material External Surfaces G b Monitoring Pressure Stainless VII.J-15 3.3.1-94 408 Valve body boundary steel Air- indoor (ext) None None (AP-17) A

Attachment 1 NL-09-079 Page 28 of 51 Table 3.4.2-5-5-1P2 Wash Water System Components Required to Support AFW Pump Room Fire Event Summary of Aging Management Review Table 3.4.2-5-5-1P2 Wash Water System (WW) Components Intended Aging Effect Aging Management 1801 Vol. 2Not Component Type Function Material Environment Requiring Programs Item Function Management Item Pressure NOne NeO% VII.I-1 3.3.1-43 408 Bolting boundary Carbon steel Air-outdoor (ext) Loss of material Bolting Integrity (AP-28) A Bolting Pressure Stainless Air-outdoor (ext) NeQ NeO% . 408 boundary steel Loss of material Bolting Inteqrity G Pressure Stainless Raw water (ext) Loss of material Bolting Integrity VII.C1-15 3.3.1-79 C boundary steel Raw w54 NeG% -- -- 408 Expansion joint Pressure Nene Periodic Surveillance G boundary Elastomer Air-outdoor (ext) Cracking and Preventive Maintenance Pressure Change of Periodic Surveillance -- -- 408 Expansion ioint boundary Elastomer Air-outdoor (ext) material and Preventive G Qroperties Maintenance NeQe VII.C1-1 3.3.1-75 408 Pressure Neo% Periodic Surveillance (AP-75) E Expansion joint boundary Elastomer Raw water (int) Cracking and Preventive Maintenance Pressure Change of Periodic Surveillance VII.C1-1 3.3.1-75 408 Expansion joint boundary Elastomer Raw water (int) material and Preventive (AP-75) E prop erties Maintenance

Attachment 1 NL-09-079 Page 29 of 51 Table 3.4.2-5-5-1P2 Wash Water System (WW) Components Aging Effect Aging Management UREG- Table I Notes Component Type Intended Material Environment Requiring Programs 1801 Vol. 2 Item Function Management Item Pressure Stainless NOne NeG, e-... 408 Flex hose boundary steel Loss of material External Surfaces G Monitorinq None VII.C1-15 3.3.1-79 408 Pressure Stainless None Periodic Surveillance (A-54) E boundary steel Loss of material and Preventive Maintenance N4% NOe VII.I-9 3.3.1-58 408 Pressure Nozzles boundary Carbon steel Air-outdoor (ext) Loss of material External Surfaces (A-78) A Monitoringq Noe VI1.C1-19 3.3.1-76 408 Pressure Carbon steel Raw water (int) N4e, Periodic Surveillance (A-38) E Nozzles boundary Loss of material and Preventive Maintenance NNoe N4Ge VII.I-9 3.3.1-58 408 Pressure Piping boundary Carbon steel Air-outdoor (ext) raM External nSurfaces Loss of material A ounaryMonitoring NGe% VII.Cl-19 3.3.1-76 408 Piping Pressure C NGe% Periodic Surveillance (A-38) E boundary Carbon steel Raw water (int) Loss of material and Preventive Maintenance Stainless Nee Ne -- -- 408 Pressure Piping boundary steel Air-outdoor (ext) Loss of material External Surfaces G Monitoring

Attachment 1 NL-09-079 Page 30 of 51 Table 3.4.2-5-5-1P2 Wash Water System (WW) Components AgngEfetNUREG- Tal ComponentAging Effect Aging Management 1801 Vol. 2 I Notes Function Material Environment Requiring Programs Item CmoetTp FucinManagement Item None VII.C1-15 3.3.1-79 408 Pressure Stainless None Periodic Surveillance (A-54) E Piping boundary steel Raw water (int) Loss of material and Preventive Maintenance G ahN oe E xten a S urfaee 40 8 P re ss u re Pump casing boundary Stainless Air-outdoor (ext) Loss of material External Surfaces G ouay steel Monitorig Noe, VIIC1-15 3.3.1-79 408 Pressure None Periodic Surveillance (A-54) E Pump casing boundary Stainless Raw water (int) Loss of material and Preventive steel Maintenance Pressure Stainless Periodic Surveillance VII.C1-15 3.3.1-79 408 Pump casing boundary steel Raw water (ext) Loss of material and Preventive (A-54) E Maintenance Stainless None None -- -- 408 Tuigboundary Pressure steel Loso aeilMonitoring Tubing steel Air-outdoor (ext) Loss of material External Surfaces G None VII.C1-15 3.3.1-79 408 Pressure Stainless None Periodic Surveillance (A-54) E Tubing boundary steel Raw water (int) Loss of material and Preventive Maintenance Pressure None VII.I-9 3.3.1-58 408 Valve body boundary Carbon steel Air-outdoor (ext) Loss of material External Surfaces A-q A Monitring NL-09-079 Page 31 of 51

Attachment 1 NL-09-079 Page 32 of 51 Table 3.4.2-5-6-1P2 Feedwater System Components Required to Support AFW Pump Room Fire Event Summary of Aging Management Review Table 3.4.2-5-6-1P2 Feedwater System (FW)

Agntendeect Effect IntendAging Aging ANUREG-Management 1801 Vol. 2NoeTable I Component Type Function Material Environment Requiring Programs Item Management P Item None V111.B3-3 3.4.1-37 408 Heat exchanger Pressure Stainless (tubes) boundary steel Steam (ext) Water Chemistry Control (SP-43)

Loss of material-Prmy&Seodr C

- Primary & SecondLary Heat exchanger Pressure Stainless Steam (ext) Cracking Water Chemistry Control VIII.B1-2 3.4.1-39 408 (tubes) boundary steel S - Primary & Secondary (SP-441 C 3.4.1-16 408 Heat exchanger Pressure Stainless Treated water NGe% None Control VID14 Water ChemistryContaA (SP-16) A, 404 boundary steel > 140°F (int) Loss of material W Primary (tubes) - Primary & Secondary Heat exchanger Pressure Stainless Treated water Cracking Water Chemistry Control VIII.D1-5 3.4.1-14 408 (tubes) boundary steel > 140°F (int) - Primary & Secondary (SP-17) C404

Attachment 1 NL-09-079 Page 33 of 51 Table 3.4.2-5-7-1P2 Instrument Air System Components Required to Support AFW Pump Room Fire Event Summary of Aging Management Review Table 3.4.2-5-7-1P2 Instrument Air System (IA)

Intended Aging Effect Aging Management 1UREG- Table 1 Component Type Function Material Environment Requiring Programs 1801 Vol. 2 Item Notes ComponentType Function_ Management Item BPressure None None VII.1-1 3.3.1-43 408 Bolting iboundary Carbon steel Air-outdoor (ext) Loss of material Bolting Integrity (AP-28) A Pressure Stainless A t ) Noe None -- -- 408 Bolting boundary steel Air-outdoor (ext) Loss of material Bolting Integrity G Pressure NGPe VII.G-9 3.3.1-28 408 Heatexchanger boundary and Copper alloy Condensation (int) None Periodic Surveillance (AP-78) E (tubes) h yat >15% zn Loss of material and Preventive Maintenance Periodic Surveillance - -- 408 Hatues e Heat transfer Co>% al Condensation (int) Fouling and Preventive G (tubes) >15% zn Maintenance Heat exchanger Pressure Nae VI1.C2-4 3.3.1-51 408 (tubes) boundary and Copper alloy Treated Water No e Water Chemistry Control (AP-12) D h(btes)e >15% zn (ext) Loss of material -Closed Cooling Water Heat exchanger Pressure Copper alloy Treated Water Nene NG% VII.C2-6 3.3.1-84 408 (tubes) boundary >15% zn (ext) Loss of material Selective Leachinq (AP-431 C Heat exchanger Copper alloy Treated Water Fouling Water Chemistry Control VII.C2-2 3.3.1-52 408 (tubes) Ceate - Closed Cooling Water (AP-80) D

Attachment 1 NL-09-079 Page 34 of 51 Table 3.4.2-5-7-1P2 Instrument Air System (IA)

Intended Aging Effect Aging Management NUREG- Table I Component Type Function Material Environment Requiring Programs1801 Vol. 2 Item Notes Management Item Pressure V. F-3 3.2.1-53 408 Copper alloy Air - indoor (ext) None None (EP-10) C Tubing boundary Pressure VLI.J-3 3.3.1-98 CA40 boundary Copper alloy Air - treated (int) None None (AP-8)

Tubing Tubing Pressure bonay sel Stainless Air - indoor (ext) None None A-7A VII.J-15 3.3.1-94 408 boundary steel L)AP-17) A Tubing Pressure Stainless Air - treated (int) None None VII.J-18 3.3.1-98 A. 408 boundary steel (AP-20)

N Nne VII.D-3 3.3.1-57 408 Pressure Piping boundary Carbon steel Air-indoor (ext) Loss of material External Surfaces A-q A boundaryMonitoring Pressure Carbon steel Air-treated (int) None None VII.J-22 3.3.1-98 A 408 Piping boundary e(AP-4 Pressure Stainless VII.J-15 3.3.1-94 408 Piping boundary steel Air-indoor (ext) None None 1 A Pressure Stainless Air-treated (int) None None VII.J-18 3.3.1-98 A 408 Piping boundary steel (AP-20)

Pressure V.F-3 3.2.1-53 408 boundary Copper alloy Air - indoor (ext) None None (EP-30) C Valve body Pressure VII.J-3 (AP-8) 3.3.1-98 A.408 Valve body boundary Copper alloy Air - treated (int) None None Pressure Copper alloy Air - indoor (ext) None None V.F-3 3.2.1-53 408 Valve body boundary >15% zn LEP-0

____ C Pressure Copper alloy Air - treated (int) None None VII.J-3 3.3.1-98 A. 408 Valve body boundary >15% zn AP(8

Attachment 1 NL-09-079 Page 35 of 51 Table 3.4.2-5-7-1P2 Instrument Air System (IA)

Aging Effect NUREG-Intended Aging Management 1801 Vol. 2 Component Type Function Material Environment Requiring Programs Item Notes Function Management Item Pressure None None VII.D-3 3.3.1-57 408 Valve body boundary Carbon steel Air - indoor (ext) Loss of material Axterna Pressure VII.J-22 3.3.1-98 A, 40 Valve body boundary Carbon steel Air - treated (int) None None (APV-)

Pressure Stainless VII.J-15 3.3.1-94 408 Valve body boundary steel Air -indoor (ext) None NoneA Pressure Stainless Air - treated (int) None None VII.J-18 3.3.1-98 A, 408 Valve body boundary steel Air (AP-20)

Attachment 1 NL-09-079 Page 36 of 51 Table 3.4.2-5-8-1P2 Instrument Air Closed Cooling System Components Required to Support AFW Pump Room Fire Event Summary of Aging Management Review Table 3.4.2-5-8-1P2 Instrument Air Closed Cooling System (IACC)

Intended Aging Effect Aging Management 1UREG- Table I Component Type Function Material Environment Requiring Programs 1801 Vol. 2 Item Notes Management Item Heat exchanger Pressure Copper> VI1.C1-3 3.3.1-82 408 (tubes) boundar 15% Zn Raw water (int) Loss of material Service Water Integrity A-65) C (inhibited)

Copper> VII.C1-6 3.3.1-83 408 (tubes) Heat transfer 15% Zn Raw water (int) FS (inhibited) Fouling Service W__

Water Integrity C

____VII.E1-2 3.3.1-51 408 Pressure Copper> Water Chemistry Control (AP-34) D Heat exchanger (uest boePsunary 15% Zn Treated water (ext) Loss of material -Closed Cooling Water (tubes) boundary 2(inhibited)

Copper> Noe VI1.C2-2 3.3.1-52 408 Heat exchanger D Heat transfer 15% Zn Treated water (ext) Water Chemistry Control (AP-80)

(tubes) (inhibited) Fouling - Closed Cooling Water

Attachment 1 NL-09-079 Page 37 of 51 Table 3.4.2-5-9-1P2 Service Water System Components Required to Support AFW Pump Room Fire Event Summary of Aging Management Review Table 3.4.2-5-9-1P2 Service Water System (SW)

Iginendeect IntendAging Effect Aging ANUREG- Management 1801 Vol. 2 Table Noe N

Component Type Function Material Environment Requiring Programs Item Management Item Pressure ACn-eutdeei-:(e*x None None VII.D-1 3.3.1-44 408 Bolting boundary Carbon steel Condensation (ext) Loss of material Bolting Integrity (A-103) C Pressure Stainless Air-outdeer-(e( Nne None VII.F1-1 3.3.1-27 408 Bolting boundary steel Condensation (ext) Loss of material Bolting Integrity (A-09) E Nozzles Prsue Carbon steel A ee None NceExternal None Surfaces V11.1-11 (A-81) 3.3.1-58 408 A

Pressure t) .

boundary Condensation (ext) Loss of material Monitoring Carbon steel Raw water (int) None None VII.C1-19 3.3.1-76 408 Nozzles Pressure boundary Loss of material Service Water Integrity (A-38) A A outoo None VI1I-11 3.3.1-58 408 Pressure Piping boundary Carbon steel C L External Surfaces (A-81) A yCondensation (ext) Loss of material Monitoring Pressure None None VI1.C1-19 3.3.1-76 408 Piping boundary Carbon steel Raw water (int) Loss of material Service Water Integrity (A-38) A Piping Pesr Stils Stainless Ar-uee;x A( NG%PeExternal None Surfaces VII.F1-1 (A-09) 3.3.1-27 408 E

Pressure boundary steel Condensation (ext) Loss of material Monitoring

Attachment 1 NL-09-079 Page 38 of 51 able 3.4.2-5-9-1P2 Service Water System (SW)

Aging Management Table 1 Aging Effect Component Type ntn Material Environment Requiring 1801 Vol 2 Notes I Function Management Programs ItemItem Pressure Stainless Raw water (int) None None VI1.C1-15 3.3.1-79 408 Piping boundary steel Loss of material Service Water Integrity (A-54) A Pressure CopralyA-,er( oeExternal None Surfaces VII.F1-16 (A-46)E 3.3.1-25 408 Tubing boundary Condensation (ext) Loss of material MonitoringS Pressure None None VII.C1-9 3.3.1-81 408 Tubing boundary Copper alloy Raw water (int) Loss of material Service Water Integrity (A-44) A Nne VII.F1-1 3.3.1-27 408 TubingPressure Stainless ACr-outdon (ex)NLos External Surfaces (A-09) E boundary steel Condensation (ext) Loss of material Monitoring Tubing Pressure Stainless Rawwater None None VII.C1-15 3.3.1-79 408 boundary steel (int) Loss of material Service Water Inteqrity (A-54) A VII.1-11 3.3.1-58 408 ValvePressure Carbon steel Ae r External Surfaces (A81) A boundary Condensation (ext) Loss of material Monitoring Pressure None NGe% VII.C1-19 3.3.1-76 408 Valve body boundary Carbon steel Raw water (int) Loss of material Service Water Integrity (A-38) A Valvee Stines Abody -x* NoeExternal None Surfaces VII.F1-1 (A-09) 3.3.1-27 408 E

Pressure Stainless Valve body boundary steel Condensation (ext) Loss of material Monitoringq Pressure Stainless RNoe None VII.C1-15 3.3.1-79 408 Valve body boundary steel Raw water (int) Loss of material Service Water Integrity (A-54) A

Attachment 1 NL-09-079 Page 39 of 51 Table 3.4.2-5-10-1P2 Lube Oil System Components Required to Support AFW Pump Room Fire Event Summary of Aging Management Review

Attachment 1 NL-09-079 Page 40 of 51 Table 3.4.2-5-11-1P2 River Water Service System Components Required to Support AFW Pump Room Fire Event Summary of Aging Management Review Table 3.4.2-5-11-1P2 River Water Service System (RW)

Intended Aging Effect Aging Management NUREG- Table I Component Type Function Material Environment Requiring Programs 1801 Vol. 2 Item Notes Management Item Pressure None Neoe VII.I-1 3.3.1-43 408 Bolting boundary Carbon steel Air-outdoor (ext) Loss of material Bolting Integrity (AP-28) A Pressure Stainless Nene None .... 408 Bolting boundary steel Air-outdoor (ext) Loss of material Bolting Integrity G None VII.I-9 3.3.1-58 408 Pressure Loss of materal External Surfaces (A-78) A Piping boundary Carbon steel Air-outdoor (ext)

Monitorinq None VII.C1-19 3.3.1-76 408 Pressure None Periodic Surveillance A38 E Piping boundary Carbon steel Raw water (int) Loss of material and Preventive Maintenance None VII.I-9 3.3.1-58 408 Pressure Garben-steel A Pump casing Gray cast Air-outdoor (ext) L External Surfaces iAm boundary ironLoss of mateialMonitorin None VII.C1-19 3.3.1-76 408 Pressure Gas None Periodic Surveillance (A-38) E Pump casing boundary Gray cast Raw water (int) Loss of material and Preventive iron Maintenance

Attachment 1 NL-09-079 Page 41 of 51 Table 3.4.2-5-11-1P2 River Water Service System (RW)

Agntendeect dAging Effect Aging Management 1801 Vol. 2NoeTable I NUREG-Component Type Function Material Environment Requiring Programs Item Item Notes Management Item VIL.CI-11 3.3.1-85 A Pressure Ga-ben-steel Pump casing Gray cast Raw water (int) Loss of material Selective Leaching (A-51) nboundary iron None None .. 408 Pressure Stainless Loss Tuigboundary Tubing boury steel steel Air-outdoor (ext) Nsn of ematerial Moiorn External Surfaces G Monitoring NneO VII.C1-15 3.3.1-79 408 Pressure Stainless Raw water (int) None Periodic Surveillance (A-54) E Tubing boundary steel Loss of material and Preventive Maintenance None None VII.I-9 3.3.1-58 408 Pressure Loss of material Moiorn ValveVav oyboundary body Carbon steel Air-outdoor (ext) Non e External Surfaces (A-78) A Monitoring NGne VII.C1-19 3.3.1-76 408 Pressure None, Periodic Surveillance (A-38) E Valve body boundary Carbon steel Raw water (int) Loss of material and Preventive Maintenance NG% None -- -- 408 Pressure Stainless Valve body steel Air-outdoor (ext) L om a External Surfaces G yboundary steel Loss of material Monitoring None VII.C1-15 3.3.1-79 408 Pressure Stainless None Periodic Surveillance (A-54) E Valve body boundary steel Raw water (int) Loss of material and Preventive Maintenance

Attachment 1 NL-09-079 Page 42 of 51 Table 3.4.2-5-12-1P2 Fresh Water Cooling System Components Required to Support AFW Pump Room Fire Event Summary of Aging Management Review Table 3.4.2-5-12-1P2 Fresh Water Cooling (FWC) System Intended Aging Effect Aging Management 1UREG- Table 1 Component Type Function Material Environment Requiring Programs 1801 Vol. 2 Item Notes Management Item Neae .. 408 Heat exchanger (tubes) boundary s eGper-alley Titanium Noe Loss of material Periodic Surveillance and Preventive F Maintenance Periodic Surveillance ....- F Raw water (int) Fouling and Preventive F Heat exchanger Heat transfer Titanium (tubes) Maintenance traRsfe Neat N-e.. 408 Heat exchanger a-pp&esalley Treated Water Noee Periodic Surveillance F (tubes) andPressure Titanium (ext) Loss of material and Preventive boundary Maintenance Treated Water Periodic Surveillance ....- F Heatues Heat transfer TitanWiue Fouling and Preventive (tubes) H(ext) Maintenance

Attachment 1 NL-09-079 Page 43 of 51 Table 3.4.2-5-13-1P2 IPI Station Air System Components Required to Support AFW Pump Room Fire Event Summary of Aging Management Review Table 3.4.2-5-13-1P2 IPI Station Air (SA) System Component Type Intended Function Material Environment Aging Effect Requiring AgingPrograms Management NUREG-1801 Vol. 2 Table Item 1 Notes Component TypeFunctionManagement

_ Item Pressure sNone None VII.I-4 3.3.1-43 408 Bolting boundary Carbon steel Air-indoor (ext) Loss of material Boltingq Integrity (AP-27) A Pressure Stainless Air-indoor (ext) None None VII.J-15 3.3.1-94 408 Bolting boundary steel (AP-17) A Pressure None None VII.D-3 3.3.1-57 408 Filter housing boundary Filtr husig Carbon bundry steel Air-indoor (ext) Loss of material ossof External ateialMon Surfaces ito ringq (A-80) A None VII.D-2 3.3.1-53 408 Filter Housing Pressure None Periodic Surveillance (A-26) E boundary Loss of material and Preventive Maintenance Pressure NOee None VII.D-3 3.3.1-57 408 Piping boundary Carbon steel Air-indoor (ext) Loss ofe ExternaligA Surfaces None VII.D-2 3.3.1-53 408 Pressure None Periodic Surveillance (A-26) E Piping boundary Carbon steel Condensation (int) Loss of material and Preventive Maintenance Pressure Stainless VII.J-15 3.3.1-94 408 Piping boundary steel Air-indoor (ext) None None (AP-17) A

Attachment 1 NL-09-079 Page 44 of 51 Table 3.4.2-5-13-1P2 IP1 Station Air (SA) System AgngEfec Aging Effect Aging Management NUREG-1801 Vol. 2 Tal Item Component Type Function Material Environment Requiring Programs NU01 TabItem Notes ComponentType Function_ Management Item Pressure Stainless NRne Nee VII.D-4 3.3.1-54 408 Piping boundary steel Condensation (int) Loss of material One-Time Inspection (AP-81) E Stainless Nei, e NePe VII.D-4 3.3.1-54 3.3.1-54 408 4

Filtration Stainless Condensation (int) None NG% VIID-4 Strainer One-Time Inspection (AP-81) E steel Loss of material SrieFitain Stainless Condensation (ext) None NGPe VII.D-4 3.3.1-54 408 Stane ilrtin steel Loss of material One-Time Inspection (6p-811 E NGne None VII.D-3 3.3.1-57 408 Pressure (A-80) A Strainer housing boundary Carbon steel Air-indoor (ext) Loss of material External Surfaces Monitoring Noe VII.D-2 3.3.1-53 408 Pressure NGe% Periodic Surveillance (A-26)E Strainer ousing boundary Carbon steel Condensation (int) Loss of material and Preventive Maintenance NeGe VII.D-3 3.3.1-57 408 TankPressure Carbon steel Air-indoor (ext) N External Surfaces A-8 A boundary Loss of material Monitoring None VII.D-2 3.3.1-53 408 Pressure C s N ne Periodic Surveillance iA-2 E Tank . boundary Carbon steel Condensation (int) Loss of material and Preventive Maintenance NG% VII.D-3 3.3.1-57 408 Pressure A Tubing boury Carbon steel Air-indoor (ext) Loss of mAr External Surfaces boundary Lossofmateria ExnterinalSurf

Attachment 1 NL-09-079 Page 45 of 51 Table 3.4.2-5-13-1P2 IP1 Station Air (SA) System Component Type Intended Function Material Environment Aging Effect Requiring Management AgingPrograms NUREG-1801 Vol. 2 Table Item I Notes Management Item None VII.D-2 3.3.1-53 408 Pressure None Periodic Surveillance (A- E Tubing boundary Carbon steel Condensation (int) Loss of material and Preventive Maintenance Pressure Stainless VII.J-15 3.3.1-94 408 Tubing boundary steel Air-indoor (ext) None None (AP-17) A Pressure Stainless None None VII.D-4 3.3.1-54 408 Tubing boundary steel Condensation (int) Loss of material One-Time Inspection (AP-81) E Pressure V.F-3 3.2.1-53 408 Tubing boundary Copper alloy Air-indoor (ext) None None (EP-10) C NGe% VII.G-9 3.3.1-28 408 Pressure C None Periodic Surveillance (AP-78) E Tubing boundary Copper alloy Condensation (int) Loss of material and Preventive Maintenance NG% None VII.D-3 3.3.1-57 408 Pressure Trap boundary Carbon steel Air-indoor (ext) Loss of material External Surfaces (fA&8 A None VII.D-2 3.3.1-53 408 Pressure Carbon steel Condensation (int) Ne Periodic Surveillance (A-26) E Trap boundary Loss of material and Preventive Maintenance Nne None VII.D-3 3.3.1-57 408 Pressure A Valve body Carbon steel Air-indoor (ext) Loss of material External Surfaces (A-80) boundary y Monitoring NL-09-079 Page 46 of 51

Attachment 1 NL-09-079 Page 47 of 51 As a result of the previous table changes, the following changes are required to Appendix A (Changes are shown as ti.kl.eth,.e..g. for deletions and underlines for additions).

A.2.1.26 One-Time Inspection Program One-time inspection activities on the following confirm that loss of material is not occurring or is so insignificant that an aging management program is not warranted.

" internal surfaces of stainless steel drain piping,.piping elements and components containing raw water (drain water)

• internal surfaces of stainless steel piping, piping elements and components in the station air containment penetration exposed to condensation

• Internal surfaces of stainless steel piping, tubing., strainers and valve bodies in the IP1 station air system exposed to condensation

• internal surfaces of stainless steel EDG starting air tanks, piping, piping elements and components exposed to condensation

" internal surfaces of carbon steel and stainless steel tanks, piping, piping elements and components in the RCP oil collection system exposed to lube oil

• internal surfaces of auxiliary feedwater system stainless steel piping, piping elements and components exposed to treated water from the city water system A.2.1.28 Periodic Surveillance and Preventive Maintenance Program 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.

Surveillance testing and periodic inspections using visual or other non-destructive examination techniques verify that the following components are capable of performing their intended function.

" reactor building cranes (polar and manipulator), crane rails, and girders, and refueling platform

• recirculation pump motor cooling coils and housing

" city water system components

" charging pump casings

" plant drain components and backwater valves

• station air containment penetration piping

• HVAC duct flexible connections

" HVAC stored portable blowers and flexible trunks

• EDG exhaust components

Attachment 1 NL-09-079 Page 48 of 51

• EDG duct flexible connections

• EDG air intake and aftercooler components

• EDG air start components

• EDG cooling water makeup supply valves

• security generator exhaust components

• security generator radiator tubes

• SBO/Appendix R diesel exhaust components

• SBO/Appendix R diesel turbochargers and aftercoolers

• SBO/Appendix R diesel cooling water heat exchangers

• SBO/Appendix R diesel fuel oil cooler

• diesel fuel oil trailer transfer tank and associated valves

• auxiliary feedwater components

• containment cooling duct flexible connections

• containment cooling fan units internals

• control room HVAC condensers and evaporators

• control room HVAC ducts and drip pans

• control room HVAC duct flexible connections

• circulating water, city water, intake structure system, emergency diesel generator, fresh water cooling, instrument air, integrated liquid waste handling, lube oil, miscellaneous, radiation monitoring, river water, station air, waste disposal, wash water, and water treatment plant system piping, piping components, and piping elements

• pressurizer relief tank

• main steam safety valve tailpipes

• atmospheric dump valve silencers

• feedwater system sight glasshousings

• off-site power feeder, 138 kV underground transmission cable

• main condenser tube internal surfaces

• instrument air aftercooler tube internal surfaces

• fresh water/river water heat exchanger internal and external surfaces A.2.1.39 Water Chemistry Control - Closed Cooling Water Program The Water Chemistry Control - Closed Cooling Water Program is an existing program that includes preventive measures that manage loss of material, cracking, or fouling for components in closed cooling water systems (component cooling water (CCW), instrument air (IP2 only), conventional closed cooling (CCC), instrument air closed cooling (IACC), emergency diesel generator cooling, security generator cooling, and SBO/Appendix R diesel generator cooling). These chemistry activities provide for monitoring and controlling closed cooling water chemistry using procedures and processes based on EPRI guidance for closed cooling water chemistry.

Attachment 1 NL-09-079 Page 49 of 51 As a result of the previous table changes, the following changes are required to Appendix B (Changes are shown as st*ikethroughs for deletions and underlines for additions).

B.1.27 One-Time Inspection Proaram Descriotion One-time inspection activities on the following confirm that loss of material is not occurring or is so insignificant that an aging management program is not warranted.

" Internal surfaces of drain system stainless steel piping, tubing, and valve bodies exposed to raw water (drain water) in EDG buildings, primary auxiliary buildings, and electrical tunnels. Also included are drains in the IP3 auxiliary feed pump building

" Internal surfaces of stainless steel valve bodies in the station air containment penetration exposed to condensation

• Internal surfaces of stainless steel piping, tubing, strainers and valve bodies in the IPN station air system exposed to condensation

• Internal surfaces of stainless steel piping, strainers, strainer housings, tanks, tubing and valve bodies exposed to condensation in the emergency diesel generator (EDG) starting air subsystem B.1i.29 Periodic Surveillance and Preventive Maintenance Proaram 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.

Reactor building Use visual or other NDE techniques to inspect the surface condition of carbon steel components of the reactor building cranes (polar and manipulator), crane rails, and girders, and refueling platform to manage loss of material. [existing]

Containment spray system IP3: Perform wall thickness measurements of the NaOH tank to manage loss of material. [existing]

IP3: Perform visual or other NDE inspections on the inside

Attachment 1 NL-09-079 Page 50 of 51 surfaces of a representative sample of stainless steel components exposed to sodium hydroxide to manage loss of material and cracking.

Safety injection system Perform operability testing to manage fouling for recirculation pump motor cooling coils.

Use visual or other NDE techniques to internally inspect the recirculation pump cooler housing to manage loss of material.

Main steam system Use visual or other NDE techniques to inspect a representative sample of the internal surfaces of the carbon steel main steam safety valve tailpipes and atmospheric dump valve silencers to manage loss of material.

Circulatina water system Use visual or other NDE techniques to inspect a representative sample of the internals of circulating water piping, piping elements and components exposed to raw water to manage loss of material, cracking and change in material properties.

City water system Use visual or other NDE techniques to inspect a representative sample of the internals of city water piping, piping elements, and components exposed to treated water (city water) to manage loss of material.

Condensate system Use visual or other NDE techniques to inspect a representative sample of the internal surfaces of the main condenser tubes exposed to raw water to manage loss of material and fouling.

River water system Use visual or other NDE techniques to inspect a representative sample of the internals of river water piping, piping elements and components exposed to raw water to manage loss of material and cracking.

Fresh water cooling system Use visual or other NDE techniques to inspect a representative sample of the internal and external surfaces of the fresh water/river water heat exchanger tubes exposed to raw water to manage loss of material and fouling.

Attachment 1 NL-09-079 Page 51 of 51 Wash water system Use visual or other NDE techniques to inspect a representative sample of the internals of wash water piping, piping elements and components exposed to raw water to manage loss of material, cracking and change in material properties.

Chemical and volume During quarterly surveillances perform visual inspection of control system the external surface of charging pump casings to manage cracking. [existing]

Plant drains Use visual or other NDE techniques to inspect a representative sample of the internals of carbon steel plant drain piping, piping elements, and components to manage loss of material.

IP2: Use visual or other NDE techniques to inspect the internals of backwater valves to manage loss of material.

[existing]

Station air system Use visual or other NDE techniques to inspect a representative sample of containment penetration piping and the internals and externals of station air piping, piping elements and components to manage loss of material.

Use visual or other NDE techniques to inspect a representative sample of the internals of station air piping, piping elements and components exposed to raw water to manage loss of material and cracking.

Instrument air system Use visual or other NDE techniques to internally inspect the heat exchanger tubes on the instrument air aftercoolers to manage loss of material and fouling.

ATTACHMENT 2 TO NL-09-079 List of Regulatory Commitments, Revision 9 ENTERGY NUCLEAR OPERATIONS, INC.

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

Attachment 2 NL-09-079 Page 1 of 17 List of Regulatory Commitments Rev. 9 The following table identifies those actions committed to by Entergy in this document.

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

1. COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION

/ AUDIT ITEM 1 Enhance the Aboveground Steel Tanks Program for P2: NL-07-039 A.2.1.1 eptember 28, A.3.1.1 IP2 and IP3 toth otm thickness measurements of perform pom013 B.1.1 the bottom surfaces of the condensate storage tanks, city water tank, and fire water tanks once during the IP3:

first ten years of the period of extended operation. December 12, Enhance the Aboveground Steel Tanks Program for 2015 IP2 and IP3 to require trending of thickness measurements when material loss is detected.

2 Enhance the Bolting Integrity Program for IP2 and IP3 IP2: NL-07-039 A.2.1.2 to clarify that actual yield strength is used yil teghi sdg in selecting September 28, A.3.1.2 013 B.1.2 materials for low susceptibility to SCC and clarify the prohibition bolting. on use of lubricants containing MoS 2 for 1P3:

I3 NL-07-153 L0 -5 Audit ui Items tm December 12, 201,241, The Bolting Integrity Program manages loss of 2015 270 1 preload and loss of material for all external bolting.

3 Implement the Buried Piping and Tanks Inspection IP2: NL-07-039 A.2.1.5 Program for IP2 and IP3 as described in LRA Section September 28, A.3.1.5 B.1.6. 2013 B.1.6 NL-07-153 Audit Item This new program will be implemented consistent with IP3: 173 the corresponding program described in NUREG- December 12, 1801 Section XI.M34, Buried Piping and Tanks 2015 Inspection.

Attachment 2 NL-09-079 Page 2 of 17

1. COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION II I I AUDIT ITEM IP2: NL-07-039 A.2.1.8 4 Enhance the Diesel Fuel Monitoring Program to September 28, A.3.1.8 include cleaning and inspection of the IP2 GT-1 gas turbine fuel oil storage tanks, 1P2 and IP3 EDG fuel oil 2013 B.1.9 NL-07-153 Audit items day tanks, IP2 SBO/Appendix R diesel generator fuel IP3: 128,129, oil day tank, and IP3 Appendix R fuel oil storage tank December 12, 132, and day tank once every ten years.

2015 NL-08-057 491,492, Enhance the Diesel Fuel Monitoring Program to 510 include quarterly sampling and analysis of the IP2 SBO/Appendix R diesel generator fuel oil day tank, IP2 security diesel fuel oil storage tank, IP2 security diesel fuel oil day tank, and IP3 Appendix R fuel oil storage tank. Particulates, water and sediment checks will be performed on the samples. Filterable solids acceptance criterion will be less than or equal to 10mg/l. Water and sediment acceptance criterion will be less than or equal to 0.05%.

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

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

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

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

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

Attachment 2 NL-09-079 Page 3 of 17

1. COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION I AUDIT ITEM Enhance the Diesel Fuel Monitoring Program to direct the addition of chemicals including biocide when the presence of biological activity is confirmed.

5 Enhance the External Surfaces Monitoring Program P2: NL-07-039 A.2.1.10 for IP2 and IP3 to include periodic inspections of September 28, A.3.1.10 systems in scope and subject to aging management 013 B.1.11 review for license renewal in accordance with 10 CFR IP3:

54.4(a)(1) and (a)(3). Inspections shall include areas December 12, surrounding the subject systems to identify hazards to 015 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).

6 Enhance the Fatigue Monitoring Program for IP2 to IP2: NL-07-039 A.2.1.11 Septmber28,A.3.1.11 monitor steady state cycles and feedwater cycles or September 28, perform an evaluation to determine monitoring is not 013 B.1.12, required. Review the number of allowed events and NL-07-153 Audit Item resolve discrepancies between reference documents 164 and monitoring procedures.

Enhance the Fatigue Monitoring Program for IP3 to IP3:

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

Attachment 2 NL-09-079 Page 4 of 17 COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION I_ I 1 JIIAUDIT ITEM 7 Enhance the Fire Protection Program to inspect IP2: NL-07-039 A.2.1.12 external surfaces of the IP3 RCP oil collection September 28, A.3.1.12 systems for loss of material each refueling cycle.

2013 B.1.13 Enhance the Fire Protection Program to explicitly IP3:

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

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

Enhance the Fire Protection Program for IP3 to visually inspect the cable spreading room, 480V switchgear room, and EDG room CO 2 fire suppression system for signs of degradation, such as corrosion and mechanical damage at least once every six months.

Attachment 2 NL-09-079 Page 5 of 17 COMMITMENT IMPLEMENTATION1 SCHEDULE SOURCE 1LRA RELATED SECTION I AUDIT ITEM IP2: NL-07-039 A.2.1.13 8 Enhance the Fire Water Program to include inspection S eptember 28, A.3.1.13 of IP2 and IP3 hose reels for evidence of corrosion.

2013 B.1.14 Acceptance criteria will be revised to verify no NL-07-1 53 Audit Items unacceptable signs of degradation.

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

Enhance the Fire Water Program to perform wall thickness evaluations of IP2 and IP3 fire protection piping on system components using non-intrusive techniques (e.g., volumetric testing) to identify evidence 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 si-qnificant corrosion.

Attachment 2 NL-09-079 Page 6 of 17

1. COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION I_ I I / AUDIT ITEM Enhance the Flux Thimble Tube Inspection Program IP2: NL-07-039 A.2.1.15 9

for IP2 and IP3 to implement comparisons to wear September 28, A.3.1.15 rates identified in WCAP-12866. Include provisions to 2013 B.1.16 compare data to the previous performances and IP3:

perform evaluations regarding change to test December 12, frequency and scope.

2015 Enhance the Flux Thimble Tube Inspection Program for IP2 and IP3 to specify the acceptance criteria as outlined in WCAP-1 2866 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.

Attachment 2 NL-09-079 Page 7 of 17

1. COMMITMENT IMPLEMENTATION1 SOURCE RELATED SCHEDULE LRA SECTION I _I AUDIT ITEM IP2: NL-07-039 A.2.1.16 10 Enhance the Heat Exchanger Monitoring Program for September 28, A.3.1.1.6 IP2 and IP3 to include the following heat exchangers 2013 B.1.17, in the scope of the program.

NL-07-153 Audit Item

" Safety injection pump lube oil heat exchangers 1P3: 52 December 12,

" RHR heat exchangers 2015

• 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

• Secondary system steam generator sample coolers

• Waste gas compressor heat exchangers

" SBO/Appendix R diesel jacket water heat exchanger (IP2 only)

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

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

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

Attachment 2 NL-09-079 Page 8 of 17

1. COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION I AUDIT ITEM 11 Delete commitment. A.3.1.07 Enhance the IS' Program Fnor 1122 and 13 to proVide 1..418 Apcrio-dic visual inspections to confirmn the absence et N1=-07-15 Audi4-te agn ffects for lubrite sliding supports used in the W1-.5 steam generator and reactor coolant PUMP suppo ,- NL-09-056

&ystems _ _

12 Enhance the Masonry Wall Program for IP2 and IP3 1P2: NL-07-039 A.2.1.18 to specify that the IP1 intake structure is included in September 28, A.3.1.18 the program. 2013 B.1.19 IP3:

December 12, 2015 Enhance the Metal-Enclosed Bus Inspection Program IP2: NL-07-039 A.2.1.19 to add IP2 480V bus associated with substation A to September 28, A.3.1.19 the scope of bus inspected. 2013 B.1.20 NL-07-153 Audit Items Enhance the Metal-Enclosed Bus Inspection Program IP3: 124, for IP2 and IP3 to visually inspect the external surface December 12, NL-08-057 133, 519 of MEB enclosure assemblies for loss of material at 2015 least once every 10 years. The first inspection will occur prior to the period of extended operation and the acceptance criterion will be no significant loss of material.

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

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

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

Attachment 2 NL-09-079 Page 9 of 17

1. COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION

/ AUDIT ITEM Implement the Non-EQ Bolted Cable Connections eP2: NL-07-039 A.2.1.21 14 Program for IP2 and IP3 as described in LRA Section September 28, B.1.22. 2013 B.1.22 IP3:

December 12, 2015 15 Implement the Non-EQ Inaccessible Medium-Voltage IP2: NL-07-039 A.2.1.22 September 28, A.3.1.22 Cable Program for IP2 and IP3 as described in LRA 2013 B. 1.23 Section B.1.23. NL-07-153 Audit item This new program will be implemented consistent with IP3: 173 the corresponding program described in NUREG- December 12, 1801 Section XI.E3, Inaccessible Medium-Voltage 2015 Cables Not Subject To 10 CFR 50.49 Environmental Qualification Requirements.

16 Implement the Non-EQ Instrumentation Circuits Test IP2: NL-07-039 A.2.1.23 Review Program for IP2 and IP3 as described in LRA September 28, A.3.1.23 Section B.P1.24. 2013 B. 1.24 NL-07-153 Audit item This new program will be implemented consistent with IP3: 173 the corresponding program described in NUREG- December 12, 1801 Section XI.E2, Electrical Cables and 2015 Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Used in Instrumentation Circuits.

17 Implement the Non-EQ Insulated Cables and IP2: NL-07-039 A.2.1.24 Connections Program for IP2 and IP3 as described in September 28, A.3.1.24 LRA Section B.1.25. 2013 B.1.25 NL-07-153 Audit item This new program will be implemented consistent with IP3: 173 the corresponding program described in NUREG- December 12, 1801 Section XI.E1, Electrical Cables and 2015 Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements.

Attachment 2 NL-09-079 Page 10 of 17

1. COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION I AUDIT ITEM 18 Enhance the Oil Analysis Program for IP2 to sample SP2: NL-07-039 A.2.1.25 and analyze lubricating oil used in the SBO/Appendix S013 B.1.26 R diesel generator consistent with oil analysis for other site diesel generators. IP3:

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

19 Implement the One-Time Inspection Program for IP2 SP2: NL-07-039 A.2.1.26 and IP3 as described in LRA Section B.1.27. September 28, A.3.1.26 2013 B.1.27 This new program will be implemented consistent with NL-07-153 Audit item the corresponding program described in NUREG- IP3: 173 1801,Section XI.M32, One-Time Inspection. December 12, 2015 20 Implement the One-Time Inspection - Small Bore P2: NL-07-039 A.2.1.27 Piping Program for. IP2 and IP3 as described in LRA September 28, A.3.1.27 Section B.1.28. 2013 B. 1.28 NL-07-153 Audit item This new program will be implemented consistent with rP3: 173 the corresponding program described in NUREG- December 12, 1801,Section XI.M35, One-Time Inspection of ASME 2015 Code Class I Small-Bore Piping.

21 Enhance the Periodic Surveillance and Preventive IP2: NL-07-039 A.2.1.28 Maintenance Program for IP2 and IP3 as necessary September 28, AB3.1.28 to assure that the effects of aging will be managed such that applicable components will continue to perform their intended functions consistent with the DP e1 current licensing basis through the period of extended De r1

___operation. 2015

Attachment 2 NL-09-079 Page 11 of 17

1. COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION

/ AUDIT ITEM IP2: NL-07-039 A.2.1.31 22 Enhance the Reactor Vessel Surveillance Program for Sptb 28, A.2.1.31 IP2 and IP3 revising the specimen capsule withdrawal September 28, 2013 A.3.1.31 B.1.32 schedules to draw and test a standby capsule to cover the peak reactor vessel fluence expected IP3:

through the end of the period of extended operation. December 12, Enhance the Reactor Vessel Surveillance Program for 2015 IP2 and IP3 to require that tested and untested specimens from all capsules pulled from the reactor vessel are maintained in storage.

23 Implement the Selective Leaching Program for IP2 SP2: NL-07-039 A.2.1.32 and IP3 as described in LRA Section B.1.33. September 28, A.3.1.32 2013 B. 1.33 This new program will be implemented consistent with NL-07-153 Audit item the corresponding program described in NUREG- IP3: 173 1801,Section XI.M33 Selective Leaching of Materials. December 12, 2015 24 Enhance the Steam Generator Integrity Program for IP2: NL-07-039 A.2.1.34 IP2 and IP3 to require that the results of the condition eptember 28, A.3.1.34 monitoring assessment are compared to the 013 B.1.35 operational assessment performed for the prior IP&

operating cycle with differences evaluated. DP December e112, 2015 25 Enhance the Structures Monitoring Program to IP2: NL-07-039 A.2.1.35 explicitly specify that the following structures are September 28, A.3.1.35 included in the program. 2013 B.1.36

• Appendix R diesel generator foundation (IP3) NL-07-153 I

• Appendix R diesel generator fuel oil tank vault IP3: Audit items (IP3) December 12, 86, 87, 88,

• Appendix R diesel generator switchgear and 2015 NL-08-057 417 enclosure (IP3)

• city water storage tank foundation

• condensate storage tanks foundation (IP3)

• containment access facility and annex (IP3)

• discharge canal (1P2/3)

• emergency lighting poles and foundations (1P2/3)

• 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) __

Attachment 2 NL-09-079 Page 12 of 17

1. COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION I I___ I 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)

• service water pipe chase (IP2/3)

• service water valve pit (IP3)

• superheater stack

• transformer/switchyard support structures (IP2)

• waste holdup tank pits (IP2/3)

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

" cable trays and supports

• concrete portion of reactor vessel supports

• conduits and supports

• cranes, rails and girders

• equipment pads and foundations

" fire proofing (pyrocrete)

• HVAC duct supports

" jib cranes

• manholes and duct banks

• manways, hatches and hatch covers

• monorails

• new fuel storage racks

• sumps, sump screens, strainers and flow barriers Enhance the Structures Monitoring Program for IP2 and IP3 to inspect inaccessible concrete areas that are exposed by excavation for any reason. IP2 and IP3 will also inspect inaccessible concrete areas in environments where observed conditions in accessible areas exposed to the same environment indicate that significant concrete degradation is occurring.

Enhance the Structures Monitoring Program for IP2 and IP3 to perform inspections of elastomers (seals, gaskets, seismic joint filler, and roof elastomers) to

Attachment 2 NL-09-079 Page 13 of 17

1. COMMITMENT IMPLEMENTATION, SOURCE RELATED SCHEDULE LRA' SECTION I_ I I I I AUDIT ITEM identify cracking and change in material properties and for inspection of aluminum vents and louvers to identify loss of material.

Enhance the Structures Monitoring Program for IP2 NL-08-127 Audit Item and IP3 to perform an engineering evaluation of 360 groundwater samples to assess aggressiveness of groundwater to concrete on a periodic basis (at least once every five years). IPEC will obtain samples from at least 5 wells that are representative of the ground water surrounding below-grade site structures and perform an engineering evaluation of the results from those samples for sulfates, pH and chlorides.

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

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

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

26 Implement the Thermal Aging Embrittlement of Cast IP2: NL-07-039 A.2.1.36 Austenitic Stainless Steel (CASS) Program for IP2 September 28, A.3.1.36 and as described in LRA Section B.1.37. 2P3 013 B.1.37 NL-07-153 Audit item This new program will be implemented consistent with IP3: 173 the corresponding program described in NUREG- December 12, 1801,Section XI.M12, Thermal Aging Embrittlement 2015 of Cast Austenitic Stainless Steel (CASS) Program.

Attachment 2 NL-09-079 Page 14 of 17

1. COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION I AUDIT ITEM IP2: NL-07-039 A-2.1.37 27 Implement the Thermal Aging and Neutron Irradiation IptemNer 28,3 A.3.1.37 Embrittlement of Cast Austenitic Stainless Steel 013 2.1.37 (CASS) Program for IP2 and IP3 as described in LRA NL-07-153 Audit item Section B.1.38. .....

• I-P3:u173 IP3: 173 This new program will be implemented consistent with December 12, the corresponding program described in NUREG- 015 1801 Section XI.M13, Thermal Aging and Neutron Embrittlement of Cast Austenitic Stainless Steel (CASS) Program. ___. ___

28 Enhance the Water Chemistry Control - Closed IP2: NL-07-039 A.2.1.39 Cooling Water Program to maintain water chemistry of September 013 28, A.3.1.39 B. 1.40 the IP2 SBO/Appendix R diesel generator cooling NL-08-057 Audit item system per EPRI guidelines. IP3: 509 Enhance the Water Chemistry Control - Closed December, 12, Cooling Water Program to maintain the IP2 and IP3 2015 security generator and fire protection diesel cooling water pH and glycol within limits specified by EPRI guidelines.

29 Enhance the Water Chemistry Control - Primary and IP2: NL-07-039 -A.2.1.40 Secondary Program for IP2 to test sulfates monthly in September 28, B.1.41 the RWST with a limit of <150 ppb. 2013 30 For aging management of the reactor vessel internals, P2: NL-07-039 A.2.1.41 IPEC will (1) participate in the industry programs for SePtember28, A.3.1.41 investigating and managing aging effects on reactor internals; (2) evaluate and implement the results of lP3:

the industry programs as applicable to the reactor December 12, internals; and (3) upon completion of these programs,... 013 but not less than 24 months before entering the period.

of extended operation, submit an inspection plan for reactor internals to the NRC for review and approval. 'IP2: NL-07-039 A:2.2.1.2 31 Additional P-T curves will be submitted as required Se ptember 28, A.3.2.1.2 per 10 CFR 50, Appendix G prior to the period of e20r13 4.2.3 extended operation as part of the Reactor Vessel Surveillance Program. 1P3:

December 12, 2015 .

32 As required by 10 CFR 50.61 (b)(4), IP3 will submit a IP3: NL-07-039 A.3.2.1.4 plant-specific safety analysis for plate B2803-3 to the' December 12, 4.2.5 NRC three years prior to reaching the RTpTs 2015 NL-08-127

.screening criterion. Alternatively, the site may choose to implement the revised PTS rule when approved.

Attachment 2 NL-09-079 Page 15 of 17 COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION

/ AUDIT ITEM IP2: NL-07-039 A.2.2.2.3 33 At least 2 years prior to entering the period of September 28, A.3.2.2.3 extended operation, for the locations identified in LRA 2011 4.3.3 Table 4.3-13 (IP2) and LRA Table 4.3-14 (IP3), under NL-07-153 Audit item the Fatigue Monitoring Program, IP2 and IP3 will IP3: 146 implement one or more of the following:

December 12, NL-08-021 (1) Consistent with the Fatigue Monitoring Program, 2013 Detection of Aging Effects, update the fatigue usage calculations using refined fatigue analyses to determine valid CUFs less than 1.0 when accounting for the effects of reactor water environment. This includes applying the appropriate Fen factors to valid CUFs determined in accordance with one of the following:

1. For locations in LRA Table 4.3-13 (IP2) and LRA Table 4.3-14 (1P3), with existing fatigue analysis valid for the period of extended operation, use the existing CUF.

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

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

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

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

34 1P2 SBO /Appendix R diesel generator will be April 30, 2008 NL-07-078 2.1.1.3.5 installed and operational by April 30, 2008. This Complete NL-08-074 committed change to the facility meets the requirements of 10 CFR 50.59(c)(1) and, therefore, a license amendment pursuant to 10 CFR 50.90 is not required.

Attachment 2 NL-09-079 Page 16 of 17

1. COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION

/ AUDIT ITEM 35 Perform a one-time inspection of representative IP2: NL-08-127 Audit Item sample area of IP2 containment liner affected by the September 28, 27 1973 event behind the insulation, prior to entering the 013 extended period of operation, to assure liner degradation is not occurring in this area.

Perform a one-time inspection of representative IP3:

sample area of the IP3 containment steel liner at the December 12, juncture with the concrete floor slab, prior to entering 2015 the extended period of operation, to assure liner degradation is not occurring in this area.

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

IP2: NL-08-127 Audit Item 36 Perform a one-time Inspection and evaluation of a ISeptember 28, 359 sample of potentially affected IP2 refueling cavity S013 concrete prior to the period of extended operation. 013 The sample will be obtained by core boring the refueling cavity wall in an area that is susceptible to exposure to borated water leakage. The inspection will include an assessment of embedded reinforcing steel.

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

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

IP2:NL-08-127 Audit Item 37 Enhance the Containment Inservice Inspection (CII- September 28, 361 IWL) Program to include inspections of the Setebe13, 6 containment using enhanced characterization of degradation (i.e., quantifying the dimensions of noted indications through the use of optical aids) during the December 12, 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.

Attachment 2 NL-09-079 Page 17 of 17

1. COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION I AUDIT ITEM IP2: NL-08-143 4.2.1 38 For Reactor Vessel Fluence, should future core loading patterns invalidate the basis for the projected e mr2 values of RTpts or CvUSE, updated calculations will 0 be provided to the NRC. I P3:

December 12, 2015 39 Install a fixed automatic

.- fire supprcco for Iyte NL-09-056 24.5 22 in the Auxiliary Fed .t.r R......

Pm NL-09-079